Banco Sabadell

Governance roles

Reference: pages 195-202.

Banco Sabadell's most senior decision-making body is the Board of Directors (14 members as at 31 December 2025: two Executive Directors, ten Independent Directors, two Other External Directors; six women, 43% of the Board). The Board "is directly responsible for approving the Institution's general strategies" and for "establishing principles, commitments and objectives in the area of sustainability."

Board Strategy and Sustainability Committee (set up 2021, chaired by the Chairman, met 14 times in 2025): analyses and reports to the Board on environmental risk policy, oversees the model for identifying and managing sustainability risks and opportunities, and reviews the Sustainability Report before sign-off.

Sustainability Committee (chaired by the General Manager and People & Sustainability Director, 11 members, met 11 times in 2025): sets and monitors the Sustainability Programme. The People & Sustainability division, created in January 2025 by merging the Sustainability and People divisions, manages ESG strategy day to day and reports to the CEO. The Board has "received specific training on climate risk management."

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

Reference: pages 202-205.

Material IROs are "grouped into a total of six topics: Climate change mitigation and adaptation, Energy, Own workforce, Access to products and services and non-discrimination, Cybersecurity and data protection, and Business conduct," each with a defined governance path to the Management Committee and relevant Board Committees.

For climate change, decarbonisation-pathway data is "sent regularly to the Board Risk Committee," and the Delegated Credit Committee reviewed risk limits for large groups on 210 occasions in 2025, taking ESG classification and IRCA rankings into account. For own workforce, the Management Committee "validates, on an annual basis, compliance with the annual targets for female representation." The Board Audit and Control Committee monitors "the sufficiency, clarity and integrity of all financial and related non-financial disclosures" before publication.

Integration of sustainability-related performance in incentive schemes

Reference: pages 206-209.

The Synthetic Sustainability Indicator (SSI) carries a 10% weight in short-term variable remuneration for the whole Group, split across four blocks: rating-agency scores (20%), Sustainable Finance Plan delivery/decarbonisation pathways (20%), % women in management (20%) and Green/Social Loans and Sustainability-Linked Loans volumes (40%).

For 2025-2027 multi-year (long-term) remuneration, the sustainability indicator is weighted at 20% alongside TSR (40%) and ROTE (40%); for the CEO and CRO specifically it is weighted at 14% and 13% respectively. "Remuneration components must contribute to the promotion of environmental, social and governance actions," and targets, weighting and achievement scales are approved by the Board of Directors on a proposal from the Board Remuneration Committee.

Statement on due diligence

Reference: pages 217-219 (1.3.4 Due diligence procedures in relation to human rights).

Banco Sabadell has a Human Rights Policy and a Human Rights Due Diligence Procedure (both approved 2021, reviewed annually), applying globally across Banco Sabadell, TSB and Banco Sabadell Mexico and extending to business partners without their own equivalent policy. Commitments draw on the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, ILO guidelines, the UN Global Compact and the Equator Principles (signatory since 2011).

Control tools cover accessibility complaints, suspicious-transaction/digital-fraud monitoring and AML/CFT screening. In 2025 the Group received no workplace complaints related to human rights, forced labour or child labour from its own workforce, though the Harassment Prevention Committee received four complaints of workplace and/or sexual harassment, with no resulting penalties or compensation for discrimination or harassment recorded.

Risk management and internal controls over sustainability reporting

Reference: pages 219-220 (1.3.5).

The Group's Policy on Internal Controls over Sustainability Reporting (ICSR) builds "a control framework over the sustainability information disclosed," identifying the data-generation processes behind quantitative IRO indicators and designing controls referenced to CNMV guidance, assessed and certified through the Bank's Governance, Risk and Compliance (GRC) tool by Senior Management at three hierarchical levels.

With the CSRD's entry into force, the ICSR unit "has identified risks and designed controls over the new double materiality exercise" covering both the planning and report-completion phases. The Board of Directors delegates supervision to the Board Audit and Control Committee, which receives the ICSR situation at least annually and the control-assessment results and conclusions at year-end.

Strategy, business model and value chain

Reference: pages 170-171 (1.1 Introduction); page 174 (value-chain framing in the DMA results).

The Sustainability Report covers "the entire Banco Sabadell Group, as it does in the financial statements," including TSB (UK retail banking, over five million customers) - though "in 2025 ... Banco Sabadell agreed to sell this UK arm to Banco Santander," a transaction "expected to close in the first half of 2026, subject to regulatory approvals" - and Banco Sabadell Mexico.

The report is prepared under the 2023 ESRS with the "Quick Fix" transitional arrangements (Commission Delegated Regulation (EU) 2025/1416), including phase-in relief for quantitative anticipated-financial-effects information (SBM-3 and E1-9) and entity-specific disclosures. Value-chain information is given "where appropriate": E1 covers the financed portfolio's decarbonisation pathways (downstream), S4 covers consumers and end-users (downstream), and G1 covers supplier relationships (upstream).

Interests and views of stakeholders

Reference: pages 178-179.

The double materiality assessment involved 1,612 participants: General Management (1%), business customers (26%), retail customers (33%), employees (36%) and suppliers (4%). General Management contributed to both impact materiality (scale, irremediability, likelihood) and financial materiality (financial effects, likelihood, trend); retail customers, business customers, employees and suppliers were surveyed on impact-scale only.

Engagement channels were tailored by group: surveys for suppliers, employees, retail and business customers (sample size set for 95% statistical confidence); 20 interviews with General Management across business areas; and internal documentation, reports and public sources for the Financial Community, Bodies and Institutions, Society and Peers.

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

Reference: pages 173-177.

Materiality thresholds were set from a normal-distribution cut-off: impacts scoring above 3.45 (19 material impacts identified) and risks/opportunities scoring above 2.10 (4 material opportunities, 5 material risks). Material sustainability topics are Climate change (E1), Own workforce (S1), Consumers and end-users (S4), Business conduct (G1) and the entity-specific topic Tax responsibility; E2, E3, E4, E5, S2 and S3 scored non-material on both impact and financial materiality.

On financial materiality, the Bank "concluded that the current risks identified ... currently produce no significant effects" on the financial statements, while the identified opportunities (sustainable-finance solutions, digital-channel customer acquisition, cross-selling) "have material significance." The 2025 update added two material impacts (diverse-workforce integration; financial-education access) versus the 2024 DMA, with no other changes.

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

Reference: pages 178-181.

The DMA runs four phases: (1) defining the perimeter, including the priority ESG topics and stakeholder groups; (2) impact materiality - "56 impacts were identified" and assessed on scale, scope, irremediability and likelihood, with severity outranking likelihood for potential negative human-rights impacts; (3) financial materiality - "42 ESG risks and 21 ESG opportunities" assessed on short/medium/long-term financial effect and likelihood; (4) setting thresholds from the normal distribution of each sample (impacts: 3.45; risks/opportunities: 2.10) and verifying results through expert judgement with first-level managers responsible for each IRO.

Internal controls over the DMA sit within the Internal Controls over Sustainability Reporting (ICSR) framework (see GOV-5). Results, process and methodology were reported to the Sustainability Committee, the Management Committee and the Board Audit and Control Committee.

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

Reference: pages 182-183 (Disclosure requirements addressed in the Sustainability Report); Annex 5.6 Correlation table with the CSRD, pages 526-530.

The report states the disclosure requirements it covers by topic: ESRS 2 (GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1 (E1-1 to E1-9), S1 (S1-1 to S1-6, S1-8, S1-9, S1-10, S1-12 to S1-17), S4 (SBM-2, SBM-3, S4-1 to S4-5) and G1 (GOV-1, IRO-1, G1-1 to G1-4), plus the entity-specific topic Tax responsibility. "The sections of the Sustainability Report in which information regarding these disclosure requirements can be found are provided in Annex 5.6 Correlation table with the CSRD," which maps each disclosure requirement to the report section covering it.

E2, E3, E4, E5, S2 and S3 are absent from this list because the DMA found them non-material (see SBM-3).

Transition plan for climate change mitigation

Reference: pages 362-365, 379-380 (2.1.1).

Banco Sabadell is "a signatory of the Collective Commitment to Climate Action (CCCA)" and aligned with the Net-Zero Banking Alliance (NZBA) voluntary framework, "in order to attain emissions neutrality in its investment and lending portfolios by 2050." Three pillars structure the plan: a strategic action framework (decarbonisation pathways embedded in the Risk Appetite Framework), support for customers in transition (Sustainable Financing Framework, KYC and customer-support phases), and ESG credit-risk management guidelines.

"The Institution does not have a CapEx plan for the transition since, as a financial institution, the transition plans focus primarily on providing support for customers' transition through the Bank's products and services." Locked-in Scope 1/2 emissions "are not material for the Bank's operations" and have no significant impact on its financial statements. Separately, in Spain the Bank set a 2030 target of -9% in Scope 1&2 emissions versus a 2024 base year.

Policies related to climate change mitigation and adaptation

Reference: pages 209-210 (1.3.3 Framework of policies).

Two Board-approved policies anchor the climate approach. The Sustainability Policy (last updated April 2025) commits to "climate change mitigation and adaptation, aligned with the business strategy, the risk appetite and the Group's processes and controls," to energy efficiency and GHG reduction, and to financing renewable-energy projects; it applies across Banco Sabadell, TSB and Banco Sabadell Mexico. The Environmental and Social Risk Framework (last updated July 2023) "lays down general criteria" applying to all sectors (aligned with the Global Compact and ILO principles) and sector-specific criteria for mining, energy, agriculture, infrastructure and defence, applicable to new loan transactions to groups or companies with turnover above €40 million.

A separate Environmental Risk Policy, approved by the Board of Directors, lays down "general guidelines for the management and control of environmental risk," covering both physical and transition risk factors.

Actions and resources in relation to climate change policies

Reference: pages 380-386 (own-operations decarbonisation actions).

Scope 1: in Spain, an HVAC upgrade scheme targets refrigerant-gas leaks; in the UK, TSB's Energy Optimisation Programme cut location-based gas/electricity consumption by -2,084 MWh versus 2024, and 98% of TSB's company-car fleet is now electric (up from 93%).

Scope 2: "100% of the electricity acquired for use in its facilities has a renewable origin certification" across all geographies; in Spain, solar panels generate 3.4% of electricity consumed, with the CBS Sant Cugat photovoltaic expansion projected to add 1,400 MWh/year, alongside LED-lighting rollout across all corporate buildings and most of the branch network.

Scope 3: business-travel and commuting emissions are addressed via a 2025 Workplace Travel Plan for the two largest Catalonia corporate buildings, targeting -3.45%/year in private-vehicle use and -2.69%/year in GHG emissions, backed by 30 identified mobility schemes.

Targets related to climate change mitigation and adaptation

Reference: pages 365-380.

Banco Sabadell has published sectoral decarbonisation targets for 2030 covering 11 GHG-intensive sectors (Electricity, Oil & Gas, Cement, Coal, Iron & Steel, Automotive, Aviation, Residential mortgages, Commercial real estate, Aluminium, Shipping), set against IEA NZE2050, SBTi, CRREM or IMO reference pathways consistent with 1.5°C. Examples: Oil & Gas -23% financed emissions by 2030 vs 2020 (16.2% achieved by 2024); Coal - zero exposure to thermal coal mining by 2030; Commercial real estate (Spain) -51% emission intensity by 2030 vs 2023 (12.8% achieved by 2024). Farming has no quantitative target: "the lack of robust methodologies and comparable data means that quantitative targets cannot be established."

Own operations: Spain targets -9% Scope 1&2 emissions by 2030 vs a 2024 base year; TSB (UK) targets -65% Scope 1 and -42% for the relevant Scope 3 categories by 2030 vs a 2023 base year (already -37.6% and on track as of 2025).

Energy consumption and mix

Reference: pages 407-410 (2.1.3).

Group-wide total energy consumption was 58,998 MWh in 2025 (down from 65,141 MWh in 2024), of which 87.3% came from renewable sources (51,477 MWh), up from 86.9% in 2024, and fossil fuels fell to 12.8% (7,521 MWh). No nuclear-sourced consumption is reported.

In Spain, renewable share was 92.5% of 42,787 MWh total consumption, supported by on-site solar generation (3.4% of Spanish electricity use). In TSB (UK), fossil-fuel consumption fell to 28.7% of a 15,065 MWh total following the Energy Optimisation Programme. Diesel consumption rose sharply (+77% vs 2024) due to backup-generator use during the April 2025 Spanish blackout.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 409-411 (own operations); pages 413-415 (financed portfolio).

Own operations, Group-wide (market-based): Gross Scope 1 = 3,029 tCO2e (2025, +23.1% vs 2024); gross market-based Scope 2 = 18 tCO2e; significant Scope 3 (purchased goods/services, water, paper, plastic, waste, business travel, employee commuting) = 9,455 tCO2e. Total market-based GHG emissions = 12,502 tCO2e, down 4.4% versus 2024; total location-based emissions fell 34% to 17,931 tCO2e.

Financed portfolio (Category 15): absolute Scope 1&2 financed emissions reached 15.225 million tCO2eq, an intensity of 74.8 tCO2eq/€m financed (average data quality 3.13), down 3.8% year on year. The business portfolio contributes approximately 56% of the financed footprint while representing 36% of credit exposure; the largest contributing sectors are agriculture/forestry/fishing, steel, construction materials and industrial chemicals.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 385-387.

In 2025 Banco Sabadell renewed its commitment to offset all Scope 1, 2 and 3 emissions in Spain, Mexico and the USA (and Scope 1&2 for TSB) through reforestation carbon credits: a project in Curiscao y Vegacebrón (Asturias, Spain, pine reforestation registered with MITECO) and a forestry-management project in Calakmul, Mexico (registered with the Climate Action Reserve/ICROA). Total emissions offset came to 7,689 tCO2e for the Group, plus 898 tCO2e for TSB via Forest Carbon's ArBolivia project.

Carbon credits cancelled in 2025 totalled 8,587 tCO2e (2024: 8,203 tCO2e), 100% from removal projects (0% reduction projects), 100% carrying a recognised quality standard, 72% from projects within the EU, and 0% qualifying as corresponding adjustments.

Internal carbon pricing scheme

Reference: page 386.

"The Institution has established carbon pricing for emissions from its own operations, which materialises through the offsetting of emissions ... The average cost of this offset was c.€20 per metric tonne of CO2e in 2025."

For the financed portfolio, the Bank applies pricing mechanisms rather than a single shadow price: discounted pricing for Green and Social Loans (GSLs) aligned with the EU Taxonomy, and Sustainability-Linked Loans (SLLs) whose price is adjusted year to year against customer-reported KPI performance. A separate internally developed methodology assigns a direct cost to greenhouse-gas emissions when quantifying transition-risk impacts on income, low-carbon capex and expenses within the NGFS-aligned heatmaps.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Reference: pages 389-390 (stress testing); pages 404-406 (rating and collateral adjustments).

Climate stress tests are embedded in the ICAAP: "the economic capital requirements for this risk are around 1% of total economic capital requirements, meaning that the risk has a limited impact on the Group's solvency." Physical-risk exposure in the Spanish business portfolio is 0.1% "Very High" and 7% "High" (down from 10.2% high/very-high in 2024); transition-risk exposure to the "High" category is around 0.01%.

The Bank adjusts large-corporate ratings (PD) when the IRCA score is poor or unmitigated disputes exist, and lowers collateral appraisal values for physical-risk exposure and for properties with an energy rating below D. Quantitative disclosure of anticipated financial effects at both SBM-3 (general) and E1-9 level uses the "Quick Fix" transitional phase-in relief; several E1-9 sub-datapoints (benchmark-portfolio physical-risk exposure, acute/chronic disaggregation, real-estate energy-efficiency breakdown, opportunity exposure) are marked "Information not required for 2025."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 "Managing and monitoring the risks associated with climate change" section (2.1.2), where this content is disclosed in the FY2025 report (pages 387-401). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk: modelled under three scenarios similar to NGFS - Orderly Transition (limits warming to 1.6°C by 2050), Disorderly Transition (1.7°C by 2060) and Current Policies/Hot House World (>2°C from 2050) - built with Oxford Economics data over a 30-year horizon, plus flooding and forest-fire indicators to 2050. Transition risk: heatmaps aligned to the same three scenarios classify loan-book activities by income/cost/capex sensitivity; Spain physical-risk exposure and UK/Mexico/US hurricane exposure are assessed separately for TSB, Mexico and Miami. Scope: business lending and mortgage portfolios in Spain, TSB and Mexico. The Orderly Transition scenario is monitored as "the most likely," with Hot House World tracked as the worst case; the analysis is refreshed and reported quarterly to the Sustainability and Technical Risk Committees. Temperature-projection rationale for each scenario is stated; no single scenario is explicitly labelled "1.5°C-aligned with no or limited overshoot" for transition risk.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate risk management section (pages 176, 389-390, 400-406). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report does not state whether a resilience analysis "as defined under the ESRS" was or was not performed; instead it presents quantified stress-test conclusions that speak to resilience. On strategy implications, SBM-3 concludes the Bank's identified climate risks "currently produce no significant effects" on the financial statements, while climate-related opportunities (sustainable-finance solutions, climate-transition advisory) "have material significance" and the Institution is actively pursuing them.

On capacity to adjust (financial-resource flexibility): the ICAAP-embedded stress test finds economic capital required for climate risk is "around 1% of total economic capital requirements," and physical-risk exposure rated High/Very High in the business portfolio fell from 10.2% (2024) to 7.1% (2025) following methodology improvements. Response mechanisms include rating and collateral-valuation adjustments and quarterly reporting of decarbonisation-pathway alignment to the Sustainability and Technical Risk Committees.

Policies related to own workforce

Reference: pages 211-213 (1.3.3 Framework of policies).

Board-approved policies covering own workforce include the Remuneration Policy (last update November 2025), which "establishes the remuneration criteria common to all Sabadell Group staff," the Prevention Plan for occupational hazard prevention (approved by the State Health and Safety Committee, April 2023), and the Plan for Effective Equality between Women and Men (negotiated and signed with workers' legal representatives, February 2022), which sets out "a set of positive measures and actions to incorporate the principle of equality between women and men," structured around objectives, a starting-point diagnosis, a remuneration audit and monitoring arrangements. The Group-wide Human Rights Policy (see GOV-4) also applies to the workforce.

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

Reference: pages 452-454 (3.1.7 Dialogue with employees).

Formal social dialogue runs through nine trade union sections and Works Councils voted in every four years; in Spain "100% of workers are covered by the Collective Bargaining Agreement for Banks" and 100% are represented by workers' legal representatives. Beyond collective bargaining, the Group runs "The Bank we aim to be" engagement survey twice yearly (75% participation H1 2025, 77% H2 2025), measuring commitment, meritocracy, management, wellbeing, sustainability, equality and work-life balance, plus smaller "pulse check" surveys to a random employee sample and the weekly FlashIN internal newsletter. Commitment scored 78% (H1) and 80% (H2), both above the 70% target.

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

Reference: page 453 (Assistance and Grievances Office); pages 484-487 (whistleblowing channel).

The Assistance and Grievances Office (AGO), accessed via the internal portal, resolves employee queries on management, career, compensation, diversity, work-life balance, occupational-hazard prevention and labour relations, escalating specialised matters to a second level; it handled 45,165 queries in 2025 with a 4.38/5 satisfaction rating. Separately, the Group's whistleblowing channel, governed by the Policy on the Internal Reporting System and Protection of Reporting Persons (transposing Directive 2019/1937), lets stakeholders including employees report breaches "without fear of any kind of retaliation when used in good faith," managed by the Corporate Ethics Committee and its Chief Compliance Officer.

Taking action on material impacts on own workforce, and effectiveness of those actions

Reference: pages 417, 432-438 (Diversity, Fairness and Inclusion); pages 428-429 (Training).

Because the identified own-workforce impacts are the gender pay gap (potential negative) and workforce diversity, quality of life, training and remuneration (actual positive), action centres on the Diversity, Fairness and Inclusion (DFI) procedure (introduced 2025) and the third Equality Plan (renewed 2022 with 100% legal-representative agreement): recruitment without discriminatory bias, promotion of women into senior/middle management, monitoring of pay-review impact on the gender pay gap, and mentoring/leadership programmes for female talent. Training resources were expanded via specialisation programmes (PROEDE, LERNMI, Sectoral Financial Analysis) and 97.97% of employees completed at least one sustainability course. "The Group has allocated the necessary resources (personal and economic) to ensure that material impacts are managed," and states "no material risks or opportunities have been identified in connection with its own workforce."

Targets related to own workforce

Reference: pages 436-437.

Since 2021, targets set for 2025 (Spain perimeter): 40% female Board membership (met 2024; up from 27% in 2021); 33% of senior-management roles held by women (met 2024; 35.1% as at end-2025, up from 29.1% in 2021); 41% of middle-management roles held by women (met 2022; 43.4% as at end-2025, up from 38.8% in 2021); continuous annual reduction of the gender pay gap in Spain, the UK and Mexico; and renewal of the Equality in the Workplace Seal of Distinction (renewed 2025, first obtained 2017).

Characteristics of the undertaking's employees

Reference: pages 418-420.

As at 31 December 2025, Banco Sabadell Group had 18,736 employees (18,769 in 2024, -0.2%): 99% on permanent contracts, average age 46, average tenure 17 years, 29% based outside Spain, and 54.7% women. By professional category: senior management 913 (324 women), middle management 3,390 (1,456 women), specialist staff 12,607 (7,183 women), administrative staff 1,826 (1,286 women). The Group also had 233 non-employee workers in Spain on temporary-agency contracts covering short-term absences and leave, 100% located in the branch network.

Collective bargaining coverage and social dialogue

Reference: pages 451-452 (3.1.6.3 Trade union rights and right of association).

"In Spain, 100% of workers are covered by the Collective Bargaining Agreement for Banks", negotiated with nine trade union sections operating state-wide and by autonomous community; 100% of the Spanish workforce is also represented by workers' legal representatives. In the UK, TSB's agreement with Accord and Unite (renewed 2023) covers 90% of the workforce. In Mexico there is "no relationship between people and union representatives." There are no European Works Council, SE or SCE agreements in place.

Diversity metrics

Reference: pages 432-436.

Gender split (2025): 54.7% women overall; by age band, Under 30: 1,663 (794 women), 30-50: 10,571 (5,974 women), Over 50: 6,502 (3,481 women). Women's share by category: senior management 35.5% (up from 34.3% in 2024), middle management 42.9%, specialist staff 57.0%, administrative staff 70.4%; women accounted for 47.7% of 2025 promotions.

Functional diversity: 280 employees (1.5% of the Group) with a registered disability, split 110 men/170 women. Since June 2024 the Bank has run a Plan on Inclusion Measures for the LGBTI community and was recognised in 2025 by REDI and Actualidad Económica among the top 25 most inclusive companies for the LGBTI community in Spain.

Adequate wages

Reference: page 451 (collective bargaining coverage); pages 439-440 (Remuneration policy).

The report gives no separate benchmark against a statutory or reference minimum/living wage; the substantive basis given is collective bargaining. "In Spain, 100% of workers are covered by the Collective Bargaining Agreement for Banks", which sets sectoral pay floors, and the Remuneration Policy commits to "a competitive and fair remuneration system (external competitiveness and internal fairness)" aligned with market benchmark indices. Outside Spain, "the prevailing legislation in each country is applied." No distinct wage-adequacy assessment or gap-to-minimum-wage figure is disclosed beyond this collective-bargaining basis.

Persons with disabilities

Reference: pages 435-436.

"The number of people with functional diversity in the Group as at December 2025 was 280, meaning that employees with functional diversity represent 1.5% of the total" (287 in 2024), split by category: senior management 6, middle management 28, specialist staff 198, administrative staff 48. The Group "establishes measures for the adjustment of workstations where required by people with functional diversity" and, under Spain's General Disability Law, "implements alternative supported employment measures by hiring services and supplies from special employment centres" - amounting to €3.4 million invoiced from Special Employment Centres in 2025 (€2.9m in 2024).

Training and skills development metrics

Reference: pages 428-429.

Training pillars: alignment with business/regulatory needs, professional development, budget efficiency, sector-leading innovation, and adaptation to digital transformation. Regulatory training represented 76% of total 2025 training hours (82% in 2024), including mandatory MiFID/IDD/LCCI certification renewal (59% of regulatory training, down from 76% in 2024). Named programmes include PROEDE (Business Banking management), LERNMI (insurance-selling skills for the branch network) and the Sectoral Financial Analysis Specialisation Programme. On sustainability specifically, 97.97% of employees completed at least one course, and a "Sustainable Finance Certification" is offered with Carlos III University Madrid (UC3M).

Health and safety metrics

Reference: pages 449-450 (3.1.6.2).

The Prevention Plan, approved by the State Health and Safety Committee, "ensures the integration of occupational hazard prevention" and "covers 100% of those working at Banco Sabadell Group." The number of work-related accidents in 2025 was 143 (versus 136 in 2024). "No severe accidents were recorded during the period, nor were there any fatalities as a result of work-related accidents." Each accident triggers an investigation by the Joint Prevention Service to determine preventive or corrective action; Mexico did not record any accidents.

Work-life balance metrics

Reference: pages 446-448 (3.1.6.1).

Work-life balance measures sit in the Equality Plan and a dedicated Guide, including extended unremunerated leave beyond CBA minimums, reduced working hours for care of children under 12 or dependent relatives, flexible start/finish times, and 19 weeks of birth/care leave (6 mandatory). "100% of employees had access to leave for family reasons"; 320 people took it in 2025 (195 men, 125 women). Additional entitlements include up to 200 paid hours/year of Individual Training Leave, a school allowance, lactation rooms, and telework up to six days a month. The 25th Collective Bargaining Agreement for Banks (2024-2026) sets a 1,700-hour maximum annual working time, an 80-hour/year overtime cap, and 31 business days of paid annual leave.

Compensation metrics (pay gap and total compensation)

Reference: pages 439-440.

Gross (unadjusted) gender pay gap, Group-wide, end-2025: 22.47% (average), 17.48% (median) (calculated per Royal Decree 902/2020). The adjusted pay gap for Spain, certified with Pompeu Fabra University's Economics and Business Department, was 4.22% (average) and 2.28% (median) in 2025, down from 4.80%/2.64% in 2024, after controlling for job- and individual-level characteristics. "Banco Sabadell's remuneration models do not generate a pay gap," with equal pay for equal work as a stated policy principle; the Sustainability Indicator ties 10% of short-term and 20% of long-term Identified Staff remuneration partly to closing the gap.

Incidents, complaints and severe human rights impacts

Reference: pages 218-219 (1.3.4).

"The Group has not received any workplace complaints related to human rights from its own workforce, nor any complaints of forced or child labour." In 2025 the Harassment Prevention Committee received four complaints of workplace and/or sexual harassment; there were "no records of any penalties or compensation for injury and damages as a result of any cases of discrimination and harassment." None of the human-rights-related complaints received through the Customer Care Service (SAC) in 2025 "resulted in any violation of human rights affecting consumers or end-users."

Policies related to consumers and end-users

Reference: pages 454-456.

The Group's consumer-facing commitments sit under the 2022 Sabadell's Commitment to Sustainability framework and the Sustainability Policy, structured around three courses of action: supporting customers' transition to a sustainable economy, offering sustainable investment opportunities, and "work[ing] together for a sustainable and cohesive society" (financial education, inclusion, secure transactions). Cybersecurity/data-protection commitments include keeping controls aligned with ISO 27001 and the NIST Cybersecurity Framework, reviewed by an independent third party, and maintaining mandatory annual cybersecurity/data-protection training for employees and partners.

Processes for engaging with consumers and end-users about impacts

Reference: pages 456-457 (3.2.1 Customer experience and customer care).

Quantitative engagement runs through the Customer Experience Indicator (CXI), an internal NPS-style daily survey sent to customers with recent contact - in 2025 sent to over 1.2 million retail customers (around 30% of the total), ending the year at +9%, two points above the 7% target - plus monthly satisfaction surveys, mystery-shopping branch-quality surveys, and periodic Retail/Business Banking financial-behaviour studies. Qualitative research (in-depth interviews, segment focus groups, behavioural-economics techniques) feeds designed actions monitored by dedicated customer-experience committees in the Business Banking and Retail Banking divisions.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: pages 457-458 (Customer Care Service).

The Customer Care Service (SAC), required under Order ECO 734/2004, "is in charge of handling and resolving complaints and claims brought forward by users of financial services" of Banco de Sabadell, S.A. and its associated entities (Sabadell Asset Management, Urquijo Gestión, Sabadell Consumer Finance). Its head reports to the Board of Directors at least semi-annually and is independent of business/operational lines. Customers can lodge complaints in branch, by printed or electronic form, by email or by post; the SAC can also issue recommendations from its analysis of complaints received. Procedures were updated in 2025 following Organic Law 1/2025 and Law 10/2025 on customer care services.

Taking action on material impacts on consumers and end-users, and effectiveness of those actions

Reference: pages 468-471 (Vulnerable customers; Accessibility; Sogeviso).

The Bank tracks financial, digital and regional vulnerability: financial-vulnerability actions include debt-recovery team training on the Code of Good Practice; regional-vulnerability actions include five mobile branch vehicles (Asturias, Galicia, León) and the Correos Cash service letting customers withdraw cash at any Correos office. Accessibility measures cover WCAG 2.2 AA-aligned digital channels, a dedicated accessibility helpline and sign-language video interpretation, Braille documentation, notched and Braille-format cards, and ATM/POS upgrades. Sogeviso, a wholly owned subsidiary, manages social housing for customers unable to keep up mortgage payments and in 2025 fully managed 1,763 affordable-rental properties under Madrid's "Plan Vive" (92.1% occupancy).

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

Reference: pages 454-456.

Set in 2022 under Sabadell's Commitment to Sustainability (2021 baseline), with 2021-2025 results: mobilise €65bn in sustainable finance - achieved over €76bn, exceeding the target by more than 17%; grant >€15bn to micro-enterprises - reached >€13.2bn (88% of target); reach 10,000 annual recipients of financial-education programmes - reached 9,581 (up from a 6,300 reference value); reach 2,000 participants in social-impact projects - reached 3,100. Cybersecurity targets (ISO 27001/NIST alignment, independent review, mandatory training) were also tracked for 2025.

Corporate culture and business conduct policies and corporate culture

Reference: pages 482-485 (4.1.1 Code of Conduct).

The Board-approved Code of Conduct sets "the catalogue of principles, obligations and duties" for everyone acting for the Group, under the "direct supervision and approval of the Corporate Ethics Committee and the Board of Directors," applying to governing-body members, employees, external suppliers and business partners in every jurisdiction; staff must formally adopt it individually. It sits alongside the Corporate Crime Prevention Policy (certified to UNE 19601 and ISO 37001 since 2023, recertified end-2025 with "no non-conformities identified"), the General Policy on Conflicts of Interest, and the Policy on the Internal Reporting System and Protection of Reporting Persons.

Management of relationships with suppliers

Reference: pages 493-497 (4.2).

Governed by the Procurement Policy and Supplier Code of Conduct (referencing the UN Global Compact and ILO conventions on forced/child labour, remuneration and freedom of association), the supplier lifecycle runs need identification, DORA/EBA categorisation, risk assessment (annual for essential services, triennial for non-essential), competitive-tender selection where the ESG score is "a decisive factor," accreditation, contracting and ongoing monitoring, with 11 ESG-criteria audits completed in 2025 (one requiring major improvements, no critical recommendations).

As at end-2025: 788 suppliers invoiced over €100,000, the top 20 representing 46% of invoicing; 93.1% of invoicing came from suppliers scored ESG category A+, A or B; €3.4m was invoiced by Special Employment Centres. An internal invoice platform and weekly payment runs (against a two-to-three-day validation and accounting turnaround) support the payment-timeliness objective.

Prevention and detection of corruption and bribery

Reference: pages 485-487 (4.1.2).

The Group's Anti-Corruption Policy, developed with reference to the UN Global Compact's Anti-Corruption Risk Assessment Guide, sits within the Corporate Crime Risk and Anti-Corruption Management and Organisation Model, ultimately overseen by the Board of Directors and the Corporate Ethics Committee, and re-evaluated annually. "As a result of the activities carried out as part of the aforesaid model and the management of the whistleblowing channel ... no risks related to corruption materialised in 2025, or in 2024, 2023, 2022 or 2021." Detection tools include a dedicated whistleblowing-channel area for corruption/bribery reports and rigorous onboarding controls on political-party-linked accounts (the Bank makes no contributions to political parties or politically exposed persons). Effectiveness is monitored via Code of Conduct adherence rates, the annual Corporate Crime Prevention and Anti-Corruption Control Plan, and AENOR/UNE 19601/ISO 37001 certification maintenance.

Targets related to business conduct

Back-filled from the business conduct chapter (4.1.2, 4.1.4), where effectiveness tracking is addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Banco Sabadell discloses no stated numerical target for corruption prevention outcomes; instead it reports effectiveness tracking in the absence of one: "The Institution carries out continuous monitoring of the effectiveness of its model through a variety of activities," including the percentage of employees adhered to the Code of Conduct, staff adherence to the Corporate Crime Risk and Anti-Corruption Statement of Compliance, annual implementation of the Corporate Crime Prevention and Anti-Corruption Control Plan, and maintenance of AENOR/UNE 19601/ISO 37001 certification. 2025 training completion rates were tracked by course: Code of Conduct 98.9%, RIC (securities-market code) 97.0%, Anti-Corruption 99.5%, Corporate Crime Prevention 99.5%, Whistleblowing channel 98.8%.

Confirmed incidents of corruption or bribery

Reference: page 487.

For 2025: "There have been no convictions or fines for breaches of anti-corruption and bribery laws"; "there have been no confirmed incidents of corruption or bribery in the Institution, with no employee having been dismissed or penalised internally for incidents related to this topic, and with no contract with business partners having been terminated or not renewed due to infractions related to corruption and bribery"; and "there have been no public legal cases regarding corruption or bribery brought against the undertaking and its own workers during the reporting period or during previous years."