Bank of Ireland Group

The role of the administrative, management and supervisory bodies

Reference: pages 54, 118-119 (index: GOV-1 at pages 54 and 118; G1.GOV-1 at pages 54 and 205).

The Bank of Ireland Group plc Board is supported by the Group Sustainability Committee (GSC) and the Board Risk Committee (BRC), which monitor climate-related risks and progress against commitments such as Science-Based Targets and the UN Principles for Responsible Banking (page 118).

• GSC: guides the Sustainability Strategy and recommends it to the Board. It approved the material IROs from the 2024 DMA and challenged the 2025 refresh before the Group Audit Committee (GAC) approved it. It met three times in 2025.
• BRC: met three times in 2025 on ESG matters and reviews the DMA every three years with the GSC.
• GAC: met five times on sustainability matters in 2025, including to approve the 2025 Sustainability Statement and the DMA refresh.
• Executive level: the Group Executive Committee (GEC) holds overarching responsibility for delivering the Sustainability Strategy, with specific responsibility delegated to the Chief Sustainability and Investor Relations Officer. It met five times in 2025 on CSRD implementation (page 119).

Expertise: in 2025 the Board drew on external experts on sustainability in strategy and the green transition (page 119). The Board skills matrix is on page 54, and the gender diversity and independence datapoints are indexed to pages 78 and 54 (page 214).

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

Reference: page 118 (index: page 118); supporting pages 119, 150, 157, 160.

The GSC and BRC "monitor how identified material IROs are being managed through policies, actions and targets" (page 118). In 2025 the GSC discussed the 2025 Sustainability Statement, the Sustainability Report and the UNPRB progress statement, and reviewed the annual DMA refresh (page 118).

• GAC: its terms of reference cover the integrity of external reporting, including ESG disclosures under CSRD, and it approved the 2025 Sustainability Statement (page 118).
• Sustainability Decision Group: chaired by the Chief Sustainability and Investor Relations Officer, it reviews and challenges sustainability matters, including the material IROs from the DMA and annual refresh, and updates the GEC on progress (page 119).
• Metrics reviewed: the GSC reviews key risk metrics on the lending portfolio each quarter: exposure to transition climate risks, sectoral concentrations, the energy efficiency profile of property lending and exposure to physical climate risks (page 150). Sustainable finance and SBT progress carries a RAG status reported to the SDG, GEC, BRC, GSC and Board (pages 157, 160).

Detail on how management oversees target setting and monitors progress sits in the topical standards (page 119).

Integration of sustainability-related performance in incentive schemes

Reference: pages 105, 108 (Remuneration Report, incorporated by reference; index: GOV-3 at pages 105 and 108, E1.GOV-3 at page 105).

All eligible employees of participating Group entities can receive an award under the discretionary Group Performance Scheme (GPS), and executive directors take part on the same basis as the wider workforce (page 105). For 2025 the Group Remuneration Committee reviewed the GPS pool against profit and "a range of financial and non-financial measures, including affordability, customer and ESG (Green lending, customer satisfaction and employee engagement)" (page 105).

The Committee also noted "strong progress against our climate initiatives of increasing green / sustainable financing" (page 105). About 10,700 eligible employees, including executive directors, took part in the 2025 GPS, and awards are limited to €20,000 under current remuneration restrictions (page 105).

For the wider workforce, "ESG is mainstreamed into our performance management system" (page 108).

Statement on due diligence

Reference: page 217 (index: page 217; ESRS 2 GOV-4 paragraph 30 datapoint, page 214).

The statement maps each core element of due diligence to the ESRS disclosure and pages where it is covered (page 217):

• Embedding due diligence in governance, strategy and business model: GOV-2, GOV-3, SBM-3 (pages 103, 118, 124)
• Engaging with affected stakeholders: GOV-2, SBM-2, IRO-1 (pages 118, 121)
• Identifying and assessing adverse impacts: IRO-1, SBM-3 (pages 121, 124)
• Policies: E1-2 and the entity-specific Digital Banking topic (pages 158, 212)
• Actions: E1-3 and Digital Banking (pages 159, 212)
• Tracking effectiveness: E1-4 and Digital Banking (pages 160, 212)

It names the two material negative impacts: "Climate Change (E1-Impact 4) and Digital Banking (Digital Banking-Impact 1), see page 126 for details" (page 217).

Risk management and internal controls over sustainability reporting

Reference: page 120 (index: page 120).

The Group applies its Risk and Control Self Assessment and three lines of defense approach to sustainability reporting. It "identified the operational risks in respect of sustainability reporting, which were similar to existing risks in the Group's Annual Report" and applied the existing controls over the Annual Report to the CSRD disclosures where appropriate (page 120).

Three key risks are named, each rated on the Group's Risk Assessment Matrix by frequency and impact: non-compliance with ESRS, incorrect data capture and incorrect stakeholder input (page 120). The controls listed are:

• reporting standards and regulatory guidance, with assurance from the Group's external auditors;
• affirmations from business owners who supply inputs, attesting to data quality;
• review of manual adjustments and reconciliation of inputs to source, with assumptions and estimates documented in the topical standards;
• approval with GAC and GSC review and sign-off (page 120).

Strategy, business model and value chain

Reference: pages 115-117, 150, 187 (index also lists pages 12, 19, 41, 43, 45, 47, 49, 67, incorporating the divisional review and Strategic Report; phase-in applied to SBM-1 paragraphs 40b and 40c).

Strategy (page 115): sustainability is one of three core strategic pillars (Sustainable Company, Stronger Relationships, Simpler Business). The "Investing in Tomorrow" Sustainability Strategy has three pillars: Supporting the Green Transition, Enhancing Financial Wellbeing and Helping Colleagues to Thrive. Refreshed strategies for 2026 to 2028 are on pages 12 and 21.

Business model (page 116): Banking through Retail Ireland, Retail UK and Corporate & Commercial, plus Wealth and Insurance through New Ireland and Davy, with sustainable products such as the EcoSaver Mortgage, Enviroflex and Sustainability-Linked Loans.

Value chain (page 117): upstream is suppliers; downstream is retail, corporate and commercial customers and wealth and insurance clients; own operations are properties, internal functions and the Group's own energy, water and waste.

Exposure (page 150): the Group has "no direct exposure in fossil fuels extraction, in cultivation and production of tobacco, and in financing of controversial weapons", and 76% of customer lending is residential and commercial property and car finance. Headcount was 11,577 at 31 December 2025 (page 187).

Interests and views of stakeholders

Reference: pages 67, 69, 121, 180 (index: SBM-2 at page 67; S1.SBM-2 at pages 69 and 180).

The Board engaged shareholders and investors through results presentations, roadshows and conferences, and engaged regulators, colleagues and communities during the year (pages 67, 69). Colleague views come through the annual Open View survey, with 82% of eligible employees taking part in 2025 (2024: 85%) (page 180), and through 'Open Door' sessions run by the Workforce Engagement Director, who reports to the Board (pages 69, 185).

For communities, €500,000 was allocated through the Bank of Ireland Community Fund in 2025, and since 2020 the Group has facilitated €3 million for 307 community projects (page 69).

For the DMA, the prioritized stakeholder groups were investors and shareholders, regulators, customers, suppliers, employees and business partners. They were consulted through surveys, interviews, media analysis and, for regulators and employees, proxies (page 121).

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

Reference: pages 124-130, 392 (index: SBM-3 at pages 124 and 392).

The 2025 DMA refresh leaves six material topics: E1 Climate Change, S1 Own Workforce, S3 Affected Communities (now including the former entity-specific topic of Housing), S4 Consumers and End-Users, G1 Business Conduct and the entity-specific topic of Digital Banking (page 125). S2 is no longer material and E2 to E5 remain non-material (page 123).

The tables on pages 126-130 give each IRO an ID, value-chain position and time horizon. Counted from them: E1 has 14 rows (3 actual positive impacts, 1 actual negative impact, 5 opportunities, 5 risks), S1 5, S3 8, S4 6, G1 9 and Digital Banking 6. The two negative impacts are E1-Impact 4 (financing sectors that use large amounts of fossil-based energy) and Digital Banking-Impact 1 (IT failures and outages).

On strategy, operational and financial planning runs over 1 to 3 years, near-term SBTs and the Climate Transition Plan are set to 2025 and 2030, and net zero is committed by 2050. The ICAAP assesses transition and physical risk drivers by risk type over short, medium and long term (page 124).

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

Reference: pages 121-123 (index: IRO-1 at pages 121 and 123; G1.IRO-1 at page 121).

A full DMA was run in 2024 and refreshed in 2025; the Group plans a full DMA every three years and an annual refresh (page 121). It covers inside-out and outside-in lenses in five stages: identification, stakeholder engagement, impact and financial materiality, finalization and documentation, and governance, with results approved jointly by the GSC and BRC (page 121).

Impacts were scored on scale, scope, likelihood (potential impacts only) and irremediable character (negative impacts only); risks and opportunities on magnitude and likelihood (pages 122-123). For credit risk the Group mapped its corporate portfolio to external industry and country scores to indicate exposure to ESG risk factors (page 122). A topic is outside-in material if it affects "a significant portion of the Group's portfolio" and is critical to strategy; the materiality thresholds were "selected by Group subject matter experts" (page 123).

In the 2025 refresh, S2 stopped being material (its risk moved to G1 Business Conduct) and S3 was merged with the entity-specific topic of Housing. E2 to E5 stayed non-material after ICAAP 2025 put non-climate environmental risks at about one seventh of the impact of climate risk (page 123).

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

Reference: pages 124, 213-217 (index: the DR table on pages 213-214, EU-law datapoint tables on pages 214-216).

The index on pages 213-214 lists BP-1 to IRO-2 in ESRS 2, then E1.GOV-3 and E1-1 to E1-7, S1.SBM-2 and S1-1 to S1-6, S1-8 to S1-10, S1-16 and S1-17, the S3 and S4 entries, and G1.GOV-1, G1.IRO-1 and G1-1 to G1-4, each with a page number. It uses the 2023 ESRS numbering. E2, E3, E4, E5 and S2 appear only for IRO-1 or SBM entries and carry the footnote "Non-material topic". Phase-in is applied to SBM-1 paragraphs 40b and 40c.

The tables on pages 214-216 list datapoints from other EU legislation (SFDR, Benchmark Regulation, Pillar 3, EU Climate Law) with page numbers or "n/a - Not material for the Group", for example for E2-4, E3-1, E3-4, E5-5, S1-14 and the S2 datapoints.

On managing material IROs (page 124), ESG risk runs through the Group's principal risk types under the ESG Risk Management Framework. Policies are tabled on pages 131-138; actions, targets and metrics sit in the topical sections.

Transition plan for climate change mitigation

Reference: pages 140-145 (index: pages 140 and 144).

The Climate Transition Plan sits under the Sustainability Strategy, and the GSC oversees it on behalf of the Board (page 140). In 2022 the Group became the first Irish bank with science-based targets validated by the SBTi, covering all operations and 71% of its FY20 baseline loan book, which the SBTi classifies as in line with 1.5°C (page 140). A footnote says the residential and CRE lending targets are in line with a pathway below 2°C.

• Own operations: net zero by 2030 from a 2020 baseline of 6,238 tCO2e, through heat pumps and solar, switching kerosene to hydrotreated vegetable oil, fleet electrification, further efficiencies and offsets for the residual 5-10% (page 142).
• Lending: from a 2020 base, 48% per m2 for residential mortgages, 56% per m2 for commercial real estate and 76% per kWh for electricity generation by 2030; 25% SBT portfolio coverage by 2025 for corporate loans and for bonds (pages 143-144).
• Sustainable finance: €15 billion by 2025 (exceeded) and €30 billion by 2030 (page 141).

The plan is supported by "continuous internal funding", and the Group calls capital expenditure quantification "less relevant for a bank" (page 141).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate-related IROs section (E1.IRO-1, E1.SBM-3), where this content is disclosed in the FY2025 report (pages 146-149, 153-154). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 146-149, 153-154 (index: E1.IRO-1 at pages 121 and 146).

• Risk types: transition (policy and legal, technology, market, reputation) and physical (acute, chronic), mapped to each principal risk type and rated for short (within 3 years), medium (3 to 5 years) and long term (over 5 years) (pages 146, 148).
• Scenarios: the starting point is reference scenarios from the Network of central banks and Supervisors for Greening the Financial System (NGFS). Internal scenarios were built in 2023 and cover mortgage, CRE and motor finance lending (pages 146-147). The pages do not name individual NGFS scenarios.
• Physical risk: Moody's data at NUTS 3 level for floods, storms, wildfire, heat stress, sea level and water stress, plus JBA flood scores projected on the RCP 8.5 pathway, "where emissions continue to rise throughout the 21st century and global temperatures increase by 2100 by 3.2 to 5.4 degrees" (pages 153-154).
• Process: an annual group-wide ESG materiality assessment feeds the ICAAP, and its output informed the DMA (page 147).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate-related IROs section (E1.SBM-3), where this content is disclosed in the FY2025 report (pages 146-147, 159-160). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 124, 146-147, 159-160 (index: E1.SBM-3 at page 146).

The Group stress tests its financial position and business processes with adverse climate scenarios, using the results "to size the materiality of potential risk events to ensure that the Group has adequate financial resources to absorb potential impacts" (page 147).

• Capital: because its models "cannot fully address all emerging climate risk drivers at this time", the Group adds the climate risk materiality result as an extra economic capital requirement in the ICAAP (page 147).
• Impairments: post model adjustments for the SME portfolio and for Retail Ireland and UK residential mortgages, extended in 2025 to transition risks (insurability) (page 147).
• Adaptation: flood insurance is required for property lending, flood defenses were installed on a number of exposed sites, and a 2025 scenario test on adverse weather checked support for important business services (pages 159-160).
• Limits: short-term impacts can be mitigated "by holding adequate capital buffers and providing for ECL" (page 147).

Policies related to climate change mitigation and adaptation

Reference: pages 131-132, 158 (index: page 158).

The policy table on pages 131-132 covers the Group Environmental policy and Group Energy policy (approved by the Group CEO and reviewed annually under the ISO 50001 and ISO 14001 certifications), the Sustainable Finance Framework, the Green Bond Framework, the Code of Supplier Responsibility, and the Credit Risk, Property Collateral Valuation and Business and Strategic Risk policies. Climate risk sits under the ESG Risk Management Framework (page 158).

Page 158 lists the external standards behind the policies: UNPRB, UN Principles for Responsible Investing, SBTi, PCAF, ISO 50001 and ISO 14001, and the loan and bond principles for green and sustainability-linked finance.

In 2025 the Group refreshed its UNEP FI Portfolio Impact Analysis on its €83 billion loan portfolio. "Climate Stability" and "Finance" remain the most significant areas of impact (page 158).

Actions and resources in relation to climate change policies

Reference: pages 144-145, 159-160 (index: pages 144 and 159).

Actions follow the plan's twin targets: decarbonization of the lending portfolio and own operations, and sustainable finance (page 159). Own operations emissions fell by 1,066 tCO2e (17% of the 2020 baseline) in 2025 through heat pumps and hydrotreated vegetable oil (c.570 tonnes), lower F-gas emissions (c.270), fleet electrification (c.200) and a new 100 kWp solar system at the Group IT Centre, which now has a 200 kWp array (page 145).

Sustainable finance grew 20% to c.€17.7 billion in 2025 (2024: €14.7 billion), and the Group raised €1.5 billion in green bonds, bringing 2023-2025 green issuance to €3.75 billion (page 145).

Adaptation actions include flood insurance as a requirement for property lending, climate factors in credit assessment, flood defenses at exposed sites and quarterly reporting of physical risk exposure to executive and board committees (pages 159-160). The Group has planned future actions and CapEx within its Transition Plan (page 159).

Targets related to climate change mitigation and adaptation

Reference: pages 160-163 (index: page 160).

The Group's SBTi-validated Scope 1, 2 and 3 targets use a 2020 base year, with progress rated by RAG status each quarter (page 160).

• Own operations (Scope 1 and 2): 49% reduction by 2030 from 6,238 tCO2e. Absolute emissions fell 64% to 2,258 tCO2e, so the 2030 target was achieved in 2025 (page 161).
• Residential mortgages: 48% per m2 by 2030; down 19% (amber; the UK portfolio is lagging) (pages 160-161).
• Commercial real estate: 56% per m2 by 2030; down 34% (page 160).
• Electricity generation project finance: 76% per kWh by 2030; down 43% (pages 160, 162).
• Corporate loans: 25% SBT coverage by 2025; reached 46% (page 163).
• Corporate bonds: 25% coverage by 2025; reached 10%, rated red because banks were slow to get targets validated (page 163).

Sustainable finance targets are €15 billion by 2025 and €30 billion by 2030 (page 141).

Energy consumption and mix

Reference: page 174 (index: page 174).

Of 2025 renewable energy, 25,202 MWh was purchased or acquired electricity, heat, steam and cooling from renewable sources, 1,345 MWh was renewable fuel and 138 MWh was self-generated (page 174). The Group reports final energy consumption in MWh and does not offset energy consumption (page 174).

The high-climate-impact sector datapoints are marked "n/a - Group is a Financial Institution and does not belong to high climate impact sectors" (page 215).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 164-167 (index: page 164).

Financed emissions are the only significant Scope 3 category (page 168). Own operations emissions were 7,491 tCO2e market-based (2024: 9,106) (page 164). Customer lending financed emissions fell 11% and weighted average carbon intensity 12% (page 166). The PCAF average data quality score is 4, and financed emissions exclude Davy and New Ireland (pages 164-165).

The Group says supply chain overlaps can't be quantified under PCAF, so "the aggregated totals overestimate the underlying volumes of emissions" (page 166). Intensity is calculated on total operating income of €4,165 million (page 164).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 141, 174 (index: page 174; EU Climate Law datapoint at page 215).

The SBTi-validated targets are gross targets and "do not include GHG removals, carbon credits or avoided emissions"; the own-operations net zero target allows up to 10% carbon offsets after at least 90% reduction (page 141).

In 2024 the Group developed a Carbon Offsetting Policy to neutralize the residual 5-10% of own-operations emissions, endorsed in 2025 by ERM through a Second Party Opinion (pages 141, 174). The Sustainable Finance Working Group manages the Carbon Offset Inventory and reports annually to the Sustainability Decision Group. Offsets will come only from accredited standards such as Verra, Gold Standard, Plan Vivo, ACR and CAR, with at least 75% bought in Ireland and the rest in the UK, Spain, France, Germany and the US (page 174).

Page 174 gives no tonnes of removals or credits purchased or cancelled in 2025.

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

Reference: pages 151, 153 (EU-law datapoint table, page 215). Partial: E1-9 is not in the DR table on page 213; this entry covers only the datapoints the company indexes to it.

The company's datapoint table indexes E1-9 paragraph 66 (exposure of the benchmark portfolio to physical risks) and paragraphs 66(a) and 66(c) (amounts by acute and chronic physical risk) to page 153, and paragraph 67(c) (real estate carrying value by energy-efficiency class) to page 151 (page 215).

On page 153, exposure sensitive to physical climate risks is €1,174 million, 1.63% of total exposure (down 0.04% year on year), split across UK mortgages, RoI mortgages and commercial lending. Commercial lending rose because flood risk coverage of the CRE portfolio increased.

On page 151, 55% of new RoI mortgage lending in 2025 was in EPC categories A to B, 46% of UK properties are in A to C, and 38% of the CRE portfolio is in A to B. The ICAAP quantifies potential climate impacts by risk type (pages 147-149).

Policies related to own workforce

Reference: pages 181, 184-186 (index: pages 181, 184, 185 and 186); policy table on pages 134-136.

On discrimination, equal opportunity and inclusion (page 181):

• Inclusion and Diversity policy: the Group does not tolerate discrimination against any applicant, colleague or customer on protected characteristics; it is reviewed annually using Open View feedback.
• Recruitment policy: inclusive hiring training for interviewers, diverse interview panels, and software that flags age, gender and ableist language in job adverts.
• Respect at Work policy: covers bullying, discrimination and harassment, with informal and formal complaint routes and mediation.

On working conditions (pages 184-186): the Remuneration policy, the Speak Up policy and a Health and Safety policy in line with ISO 45001. The Group "has not adopted a policy with reference to collective bargaining and social dialogue" but has written agreements with employee representative bodies (page 184). The Human Rights policy follows the UN Guiding Principles and OECD Guidelines, prohibits forced labor and commits to ending child labor (page 187). The Group states "There are no material IROs related to Human rights" (page 135).

Taking action on material impacts on own workforce

Reference: pages 182-185 (index: pages 182 and 184).

Equal treatment and opportunities (page 182): the Inclusion Passport records agreed workplace accommodations; talent programs support women in middle and senior management; 2025 achievements include Investors in Diversity Gold accreditation and a neuroinclusion toolkit with auticon; biennial Inclusion, Diversity and Respect at Work training; and internship partnerships (APNI 5 interns, up from 4; DCU 8, up from 5; TCPID 31 since 2013, 3 hired permanently).

Training and skills (pages 182-183): a multi-year skills program built on a Group-wide skills assessment; 47% of applicable employees (2024: 43%) have used future skills pathways; the AI Academy had 1,198 colleagues registered in 2025; and 'My Career Coach' drew more than 600 sign-ups.

Working conditions (pages 184-185): the 'My Reward' platform, wellbeing supports (employee assistance, private health contribution, wellbeing app), day-one family leave entitlements and a hybrid-working hub network that reaches 20 locations once four new hubs open in 2026.

Targets related to own workforce

Reference: pages 183, 185 (index: pages 183 and 185).

The future skills metric is cumulative since 2021 and counts unique registrations against active users at 31 December 2025; the target was set in 2022 (page 183). The gender appointments target was set in March 2018 and is tracked regularly, with details sent to each division monthly (page 183). Both metrics exclude the Davy workforce (page 183).

The Group states: "The Group have not consulted its workforce or workers representatives when setting targets" (page 183). For working conditions it has not set a target and instead tracks reward uptake, benchmarks pay against peers and monitors Open View sentiment questions (page 185).

Characteristics of the undertaking's employees

Reference: pages 187-188 (index: pages 187 and 331).

At 31 December 2025 total headcount was 11,577 (2024: 11,488) and FTE was 11,287 (2024: 11,188) (pages 187, 331). Leavers numbered 962 (2024: 899), a turnover rate of 8.3% (2024: 7.8%) (page 187).

By country (headcount, 2025 with 2024 in brackets): Republic of Ireland 9,562 (9,443), United Kingdom 1,954 (1,978), United States 37 (38), France 12 (13), Germany 7 (10), Spain 5 (6) (page 187).

By gender and contract (page 188): 6,301 female and 5,276 male; 11,300 permanent (6,143 female, 5,157 male) and 277 temporary (158 female, 119 male). The Group does not employ non-guaranteed hours employees.

It does not report "other" or "not disclosed" gender because voluntary self-declared data cannot be fed into the current HR reporting system (page 188).

Collective bargaining coverage and social dialogue

Reference: pages 188-189 (index: page 188).

At 31 December 2025, 72.0% of employees (2024: 72.2%) were at grades covered by collective bargaining agreements. The coverage rates by region are (page 188):

• EEA countries with significant employment (Ireland only): 71.9% for collective bargaining and 71.9% for social dialogue (2024 restated: 72.2%)
• Outside the EEA (UK only): 75.2% (2024 restated: 74.7%)

Coverage applies to Bands 1-3 in the Republic of Ireland and the UK, defined as entry level to middle management (page 186). Page 189 places Ireland and the UK in the 60-79% coverage band and Ireland in the 60-79% band for workplace representation.

The Group restated the 2024 figures to correct a prior-period calculation error: the EEA rate rose from 59.3% to 72.2% and the non-EEA rate from 12.9% to 74.7% (page 188). It has no European Works Council, SE Works Council or SCE Works Council agreements (page 188).

Diversity metrics

Reference: page 189 (index: page 189).

Senior management, defined as employees in Bands 4-7, is 59% male and 41% female at 31 December 2025 (page 189). The Group says it "believes that appropriate diversity delivers better business outcomes and seeks to have a workplace reflective of society" (page 189).

The figure counts permanent and fixed-term employees who fall within the senior management definition at the end of the reporting period. Davy uses its own definition, Associate Director and above (page 189). A chart on the same page shows the distribution of employees by age group at 31 December 2025.

Separately, 47% of 2025 senior management appointments were female (2024: 48%), against a 45%-55% target range (page 183).

Adequate wages

Reference: page 185 (index: page 185).

The Group states that "All employees receive a fair and adequate wage and are paid above the minimum wage in each relevant jurisdiction" (page 185).

Supporting processes: the Group uses recognized external benchmarks to compare pay with industry peers and other industries competing for talent in each of its geographies (page 185). The Career and Reward framework sets out career paths and salary levels to support transparency and equity, and employees can see their pay and benefits and their Total Reward Statement through the 'My Reward' platform (page 184).

The page does not give a country-by-country breakdown of wage levels against adequate wage benchmarks.

Compensation metrics (pay gap and total compensation)

Reference: page 189 (index: page 189; EU-law datapoints 97(a) and 97(b), page 216).

The Group's gender pay gap is 24% (2024: 26%) (page 189). The annual remuneration ratio of the highest paid individual to the median annual total remuneration of all other employees is 27:1 (2024 restated: 20:1) (page 189).

The 2024 ratio was restated to include Fixed Share Allowances, which raised it from 18:1 to 20:1 (page 189). Data comes from payroll at 30 June 2025, except the UK at April 2025, in line with the Irish Gender Pay Gap Information Act 2021 and the UK Equality Act 2010 regulations (page 189). The same dataset supports the remuneration ratio. The Group says there were no material differences in headcount, promotions and out-of-course salary increases between the data date and the reporting period (page 189). Davy is not required to report under the UK legislation because it does not meet the headcount (page 189).

Incidents, complaints and severe human rights impacts

Reference: page 190 (index: page 190; EU-law datapoints, page 216).

In 2025 the Group recorded 5 incidents of discrimination, including harassment (2024: 2), reported through its channels for workers to raise concerns. Another 2 matters (2024: 10) covered working conditions, equal treatment or other work-related issues. The figures count all matters raised, "whether upheld or not" (page 190).

There were no complaints to the National Contact Points for the OECD Multinational Enterprise (2024: nil), and no fines, penalties or compensation for damages from these incidents and complaints (2024: nil) (page 190).

The Group had no severe human rights incidents connected to its own workforce, affected communities or consumers and end-users (2024: nil), and no related fines. It defines severe incidents as cases of modern slavery, human trafficking or child labor (page 190).

Policies related to affected communities

Reference: pages 186, 190, 192 (index: pages 186, 190 and 192); policy table on pages 131-132 and 138.

The Group says "These policies cover all affected communities" (page 192). Those tied to the S3 IROs are:

• Sustainable Finance Framework: criteria for classifying lending as sustainable; linked to S3-Impact 1 and 2, S3-Risk 3 and S3-Opportunity 3 (page 131).
• Green Bond Framework: eligible loans and use of proceeds; linked to S3-Impact 1 (page 131).
• Business and Strategic Risk policy (S3-Risk 1 and 3), Customer Protection Risk policy (S3-Risk 2) and Reputation Risk Management Framework (S3-Risk 1 to 3) (pages 132, 138).

On human rights, the Human Rights policy follows the UN Guiding Principles and OECD Guidelines and covers communities as well as the workforce and consumers (page 186). The Group says it "does not operate within any countries or geographic areas that are at significant risk of incidents of forced labour, compulsory labour or child labour" (page 186). It also notes there are "no material IROs related to Human rights" (page 135). The S3-1 EU-law datapoints are indexed to pages 186 and 190 (page 216).

Taking action on material impacts on affected communities

Reference: pages 190, 192-196 (index: pages 190, 192, 196 and 331).

Infrastructure (S3-Impact 1, page 192): in 2025 the Group joined 23 other banks and EIFO to finance East Anglia 3 (about 1.4 GW), co-led the 1.1 GW Inch Cape wind farm, provided €55 million for the 105 MW Derrinlough Wind Farm, and joined a lending consortium for a PPP building five higher education facilities (July 2025).

Housing (S3-Impact 2, pages 194-195): a €1 billion fund supports up to 10,000 social and affordable homes; at December 2025 more than €550 million of debt and equity funding supported c.12,700 of them. The Group holds c.47% of First Home Scheme drawdowns, financed c.16,000 home purchases in 2025 (42% of the Irish mortgage market) and committed €100 million of equity in December 2025.

Financial wellbeing (page 193): over 26,000 adults used financial education programs, and more than 8,600 primary and 129,500 secondary students took part in 2024/25.

Avoiding harm (page 196): controls so no one is shut out of the financial system solely for lacking standard ID, and due diligence on sustainable energy projects.

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

Reference: pages 196-197 (index: page 196).

Progress on the partnership target is reported to the GSC quarterly (page 196). The Group says it has "not engaged directly with affected communities in the setting, tracking or evaluation" of the targets (page 197). For risks it uses internal KRIs on conduct risks, monitored monthly with a very low risk appetite for breaches (page 197).

Policies related to consumers and end-users

Reference: pages 186, 190, 199-202 (index: pages 186, 190, 199, 200, 201 and 202); S4-1 paragraph 16 datapoint at page 131.

For the financial wellbeing impact the Group says "While there is not an explicit policy in place", the Group Strategy 2023-2025, the Sustainability Strategy 2023 to 2025 and the Financial Wellbeing Ambition 2023-2025 guide management of the material impact and opportunities (page 199).

• Information-related impacts: the Group Data Privacy policy requires privacy by design and by default, respect for data subject rights, breach management and legal checks before personal data is transferred to a third party; the Data Risk and Information Security and Cyber Risk policies sit alongside it (pages 201-202).
• Social inclusion: the Customer Protection Risk policy sets requirements against inadequate advice, misleading information, unsuitable products and unacceptable service (page 202).
• Human rights: the Human Rights policy covers consumers and end-users (page 186).

The policies "cover all consumers and / or end-users rather than specific groups" (pages 201-202).

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: pages 190, 199-203, 392 (index: pages 190, 199, 200, 201, 202 and 392).

Financial wellbeing (pages 199-200): the Mi365 in-app money tool, a borrowing tool launched in May 2025, and a Customer Engagement Engine that produced 2.4 billion impressions (2024: 2.3 billion) and 3.3 million engagements (2024: 3.1 million). Fraud measures include over 225 dedicated colleagues and over 104 fraud awareness events.

Inclusion (page 201): dementia awareness training from November 2025, digital accessibility work under the European Accessibility Act, SignVideo and the Irish Text Relay Service, and voluntary gambling blocks on debit and credit cards.

Privacy (page 201): all colleagues complete annual mandatory information security training.

Risk of detriment (pages 202-203): Customer Protection policy controls, ongoing monitoring of complaints and errors, and annual reviews of error management. A provision is held for customer redress on historical commission arrangements in UK motor finance (pages 202, 392).

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

Reference: pages 200, 202 (index: pages 200 and 202).

The Group's targets come from its UNPRB Commitment to Financial Health and Inclusion and apply to personal customers in the Republic of Ireland (page 200):

• raise from 62% (April 2023) to 70% by 2030 the share of customers confident they have funds to cover an unexpected day-to-day expense; the 2025 figure was 64% (2024: 60%);
• raise from 44% (April 2023) to 50% by 2030 the share confident they have funds to cover a major unexpected event; the 2025 figure was 45% (2024: 47%).

The metrics come from the Bank of Ireland Financial Resilience Survey run with RED C among customers who name the Group as their main day-to-day bank; "They are not validated by an external body" (page 200). Progress is reported to the GSC quarterly (page 200).

The Group does not publish a target for the information-related opportunity; it tracks internal metrics on data privacy training and policy compliance (page 202). Internal KRIs on conduct and operational risk are monitored with a very low risk appetite for breaches (page 202).

Business conduct policies and corporate culture

Reference: pages 184, 186, 205-209 (index: pages 184, 186, 205, 206, 207, 208 and 209).

The Board approves the Group Code of Conduct, which "sets the standard for all employees and Directors of the Group" in dealings with customers, suppliers, employees, shareholders and regulators (page 205). All colleagues must complete annual Code of Conduct web-based training and are expected to have read and understood the Code (page 206). A breach can lead to disciplinary action up to dismissal and to regulatory or criminal consequences, and formal investigations aim to finish within 20 working days of the first investigation meeting (page 206).

Related policies are Speak Up (page 184), Disciplinary, Financial Crime, Procurement and Third Party policies (pages 136-137) and a Group Regulatory Compliance Framework approved by the Board in March 2025 (page 196). Culture actions in 2025 covered purpose and values, recognition, learning, wellbeing and inclusion, backed by seven colleague-led I&D networks (page 206).

The EU-law table marks G1-1 paragraphs 10(b) and 10(d) "n/a - policy in place" (page 216).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed under the topic's own "Targets" headings rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Reference: pages 207, 209.

Corruption and bribery (page 209): "The Group set a target of having zero P0 issues", where P0 is the most severe risk or risk issue based on residual risk exposure.

No target, effectiveness tracked instead:

• Corporate culture: the Group does not set a target and tracks effectiveness through the annual Open View survey, the Disciplinary policy review by Employee Relations and monthly KRIs, such as open issues on ineffective regulatory change governance (page 207).
• Supplier relationships: no target, with a KRI on the percentage of critical suppliers that comply with the Code of Supplier Responsibility (page 207).
• Whistleblower protection: no target, with effectiveness tracked through the Open View survey (page 209).

The Group labels these sections "G1-4" in its statement (pages 207, 209).

Incidents of corruption or bribery

Reference: pages 207, 209 (index: pages 207 and 209; EU-law datapoint 24(a) at page 216).

"In 2025, there have been no convictions (2024: €nil) and no fines (2024: €nil) for violations of anti-corruption and antibribery laws for the Group" (page 209). The count of convictions and the amount of fines covers all convictions and fines paid as a result of convictions by a court of law in proceedings against Group entities in the reporting year (page 209).

The EU-law datapoint table marks G1-4 paragraph 24(b), standards of anti-corruption and anti-bribery, "n/a - no breaches" (page 216).

Pages 207 and 209 report convictions and fines but no separate count of confirmed corruption or bribery incidents. The Group's target for corruption and bribery is zero P0 issues, its most severe risk issue rating (page 209), and the Group tracks key risk indicators on corporate culture monthly (page 207).