AXA

Reference: pages 140-142 (section 4.1.3.1 - Sustainability governance at AXA). Page numbers throughout this entry are PDF pages of the 2025 Universal Registration Document; the printed folio is two lower.

Listed in AXA's ESRS content index under ESRS 2 GOV-1 with a cross-reference to section 4.1.3.1 (page 252). Composition and diversity of the Board, and the independence of directors, are incorporated by reference to section 3.2 of the same document (page 251).

"As of December 31, 2025, the Board comprised 14 members (compared to 15 members as of December 31, 2024), including one executive member (the Chief Executive Officer) and 13 non-executive members, including one director representing employee shareholders and two directors representing employees" (page 140). "In 2025, the average ratio of women on the Board was 56% ... and 44% of men, compared to 59% and 41%, respectively, in 2024." Six nationalities were represented, down from eight.

Duties are split across three Board committees (page 141): the Audit Committee "monitors the process of preparing sustainability-related information"; the Compensation, Governance & Sustainability Committee reviews the sustainability strategy at least once a year; the Finance & Risk Committee "reviews the Group's responsible investment policy". The Sustainability Statement is recommended to the Board by the Audit Committee and the CGSC jointly.

Reference: pages 142-143 (section 4.1.3.1); index entry on page 252.

AXA sets out what the Board and its committees examined in 2025 in a table of "Material IROs / Activity" (page 142). Environmental items included the 2024 Sustainability Statement, the Article 29 Loi Energie-Climat report, "SBTi (Science-Based Target Initiative) and FINZ (Financial Institutions Net-Zero) Standard", transition underwriting, the internal model and natural catastrophes, and nature, biodiversity and oceans. Social items included the Pulse employee engagement survey results, the Group diversity and inclusion strategy, responsible investments, the AXA Group Defense Policy and "Workforce dynamics and potential impact of Gen AI". Governance items included conduct and customer protection, the vendor risk framework, the annual whistleblowing investigations report, bi-annual compliance reports and financial crime.

At executive level the Management Committee "oversees material sustainability-related initiatives across the Group", supported by the Role in Society Steering Committee, which "meets monthly and is co-chaired by the Group Chief Underwriting and Pricing Officer, Group Chief Investment Officer, and Group Chief Communication, Brand and Sustainability Officer" and is "responsible for setting targets on key sustainability matters, including material IROs, and tracking their progress".

Reference: page 251 (incorporation by reference) and page 143.

GOV-3 is one of two disclosure requirements AXA incorporates by reference rather than reproducing in the sustainability chapter. The table of "Disclosure requirements and incorporation by reference" lists "ESRS 2 - GOV 3 | Integration of sustainability-related performance in incentive schemes | Compensation and share ownership | 3.5" (page 251), and the ESRS content index repeats the cross-reference to section 3.5 (page 252). The E1 index also lists ESRS 2 GOV-3 against section 4.1.3.1 (page 253).

What the sustainability chapter itself says is short: "Sustainability criteria are integrated into the executives' compensation, which includes long-term and short-term incentives. These measures encourage employees to take meaningful actions toward sustainability" (page 143), with a pointer to sections 3.5.1.2 and 3.5.1.3 for the compensation policy of the Chairman and of the Board members. The Compensation, Governance & Sustainability Committee "reviews the CEO's Group and individual performance conditions (including sustainability related) as well as the performance conditions (including sustainability related) of the long-term incentives granted to the CEO and the Management Committee members" (page 141).

The quantified link between remuneration and sustainability targets therefore sits in Chapter 3 of the URD, outside the assured sustainability sections 4.1 to 4.5.

Reference: page 143 (section 4.1.3.2 - Statement on due diligence).

Listed in the ESRS content index under ESRS 2 GOV-4 against section 4.1.3.2 (page 252), and in the EU-legislation datapoint table as "ESRS 2 GOV-4 Statement on due diligence paragraph 30" mapped to SFDR "Indicator number 10 Table #3 of Annex 1" (page 258).

The disclosure is a mapping table rather than a narrative: "AXA adopted a dynamic due diligence process following ESRS recommendations. The core elements of this due diligence process are described in accordance with ESRS disclosure requirements, as indicated below" (page 143). The five core elements are cross-referenced as follows: (a) embedding due diligence in governance, strategy and business model to section 4.1.1; (b) engaging with stakeholders in all key steps to section 4.1.2.1; (c) identifying and assessing adverse impacts to section 4.1.2.2; (d) taking actions to address those adverse impacts to section 4.1.4; and (e) tracking the effectiveness of these efforts and communicating, also to section 4.1.4.

Section 4.1.4 is the "AXA for Progress Index", the Group's set of strategic key performance indicators (pages 145-146). Human-rights due diligence proper is carried in the Vigilance Plan (section 4.7, from page 283) and in the 2025 Human Rights Risk Assessment Report prepared by Deloitte (page 216).

Reference: page 144 (section 4.1.3.3); index entries on pages 251-252, which also cross-refer to section 5.2.

AXA states that sustainability reporting "use[s] risk management and internal control systems originally designed for financial reporting. The preparation of this Sustainability Statement follows the same approach and diligence process." Controls "aim to reduce compliance risks (e.g., liability risk related to sustainability disclosures) and are part of the Group's operational risk management framework which is deployed throughout the Group", with a presentation of key controls shared annually with the Group Operational, Information, Audit, Risk and Compliance Committee.

Ownership is named: "The Sustainability statement is prepared annually and managed by the Planning, Budget, Results, Central (PBRC) Department." Manuals cited are the Sustainability Reporting Manual, the Environmental Reporting Methodology & Process Handbook, the Digital Sustainability Environmental Reporting Protocol and the Social Data Reporting User Guide. "Department heads sign off the contributions before this Sustainability Statement is presented to key committees. Additionally, the internal control program over sustainability reporting, which provides independent testing of key controls, has been further strengthened expanding its scope to additional material indicators."

Reference: pages 128-130 (sections 4.1.1.1 and 4.1.1.2), with the detailed business model incorporated by reference to section 1.2 (pages 251-252).

AXA's stated purpose is "act for human progress by protecting what matters". In 2025 the Group "further operationalized this ambition by rolling out its Sustainability Guiding Framework at Group level. Anchored in AXA's purpose, the framework articulates six priorities organized around two pillars: Nature (mitigation, transition and adaptation) and People (health & well-being, financial empowerment and access to knowledge)" (page 128). This sits under the "Expanding AXA's role in society" pillar of the 2024-2026 plan "Unlock the Future".

The value chain is split three ways: "AXA's investment activities, where the Group is indirectly connected to the impacts of its investees on people and the environment; AXA's insurance activities, where the Group's impacts on sustainability matters are indirectly connected to the impacts of its insureds on people and the environment; AXA's activities as a company, encompassing actions under AXA's direct control, with potential indirect impacts arising through AXA's relationship with its business partners" (page 130). A value-chain diagram on the same page runs from product and service development through marketing and distribution, underwriting, policy administration, asset and investment management to claim management.

Reference: pages 131-134 (section 4.1.2.1 - Key stakeholders); index entry on page 252, repeated under S1, S2 and S4.

Five stakeholder categories are described with the engagement channel and the outcome (page 132): investees (engagement with management, discharging shareholder duties); policyholders and customers (studies, surveys, client sustainability dialogues, the Future Risks Report and the Mind Health Report); employees (social dialogue with representatives, Pulse survey, Inclusion survey); business partners and suppliers (sustainable procurement guidelines, sustainability clause, responsible procurement programme); and other institutions and technical bodies (local coalitions, working groups).

Two customer studies are quantified: "the Future Risks Report identifies potential emerging risks for AXA by surveying about 3,600 experts across 57 countries and 23,000 individuals from 17 countries", and the fifth Mind Health Report "surveyed 17,000 respondents from 16 countries across Europe, Asia and America" (page 133).

The route from engagement into strategy is named: insights "inform the discussions of the Role in Society Steering Committee (RISSC)", and "the Management Committee reviewed the definition of the Group's value chain and stakeholder mapping as part of the double materiality results validation process. This review was initiated in 2024 and its results were not changed in the second year as part of the 2025 DMA update" (page 133).

Reference: pages 135-139 (section 4.1.2.2); index entry on page 252, repeated under E1, E4, S1, S2 and S4.

The results table on pages 138-139 sets out every material IRO with a marker showing which of the three value chains it attaches to (As an investor / As an Insurer / As a company) and a section cross-reference. AXA counts these markers rather than table rows: it states elsewhere that it has "23 material IROs" (pages 124, 163, 188) and that it "identified nine IROs on climate change" (page 151), matching the nine markers in the E1 block exactly.

Environmental IROs cover climate change mitigation (a negative impact across all three value chains, a positive impact as investor and insurer, and a transition and physical risk to the investment portfolio), climate change adaptation (a positive impact from providing financial protection, a risk of "a higher frequency and intensity of climate-related perils", and an opportunity from prevention services), nature and ecosystems, and circular economy. Social IROs cover own workforce, workers in the value chain in investee companies, and consumers. Governance IROs cover corruption and bribery, ethical culture and whistleblower protection, and irresponsible procurement including payment practices. Four IROs are entity-specific: inclusive insurance, employee volunteering, and two on data privacy and data security (pages 222, 225).

Reference: pages 135-137 (section 4.1.2.2), with the topic-specific methodologies summarised on page 136.

Listed in the ESRS content index against section 4.1.2.2, and repeated as "ESRS 2, IRO-1" under E1, E2, E3, E4, E5 and G1 (pages 253-255, 258).

The DMA was "conducted in 2024 and updated in 2025" (page 135). AXA "identified 16 sustainability matters by considering ESRS guidance, previous sustainability risk assessments, and stakeholder engagement", and "the relevance of each sustainability matter was evaluated during a consultation phase involving 125 internal experts across various functions and entities, as well as 11 external stakeholders using individual interviews and collective workshops". Eleven groups of key stakeholders were mapped across the activities, with insurance and investment treated as distinct value chains.

Thresholds are disclosed: impacts were scored on five-point scales for scale, scope and, for negative impacts, irremediable character, and "where a score was equal to or above 4, the materiality assessment concluded that the impact was material" (page 136). Financial materiality used magnitude, likelihood and time horizon on the same scale, with the same threshold of four (page 137).

Reference: pages 251-262 (section 4.5.3 - Regulatory tables). Page numbers cited throughout this record are PDF pages of the URD; the printed folio at the foot of each page is two lower (PDF page 252 prints "250").

AXA publishes a genuine ESRS content index. Section 4.5.3.2 states: "The identification of the information to report was based on the implementation guidance provided by the EFRAG listing qualitative and quantitative data points. The list of ESRS Disclosure Requirements (DR) that the Group followed in its Sustainability Statement is presented below. DR flagged as 'Phased-in Disclosure Requirement' means that AXA has used phase-in provisions" (page 252).

The index runs standard by standard with a section title and a numbered section reference for each DR: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) on page 252; E1 on page 253, where E1-8 Internal carbon pricing is "Not applicable." and E1-9 is "Phased-in Disclosure Requirement."; E2 and E3 on page 254, where E2-4, E2-5, E3-4 are "Not material" and E2-6, E3-5 "Not applicable"; E4 and E5 on page 255, where E4-5, E5-4 and E5-5 are "Not material"; S1 on page 256, where S1-11 is "Phased-in Disclosure Requirement."; S2 and S4 on page 257, where S2-5 and S4-5 are "Not applicable"; and G1 on page 258, where G1-5 Political influence and lobbying is "Not material". There is no S3 table: section 4.5.3.4 "List of non-material topics" contains a single entry, "S3 Affected communities" (page 266).

Reference: pages 153-156 (section 4.2.1.2 - AXA's Climate Transition Plan), with progress on pages 146 and 179.

"AXA's CTP is embedded in and aligned with AXA's overall business strategy and financial planning. It is integrated at the highest level with the Group strategic plan 'Unlock the Future' featuring a pillar 'Expanding AXA's role in society'. One focus of this pillar is 'Climate Transition' in order to: (i) expand prevention and consulting services for adaptation, and (ii) increase transition underwriting and financing in core activities. AXA's CTP was approved by the Board on March 12, 2025" (page 153).

The plan carries 2030 intermediate decarbonisation targets for all three value chains (page 154): as an investor, a 54% cut in the carbon intensity of General Account assets versus 2019, with 50% achieved in 2025 (66 to 33 tCO2 eq per Euro million); as an insurer, a 30% absolute cut in Insurance-Associated Emissions for the 88 largest corporate clients versus 2021, achieved in 2025 (386,849 to 270,665 tCO2 eq), plus a 20% intensity cut for other corporate clients (28% achieved) and for retail motor (13% achieved); and as a company, a 50% absolute cut in own-operations emissions versus 2019, with 64% achieved (155,099 to 55,843 tCO2 eq).

"AXA's CTP decarbonization targets are defined on a gross basis, i.e. excluding GHG removals, carbon credits, or avoided emissions, and have not been separately validated by an external body" (page 153).

Back-filled from ESRS 2 IRO-1 and section 4.2.1.6 - Addressing climate change risks, where this content is disclosed in the FY2025 report (pages 183-187). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 152-153, 183-187.

Physical / transition classification (¶15). AXA classifies its two material climate risks explicitly: "AXA has identified transition risks, in respect of its investment portfolio, and physical climate risks, in respect of its insurance portfolio", and defines each term (page 153). The E1 IRO table names them as the exposure of the investment portfolio to "physical and transition climate risks that may adversely affect asset valuation" and of the P&C portfolio to "a higher frequency and intensity of climate-related perils" (page 152).

Methodology (¶16). Climate risk analysis "involves inputs from expert teams" and is "further explored in the Own Risk & Solvency Assessment (ORSA) which follows Solvency II directive guidelines and is reviewed with the Autorité de contrôle prudentiel et de résolution (ACPR)", supported by the ACPR Climate Pilot Stress Test (2020) and Climate Stress Test (2023) (page 184). P&C physical risk models "look at three main factors: changes in hazard, exposure, and vulnerability, and model the evolution of Average Annual Losses (AAL)" (page 185). Transition risk uses the CPRS sector classification over listed corporate debt and equities (page 186).

Back-filled from ESRS 2 SBM-3 and section 4.2.1.6 - Addressing climate change risks, where this content is disclosed in the FY2025 report (pages 184-188). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 184-188.

Results (¶19(a)). "In 2025, AXA also updated its resilience analysis in the context of the 2024 ORSA" (page 184). The conclusion is stated plainly: "Based on the physical and transition risks analysis performed on the above-mentioned portfolios, the financial impacts remain manageable in the considered timeframes and do not raise material concerns requiring additional measures to adapt the strategy or the business model" (page 187), and "Based on AXA's analysis, there is no significant risk of a material financial effect within the next annual reporting period to the carrying amounts of assets and liabilities reported in the related financial statements" (page 187). For Life and Health: "these studies and stress tests show that climate change could have a long-term financial impact on Life & Health businesses, but the impact is expected to be small and gradual. AXA believes that any changes will happen slowly enough to allow for management actions like timely repricing" (page 186).

Reference: pages 157-160 (investor), 164-172 (insurer) and 174-176 (company); index entry on page 253 pointing to sections 4.2.1, 4.2.1.2, 4.2.1.3, 4.2.1.4 and 4.2.1.5.

The central instrument is the AXA Energy Policy: "AXA has established the AXA Energy Policy to manage material IROs within its investment portfolio. Since 2015, AXA has implemented multiple restrictions related to fossil fuels investments, notably in the thermal coal and oil & gas sectors. The policy aims to progressively align investments with net-zero trajectories" (page 157). It is defined, implemented and monitored by the Responsible Investment Committee, published on the Group website, and applied to underwriting as well as investment.

Thermal coal exclusions are quantified: AXA prohibits investment in "Mining companies with a coal revenue share exceeding 10% in EU and OECD countries and 15% in all other countries, or with an annual coal production of over 20 million tons", in "Power generation companies with a coal share of power production (energy mix) exceeding 10% in EU and OECD countries and 15% in all other countries, or with over 10 GW of coal-based power installed capacity", and in certain coal industry partners. A long-term exit strategy reduces thermal coal exposure "to zero by 2030 in respect of companies established or operating primarily in the European Union and OECD countries, and by 2040 in respect of companies in the rest of the world" (page 157).

Reference: pages 155-156 (lever and action tables), 173-178 (own operations and adaptation); index entry on page 253.

The CTP action tables set out, for each value chain, the action and its scope (page 155). As an investor: restrict investments in the fossil fuel sector; make investment decisions using climate-related criteria; finance the climate transition with €5 billion per year; engage with investees on their transition strategies. As an insurer: restrict insurance policies in the fossil fuel sector across all lines including facultative reinsurance, with named carve-outs; support transition underwriting to reach €6 billion of P&C gross written premiums cumulative 2024-2026 across eight named entities; engage with the largest corporate clients; develop sustainable claims management in motor. As a company: reduce emissions from energy, car fleet, business travel and digital technologies; engage suppliers on purchased goods and services.

Own-operations actions are concrete: "Since 2025, AXA is sourcing 100% of its electricity consumption from renewable sources. AXA notably signed a Europe-wide Virtual Power Purchase Agreement (VPPA) in 2023 to cover the electricity consumption of all the Company's buildings and data centers in Europe from 2025 and onward ... The VPPA has been live since the 1st of May 2025" (page 174).

Reference: pages 154 (target table) and 146 (AXA for Progress Index results); index entry on page 253.

AXA sets 2030 intermediate decarbonisation targets for each value chain, each with a stated scope and an explicit statement on 1.5°C alignment (page 154).

As an investor: "54% reduction in the carbon intensity of AXA's investment portfolio (General Account assets) by 2030, relative to 2019", covering 40% of General Account assets. "The target is in line with the NZAOA recommendation and interpretation of the modelled scenarios from the IPCC Sixth Assessment Report (AR6 WGIII) for a +1.5°C pathway with no or limited overshoot, with the GHG emissions reductions in the range of 40-60 per cent by 2030 compared to a 2019 baseline year." 2025 performance: -50%.

As an insurer: a 30% absolute reduction in Insurance-Associated Emissions for the 88 largest global commercial clients versus 2021, aligned to 1.5°C; -30% achieved. Two further targets are explicitly not aligned: the 20% intensity target for other corporate clients "does not adhere to a +1.5°C pathway as the industry sectors were limited to the most material sectors", and the retail motor target "does not adhere to the IPCC 1.5 C pathway as Personal Motor Vehicle usage is not an industry economic activity modeled by the IPCC". Achieved: -28% and -13%.

Reference: page 181 (Energy consumption and mix table, section 4.2.1.5); methodology in section 4.5.2.1; index entry on page 253.

Total energy consumption for 2025 was 189,975 MWh, down from 210,500 MWh in 2024, "decreasing by 10% compared to 2024, mainly due to some site closures as well as the ongoing data center infrastructure rationalization programs and the transfer of services to cloud computing services. This decrease represents 40% compared to 2019, exceeding the 2025 target" of a 10% reduction.

Reference: pages 179-181 (GHG emissions by Scope, section 4.2.1.5) and page 161 (financed emissions); index entry on page 253.

The mandatory table is presented against a restated 2019 base year, which excludes AXA IM following its disposal in July 2025 (pages 178-179). Figures in tCO2 eq.

Reference: pages 182-183 (Climate contribution (carbon credits), section 4.2.1.5); index entry on page 253.

AXA reports no GHG removals of its own. Its E1-7 disclosure is entirely about carbon credits financed outside the value chain: the Group "targets achieving a 50% reduction in its GHG emissions related to energy Scopes 1 and 2, car fleet and business travel, between 2019 and 2030, while financing GHG emission reduction projects outside the value chain by purchasing carbon credits, corresponding to the volume of residual emissions" (page 182). Selection criteria require projects to "(i) have a significant positive environmental impact; (ii) be located in countries where AXA operates; and (iii) meet high quality standards through certification".

Reference: pages 191-193 (sections 4.2.2.2 and 4.2.2.3); index entry on page 254.

AXA treats E2 to E5 through one combined nature analysis: "AXA adopted a common process to identify and assess material impacts, risks, dependencies and opportunities related to pollution (ESRS E2), water and marine resources (ESRS E3), biodiversity and ecosystems (ESRS E4), resource use and circular economy (ESRS E5). Consequently, to ease readability and unless otherwise specified, the following disclosures apply equally to the various environmental topics previously mentioned" (page 190).

The policy AXA points to is its ecosystem conversion and deforestation framework, implemented in 2021 and reviewed in 2025, which "relies on three complementary screening approaches: the assessment of exposure to commodities associated with deforestation, the monitoring of biodiversity and land-use-related controversies, and the evaluation of companies' impacts on forests" using CDP data. AXA "excludes from its General Account companies involved in unsustainable palm oil production, those facing 'high' or 'severe' biodiversity and land-use controversies" (page 191).

AXA is explicit about the limit: "At present, AXA does not have any established policies, action plans or targets that specifically focus on water preservation and pollution. However certain action plans and policies with respect to nature and ecosystems may incorporate elements relating to these topics" (page 192).

Reference: pages 191-192 and 193-195; index entry on page 254 pointing to section 4.2.2.2.

Actions against the combined nature IRO, which covers pollution alongside water and biodiversity, are investor engagement and underwriting controls rather than abatement in AXA's own operations, which were assessed as immaterial: "no material impacts or dependencies have been identified in AXA's own operations and sites" (page 190).

As an investor: "In 2025, AXA Group initiated engagement on biodiversity with 20 companies operating in the Food & Beverage, Chemicals and Environmental Services industries" (page 191), with outcomes "presented annually to the RIC, which could decide whether to restrict or exclude investments in issuers that are not aligned with AXA's ambitions" (page 192). AXA holds approximately €0.8 billion of sustainable forestry investments covering "around 72,000 hectares of forests primarily located in France, Australia, and Finland", and committed "a €10 million investment alongside 16 other institutional investors to the 'Fonds de Place Objectif Biodiversité'".

As an insurer, AXA XL deployed two digital tools relevant to pollution and water: "the Water Impact and Sustainability Tool (WISE) and the Nature Environmental Sensitivity Tool (NEST) ... The NEST tool ... applies algorithms to assess the environmental risks of individual sites and facilities. The outputs include environmental sensitivities scores and high-resolution maps for each location" (page 195).

Reference: pages 192 and 196; index entry on page 254 pointing to section 4.2.2.2.

AXA discloses no numeric pollution reduction target and says so directly: "At present, AXA does not have any established policies, action plans or targets that specifically focus on water preservation and pollution. However certain action plans and policies with respect to nature and ecosystems may incorporate elements relating to these topics" (page 192). On the ENCORE-based impact and dependency metrics it adds: "Considering the limited maturity of the methodology and data, AXA has not set any objective on these metrics and no specific time horizon has been set for the completion of the actions listed above."

What AXA does track against a target sits on the insurance side, where environmental prevention is measured together with biodiversity and water: "the best metric to prove the efforts in environmental risks prevention (pollution, biodiversity water) is the number of Nature and biodiversity prevention services delivered to companies. As a first step, only AXA XL is in the scope of this target and metric" (page 195). The result: "All the efforts developed in 2025 have succeeded in delivering 86 Nature and Biodiversity prevention services against the 50 initially planned as a target. Following this, AXA is considering the next target to be implemented in this area" (page 196).

Reference: pages 191-192 (section 4.2.2.2); index entry on page 254.

E3-1 is listed in AXA's index against "Addressing nature and ecosystems as an investor", the same section used for E2 and E4, because AXA applied "a common process to identify and assess material impacts, risks, dependencies and opportunities related to pollution (ESRS E2), water and marine resources (ESRS E3), biodiversity and ecosystems (ESRS E4), resource use and circular economy (ESRS E5)" (page 190).

The disclosure is candid that no dedicated water policy exists: "ENCORE provides ratings on water pollution (impact) and water supply services (dependency), enabling the consideration of these aspects in the Group's nature-related potential impacts and dependences analysis. ENCORE analysis reveals potential materiality related to pollution mitigation and water preservation of sectors in which investees are present. Conclusions are preliminary. At present, AXA does not have any established policies, action plans or targets that specifically focus on water preservation and pollution. However certain action plans and policies with respect to nature and ecosystems may incorporate elements relating to these topics" (page 192).

Reference: pages 191-195; index entry on page 254 pointing to section 4.2.2.2.

Water-related actions are presented inside the combined nature workstream rather than as a standalone water programme. As an investor, the ecosystem conversion and deforestation policy screening, the 2025 biodiversity engagement with 20 Food & Beverage, Chemicals and Environmental Services companies, the €0.8 billion sustainable forestry portfolio and the €10 million commitment to the "Fonds de Place Objectif Biodiversité" are the actions listed against the nature IRO (pages 191-192).

The clearest water-specific action is on the insurance side: AXA XL developed "the Water Impact and Sustainability Tool (WISE) ... [which] allows companies to assess water scarcity and liabilities at their owned or supply chain assets. The outputs are developed from a combination of open-source databases and bespoke company information assessing regulatory risks, reputational risks, physical risks and operational risks, either now or in the future based on climate modelling data" (page 195). AXA also cites nature-based solutions insurance including "mangroves forests and coral reefs parametric insurance provided by AXA Climate or AXA XL's Political Risk, Credit and Bond offer that helps marine conservation-linked bonds, also known as 'blue bonds'", used to expand marine protected areas and fund conservation trusts "in the Seychelles, Belize, Barbados, Ecuador, and in Gabon" (page 193).

Reference: pages 192, 195-196 and 182; index entry on page 254 pointing to section 4.2.2.2.

AXA sets no water-specific target and says so: "At present, AXA does not have any established policies, action plans or targets that specifically focus on water preservation and pollution" (page 192). On the nature impact and dependency metrics it adds: "Considering the limited maturity of the methodology and data, AXA has not set any objective on these metrics and no specific time horizon has been set for the completion of the actions listed above."

The target AXA does report under its combined nature heading covers water alongside pollution and biodiversity: "the best metric to prove the efforts in environmental risks prevention (pollution, biodiversity water) is the number of Nature and biodiversity prevention services delivered to companies. As a first step, only AXA XL is in the scope of this target and metric" (page 195). AXA delivered 86 such services in 2025 "against the 50 initially planned as a target. Following this, AXA is considering the next target to be implemented in this area" (page 196).

Own-operations water carries an internal reduction target reported in the "Other environmental indicators" table: water consumption per person of 4.2 m3/FTE in 2025 (4.1 in 2024), a 54% reduction against the 2019 base year versus a 10% target for 2019-2025. AXA notes "the targets set for 2025 were reached" (page 182).

Reference: pages 189-191 (section 4.2.2.1); index entry on page 255.

AXA does not present a formal biodiversity transition plan; the index maps E4-1 to its approach section, where the consideration of biodiversity in strategy and business model is set out.

Screening covered own operations and both value chains. Two own-operations initiatives are cited: a Global Biodiversity Score determined in 2022 covering purchased goods, where "the main impacts are linked to food supply and car fleet production, with pressures on land use, water consumption and pollution, but these indirect impacts remain limited in their scale"; and a study by AXA France concluded in early 2024 that "analyzed more than 3,000 sites in France to determine their proximity to biodiversity issues", revealing "limited risks of impact on nature or dependencies on ecosystem services" (page 190).

The conclusion is precautionary: "AXA considers biodiversity to be a potentially material issue ... However, determining the precise materiality of this topic remains methodologically challenging, as current measurement methods remain immature and fragmented, particularly in terms of establishing quantitative materiality thresholds ... AXA adopts a cautious and precautionary approach and treats biodiversity as material, while acknowledging that its present capacity to conduct a granular, quantitative assessment is still limited" (page 190).

Reference: pages 191 (investor) and 194-195 (insurer); index entry on page 255.

Ecosystem Conversion and Deforestation Policy. Implemented in 2021 and reviewed in 2025. As an investor, AXA "excludes from its General Account companies involved in unsustainable palm oil production, those facing 'high' or 'severe' biodiversity and land-use controversies, or those facing 'significant' controversies while at the same time having a 'critical' impact on forests according to CDP" (page 191). As an insurer, "companies producing or trading commodities (beef, palm oil, soy, timber) that face 'high' or 'severe' controversies related to 'land use and biodiversity' and that operate in 'high-risk countries' are to be referred. Depending on the engagement conclusion, these companies may be banned for construction and property covers, and marine cargo covers" (page 194).

Natural World Heritage Sites Policy. Reviewed in 2025 to "apply exclusions on companies' projects in sensitive sectors that are developing activities incompatible with the preservation of ecosystems in the NWHS: project-specific Construction covers and stand-alone Property covers for oil and gas, mining, large scale hydropower and large-scale infrastructure projects located in or in direct contact with a NWHS" (page 194).

Reference: pages 191-193 and 195; index entry on page 255 pointing to sections 4.2.2.2 and 4.2.2.3.

As an investor. "In 2025, AXA Group initiated engagement on biodiversity with 20 companies operating in the Food & Beverage, Chemicals and Environmental Services industries. Biodiversity is a multi-local issue as opposed to climate change, which is a global issue" (page 191). Engagement priorities vary by sector: with Food & Beverage companies the focus was "sustainable sourcing of raw material, including traceability and deforestation-free policies", and outcomes are "presented annually to the RIC, which could decide whether to restrict or exclude investments in issuers that are not aligned with AXA's ambitions" (page 192). By end-2025 AXA held "approximately €0.8 billion" of sustainable forestry investments, "representing around 72,000 hectares of forests primarily located in France, Australia, and Finland", and in 2025 committed "a €10 million investment alongside 16 other institutional investors to the 'Fonds de Place Objectif Biodiversité', a biodiversity focused fund dedicated to financing unlisted companies that develop solutions to preserve and restore biodiversity".

Reference: pages 192, 195-196; index entry on page 255.

AXA sets one quantified biodiversity target and is explicit that its portfolio metrics carry none.

The target. "the best metric to prove the efforts in environmental risks prevention (pollution, biodiversity water) is the number of Nature and biodiversity prevention services delivered to companies. As a first step, only AXA XL is in the scope of this target and metric" (page 195). Result: "All the efforts developed in 2025 have succeeded in delivering 86 Nature and Biodiversity prevention services against the 50 initially planned as a target. Following this, AXA is considering the next target to be implemented in this area" (page 196). Biodiversity-related premiums also count towards the €6 billion transition underwriting target to end-2026.

The metrics without a target. Using ENCORE as a sector-level knowledge base for its listed corporate portfolio, AXA reports potential high or very high impacts on biodiversity of 15% of the portfolio in 2025 (16% in 2024) and potential dependencies of 15% (15% in 2024) (page 192). It states: "Considering the limited maturity of the methodology and data, AXA has not set any objective on these metrics and no specific time horizon has been set for the completion of the actions listed above."

Reference: page 196 (section 4.2.2.4 - AXA's approach to Circular Economy as an insurer); index entry on page 255.

AXA states there is no circular economy policy, and explains why: "AXA aims to participate in the transition towards a less resource-intensive economy. While no policy has been adopted to manage the potential negative impact of its insurance activities on resources use and circular economy, AXA is exploring solutions to limit the use of raw materials in its claims management and to provide insurance coverage that is suited for circular practices" (page 196).

In place of a policy, AXA describes two working groups inside the PlanNet underwriting expert network: one "to develop circular practices in AXA's claims management processes to limit the use of new raw material", and one "to improve the understanding of the risks associated with emerging circular practices and business models, to drive their insurability, and thereby facilitating their development".

The material IRO is scoped to claims handling: "AXA's potential impacts on resource use and the circular economy arise indirectly, primarily through claims management processes in its P&C insurance activities, where the repair or replacement of damaged assets may lead to the consumption of raw materials. While these impacts remain limited in scale relative to AXA's overall business model, the Group acknowledges that they may contribute to pressures on natural resources and waste generation" (page 196).

Reference: pages 196-197 (section 4.2.2.4); index entry on page 255.

Two actions are described, both on the insurance side.

Circular practices in motor claims. "A workstream dedicated to 'sustainable claims' was created in 2024 and aimed at developing claims practices with reduced environmental impacts. In 2025, the workstream prioritized the delivery of the 'sustainable claims' target set for retail motor ... The workstream has leveraged existing initiatives already in place in several European countries, to promote (i) the use of remote expertise for claims adjusting, (ii) the repair of damaged parts rather than their replacement, and (iii) whenever replacement is necessary, the use of second-hand parts, to limit the use of raw material and prevent waste generation in downstream value chain. This workstream will continue its work over the 2024-2026 plan period" (page 196).

Insurability of reclaimed and bio-sourced materials. A workstream of Construction and Property line representatives was created in 2024 "to enhance AXA's understanding of the unique risks associated with these materials in order to facilitate their insurability". In April 2025 AXA released two pieces of work with ARUP: "a White Paper to raise awareness among underwriters on the use of reclaimed materials in the build environment, and a Checklist for on-site risk expert visits". Work continued through "a claims library, gathering loss cases related to reclaimed materials".

Reference: page 197 (section 4.2.2.4); index entry on page 255.

AXA reports one voluntary circular economy target, and discloses that it has changed how it is expressed.

"With respect to AXA's potential negative impact on resources use and circular economy, which could occur through claims management, AXA initially set a voluntary target to increase its 'sustainable claims' ratio by 10% for its retail motor business by 2026 (compared to the 2021 baseline). In 2024, the Group surpassed its initial 10% objective, achieving an 18% increase in the sustainable claims' ratio compared to 2021. Building on this progress, AXA has decided to simplify the follow-up of this metric and, from now on, monitor the increase of its sustainable claims' ratio by 2026. Additionally, the Group is expanding the geographical scope of this metric to include AXA Spain. AXA will therefore no longer communicate on the 2021 baseline, but rather monitor progress of the sustainable ratio until 2026" (page 197).

Reference: pages 203-217 (sections 4.3.1.1 to 4.3.1.5 and the Group Human Rights Policy at 4.3.2.2); index entry on page 256.

AXA lists a policy set rather than a single own-workforce policy: the Health, Wellbeing and Safety Policy (page 204), the Performance Management Policy revised by the Management Committee in May 2024 (page 206), the Group Inclusion and Diversity Policy (page 208), the Group Policy on Harassment (page 211), the AXA Group Remuneration Policy (page 211) and the Group Human Rights Policy (page 217).

"AXA's policies apply to all employees. The company uses a decentralized system, so each entity applies Group policies in ways that fit their local context and can adapt them as needed. The Chief Executive Officer of each entity is responsible for putting these policies into action" (page 203). The culture framing is "We Care and Dare for Progress", started in 2024, built on four values: "(i) Customer First, (ii) Integrity, (iii) Courage, and (iv) ONE AXA".

The Health, Wellbeing and Safety Policy "sets standards for: identifying risks related to safety in each local AXA entity; addressing risks, proactively and reactively; and measuring performance" (page 204). The Group Policy on Harassment "clearly states that harassment is not allowed; explains the steps and protections for employees who report concerns; and requires employees to speak up if they experience or witness inappropriate behavior" (page 211).

Reference: pages 212-213 (section 4.3.1.5 - Supporting social dialogue and engaging with employees) and page 134; index entry on page 256.

The formal channel is the European Works Council: "At the Group level, the European Works Council (EWC) is a key forum established by an agreement in 2009. It serves as a platform for information sharing, employee consultation, and participation. The EWC convenes twice a year for plenary sessions led by the Group CEO and holds seven smaller Bureau meetings annually. These meetings include 12 elected EWC members and a permanent guest from UNI Union Network International-Europa. The EWC's framework encompasses more than half of AXA's employees" (page 212).

A concrete 2025 outcome is recorded: "On November 27, 2025, during the 2nd annual plenary session, Thomas Buberl and the AXA Group EWC signed a charter addressing all entities concerning the conduct of European social dialogue on the development of artificial intelligence within the AXA Group. This charter formalizes the commitments made by the group with its EWC, emphasizing iterative social dialogue, as well as the training of EWC members and all employees on the safe, ethical, and sustainable use of AI."

Reference: pages 227-228 (section 4.4.1.3 - Protecting whistleblowers), cross-referenced from page 213; index entry on page 256 pointing to section 4.4.1.2.

AXA routes own-workforce remediation and concern-raising through its Group whistleblowing framework: "The process to remediate negative impacts and the channels available to AXA's own workforce to raise concerns is described in Section 4.4 - Governance information - 4.4.1.3 - Protecting whistleblowers" (page 213).

"AXA has zero tolerance to any misconduct related to a behavior or a process believed to be inappropriate, unethical or illegal which may cause detriment to (an) individual(s) or AXA. Group Standards set out that Whistleblowing is dealt with, reported, and investigated in a consistent and appropriate manner across the Group. The Group Standards and the Group Whistleblowing and Investigations guidelines mandate that all Whistleblowing concerns are reported to and managed by the independent Investigations team across the Group" (page 227).

Channels are multiple: "line management, a trusted colleague, HR, Compliance, Legal, the dedicated local Whistleblowing hotline, local Internal Audit or directly to Group Internal Audit (speak-up@axa.com) or they can be identified via a detection tool. Speak-up@axa.com is available both internally via local intranets and externally through 'axa.com' that is globally reachable to employees, suppliers, business partners, and external stakeholders."

Reference: pages 204-214 (sections 4.3.1.2 to 4.3.1.5); index entry on page 256.

Actions are grouped under health and wellbeing, upskilling, inclusion and diversity, and social dialogue.

Health and wellbeing. The "We Care" programme was rolled out "across all entities in compliance with local laws and practices" in 2025 (page 201). The "Healthy You" programme provides "in-person medical check-up every four years for employees over 40, and a digital medical check-up for all employees every two years", a yearly flu vaccination campaign, "an Employee Assistance Program that provides 24-hour mental health and psychological support", medical teleconsultations, a second medical opinion service, and "financial help covering at least 75% of cancer-related medical costs plus psychological support for employees with cancer". In 2025 AXA "launched globally the Mental Health Odyssey, a training aimed at raising awareness and supporting employees facing stress, burn-out, anxiety or depression" (page 206). Commitments extend to menopause, andropause and menstrual health conditions.

Upskilling. The Tech, Data & AI Academy programmes reached 290 leaders through the HEC Paris partnership, 32,000 participants in "GenAI for Everyone" and 25,000 in "Tech, Data & AI Essentials" (page 207). The AXA Sustainability Academy's climate adaptation module reached "over 46,000 employees certified by the end of 2025" against a target of 80,000 by 2026.

Reference: pages 203, 212 (sections 4.3.1.1 and 4.3.1.4); index entry on page 256.

AXA's S1-5 disclosure is largely a statement that Group-level targets are deliberately not set: "At Group level, AXA does not set specific targets for material impacts in relation to own workforce, since these are usually better set locally for a more customized and effective approach. The policies and actions described in relation to AXA's own workforce are already in place and therefore do not require material expenditure, but AXA continues to improve its understanding and response to social issues" (page 203).

One Group-level commitment is nonetheless disclosed, on adequate wages: "While AXA has not set formal targets for its material impacts in relation to its own workforce, nonetheless AXA seeks to offer all employees a total target cash remuneration of at least 110% of the local living wage by the end of 2026" (page 212). AXA "has also signed the B4IG (Business For Inclusive Growth) pledge, which is part of the UN Global Compact's 'Forward Faster' initiative, to show its commitment to paying a living wage."

Two further workforce-adjacent targets appear in the AXA for Progress Index but are attached to other topics: training "> 80,000 employees trained on climate adaptation by 2026" (46,420 reached in 2025) and "50% of employees" engaged in volunteering by 2026 (56% reached), the latter sitting under the entity-specific corporate culture IRO in section 4.4.1.5 (pages 145-146).

Reference: pages 203-204 (section 4.3.1.1); index entry on page 256.

AXA's workforce at 31 December 2025 was 111,262 employees "spread across 42 countries with 97% having an open-ended contract. In 2025, AXA's overall salaried workforce has remained flat with a small decrease of 1% (+1.5% increase on a like-to-like basis)". The drivers of change are given: "the new acquisition of Nobis into AXA Italy (+350), the sale of AXA IM (-2,857), and the change in CSRD reporting scope, now including AXA Nouvelle-Calédonie, AXA Polynésie Française, and three entities in Egypt (+175)" (page 203).

Non-guaranteed hours employees are footnoted as "not material, very limited number of situations" (page 204).

Headcount by region is charted on page 203, with Europe dominant (France 22,933; then 10,270, 10,148, 5,078, 4,309, 3,813, 3,002, 2,535 for other European markets), North America 2,453, Asia 9,426 across five markets, South America 5,042 and 4,581, Africa 5,876 and 1,261, and 5,883 in countries with fewer than 1,000 headcount each.

Reference: pages 202 and 204 (section 4.3.1.1); index entry on page 256.

Non-employee workers are defined first: "non-salaried workforce corresponds to the staff physically working on-site or remotely across any of AXA's entities, but who are not AXA's employees: logistics (e.g. receptionists, security guards, canteen staff, cleaning staff, and maintenance staff), IT consultants, temporary workers, student trainees/interns/apprentices (without labor contract), outsourcing agreements, third-party suppliers or strategic consultants" (page 202).

The methodology note explains the scope: "The contingent labor or temporary non-salaried workforce includes contractors, consultants or those having a contract with a job agency and freelancers. It excludes trainees, interns, apprentices, outsourcing agreements, third-party suppliers or Strategic Consulting specific services. This indicator is reported in Average Full Time Equivalent as of December 31 of the reporting year" (page 250).

Reference: page 213 (section 4.3.1.5); index entry on page 256.

AXA reports collective bargaining coverage and workplace representation for EEA countries only, in banded form:

The table is labelled "2025 and 2024", so the two years are identical. The narrative confirms the position: "In France and Germany, all AXA employees are covered by collective bargaining agreements or similar negotiated arrangements, with local laws providing a structured system for workers' councils in these countries" (page 212).

Coverage outside the EEA is not disclosed, and AXA declares this as an omission taken under transitional relief: "the information related to the coverage by collective bargaining agreements for employees outside the EEA ... required by ESRS S1 ... [was] also omitted by AXA, in accordance with the Quick fix regulation" (page 150). No global collective bargaining percentage is therefore reported.

At Group level the European Works Council agreement of 2009 "encompasses more than half of AXA's employees" (page 212), and AXA "dedicates both financial and human resources at Group and local levels to fostering robust social dialogue" (page 213).

Reference: pages 209-210 (section 4.3.1.4); index entry on page 256.

Gender distribution at top management level (page 209):

AXA notes the Global Leadership Network figure "represents a decrease of 2 percentage points from 2024 but an increase of 7 percentage points from March 2019 when the GLN was launched" (page 209). Other and not reported genders are excluded from these three tables.

Total workforce by gender: 61,528 female, 49,668 male and 66 other in 2025, against 61,796, 50,555 and 3 in 2024 (page 209).

Age distribution across the whole workforce (page 210): under 30 at 20% (22,023 in 2025, 21,850 in 2024); 30 to 50 at 56% (62,296 in 2025, 63,104 in 2024); over 50 at 24% (27,116 in 2025, 27,227 in 2024). AXA adds elsewhere that "24% of our employees worldwide (33% in Europe) are over 50 years" (page 210).

The Board-level diversity datapoints are incorporated by reference to section 3.2 and reported separately: 56% women on the Board in 2025 against 59% in 2024 (pages 140, 251).

Reference: pages 211-212 (section 4.3.1.4); index entry on page 256.

AXA discloses its approach and its certification rather than a percentage of employees paid at or above an adequate wage.

"AXA strives to pay its employees at or above the adequate wage. AXA uses the 'adequate wage' and 'living wage' to mean the same thing. A living wage can go beyond the legal minimum wage: it is the amount needed for employees and their families to afford basic needs like decent housing, food, healthcare, and education, depending on their working location" (page 211).

The external benchmark is named: "AXA has been engaging with the Fair Wage Network to conduct an analysis in all of the Group's countries of operation to assess employees' pay against local living wages. In 2023, AXA successfully obtained certification as a Living Wage employer from Fair Wage Network provider. The certification was renewed in 2024 and remains valid for two years" (page 212).

The 2025 assessment method and its limitation are both disclosed: "AXA reviews living wage levels by conducting annual assessments. For 2025, this assessment was performed directly by AXA using the Fair Wage Network benchmarks. The Fair Wage Network updates local living wage amounts annually, which can change due to economic or inflation factors. Although a few employees may fall below the new living wage level, AXA commits to address them during the subsequent pay review."

Reference: page 210 (section 4.3.1.4); index entry on page 256.

The figure is footnoted "Subject to legal restrictions on the collection of data", and AXA explains: "AXA is subject to the legal restrictions around gathering data about disability. AXA tracks the percentage of employees with disabilities, while respecting legal limits on data collection. In 2025, 3.15% of AXA's workforce had declared a disability" (page 210).

The supporting actions are quantified by entity coverage rather than by headcount. "In 2024 AXA's entities committed to adopting four practices: 1. entity-level executive sponsorship for disability; 2. annualized plans; 3. centralized budgets for workplace adjustments; and 4. policies for workplace adjustments." Progress in 2025: "81% of entities now having a disability sponsor positioned at Executive Committee level (up from 70% in 2024), 100% having disability action plans, 66% having a workplace adjustment policy (up from 30% in 2024) and 69% having a centralized budget (39% in 2024 and only 2 entities in 2023)".

The Inclusion Survey carries "optional self-identification questions on age, disability, gender, sexual orientation, ethnicity minority and socio-economic background to help AXA track progress, spot patterns and identify challenges faced by these specific groups" (page 134).

Reference: pages 206-208 (section 4.3.1.3 - Supporting workforce upskilling); index entry on page 256.

"AXA tracks the number of hours employees dedicate to training, as well as the number of completed training journeys" (page 208). The "Not reported" gender category is footnoted "not material, very limited number of situations".

The underlying programmes are described in detail. The Performance Management Policy, revised by the Management Committee in May 2024, introduced "an annual career discussion separate from the performance conversation, providing employees and managers with the opportunity to consider long-term development priorities. In 2025, the principles of the policy had been fully implemented across all AXA entities" (page 206). The Tech, Data & AI Academy reached 290 leaders through the HEC Paris partnership across nine cohorts, 40 Data & AI Business Partners, 32,000 participants in "GenAI for Everyone" and 25,000 in "Tech, Data & AI Essentials" (page 207). The AXA Managers Academy has "already reached 7,363 managers across 18 entities since their inception".

Reference: pages 204-205 (section 4.3.1.2 - Supporting health and wellbeing); index entry on page 256.

"This system is monitored through Security Assurance Framework reporting. This reporting allows local Boards of Directors, local Executive Committees, or equivalent to monitor key trends (absenteeism, accidents, campaigns, requirements, weaknesses). In 2025, 100% of employees were covered by the health and safety management system" (page 204).

The table covers "Open-ended contracts only"; days lost are working days. AXA explains that no separate accident rate is published because "The rate of recordable work-related accidents is not significant for AXA, which is why it is integrated into the global absenteeism rate of salaried workforce" (page 204).

Reference: pages 206 and 250 (section 4.3.1.2 and the social methodology note); index entry on page 256.

AXA reports work-life balance through its leave arrangements and flexible working commitments. The methodology note defines the metric basis: "The percentage of entitled employees that took family-related leave is calculated as the percentage of salaried workforce, corresponding to the ratio of number of headcounts of salaried workforce who took family-related leaves (including maternity, paternity, parental leaves) during the reporting year divided by the average headcount of salaried workforce during the reporting year. Salaried workforce who took family-related leave during the reporting year but left AXA and no longer are part of the workforce as of December 31 are included. It concerns only salaried workforce with open-ended contract" (page 250).

Specific flexibility commitments are disclosed: "AXA has further commitments to employees experiencing menopause, andropause and menstrual health conditions. These employees can ask for flexible working arrangements to accommodate symptoms and medical appointments" (page 206).

Flexible working is also cited as a driver of the Group's energy reduction: "the increase in hybrid working arrangements in all the Group's entities with the implementation of 'Smart Working'" (page 181), and "Smart Working" is named as one of the HR policies adapted from Pulse and Inclusion survey results (page 134).

Reference: page 212 (section 4.3.1.4 - Monitoring fair remuneration); index entry on page 256.

AXA flags a scope change that breaks comparability: "From 2025, AXA reports the gender pay gap and the remuneration ratio based on the total rewards which comprises of the total direct pay, profit-sharing and the benefits, whereas the 2024 reporting is based on total direct pay only." The narrative explains: "Until 2024, AXA reported its gender pay gap and remuneration ratio based on total direct pay, encompassing Fixed Salary and Variable pay (cash and AXA LTI). From 2025, the scope has been broadened to include total rewards, comprising fixed pay, variable pay (cash and AXA LTI), fixed allowances, collective profit-sharing, and benefits."

Both the unadjusted and adjusted gaps are given: "At AXA, this gap on a global level for all employees is 22% for fixed pay (median 21%), and at 26% for total direct pay (median 24%)", while "AXA's adjusted pay gap is 1.3% for fixed pay and 1.4% for total direct pay, which is lower than the 5% limit set by the European Union Pay Transparency Directive" (Directive EU 2023/970). AXA defines the adjusted gap as comparing average pay "after accounting for a selected set of professional characteristics (such as role, seniority, level, or location)".

Reference: page 211 (section 4.3.1.4 - Monitoring incidents of harassment); index entry on page 256.

The narrative confirms the figures: "In 2025, 100 cases of discrimination (including harassment) and 47 other incidents (or inappropriate behavior) categorized as 'People related matters' within AXA were reported with an amount provisioned at the end of the reporting period of €3 million. In 2025, there were zero severe human rights incidents reported related to the workforce, resulting in no material amount provisioned for fines or compensation" (page 211).

AXA adds a nil return on external grievance mechanisms: "To the best of Group's knowledge, in 2025, no complaints were filed by AXA's own workforce to National Contact Points for OECD Multinational Enterprises."

Reference: pages 217-218 (section 4.3.2.2 - Policies protecting workers in the value chain); index entry on page 257.

The Group Human Rights Policy is the named instrument: AXA "has developed a 'Group Human Rights Policy' to address negative impacts on workers' human rights and critical work-related rights in companies it invests in, companies and individual it underwrites, companies it has business with (suppliers, business partners, mergers and acquisitions), and to tackle issues such as unequal treatment or lack of diversity or inclusion within its own workforce. The policy covers areas including work-life balance, health and safety, gender equality, training, and diversity ... The policy applies to all areas of AXA's business - as an employer, business partner, insurer, and investor - and is enforced in every region where AXA operates. CEOs are accountable for the implementation of this Policy" (page 217).

Alignment is to "the United Nations Universal Declaration of Human Rights, the core standards of the International Labor Organization (ILO), the UN Global Compact, and the OECD recommendations", and the policy "explicitly addresses human trafficking, forced or compulsory labor, child labor, freedom of association, right to collective bargaining, discrimination, data privacy, health and safety, and employee well-being". It "is communicated through the AXA Group website, company intranet, and local whistleblowing policies".

Reference: pages 215-216 and 219 (sections 4.3.2.1 and 4.3.2.3); index entry on page 257.

AXA is unusually direct about the limits of its engagement reach: "The investments made by AXA do not provide privileged access to the workforce of investee companies and AXA has no established channel to communicate directly with their workers on these topics. However, concerns can be reported locally or directly to AXA through the public whistleblowing platform (speak-up@AXA.com) which is listed on the AXA website. It is however acknowledged that AXA cannot know for sure whether value chain workers of its investee companies are aware of and trust the whistleblowing process as a way to raise their concerns or needs, and whether their concerns are being addressed by the whistleblower reporting procedure" (page 219).

Engagement therefore runs through due diligence and a third-party assessment rather than direct worker dialogue. "The Group Vigilance Plan and the human rights risks assessment are the due diligence processes by which AXA identifies, prevents, mitigates and accounts for material actual and potential negative impacts on people with AXA's own operations and value chain" (page 215).

Reference: pages 215, 219 and 227-228; index entry on page 257 pointing to section 4.4.1.2.

The channel is the same Group whistleblowing platform used for own workforce: "concerns can be reported locally or directly to AXA through the public whistleblowing platform (speak-up@AXA.com) which is listed on the AXA website" (page 219). "Speak-up@axa.com is available both internally via local intranets and externally through 'axa.com' that is globally reachable to employees, suppliers, business partners, and external stakeholders" (page 227).

Remediation is escalation and engagement rather than direct remedy: "Where material negative impacts are identified, AXA relies on its existing due diligence, escalation and engagement processes to encourage corrective actions by relevant business partners or investee companies and, where appropriate, to adjust or terminate its relationships. AXA regularly reviews the outcomes of these processes, in particular through its stewardship activities and controversy monitoring, to assess their effectiveness in providing or enabling remedy" (page 215).

AXA discloses an honest limit: "It is however acknowledged that AXA cannot know for sure whether value chain workers of its investee companies are aware of and trust the whistleblowing process as a way to raise their concerns or needs, and whether their concerns are being addressed by the whistleblower reporting procedure" (page 219).

Reference: pages 218-219 (section 4.3.2.3 - Actions protecting workers in the value chain); index entry on page 257.

The main action is the integration of social and labour criteria into credit and investment decisions. "Since 2015, AXA has embedded ESG considerations at the core of its investment policy by integrating them into its credit assessment and investment processes, ensuring consideration of material social factors are part of investment decision-making. AXA's Credit Research team assesses issuer eligibility for fixed income investments, assigns Internal Credit Ratings (ICR), and sets maturity constraints, in line with AXA's Responsible Investment (RI) policies" (page 218).

The mechanism is described: "AXA's Credit Research team classifies industries into three resilience categories - high, medium, or low - based on the materiality of ESG factors. Social factors, such as labor management can be credit material, especially for business segments facing labor shortage and/or whose workforce is exposed to challenging working conditions. Inadequate health and safety practices can negatively impact a company's operating performance (e.g. accidents, injuries, operational disruptions) and may damage its license to operate, leading to legal liabilities" (page 218). Where the risk has a longer horizon, "AXA's Credit Research team may use other levers, such as proposing to cease investing or imposing maturity constraints" (page 219).

Reference: pages 220-221 (section 4.3.3.1 - Policies and actions supporting responsible commercial practices); index entry on page 257.

The core policy is the Product Oversight and Governance Policy: "In 2024, AXA updated its Group Product Oversight and Governance Policy (the 'POG' Policy). This policy, which was rolled out in 2025, is connected to the AXA Standard on Conduct and Customer Protection. Its main goal is that customers' interests are properly considered and monitored throughout the entire product's lifecycle" (page 220).

Two limbs are described. On appropriate products: "the POG Policy requires AXA entities to define who the product is meant for. AXA tests if the product fits this target market and, where required, makes necessary adjustments. Products are reviewed regularly so that they remain appropriate throughout their lifecycle. As part of this process, focus is given to the remuneration of distributors to avoid creating conflicts of interest with customers". On clear information: "the POG Policy requires AXA to make sure that the chosen distribution channel is appropriate and that distributors are qualified to sell the products."

Reference: pages 133, 220-221 (sections 4.1.2.1 and 4.3.3.1); index entry on page 257.

The affected groups are identified: "The main groups of customers who could be significantly affected by poor commercial practices are: retail customers, who rely on appropriate products and clear information provided in a timely manner; and vulnerable customers, who may face higher risk of harm from inappropriate products or unclear information" (page 220).

Engagement runs across the product lifecycle: "As an insurer, AXA interacts with customers throughout the entire lifecycle of the products, from the design phase to the end of the contract and even after", with processes at design, at the point of sale, after-sales through complaints departments, at product follow-up "using specific indicators detailed in the Group POG Policy", and through continuous improvement "based on customer feedback (such as complaint analysis, post-sales calls, surveys, claims, and 'Voice of Customers')" (page 221).

Two Group research instruments are quantified: the Future Risks Report surveys "about 3,600 experts across 57 countries and 23,000 individuals from 17 countries", and the fifth Mind Health Report "surveyed 17,000 respondents from 16 countries" (page 133). "in North America, AXA XL runs a series of monthly sustainability dialogues for construction clients" (page 133).

Reference: page 221 (section 4.3.3.1) and pages 227-228; index entry on page 257 pointing to section 4.4.1.2.

Remediation runs through local complaints departments plus the Group whistleblowing platform: "The process to remediate negative impacts and the channels available to consumers and end-users to raise concerns are the local complaints channels and the channels detailed in Section 4.4 - Governance information" (page 221).

Measures are listed: "developing accessible grievance mechanisms for consumers and end-users to report any human rights concerns or issues; providing dedicated customer service and complaints departments to address and resolve disputes efficiently and fairly; and implementing robust internal controls to provide for the effectiveness of processes in addressing consumer and end-user grievances" (page 221). After-sales handling is anchored in policy: "in addition to local laws, AXA has standards and rules in place so that customer claims and complaints are handled properly. Customers are informed about how to file claims and complaints. This is outlined in the Group Policy on Complaints Handling issued in 2025 and currently being implemented by AXA entities."

Reference: pages 220-223 (sections 4.3.3.1 and 4.3.3.2); index entry on page 257.

Actions against the negative impact are the 2025 rollout of the Product Oversight and Governance Policy through the product lifecycle, distributor qualification, complaints handling under the Group Policy on Complaints Handling issued in 2025, and the development of a Group Vulnerable Customers Policy (pages 220-221). AXA's stated approach includes "aiming for the fair treatment of all customers by offering products designed to meet their needs and expectations, and adapting products and services to address the needs of vulnerable populations, thereby reducing coverage disparities, closing protection gaps"; "integrating ESG issues into AXA's insurance business processes, in accordance with the Principles for Responsible Insurance"; and "dealing with claims in a prompt, fair, sensitive, and transparent manner" (page 220).

On the positive side, inclusive insurance is presented as a separate entity-specific impact flagged "ESRS Topic: No" (page 222). AXA EssentiALL was "founded with the mission of 'providing affordable, accessible and attractive products (insurance and services) that reach underserved communities, enabling better risk mitigation and overall financial health'" and "is composed of 17 FTEs" (page 222), overseen by an Inclusive Insurance Steering Committee including Management Committee members.

Reference: pages 224-226 (section 4.4.1.1); index entry on page 258.

"AXA has implemented a Group Compliance & Ethics Code to address the following IROs: 'AXA contributes positively to society and business environment through a corporate culture that fosters ethical behavior and trust, notably by protecting whistleblowers'. This Code seeks to establish Group-wide rules so that all AXA employees worldwide share a common understanding of the compliance, corporate culture and ethical standards the Group requires. It applies to all AXA directors, officers, and employees, as well as other personnel with employee status ... and tied agents" (page 225).

"The Code focuses on AXA's core values: Customer First, Integrity, Courage and One AXA. It also covers a variety of matters and topics, such as specific rules concerning conflicts of interest, anti-bribery and corruption, insider trading, management of confidential information ... In 2024, AXA launched its revised Compliance and Ethics Code" (page 226). The Compensation, Governance & Sustainability Committee "reviews AXA's Compliance & Ethics Code each time it is updated" (page 141).

Reference: pages 228-229 (section 4.4.1.4); index entry on page 258.

AXA identifies "as a material IRO related to business conduct topics the potential negative impact on suppliers (unfair treatment, financial instability) due to non-responsible procurement practices, including the Group's payment practices" (page 228).

The disclosure is candid that no Group policy yet exists: "This IRO is mainly addressed at local entity level. For example, payment practices to manage negative impact on suppliers are managed locally by entities to better fit the regulations and best practices. However, due to the identification of this material risk, AXA's Finance and Procurement Department will collaborate with entities to confirm the feasibility of a Group policy. Moreover, following the potential implementation of this policy, AXA will aim to plan actions to reduce the negative impact as well as define potential targets to measure those actions" (page 228).

What is in place is contractual: "AXA has a code of ethics for procurement associates to enhance diversity, honesty, and fair trade. Additionally, there is a sustainability clause included in all contracts that requires suppliers to commit to international standards and regulations" (page 229).

Reference: pages 226-227 (section 4.4.1.2); index entry on page 258.

"In order to prevent and mitigate the risk of bribery and corruption, AXA has defined a Group Anti-Bribery and Corruption ('ABC') Policy that establishes the minimum standards ... This policy is updated annually, notably to incorporate relevant regulations (for example Sapin II Law and Foreign Corrupt Practices Act 'FCPA'). The Group Anti-Bribery Officer sets the Global ABC Policy including the Group requirements and monitors its implementation across AXA entities. AXA entities have designated local Anti-Bribery ('ABC') Officers" (page 226).

The local programme content is specified: "At a minimum, the program includes the following requirements: (i) actions to mitigate risks identified during the ABC Risk Assessment exercise, (ii) a communication / awareness / training plan, (iii) actions to mitigate any recommendations raised during Group ABC Technical Reviews, (iv) major ABC activities and projects, and (v) a local control testing plan." Escalation is mandatory: "any bribery and corruption occurrence must be immediately escalated by the Local ABC Officer to the Senior Management and to the Group ABC Officer".

Reference: pages 225-231 (section 4.4.1). Recorded under the 2025/2026 ESRS numbering; the FY2025 statement was prepared under the 2023 ESRS, where business conduct targets fell under MDR-T rather than a numbered DR.

No target for the ESRS business conduct IROs, disclosed as such. For the supplier impact: "due to the identification of this material risk, AXA's Finance and Procurement Department will collaborate with entities to confirm the feasibility of a Group policy. Moreover, following the potential implementation of this policy, AXA will aim to plan actions to reduce the negative impact as well as define potential targets to measure those actions" (page 228). For corruption, bribery and corporate culture no numeric target is set; AXA states the policies and actions "are already in place and, while AXA keeps enhancing its understanding of and response to these issues, they do not require material expenditure at this stage" (page 225).

Effectiveness tracked instead, which is MDR-T's other limb. Anti-bribery training coverage of functions at risk was 99% in 2025 and 2024; convictions and fines are nil in both years (page 227). Assurance runs through an annual certification by entity CEOs to the Group CEO, Group ABC Technical Reviews, local control testing plans and bi-annual compliance reports to the Board Audit Committee (pages 224, 226-227).

Reference: page 227 (section 4.4.1.2) and pages 227-228 (section 4.4.1.3); index entry on page 258.

The narrative confirms the nil return: "In 2025, AXA was not convicted of violating anti-corruption and anti-bribery laws and the Company has not been fined on these matters" (page 227).

The methodology note explains how cases reach the Group: "The different cases of violation of anti-corruption and anti-bribery laws occurring at local entity level during the year are reported at Group level through the Group Audit Department" (page 250).

Investigation arrangements are described: allegations are triaged by independent Investigations teams "based on pre-established criteria, including categories and impact severity of the reported concern", recorded in AXA's global audit system and investigated under an Investigation Manual using "interviews, document reviews, and sometimes advanced data analysis". "Outcomes are presented to and discussed with the CEO and/or Executive Management of the entity. In cases classified as 'very high' and founded (material), the chair of the relevant Audit Committee(s) is informed" (page 228).

Reference: page 229 (section 4.4.1.4 - Monitoring supporting responsible procurement practices); index entry on page 258.

"AXA's average contractual standard payment term is 32 days. In 2025, AXA paid its suppliers within 25 days on average and 82% of invoices were in line with standard terms. Several entities are working on enhancing the data quality related to these indicators, notably from AXA Assistance and AXA Group Operations, which led to a slight increase of two days in average payment time" (page 229).

AXA discloses a material limitation in the breakdown: "From 2025, AXA is presenting the main category of suppliers, i.e. SMEs and large undertaking. However, AXA is still working on the refinement of the allocation of payments by categories of suppliers as roughly one third of them are not allocated to any category" (page 228).