BBVA

The role of the administrative, management and supervisory bodies

BBVA's Corporate Governance system

The Sustainability governance model is integrated into BBVA's corporate governance system. BBVA has a corporate governance system, made up of a set of principles, rules and mechanisms that integrate and regulate the structures and operation of its corporate bodies. This System is configured, mainly, by the provisions of the Statutes, the regulations of its different corporate bodies and the general policies of the Bank approved by the Board of Directors.

Board of Directors

One of the main elements of BBVA's Corporate Governance system is the Board of Directors, which, as the highest body of representation, administration, management and oversight, performs both the functions of management of the Entity and those of supervision and control of management.

As of December 31, 2024, BBVA's Board of Directors comprises 15 members, two of whom were executive and 13 are non-executive directors. BBVA's Board of Directors has a balanced composition, with high levels of independence and diversity, both with regard to the presence of men and women and the different types of directors, capabilities, experience and knowledge.

At the close of the 2024 fiscal year, BBVA's Board of Directors comprises 46.66% women and 53.34% men, meeting the target set forth in the Board of Directors' Selection, Suitability, and Diversity Policy.

In terms of independence, at the close of the 2024 fiscal year, BBVA's Board of Directors includes ten independent directors, representing 66.66% of the total Board members and 76.92% of the non-executive directors on the Board. In terms of nationality, the Board of Directors has a total of seven nationalities (Spanish, Turkish, Portuguese, Danish, American, Mexican and Belgian), with 40% of non-Spanish directors.

Functions and responsibilities of the Corporate Bodies

The Board of Directors shall have the powers established at any time by applicable legislation and the Bylaws. Among other functions, the Board of Directors has the power to approve the general policies and strategies of the Entity. The Board carries out, directly or through its Committees, the monitoring of the decisions adopted, including the supervision of the implementation of general policies, and the supervision of the management of the Company and its Group.

Governance model of the Corporate Bodies in matters of sustainability

Within the context of the Group's general management and control framework, the Board of Directors has incorporated Sustainability as one of the Bank's strategic priorities, as reflected in the Group's Strategic Plan for the years 2019-2024.

The Board of Directors has approved the General Sustainability Policy, which defines and establishes the general principles and management and control objectives and guidelines that the Group must follow in terms of sustainable development.

The Corporate Bodies promote that Sustainability, which includes environmental, social and governance aspects (ESG), is integrated into all the Group's businesses and activities, from a global perspective, and that the material impacts, risks and opportunities arising from it are adequately managed.

The Bank has a Global Sustainability Area, which is responsible for designing and promoting the execution of the Group's strategic Sustainability agenda and business development in this area; for establishing the Group's objectives in these matters; and for promoting and coordinating the Group's various lines of work in this area.

Board Committees

The Board of Directors has a structure of committees that assist it on matters within its competence:

• Executive Committee: supports the Board of Directors in decision-making and in the ongoing monitoring of BBVA's strategy and objectives in terms of Sustainability
• Risk and Compliance Committee: supports the Board in integrating Sustainability into the analysis, planning and management of the Group's financial and non-financial risks
• Audit Committee: supervises the process of preparing and the content of the information that must be formulated by the Corporate Bodies in matters of Sustainability for publication
• Appointments Committee: ensures that the competencies related to Sustainability are taken into account when analyzing the composition of the Board of Directors
• Remuneration Committee: analyses the selection and monitors the evolution of strategic indicators linked to variable remuneration, including indicators related to Sustainability
• Technology and Cybersecurity Committee: assists the Council in monitoring the technology strategy and managing cybersecurity

Knowledge, experience and capabilities of the Board of Directors

The Board of Directors has been strengthening its competencies in Sustainability, both through specific training and through the incorporation in recent years of directors with extensive experience and knowledge in Sustainability. The Board of Directors has an annual continuous training program, in which non-executive directors receive specific training on matters relevant to the exercise of their functions, including those related to Sustainability.

Specifically, during the 2024 financial year, some of the training sessions included in the training program of the Board of Directors dealt specifically with issues related to Sustainability.

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

Activity of the Corporate Bodies in the area of Sustainability

The Board of Directors has incorporated Sustainability as one of the Bank's strategic priorities and has approved the General Sustainability Policy. The Board of Directors has adopted other specific management decisions in the area of Sustainability, such as:

• The establishment of a strategic indicator for Sustainable Business Channeling, setting a target of 300 billion euros for the period 2018-2025
• Objectives for the decarbonization of the portfolio aligned with the goal of achieving net zero emissions by 2050
• The Investment in the Community of 550 million euros

Supervision and control processes

To supervise and control the execution of the decisions adopted by the Board of Directors in matters of Sustainability, the Corporate Bodies have reports received from both the Global Sustainability Area and the different areas of the Group, which incorporate Sustainability in the reporting of their businesses and activities.

These reports are submitted by the executive areas to the Corporate Bodies based on their competence, on a periodic or ad hoc basis.

In 2024, the Corporate Bodies have periodically received specific reports from the Global Sustainability Area, through which they have been able to monitor the different aspects of the strategy related to Sustainability and the objectives established in this area, as well as the main projects and lines of work of the Group in this area.

Likewise, the different business and global areas of the Group have reported to the Corporate Bodies on their activity, which includes Sustainability as one of its relevant pillars as it is a strategic priority of the organization, giving an account of the initiatives, projects and specific activities developed and the means available to them for the execution of this priority.

Most of the impacts, risks and opportunities derived from Sustainability that are of material importance to the Bank, listed in the "Double materiality analysis" chapter of this Report, have been reported to the Corporate Bodies throughout the year, either specifically or as part of broader reports from the different executive areas of the Bank on Sustainability matters.

Information model

BBVA's information model is characterized by providing the Corporate Bodies with information that is: complete, integral, adequate and consistent. The information model is made up of information from different sources that allows the directors to debate the issues submitted for their consideration within the corresponding Corporate Bodies and to carry out the functions assigned to them.

Directors have, prior to the meetings, the necessary information to be able to form an opinion on the issues that correspond to the Corporate Bodies, being able to request other information and advice that is required for the fulfillment of their functions, as well as request the Board of Directors for the assistance of external experts in those matters submitted to its consideration that, due to their special complexity or significance, so require.

Integration of sustainability-related performance in incentive schemes

Integration into variable remuneration for executive directors

BBVA has integrated sustainability indicators into the variable remuneration system. To promote the achievement of the objectives, the following are included in BBVA's variable remuneration system:

• Promoting new business through sustainability: Annual Variable remuneration linked to the promotion of sustainable business for all employees, including executive directors and Senior management of BBVA, as well as incentives linked to sustainable business specific to the commercial network.

• Achieving net zero emissions: since 2023, long-term variable remuneration has been linked to certain decarbonization targets for members of the collective, including executive directors and Senior management of BBVA.

Short-term incentive indicators (2024)

Long-term incentive indicators (2024)

Overall sustainability weight in remuneration

The indicators for calculating the annual variable remuneration include several non-financial or Sustainability-related indicators - NPS, Target Clients, Sustainable Business Channeling, Decarbonization of the Portfolio and Percentage of Women in Management Positions - which together represent 32.8% of the target annual variable remuneration.

Integration into financing structure

The issuance of own green, social and sustainable bonds plays a key role in achieving sustainability objectives. Business areas that issue products identified as green, social, and sustainable bonds under the applicable criteria receive a bonus, provided the financing cost of these types of bonds is lower than that of conventional bonds. This is determined by BBVA's Funds Transfer Pricing (FTP) system.

Statement on due diligence

Human rights due diligence

BBVA aims to contribute to the respect for Human Rights. This is why it frames this willpower in the Group's General Sustainability Policy and aligns it with its Code of Conduct. This policy is aligned with the International Bill of Human Rights, the Guidelines of the Organization for Economic Cooperation and Development (OECD) for Multinational Business, and the fundamental conventions of the International Labor Organization, among others.

Specifically, as provided in the General Sustainability Policy, the Group ensures compliance with all applicable laws and respect for internationally recognized human rights in all its relations with employees, customers, shareholders, suppliers and, in general, with the communities in which it conducts its businesses and activities.

Human Rights Due Diligence Process

Since 2018, the BBVA Group has carried out two global Human Rights Due Diligence exercises with the aim of preventing, mitigating and remedying potential impacts on human rights (such as human trafficking, forced labor, child labor, freedom of association and collective bargaining and, equal pay or discrimination).

Through it, BBVA has analyzed the following aspects:

• Identification of the main issues or potential impacts of operations
• Improvements within BBVA to try to prevent and mitigate these impacts
• The availability of channels and processes that facilitate grievance management

BBVA identifies the social and labor risks that arise from its activity in the different areas and countries in which it operates in order to manage the potential impacts generated, through the entity's ordinary risk management processes, or through standards and existing processes that integrate the human rights perspective, such as the Equator Principles.

ESG assessment and monitoring of customers

BBVA obtains ESG information from its customers and third parties to assess and monitor the ESG suitability of customers and deals.

Wholesale customers

BBVA assesses and monitors its wholesale customers under 4 dimensions:

• Their activities with special focus to those with potential negative environmental and social impact, covered under the Environmental and Social Framework
• Their transition risks leveraging on Transition Risk assessment tools
• Their behavior / controversies: Encompassed in the ESG controversies management procedure
• Their projects assessed under the Equator Principles

Environmental and Social Framework

The Environmental and Social Framework aims to establish criteria for the identification, assessment and monitoring of certain activities of the following sectors, selected for their high potential impact on nature and society: mining, agro-industry, energy, infrastructure and defense. The Framework identifies restrictions, either via prohibited activities or activities requiring special attention in these sectors.

BBVA, with the support of an independent advisor, analyses whether wholesale customers covered by its Framework do not engage in prohibited activities. It also analyses whether they engage in an activity requiring special attention, in which case BBVA assesses the environmental and social impacts derived from the activity to be financed.

Equator Principles

In 2004, BBVA signed the Equator Principles (EP), which establish standards for environmental and social risk management in project financing. Currently in their fourth version (EP4), these principles are applied globally in all industrial sectors.

In accordance with the EP, BBVA subjects each project under the scope of EP4 to an environmental and social due diligence analysis, considering impacts on environmental and human rights. Each deal is classified according to its risk level (categories A, B or C).

Regarding the human rights assessment and in accordance with the EP, BBVA requires due diligence on projects that may impact indigenous communities. In cases where this circumstance occurs, the free, prior and informed consent of these communities must be obtained, regardless of the geographic location of the project.

Legislative engagement

In 2024, BBVA has continued to take an active role in the field of future EU legislative initiatives, participating in the Working Groups on Sustainable Finance. BBVA contributes its opinion to the development of sectoral positions on various EU initiatives, including the work of dialogue and support with the European regulator in relation to the development of the directive on corporate due diligence in matters of sustainability.

Risk management and internal controls over sustainability reporting

ESG Reporting Committee

The Group has an ESG Reporting Committee. The Committee serves as a coordination and support body at executive level aimed at ensuring that the information to be disclosed on Sustainability matters that is to be formulated by the corporate bodies of the BBVA Group reflects the Sustainability objectives and strategy, risk management model and relevant quality standards.

The Committee is led by the Finance area and the following areas participate in it: Global Sustainability Area, Global Risk Management, Regulation & Internal Control, Legal Services, General Secretary, Data, Chair Office, Talent & Culture, and Internal Audit.

Verification of non-financial information

The information contained in the NFIS has been subject to a limited review by Ernst & Young Auditores, S. L., in its capacity as an independent verification services provider, with the scope indicated in its Verification Report which is included in the Appendix of this Management Report.

Risk management integration

The Risk and Compliance Committee supports the Board in integrating Sustainability into the analysis, planning and management of the Group's financial and non-financial risks, and in supervising their execution.

The Audit Committee supervises the process of preparing and the content of the information that must be formulated by the Corporate Bodies in matters of Sustainability for publication, as part of the public information of the Group.

Internal control processes

BBVA is constantly working on defining and adapting processes to ensure operational efficiency and adequate internal controls, including:

• The definition of solid criteria for classifying sustainable business
• Special attention to data quality
• The evaluation of non-financial risks
• The definition of mitigating measures

This process implementation is based on the integration of sustainability in the organization with a solid governance model and an identification and evaluation of aspects related to the sustainability of customers.

Data and estimates

In preparing the Consolidated Non-Financial Information Statement (NFIS), a series of estimates and assumptions has been made in various areas, including:

• Calculation of emissions
• Establishment and monitoring of transition objectives for portfolio alignment
• Estimation of the potential impacts of climate and environmental risks, as well as social and governance risks

These estimates have been made using the best information available as at December 31, 2024. The Group is pursuing various work streams to enhance the accuracy and reliability of the data. During the 2024 financial year, no significant changes have been made to the estimates from previous years.

Strategy, business model and value chain

BBVA Group's Value Chain

The ESRS consider that the scope of sustainability information extends beyond an entity's own operations and encompasses material impacts, risks, and opportunities throughout its value chain. This value chain comprises the activities, resources, and relationships that the entity employs and relies upon when defining its products or services, ranging from conception through to delivery, consumption, and end of life, across all the geographies in which it operates.

As a result of analysis, the BBVA Group's value chain has been categorized into three elements or phases:

Upstream

This phase includes entities that supply resources and provide services necessary for the development of the Group's activity. It primarily involves relationships with suppliers and partners for technology, information systems, legal or consultancy services, general supplies, among others.

Own Operations

This encompasses BBVA's own assets and internal processes that enable it to provide financial solutions, from product design and development to risk management. It also covers all BBVA Group companies and their employees.

Downstream

This refers to the phase in which BBVA markets and distributes its products and services to customers, as well as the monitoring of the effects those products and services generate in the broader environment. The Group identifies customers in its three main business segments, banking, insurance, and asset management, as the stakeholders involved in this phase of the value chain.

Business model and strategy

BBVA has defined sustainability as one of its six strategic priorities, covering the following three dimensions in the geographies where it operates:

1. Climate: Business opportunities related to global warming: electric transport, energy efficiency, renewable energy, etc.
2. Natural Capital: Business opportunities related to nature: water, land, biodiversity, and waste and pollution.
3. Inclusive growth: Business opportunities related to inclusive economic growth: inclusive infrastructures, financial inclusion, entrepreneurship, job creation, access to basic goods and services.

Strategic objectives

The execution of this strategy is based on the achievement of two main objectives:

1. Promoting new business through sustainability: Channeling 300 billion euros in sustainable business between 2018 and 2025, already achieved one year ahead of schedule with 304 billion euros channeled by 2024.

2. Achieving net zero emissions by 2050: With specific decarbonization targets for high-emission sectors and intermediate targets for 2030 for 11 sectors.

Additionally, BBVA has set itself the goal of contributing 550 million euros in social programs to benefit 100 million people between 2021 and 2025.

Business approach by customer segment

BBVA adopts a customized approach for each customer segment:

Wholesale customers (corporate and institutional)

• Sectoral solutions based on innovation and specialized knowledge
• Support in sustainability strategy implementation
• Offering sustainable products (bonds, loans, transactional banking activities)
• Preparation and monitoring of alignment plans with customers

Enterprise customers

• Simple and scalable solutions enabling economic savings (energy efficiency, fleet renewal)
• Consultation tools based on advanced data analytics
• Carbon footprint calculator for companies

Retail customers

• Customized digital solutions based on data analysis
• Focus on energy savings, mobility solutions, and financial inclusion
• Digital solutions accompanying customers throughout the entire process

Value creation approach

BBVA is promoting the creation of new business around sustainability with three priority areas:

1. Development of financial solutions: Promoting specialized solutions for customers to capture sustainability-related business opportunities
2. Differential risk management capabilities: Focusing on financing customer emissions reduction while leveraging competitive advantage in sustainability
3. Implementation of control processes: Ensuring operational efficiency and adequate internal controls, including solid criteria for classifying sustainable business

Interests and views of stakeholders

Main stakeholder groups

The General Sustainability Policy identifies BBVA's main stakeholders and other groups:

• Customers
• Employees
• Shareholders and investors
• Suppliers
• Regulators and supervisors
• Investment in the community

Stakeholder engagement approach

BBVA maintains a dialogue with customers based on:

• Sector knowledge of the implementation and execution of sustainability strategies
• Specialization in sectors that face the greatest challenges in the transition to a low-carbon economy
• Support in the analysis of the sustainability of the entire value chain of customers
• Offering sustainable products that meet financial needs and support transition
• Preparation and monitoring of alignment plans with customers

Customer engagement by segment

Wholesale customers

BBVA engages through:

• Development of sectoral roadmaps aligned with Paris Agreement objectives
• Analysis of value chain sustainability including carbon footprint of suppliers
• Dialogue on transition strategies and decarbonization plans

Enterprise customers

Engagement includes:

• Personalized dialogue adapted to sector, size, country and business maturity level
• Advisory tools such as carbon footprint calculator
• Training events with managers on sustainability solutions

Retail customers

BBVA engages through:

• Digital solutions for energy savings and sustainable mobility
• Financial inclusion initiatives for unbanked populations
• Education and awareness on sustainability issues

Industry and public sector engagement

BBVA has played an active role in various global initiatives for more than two decades, participating in:

Global initiatives:

• UN Global Compact
• Principles for Responsible Banking UNEP-FI
• Net-Zero Banking Alliance (NZBA)
• Partnership for Carbon Accounting Financials (PCAF)
• Task Force on Climate-related Financial Disclosures (TCFD)
• Task Force on Nature-related Financial Disclosures (TNFD)

Regional and sectoral engagement:

• Institute of International Finance (IIF)
• Association for Financial Markets in Europe (AFME)
• European Financial Services Roundtable (EFR)
• Spanish Banking Association (AEB)
• High Level Expert Group (HLEG) of the European Commission

Supervisory engagement

In 2024, BBVA has actively participated in working sessions with various supervisory bodies:

• European Central Bank (ECB)
• Bank of Spain
• Banking Regulation and Supervision Agency (BRSA) of Turkey
• Mexican authorities including the Bank of Mexico

Community investment

BBVA undertakes community investment programs and activities to address the most relevant challenges of the communities in which the Group is present, with the aspiration of creating opportunities for all.

The Group aims to invest 550 million euros in social programs to benefit 100 million people between 2021 and 2025, acting as an agent of social change alongside other stakeholders.

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

Material topics identified

BBVA has identified material impacts, risks and opportunities in four general topics:

1. Climate change
2. Own workforce
3. Consumers and end-users
4. Business conduct

Climate Change

Climate change is material for BBVA because it has significant effects both on the environment and on its own operations. This consideration aligns with BBVA's strategy, which integrates climate action as one of its fundamental pillars.

Material IROs for Climate Change:

Integration with strategy: The key role of banks in financing the transition to a decarbonized economy has been considered. BBVA can promote decarbonization and enhance customer resilience, generating value for both society and the Group.

Own Workforce

BBVA recognizes the importance of people as a fundamental pillar of its corporate strategy. The commitment to creating a positive work environment is material because employees contribute directly to achieving business objectives.

Material IROs for Own Workforce:

Consumers and End Users

Consumers and end users are fundamental to the Group's activity. Their satisfaction and financial security have direct impact on the Group's performance and reputation.

Material IROs for Consumers and End Users:

Business Conduct

Material IROs for Business Conduct:

Strategic integration

The results of the double materiality analysis are related to the definition of the Group's strategy and are consistent with various internal exercises to assess climate risks and non-financial risks. They reflect:

• Growing activity around sustainable business channeling
• Advances in digitalization
• Best practices in business conduct

The material IROs are concentrated in the downstream phase of the value chain, except for those related to corporate conduct and the Bank's own workforce, which fall under the Group's own operations phase.

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

Double materiality analysis process

The Group has previously identified its sustainability-related matters based on international reference standards and best practices. In 2024, the double materiality analysis process has been updated to incorporate the principles of the CSRD and ESRS, as well as the implementation guide for the assessment of materiality issued by the European Financial Reporting Advisory Group (EFRAG).

The double materiality principle means that a subtopic is classified as material if it has a significant impact on people or the environment (impact materiality), if it significantly affects the financial position of the entity (financial materiality), or for both reasons.

The applied methodology has been structured into three phases: context analysis, identification and definition of IROs, and their subsequent evaluation.

Phase A: Context analysis

In the 2024 exercise, the context analysis has been reinforced to enhance the identification of potential material topics for the Group. This approach includes:

Internal documentation considered:

• Key policies (general sustainability policy, employee policies, supplier policies, corporate governance)
• Strategic documents reflecting the Group's commitment to responsible management

External information reviewed:

• Information from regulators and supervisory entities
• Essential regulations such as Climate Change Law and European guidelines
• Topics evaluated by leading ESG rating agencies (MSCI and Sustainalytics)
• Benchmarking against key industry peers

Environmental publications:

• Broad set of publications on biodiversity, climate change, and deforestation
• Market standards such as GRI and SASB

Phase B: Identification and definition of IROs

Building on the context analysis findings, BBVA has incorporated specialized tools:

Key tools used:

• UNEP-FI Impact Tool: to identify sectoral and geographic impacts from credit portfolios
• Human rights due diligence: facilitates identification of human rights-related impacts
• Climate Change Risk Assessment: provides comprehensive perspective in risk evaluation
• Reputational and Non-Financial Risk matrices
• Sector-specific standards such as SASB and European Banking Authority (EBA) guidelines

BBVA applies a perspective that acknowledges and addresses the interdependencies among IROs, for example, those tied to investments in carbon-intensive sectors.

IRO classification criteria:

• Actual/Potential: distinguishing between current IROs and those expected in the future
• Time Horizons:
  • Short-term: Up to 1 year
  • Medium term: From the end of the first year to four years
  • Long term: More than four years
• Value Chain Phase: upstream, own operations, and downstream
• ESRS Subtopic: allocation to subtopic categories defined by ESRS

Phase C: Evaluation

Impact materiality assessment

Impact materiality (inside-out perspective) assesses the positive or negative effects of the Group's activities on people, the environment and society. Assessment organized into two key axes: severity and probability.

Severity defined through three factors:

• Scale: Measures the relevance of the impact, from minimal effects to critical consequences
• Scope: Determines geographic or sectoral extent (local, national or global)
• Irremediable Character: Applied to negative impacts, assesses ability to reverse damage

Probability: likelihood of occurrence, measured on a scale from "unlikely" to "almost certain"

Materiality thresholds:

• Current impacts: materiality assigned to those with medium-high or higher severity
• Potential impacts: materiality applies to those combining medium-high severity with medium-high probability

Financial materiality assessment

Financial materiality (outside-in approach) evaluates effects on the Group's financial position, considering:

• Growth
• Operational performance
• Access to capital

Tools employed:

• ENCORE (Exploring Natural Capital Opportunities, Risks, and Exposure): identifies risks related to natural capital
• BBVA's Climate Risk Assessment: evaluates how climate risks could affect traditional risks
• SASB standards: provides metrics for assessing social and governance risks

Stakeholder involvement

During this process, the heads of each area actively participated, contributing with their expertise in identification, definition and evaluation of IROs. This multidisciplinary approach provided a comprehensive view covering all business segments and phases of the value chain.

The process has been developed taking into account the control and governance mechanisms established by the Group, including the management and supervisory bodies.

Dynamic process

The double materiality analysis must be understood as a dynamic process, subject to periodic reviews and adjustments as the entity's needs, strategic priorities, market conditions, dialogue with stakeholders, availability of new tools, adoption of emerging technologies and regulatory changes evolve.

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

Material topics covered

Based on the double materiality analysis, BBVA covers the following ESRS topics in its sustainability statement:

1. ESRS 2 – General Disclosures: All applicable disclosure requirements
2. ESRS E1 – Climate Change: All applicable disclosure requirements for material climate-related impacts, risks and opportunities
3. ESRS S1 – Own Workforce: All applicable disclosure requirements for material workforce-related impacts, risks and opportunities
4. ESRS S4 – Consumers and End-users: All applicable disclosure requirements for material consumer-related impacts, risks and opportunities
5. ESRS G1 – Business Conduct: All applicable disclosure requirements for material business conduct-related impacts, risks and opportunities

Non-material topics

The following topics have been assessed as not material based on the double materiality analysis:

• ESRS E2 – Pollution
• ESRS E3 – Water and Marine Resources
• ESRS E4 – Biodiversity and Ecosystems
• ESRS E5 – Resource Use and Circular Economy
• ESRS S2 – Workers in the Value Chain
• ESRS S3 – Affected Communities

Legal framework and regulatory compliance

BBVA discloses non-financial information in line with the regulatory framework in force in Spain as of December 31, 2024, specifically:

• Law 11/2018 on non-financial information
• Law 7/2021 on climate change
• European Taxonomy regulation (Regulation (EU) 2020/852 and related delegated regulations)

The new regulatory framework regarding corporate sustainability information has come into force: Directive 2013/34/EU, as amended by Directive (EU) 2022/2464 (CSRD), and Delegated Regulation (EU) 2023/2772 developing the ESRS.

In the absence of transposition of the European directive, the CNMV and ICAC issued a joint statement recommending that sustainability information for 2024 should be published in accordance with the CSRD and ESRS, additionally including certain disclosures required by Law 11/2018.

Transition periods and exemptions

BBVA, in accordance with ESRS provisions, incorporates transition periods for some information requirements:

• Identification and disclosure of certain quantitative aspects relating to the value chain
• Anticipated financial effects concerning material impacts, risks, and opportunities
• Financial effects related to revenue from activities affected by physical and transition risks
• Specific characteristics of non-salaried workers
• Information concerning public or private protection programs for salaried workers

Content organization

The sustainability statement is organized in the following sections:

1. General information (ESRS 2 disclosures)
2. Environmental information (ESRS E1 – Climate Change)
3. Social information (ESRS S1 – Own Workforce, S4 – Consumers and End-users)
4. Information on governance (ESRS G1 – Business Conduct)
5. Complementary information including equivalency tables
6. Appendices with content tables for various regulatory frameworks

Verification

The information contained in the sustainability statement has been subject to a limited review by Ernst & Young Auditores, S.L., in its capacity as an independent verification services provider.

Reference to other standards

BBVA includes tables of equivalences and content references to other sustainability standards and frameworks, including:

• Responsible Banking Principles UNEP-FI
• ISSB (International Sustainability Standards Board)
• Transition plan equivalency table

Although these do not form part of the applicable legal framework, BBVA has deemed them relevant to include for stakeholder information.

Transition plan for climate change mitigation

Scope of the plan

BBVA has defined a decarbonization strategy that reflects its goal to contribute to the transition towards a low-carbon economy. The Transition Plan follows the framework of the recommendations of TCFD and the Glasgow Financial Alliance for Net Zero (GFANZ).

Entities and geographies covered:

The plan covers wholesale, enterprise and retail banking in:

• Spain
• Mexico
• Turkey
• Argentina
• Colombia
• Peru
• Uruguay

For wholesale customers, coverage also includes:

• United States
• Branches of Banco Bilbao Vizcaya Argentaria, S.A. in Belgium, France, Italy, Germany, Portugal and the United Kingdom

Value chain segments:

The transition plan addresses:

• Scope 1, 2, and 3 emissions across the value chain
• Financed emissions (Scope 3 Category 15)
• Direct operational emissions

Sector-specific alignment plans cover:

• Oil & Gas (upstream)
• Power generation
• Automotive (manufacturers)
• Steel (manufacturers)
• Cement (manufacturers)
• Thermal coal
• Aviation (airlines)
• Shipping (operators)
• Aluminum
• Real estate - commercial (Spain only)
• Real estate - residential (Spain only)

Target year(s) for net zero / carbon neutral

Net Zero target: 2050

Coal phase-out targets:

• 2030 in developed countries
• 2040 globally

Scope 1, 2, 3 reduction milestones with baseline years

Intermediate emissions reduction targets for 2030

*Baseline for coal elimination target **Published in 2024; specific reduction percentage to be disclosed within 12 months

2024 Performance vs baseline:

Alignment with 1.5°C / SBTi validation status

Climate scenarios used:

• IEA Net Zero Scenario (IEA_NZE) for: Power generation, Automotive, Aviation
• Institute for Sustainable Futures Net Zero Emissions (ISF NZ) for: Steel, Cement
• International Maritime Organization (IMO) Strategy for: Shipping
• International Aluminum Institute (IAI) Net Zero and Mission Possible Partnership 1.5°C Roadmaps (MPP) for: Aluminum
• National Integrated Energy and Climate Plan (PNIEC) for: Real estate (Spain)

Alliance memberships:

• Net Zero Banking Alliance (NZBA) member
• Principles for Responsible Banking (UNEP-FI) signatory
• Task Force on Climate-related Financial Disclosures (TCFD) aligned

BBVA is not SBTi validated but follows science-based pathways through NZBA guidelines and sector-specific methodologies (PACTA, PCAF).

Key levers / decarbonization pillars

Energy

• Financing renewable energy projects: €4,828 million in 2024 (75% growth vs 2023)
• Support for clean energy transition in power generation
• Promotion of energy efficiency measures
• Solar self-consumption financing in Mexico, Spain, Argentina, and Colombia

Process improvements

• Steel: Electric Arc Furnace (EAF) and Hydrogen-based direct reduced iron (H2-DRI) production
• Cement: Carbon capture and storage (CCS) technologies
• Power generation: Transition from coal to renewable capacity

Product/Fleet renewal

• Automotive: Financing electric and plug-in hybrid vehicles
• Aviation: Fleet renewal with more fuel-efficient aircraft
• Shipping: Modernization of vessels, use of low-carbon fuels
• Battery manufacturing and charging infrastructure

Supply chain

• Analysis of customer value chain sustainability
• Carbon footprint calculator for enterprise customers
• Support for customers in analyzing and reducing Scope 3 emissions

Customer engagement and transition support

• Transition Risk Indicator (TRi): Tool to assess customer decarbonization plans and maturity
• Customer support plans: Formalized procedure in 2024 to develop and monitor tailored support
• Sectoral transition plans with commercial strategies
• "What If" simulator for real-time impact assessment of transactions

Customer transition progress:

• Oil & Gas: 66% of portfolio actively managing transition (vs 61% in 2023)
• Power generation: 86% of portfolio actively managing transition
• Automotive: 100% of portfolio actively managing transition
• Steel: 78% of portfolio actively managing transition (vs 76% in 2023)
• Cement: 85% of portfolio actively managing transition (vs 83% in 2023)
• Thermal coal: 90% expected to meet phase-out targets
• Aviation: 90% of portfolio actively managing transition (vs 87% in 2023)
• Aluminum: 100% of portfolio actively managing transition

CapEx / investment commitments

Sustainable business channeling:

• Target: €300 billion between 2018-2025
• Achieved: €304 billion by December 31, 2024 (one year ahead of schedule)
• 2024 channeling: ~€99 billion

Climate-specific channeling in 2024:

• More than €77 billion earmarked for:
  • Electrification of industry
  • Energy efficiency measures
  • Development of renewable projects
  • Promotion of solar self-consumption
  • Transformation of transport and logistics sector

Investment in climate funds: BBVA invests in climate funds focused on decarbonization to support new low-carbon technologies and expand knowledge in financing innovative solutions.

Renewable energy growth:

• Renewable energy projects: €4,828 million by end of 2024 (75% growth vs 2023)

Locked-in emissions and stranded asset analysis

The document does not provide explicit quantification of locked-in emissions or stranded asset analysis. However, related disclosures include:

Exposure to high-emission sectors:

• 6.17% of exposure at default (EAD) at BBVA Group level to sectors defined as High Transition Risk (Oil & Gas, Electricity Generation, Autos, Steel, Cement, Coal Mining and Transport) as of December 31, 2024

Thermal coal exposure:

• Total exposure to thermal coal customers: €1,578 million as of December 2024
• Exposure to customers with limited transition expectations: €152 million (63% reduction since 2022)

Physical risk assessment: BBVA has developed an internal physical risk score for collateral-level analysis under different climate scenarios (SSP2-4.5 and SSP3-7.0) with 2040 time horizon.

Use of carbon credits / removals

Operational footprint: BBVA purchases and retires carbon credits for an amount equivalent to:

• Scope 1 emissions
• Scope 2 emissions
• Scope 3 categories:
  • Category 5 (waste generated in operations)
  • Category 6 (business travel)
  • Category 7 (employee commuting)

Disclosure on GHG removals (E1-7): The plan states BBVA uses carbon credits for operational emissions neutralization. Details on the volume, quality, certification standards, or use of carbon credits in financed emissions are not provided in the excerpts.

Governance and implementation

Sustainability Alignment Steering Group (SASG):

• Led by Global Head of Sustainability & Corporate Investment Banking
• Members: global heads of Global Risk Management, Commercial Client Solutions, Strategy & M&A, Regulation & Internal Control, and Finance
• Functions:
  • Analyzing and discussing 2030 alignment objectives
  • Evaluating compliance and portfolio decarbonization strategy
  • Analyzing sector alignment plans
  • Promoting tools, methodologies and metrics

Sector model for wholesale clients (2024): Global sector managers for:

• Energy
• Industry and transport
• Infrastructure and construction
• Consumer, retail and health
• Technology, media and communications
• Financial institutions and financial sponsors

Remuneration linkage:

• Annual variable remuneration linked to sustainable business promotion for all employees, including executive directors
• Long-term variable remuneration linked to decarbonization targets (since 2023) for identified group members

Tools and methodologies

Transition Risk Indicator (TRi):

• Assesses customer transition risk exposure and decarbonization plan credibility
• Evaluates ambition of emissions reduction targets and implementation maturity
• 91% of loan portfolio in high-emission sectors has TRi as of 2024
• Generic TRi developed in 2024 for all corporate banking customers

Sustainability Client Toolkit: Centralized repository of ESG information for frontline teams

Sectoral Transition Plans Management dashboard: Collects alignment indicators using PACTA methodology

"What If" simulator: Real-time evaluation of transaction impacts on customer and portfolio decarbonization curves

Measurement methodologies:

• PACTA (Paris Agreement Capital Transition Assessment) for: Power generation, Automotive, Steel, Cement, Aviation
• PCAF (Partnership for Carbon Accounting Financials) for: Oil & Gas, financed emissions
• IMO framework for: Shipping
• Sustainable Aluminum Finance Framework (RMI) for: Aluminum
• ENCORE tool for: Natural capital risk assessment

Industry collaboration

2024 activities:

• Strategic collaboration agreement with Rocky Mountain Institute (RMI)
• Participation in Center for Climate Aligned Finance (CCAF)
• NZBA working groups
• Cement sector decarbonization working groups
• High Level Expert Group (HLEG) of European Commission (concluded April 2024)

Phase-in and materiality

Climate change (mitigation, adaptation and energy transition) has been determined as material through the double materiality analysis. No phase-in exemptions are claimed for this disclosure.

Policies related to climate change mitigation and adaptation

BBVA has established a comprehensive policy framework to address climate change mitigation and adaptation, integrating these considerations into its sustainability governance and business strategy.

General Sustainability Policy

Policy name: General Sustainability Policy

• Scope: Applies globally across the BBVA Group, covering all geographies where it operates. The policy expressly includes the protection of natural capital and considers biodiversity and natural capital in its relationship with customers.

• Key content/principles:

  • Recognizes the need to protect ecosystem services and natural assets, as well as species and natural ecological processes
  • Considers biodiversity and natural capital in customer relationships
  • Integrates into business and activities the concerns of stakeholders (customers, employees, shareholders and investors, suppliers, regulators and supervisors, and society in general) on social, environmental, diversity, fiscal responsibility, respect for human rights, and prevention of corruption

• Governance: The Board of Directors defines, promotes and monitors the sustainability and climate change strategy. The policy is overseen by the Sustainability Alignment Steering Group (SASG), led by the Global Head of Sustainability & Corporate Investment Banking, with permanent members including global heads of Global Risk Management, Commercial Client Solutions, Strategy & M&A, Regulation & Internal Control, and Finance.

• International standards linkage: The policy aligns with the Paris Agreement objectives and follows recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), guidelines of the Net Zero Banking Alliance (NZBA), and the Glasgow Financial Alliance for Net Zero (GFANZ).

• Monitoring: Progress is monitored through the Sustainability Alignment Steering Group (SASG), which evaluates compliance with alignment objectives and the evolution of the decarbonization strategy of the loan portfolio. The Group has developed internal tools including the Transition Risk Indicator (TRi), Sustainability Client Toolkit, Alignment Management Dashboard, and "What if" Simulator.

Environmental and Social Framework

Policy name: Environmental and Social Framework

• Scope: Applies to customers globally, covering project financing and relationships with customers across all geographies where BBVA operates. Specifically identifies sectors with potential environmental and social impact (mining, agribusiness, energy, infrastructure, and defense).

• Key content/principles:

  • General prohibited activities in relation to biodiversity loss and the fight against deforestation, including:
    • New projects that put at risk UNESCO World Heritage sites, Ramsar wetlands, Partnership for Zero Extinction sites, and IUCN Category I-IV areas
    • New projects involving resettlement or violation of rights of indigenous or vulnerable groups without their free, prior and informed consent
    • New projects involving burning of natural ecosystems for land clearing
    • Restrictions on palm oil farms not certified by the Roundtable for Sustainable Palm Oil (RSPO)
    • Exclusion of new palm oil farm projects in swamps and peat-rich areas
  • Defines thermal coal customers and establishes phase-out targets (2030 for developed countries, 2040 globally)
  • Requires adequate assessment and mitigation of biodiversity risks in financed projects
  • For projects with impacts on critical habitats, requires implementation of biodiversity management plans aligned with IFC Performance Standards

• Governance: The Environmental and Social Framework is reviewed on an ongoing basis. The most recent review was conducted in December 2024 to assess its effectiveness and update it based on best practices, evolution of international standards, and stakeholder expectations.

• International standards linkage: Applies the Equator Principles (EP) for project management, requiring adequate assessment and mitigation of biodiversity risks. Aligned with IFC Performance Standards for projects with impacts on critical habitats.

• Monitoring: Customers included in the scope of the Environmental and Social Framework and Sector Alignment Plans are assessed based on their ESG profile and addressed, where appropriate, through support plans. In 2024, BBVA formalized a procedure for the development and monitoring of sector alignment plans.

Sectoral Transition Plans and Alignment Policies

BBVA has developed sectoral transition plans for 11 high-emission sectors: Oil & Gas, Power generation, Autos, Steel, Cement, Coal, Aviation, Shipping, Aluminum, and Real estate (commercial and residential).

• Scope: These plans apply at the consolidated Group level in all geographies where BBVA operates, except for real estate sector targets which apply only to Spain.

• Key content/principles:

  • Each plan includes detailed sector analysis, assessment of role in decarbonization, identification of inherent risks, response strategies, current portfolio state analysis, and alignment level assessment
  • Business opportunities with existing and new customers are identified, with different appetite levels defined for customers in each sector
  • Intermediate emissions reduction targets set for 2030 for all covered sectors
  • Net zero emissions target by 2050
  • Customer support plans based on tailored actions and strategic dialogue around decarbonization levers of each sector
  • Advisory on design and development of transition plans, monitoring of compliance
  • May include underweighting business growth or orderly exit process when customer progress does not contribute to emission reduction targets

• Governance: The Sustainability Alignment Steering Group (SASG) analyzes and discusses sector alignment plans and their updates, promotes creation and deployment of necessary tools and methodologies, and analyzes best industry practices.

• Public availability: Progress on decarbonization targets is publicly disclosed in the annual Consolidated Non-Financial Information Statement.

• International standards linkage: Targets follow Net Zero Banking Alliance (NZBA) guidelines, Paris Agreement Capital Transition Assessment (PACTA) methodology, IEA Net Zero scenario (IEA_NZE), Institute for Sustainable Futures Sectoral Pathways to Net Zero Emissions (ISF NZ), International Maritime Organization (IMO) Strategy for Shipping, International Aluminum Institute (IAI) Net Zero scenario, Mission Possible Partnership 1.5°C Roadmaps (MPP), and National Integrated Energy and Climate Plan (PNIEC) for real estate in Spain.

• Monitoring: In 2024, BBVA formalized a procedure to develop and monitor customer support plans, which constitute an internal tool to support customers and are a key part of BBVA's contribution to the energy transition. Monitoring includes definition of milestones or objectives, with steps taken to help achieve them.

Global Eco-efficiency Plan

Policy name: Global Eco-efficiency Plan

• Scope: Applies to BBVA's own operations globally, covering direct environmental impacts (Scope 1, 2, and certain Scope 3 categories).

• Key content/principles:

  • Calculation of energy consumption and carbon footprint
  • Reduction of environmental impact through energy efficiency initiatives
  • Implementation of measures to mitigate water and paper consumption
  • Use of electricity from renewable sources
  • Awareness and involvement of employees and other stakeholders
  • Purchase and retirement of carbon credits for Scope 1, 2 and Scope 3 categories 5 (waste generated in operations), 6 (business travel) and 7 (employee commuting) emissions

• Monitoring: The plan includes specific targets for emissions reduction, with regular monitoring and public reporting of progress.

Remuneration and Incentive Policies

BBVA has integrated climate and sustainability objectives into its remuneration system:

• Scope: Applies to all employees, including executive directors and senior management.

• Key content/principles:

  • Annual variable remuneration linked to the promotion of sustainable business for all employees, including executive directors and senior management
  • Incentives linked to sustainable business specific to the commercial network
  • Since 2023, long-term variable remuneration linked to certain decarbonization targets for members of the identified group, including executive directors and senior management

• Governance: Overseen by the Board of Directors through the governance structure for sustainability.

Risk Management Policies

BBVA has incorporated climate and environmental risk management into its risk management framework:

• Scope: Applies globally across all risk management processes, covering physical and transition climate risks.

• Key content/principles:

  • Integration of climate risks into different phases of the risk cycle: identification, assessment, management, reporting
  • Integration into risk appetite framework, credit underwriting circuits, and other relevant areas
  • Risk assessment exercise to determine materiality of risks on different time horizons
  • Scenario analysis and stress testing for climate risks
  • Internal taxonomy of natural capital risks based on impacts and dependencies

• Governance: Risk management is overseen by the Board of Directors and Global Risk Management function, with regular reporting to senior management and corporate bodies.

• International standards linkage: Follows recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) and aligns with European Central Bank (ECB) supervisory expectations.

• Monitoring: Key risk management metrics (KRIs) related to climate change are integrated into internal risk reports. In 2024, an internal risk metrics dashboard was developed making materially relevant information available to all BBVA teams.

Actions and resources in relation to climate change policies

Strategic Roadmap Objectives

BBVA's sustainability strategy has a roadmap with two clear objectives:

1. Promoting sustainable business globally (climate, natural capital, social sphere)

   • Target: €300 billion of sustainable business from 2018 to 2025
   • Achievement: €304 billion as of December 31, 2024 (around €99 billion in 2024)
   • Climate-specific: More than €77 billion channeled in 2024, earmarked for:
     • Electrification of industry
     • Energy efficiency measures
     • Development of renewable projects
     • Promotion of solar self-consumption
     • Transformation of transport and logistics sector
   • Inclusive growth: Around €22 billion of the entire sustainable business channeling by 2024
   • Scope: Own operations and downstream value chain (customer financing)
   • Time horizon: 2018-2025 (target period)

2. Sectoral decarbonization plans

   • Intermediate targets: Year 2030 for oil and gas, power generation, automobiles, cement, steel, coal, aviation, shipping, aluminum, and real estate (commercial and residential in Spain)
   • Scope: Downstream value chain (financed emissions)
   • Time horizon: Medium term (2030)

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Enterprise Customer Actions (€34 billion in 2024)

Corporate financing and transactional banking activity - €32 billion channeled in 2024

• Climate change: €25 billion
• Inclusive growth: €7 billion
• Scope: Downstream value chain
• Time horizon: Short-term (2024)

Financing Sustainable Projects (€4 billion total)

1. Renewable energy projects - €2 billion

   • Mainly solar and wind projects
   • Key geographies: United States (over half of total mobilization)
   • Notable examples:
     • Offshore wind farm financing (Virginia coast, USA)
     • Solar photovoltaic project and energy storage battery system (Texas, USA)
   • Scope: Downstream value chain

2. New clean technology projects - €542 million

   • Carbon capture and storage projects (United Kingdom)
   • Giga battery factory (Hungary)
   • National network of 2,900 electric vehicle charging points (Italy)
   • Portfolio of energy transition infrastructures (Italy)
   • Scope: Downstream value chain

3. Other areas including natural capital - €1 billion

   • Wastewater treatment plant expansion (Mexico)
   • Scope: Downstream value chain

Strategic Solutions and Initiatives (2024)

1. Confirming product

   • Evaluation and ranking of BBVA customers' suppliers based on sustainability criteria
   • Better discounts on invoices for higher sustainability scores
   • Outcome: Lever for corporate customers to improve value chain sustainability
   • Scope: Downstream value chain

2. Financing of new clean technologies

   • Internal development of specialized knowledge for:
     • Batteries (transport and energy storage)
     • Green hydrogen
     • Biofuels
   • Outcome: Accompanying customers in transformation of production models
   • Scope: Downstream value chain
   • Non-financial resources: Specialized knowledge development

3. Expansion in attractive markets

   • Strengthened presence in Brazil
   • Created sustainability center in Houston (energy sector hub with 4,700+ energy companies)
   • Outcome: Accompanying companies in transformation plans
   • Scope: Downstream value chain
   • Non-financial resources: Dedicated sustainability center

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Retail Customer Actions

Customized Digital Solutions for Mass Consumption and Energy Efficiency (~€1 billion)

1. Data analytics for energy savings

   • Offering customers opportunities to save energy in homes and transportation
   • Outcome: Encourage sustainable practices, reduce CO2 emissions
   • Scope: Downstream value chain

2. 2024 Financing volumes:

   • Solar panels: ~€44 million
   • Energy efficiency measures for households: ~€56 million
   • Hybrid or electric vehicles: €864 million
   • Geographies: All geographies
   • Scope: Downstream value chain

3. BBVA Spain - Household solutions (>16,000 operations financed in 2024)

   • Comprehensive set of solutions for:
     • Self-consumption options
     • Aerothermal energy
     • Windows and other sustainable technologies
   • New service: Energy-saving advisory service with tailored energy transition plans
   • Financed refurbishment of residential communities and home renovations
   • Scope: Downstream value chain
   • Outcome: >16,000 operations financed

4. Automotive sector solutions

   • One-stop-shop for cars (Spain): Financing/leasing for 200+ electric vehicle models via mobile app
   • Fleet advisory services for SMEs and companies (electric/hybrid mobility solutions)
   • Scope: Downstream value chain

Mortgages for High-Energy-Rated Homes

• Volume: €1 billion channeled in 2024
• Geographies: All geographies except Argentina
• Scope: Downstream value chain

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Sectoral Decarbonization Actions

Power Generation Sector

2030 Target: 46% reduction in carbon emissions intensity (2020 baseline)

• Baseline (2020): 343 g CO2/kWh
• 2024 Achievement: 115 g CO2/kWh (67% below 2020, 67% below market average)
• Portfolio growth: 17% vs 2023, 31% vs 2020

Actions with customers:

1. Support to customers investing in renewable energies
   • Renewable energy financing: €4,828 million (end of 2024)
   • Growth: 75% increase vs 2023
2. Active engagement with customers requiring advice in energy transition strategies
3. Focus on growth with customers actively managing transition
   • Performance metric: 86% of loan portfolio with customers actively managing transition
   • Scope: Downstream value chain
   • Time horizon: Short to medium term (to 2030)

Automobile Sector

2030 Target: 46% reduction in CO2 emissions intensity (2020 baseline), measured in g CO2/v-km

• Baseline (2020): 203 g CO2/v-km
• 2024 Achievement: 165 g CO2/v-km (19% decrease vs 2020, 4% decrease vs 2023)

Actions with customers:

1. Incorporation of new customers with lower intensity than portfolio average and below market average
2. Support for customers' progress in transition with progressive increase in electric and plug-in hybrid-electric vehicle penetration

• Scope: Downstream value chain
• Time horizon: Medium term (to 2030)

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Natural Capital Actions (2024)

Water

1. Water Footprint Loan solutions

   • Continued provision to corporate and enterprise customers globally (inspired by 2022 syndicated credit line)
   • Scope: Downstream value chain

2. BBVA Mexico Sustainability Challenge

   • Focus: Preservation, use and sanitation of water
   • Objective: Develop scientific/technological research projects and ventures for water challenges with high social impact
   • Scope: Downstream value chain

3. Blue Economy product expansion:

   • Spain: Partnership with Veolia for voluntary water footprint measurement/management
     • Target: Customers in sectors with greatest water impact
     • Promotion of efficiency measures financing and nature-based solutions for water-positive outcomes
   • Colombia: Second issue of blue bond for water management, plastic pollution reduction, marine ecosystem restoration
   • Mexico: Book runner for first blue bond (Desarrollos Hidráulicos de Cancún) focused on hydraulic infrastructure and drinking water for local communities
   • Scope: Downstream value chain

4. Water footprint measurement

   • Began measuring group's water footprint at global level
   • First analysis of water recovery projects in high water stress areas (Spain)
   • Scope: Own operations

Biodiversity and Soil

1. Biodiversity bond (BBVA Colombia with IFC)

   • Amount: Up to $70 million issued by BBVA Colombia
   • Use of proceeds:
     • Reforestation
     • Regeneration of natural forests on degraded lands
     • Conservation/rehabilitation of mangroves
     • Climate-smart agriculture
     • Restoration of wildlife habitats
   • Scope: Downstream value chain

2. Agricultural customer transition tools

   • Development of internal tools to evaluate transition of agricultural customers in Mexico and Latin America
   • Financing of efficient and precision irrigation solutions
   • Practices favoring emissions reduction and regenerative agriculture
   • Scope: Downstream value chain
   • Non-financial resources: Internal evaluation tools

Waste and Pollution

1. Circular economy initiatives (Spain, started 2024)

   • Promotion of leasing plans with maintenance solutions
   • Identified investment needs in waste management value chain of extended producer responsibility systems (packaging sectors)
   • Focus: Regulatory changes towards circular and plastic-free economy
   • Scope: Downstream value chain

2. CIB sustainable finance framework structuring

   • Agent role for €600 million bond by Spanish company specialized in citizen services
   • Use of proceeds: Environmental activities including pollution prevention/control, clean transportation, circular economy
   • Scope: Downstream value chain

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Own Operations - Energy and Emissions Management

Carbon Neutrality Actions

BBVA purchases and retires carbon credits equivalent to CO2 emissions from scopes 1, 2 and categories 5, 6, 7 of scope 3 (except Romania and Venezuela geographies)

Quality requirements:

• Certification under highest standards: VCS, Gold Standard, ARC, CAR, Plan Vivo
• From 2023: Projects must be CO2 absorption or capture projects
• Internal Voluntary Carbon Market standard based on best practices

2024 Carbon Credit Purchases:

• Two forest restoration projects in Mexico (X-Pichil and Santa Elena)
• Purchase made through BBVA's carbon credits trading desk

Credits Retired in 2024 (for 2023 footprint):

Carbon Credits Performance (2023-2024):

Expected Credits to be Retired in 2025: 212,787 tCO2eq

• Credits pending for 2023 emissions
• Total credits for 2024 emissions
• Long-term agreement negotiated by BBVA Mexico (4-year purchase agreement with local supplier)

Scope: Own operations Time horizon: Ongoing (annual)

Internal Carbon Price Mechanism

• Cost of annual carbon credit purchase assumed locally in different Group geographies (including Holding) based on individual carbon footprint
• Creates internal carbon price mechanism and local emission reduction incentives
• Each unit includes budget item for carbon credit purchase based on:
  • Estimated carbon footprint (Scope 1, 2, and categories 5, 6, 7 of Scope 3)
  • Estimated market price of CO2 capture carbon credit
• 2024 Internal carbon price: €32/ton (based on voluntary carbon market growth expectations)
• Geographies covered: Argentina, Colombia, Spain (including Holding), Mexico, Peru, Portugal, Turkey, Netherlands, Uruguay
• Scope: Own operations
• Resources: Financial (budget allocation per geography)
• Outcome: Local incentives for emission reduction

Carbon Market Development Initiatives

1. Regulated markets: Participation in EU ETS government auctions, offering products to cover customers' EU ETS obligations
2. Voluntary carbon markets: Active customer engagement; investor in Carbonplace (carbon credit trading platform)
3. Knowledge sharing: Active participation in webinars and conferences (internal/external) to promote carbon markets and help customers manage risks/opportunities
4. Advisory roles: Present in Advisory Board of European Energy Exchange (EEX) Global Carbon Index Family and LIFE COASE project (co-financed by Life Program of European Commission)

• Scope: Own operations and downstream value chain
• Non-financial resources: Partnerships (Carbonplace investment), advisory participation, knowledge platforms

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Investment Products - BBVA Asset Management

BBVA AM manages customer assets with its own Sustainability Plan aligned with Group strategy, based on:

1. ESG integration model

   • Develops internal rating for portfolio assets
   • Used for companies, governments, and collective investment institutions
   • Coverage: Significant percentage of BBVA AM's investment universe
   • Scope: Downstream value chain
   • Non-financial resources: Internal rating system

2. Exclusion policies

   • Exclusions to comply with international minimum guarantees in social, labor, and human rights
   • Governed by Exclusions Rule
   • Scope: Downstream value chain

Portfolio Performance:

• 37% lower emissions intensity than base year 2020
• 67% lower than market average (per Asset Impact data)
• Portfolio growth: 17% vs 2023, 31% vs 2020
• Strong support for clean energy

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Governance and Incentive Alignment

Long-term Incentive Indicators (2024 Annual Variable Remuneration for Identified Staff, measured to 2027):

Decarbonization indicator: Measures degree of compliance with decarbonization objectives of sectors with published specific objectives

• Link to strategy: Directly related to helping customers transition towards sustainable future and climate action objectives
• Time horizon: Multi-year measurement period to 2027
• Resources: Financial (executive remuneration tied to decarbonization performance)

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Key Performance Indicators and Outcomes

Overall Sustainable Business:

• 2018-2024 cumulative: €304 billion
• 2024: €99 billion
• Climate change 2024: €77 billion

Customer Engagement:

• Power generation: 86% of loan portfolio with customers actively managing transition
• Renewable energy financing: €4,828 million (75% growth vs 2023)

Emissions Reductions:

• Power generation intensity: 115 g CO2/kWh (67% below 2020)
• Auto sector intensity: 165 g CO2/v-km (19% below 2020)

Retail Solutions:

• Solar panel financing: €44 million
• Energy efficiency: €56 million
• Electric/hybrid vehicles: €864 million
• Household sustainability operations: >16,000 financed
• High-energy-rated mortgages: €1 billion

Targets related to climate change mitigation and adaptation

Overview

BBVA has set intermediate decarbonization targets for 2030, framed within Net Zero targets to 2050. The scope of these intermediate targets has been established considering the assets included, the metrics used to measure them, the initial level and the 2030 target.

Portfolio Decarbonization Targets by Sector

Thermal Coal Phase-Out Target

Target: Eliminate exposure to thermal coal customers by:

• 2030 in developed countries
• 2040 globally

Definition: Customers belonging to business groups with ≥5% revenues from thermal coal mining OR ≥5% installed capacity for thermal coal-fired power generation.

Baseline Year: 2022

Progress (December 2024):

• Total thermal coal portfolio: €1,578 million
• 8% reduction vs. 2022
• Customers with limited transition expectations: €152 million (63% reduction vs. 2022; 32% reduction in last year)
• 90% of financing portfolio with customers expected to manage transition in time

BBVA Asset Management (BBVA AM) Targets

Target: Intermediate decarbonization targets for portfolios to 2030, within Net Zero targets to 2050.

Scope: Assets under management

2024 Performance:

• Corporate portfolio: good performance in degree of alignment and emissions
• EU government debt portfolio: good performance in degree of alignment; overall performance affected by divergent country behavior

Own Operations Target

Target: 100% renewable electricity by 2030

Scope: BBVA's own operations globally

Notes on Methodology

• Power generation, Autos, Cement, Steel sectors use PACTA methodology with IEA_NZE and ISF NZ scenarios (2021 targets)
• Oil & Gas uses PCAF methodology for absolute Scope 1+2+3 upstream emissions (2022 target)
• Aviation uses IEA_NZE scenario, measured in gCO2/PKM adjusted for belly freight factor (2023 target)
• Shipping uses IMO 2023 decarbonization trajectory with minimum and striving ambition levels (2023 target)
• Commercial Real Estate (Spain) uses CRREM methodology and PNIEC scenario (2024 target)
• Aluminum uses SAFF (RMI methodology) with IAI and MPP 1.5°C roadmaps (2024 target)
• Thermal coal phase-out follows Environmental and Social Framework definitions (2021 target)

Important Disclaimer: Achievement and progressive progress of decarbonization objectives will depend to a large extent on actions of third parties (customers, governments, other stakeholders) and may be materially affected by such actions or lack thereof, as well as by other exogenous factors (new technological and regulatory developments, military conflicts, evolution of climate and energy crises, etc.). Consequently, these objectives may be subject to future revisions.

Energy consumption and mix

Energy consumption by source (BBVA Group)

Scope and methodology: The data shown for 2024 include Spain, Mexico, Turkey, Peru, Colombia, Argentina, Uruguay, Portugal, Venezuela, Romania and the Netherlands. Certain geographical areas (Chile, Bolivia, Switzerland, United States, Brazil and BBVA branches outside Spain) and certain BBVA Group companies are not included in the perimeter. The perimeter not included represents 2.6% of the BBVA Group's total number of employees. For 2024, estimates are used for data not available at the closing date of the report. The 2023 data differ from those published in the previous Consolidated Non-Financial Information Statement because estimates have been replaced with actual consumption data.

Renewable electricity: 97% of the electricity consumed by BBVA is renewable. Of the total renewable electricity, 52.7% is purchased via IRECs, 41.5% via PPAs, 5.6% through guarantees of origin and 0.2% comes from self-consumption facilities. The electricity consumed is 100% renewable in Colombia, Spain, Mexico, Peru, Turkey, Portugal and Uruguay, 92% in the Netherlands, 79% in Venezuela, 74% in Argentina and 29% in Romania.

No energy intensity metric per revenue disclosed.

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

Integration of climate risk into expected credit losses

In 2024, the Group has begun incorporating climate risk factors into the process of calculating expected credit losses for loan portfolios through statistical models that consider both potential damage to collateral and the effect on customers' ability to pay due to physical and transition risks in the Group's main geographies (Spain, Mexico and Turkey).

In particular, transition risk has been assessed using an approach that allows capturing its effect on the probability of default (PD) and the impact on customers' provisions in Stage 2 as well as a transfer of exposures from Stage 1 to Stage 2 for corporate portfolios. For physical risk, an approach has been used that would allow estimating the potential deterioration in the value of collateral (real estate assets in corporate and retail portfolios) and its effect on LGD.

As of December 31, 2024, the impact recorded for these risks was not significant. The Group will continue working to incorporate in these models the information available from time to time.

Time horizons for climate risk assessment

The climate change risk assessment process runs in parallel with the Group's overall risk assessment, but with a broader time frame. The analysis is carried out for:

• Short-term (CP): up to 3 years
• Medium-term (MP): from 3 years to 5 years
• Long-term (LP): more than 5 years

This enables a comprehensive consideration of the expected impacts as well as an alignment with the EBA's requirements.

Climate risk assessment methodology

In 2024, progress continued toward a quantitative approach to developing the Climate Risk Assessment, defining a series of metrics that have allowed for an objective assessment of risk levels in both transition risk and physical risk.

In the case of physical risk, the Group has assessed potential impacts for each of the hazards analyzed, as well as other environmental risks, specifically analyzing water stress scenarios. In the case of credit risk, these assessments are based on:

• NGFS transition risk scenarios: "Net Zero, Delayed Transition" and "Current Policies"
• Physical risk scenarios: SSP2-4.5 and SSP3-7.0

Additionally, progress has been made in estimating the impact of both transition risk and physical risk on BBVA's strategy and business model. The results are submitted to the highest executive risk committee (GRMC) as well as to the corporate bodies, as this management is integrated into key corporate processes such as the Risk Appetite Framework and the Internal Capital Self-Assessment (ICAAP).

Climate risk assessment results 2024

The conclusions of the risk assessment for 2024 indicate that the main risks emerge in credit portfolios in the medium and long term. In particular, the transition risk manifests itself earlier in Spain due to the faster adoption of decarbonization policies in Europe, while emerging areas present less regulatory pressure.

In the long term, the primary driver of credit risk lies in the technological investments that companies must make to achieve decarbonization.

Regarding the impact of physical risk on credit portfolios, the higher frequency/severity of extreme weather events and structural changes in weather patterns explains the deterioration shown in the medium-long term assessment.

Risk levels by geography and risk type

CLIMATE CHANGE RISK ASSESSMENT 2024

Legend:

• Low risk
• Medium-low risk
• Medium risk
• Medium-high risk
• High risk
• Not applicable

Impact by risk type and time horizon

The impact of transition risk on liquidity risk is low due to the stability of the retail deposit base and the high asset quality of the liquid asset cushion.

Market risk is also low due to the diversification of the equity portfolio and low exposure to sectors sensitive to transition risk in the fixed income portfolio.

Regarding operational risk, there is a difference in perceived risk in Spain (medium-low in the short term and medium in the medium and long term) and in the rest of the geographical areas (low) in transition risk, and in the case of physical risk, low for all the geographical areas evaluated.

Physical risk hazards identified

During 2024, BBVA has developed an internal physical risk taxonomy whose main objective is to identify the economic activities most exposed to physical climate risks and the most relevant natural hazards in the main geographies where BBVA has a presence, as well as explaining the transmission channels of physical risks to prudential financial risks.

It is identified that the most relevant natural hazards in the geographies where BBVA operates are:

• Tropical cyclone
• Heat wave
• Forest fire
• River and coastal flooding
• Drought

Policies related to own workforce

BBVA has disclosed several policies relevant to its own workforce under ESRS S1-1:

General Sustainability Policy

• Scope: All BBVA Group entities and their relations with employees, customers, shareholders, suppliers and communities
• Key principles: Ensures compliance with all applicable laws and respect for internationally recognized human rights in all relations with employees
• International standards alignment: Aligned with the International Bill of Human Rights, OECD Guidelines for Multinational Business, and fundamental conventions of the International Labor Organization
• Approval and oversight: Board of Directors

Code of Conduct

• Scope: All members of the BBVA Group
• Key principles: Establishes behavioral guidelines to align employee conduct with the Group's values; expressly prohibits any type of discrimination based on sex, race, age or sexual condition; addresses customer conduct, leadership style and harassment, management of conflicts of interest and relations with suppliers
• Approval and oversight: Board of Directors (updated July 2024)
• Public availability: Available on corporate intranet and corporate website (www.bbva.com)
• Monitoring: Monitored by the Group's Compliance area; has its own communication and whistleblowing channel; completion of mandatory corporate course every three years (92,621 employees completed by December 2024, with completion rates exceeding 98% in most geographies)

Corporate Culture Guide

• Scope: Applies to most BBVA Group entities (96.4% of the workforce); applicable to all group companies except specific entities in Bolivia, Colombia, Spain, Mexico, Peru, Portugal and Uruguay
• Key principles: Establishes framework for fostering and consolidating a robust corporate culture aligned with BBVA's values; based on BBVA's internal Code of Conduct
• Approval and oversight: Formalized in 2024; Global Head of Culture & Engagement (reports to Global Head of Talent & Culture) responsible for implementation and monitoring
• Public availability: Available on internal Culture and Commitment portal in Spanish and English
• Monitoring: Annual employee engagement survey managed by Gallup; results communicated to managers who organize team meetings and define action plans (88% of managers recorded action plans in 2024); Values Index scored 4.66 out of 5 in 2024

Diversity Guidelines

• Scope: BBVA Group employees
• Key principles: Covers five lines of work: gender diversity, LGBTIQ+ diversity, generational diversity, people with disabilities, and cultural and ethnic diversity
• Public availability: Communicated through newsletter, Intranet, Diversity Days and training on Campus (also available in English)
• Governance: Diversity teams in different areas and geographies responsible for ensuring compliance and proposing updates
• Monitoring: Specific question on diversity in Gallup engagement survey (scored 4.75 out of 5 in 2024); biweekly meetings of Community of Practice

Equality Plan

• Scope: Spain
• Approval and oversight: Signed in 2023 with employee representatives
• Key principles: Addresses equal opportunities and gender equality

Prevention and Action Protocols Against Sexual Harassment

• Scope: Main geographies where BBVA is present
• Key principles: Expressly reject any behavior of a sexual nature or connotation that attacks the dignity of a person; serves as means of preventing, detecting, correcting and sanctioning such conduct

Customer Conduct and Product Governance Policy

• Scope: All BBVA Group entities when they design or distribute products to customers, provide services or manage collective investment vehicles
• Key principles: Establishes principles for appropriate and responsible offering of products and services, transparency, managing conflicts of interest, financial inclusion, customer accessibility, prompt resolution of complaints, adequate training of personnel
• Approval and oversight: Board of Directors (approved February 9, 2022)
• International standards alignment: Aligned with European regulations including Directive 2014/65/EU (MiFID), Directive 2016/97/EU (IDD), and EBA Guidelines
• Public availability: Published on BBVA Group's internal website
• Governance: Responsibility for application falls on Global Head of Regulation & Internal Control area
• Monitoring: Reviewed annually (2024 review conducted with no modifications)

Data Protection Policy and Standard

• Scope: BBVA Group globally
• Key principles: Establishes the Group's commitment to protection of personal data as a fundamental right; defines governance structure, roles, responsibilities and data protection principles
• Approval and oversight: Board of Directors
• Public availability: Available on corporate intranet for all employees; summary published on shareholders' website
• Monitoring: Reviewed annually; monitored through data protection indicators tracking compliance, claims, rights exercised, compulsory training, and audit recommendations

General Anti-corruption Policy

• Scope: All companies in which the Group has a direct or indirect stake of more than 50%; mandatory for employees, Senior Management and directors
• Key principles: Establishes framework to prevent, detect and promote communication of corrupt practices; provides guidelines for behavior in sensitive activities; aligned with section 5.3 of Code of Conduct
• Approval and oversight: Board of Directors (updated version approved in 2023)
• International standards alignment: Aligned with United Nations Convention against Corruption and ISO recommendations
• Public availability: Communicated to all employees and members of governing bodies; public statement summarizing content on shareholders and investors website
• Monitoring: Implemented through specific procedures including Rules for Acquiring Goods and Arranging Services, Corporate Rules on Gifts and Events, regulations on donations and commercial sponsorships; corporate tool for recording gifts and events in most geographies; 175,303 transactions evaluated in 2024

General Policy on Anti-Money Laundering and Financing of Terrorism (AML/FT)

• Scope: All BBVA Group branches and subsidiaries
• Key principles: Integrated into corporate culture; provides standard framework for risk management across the Group
• Approval and oversight: Board of Directors
• International standards alignment: Integrates local regulations, international best practices of financial sector, and recommendations from Financial Action Task Force (FATF)
• Monitoring: Annual risk analyses; specific program launched in 2024 covering main geographies; case manager with AI capabilities being developed

Taking action on material impacts on own workforce

Overview

BBVA promotes employee initiatives aligned with three strategic principles for people management. In 2024, these initiatives contributed to an employee engagement score of 4.46 in the Gallup survey (+0.03 compared to 2023), ranking in the 78th percentile among all participating companies.

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Actions under strategic principle: A culture and values of inspiration and connection

Values Day 2024

• Description: Seventh edition celebrated in October 2024 under the slogan "Know, Understand and Connect", focused on BBVA's first value "The Customer comes first" and the core behavior "We are empathetic"
• Participation: More than 82,000 unique users participated in activities via the application
• Scope: Own workforce (global)
• Time horizon: Short-term (2024)

Global Volunteering Plan 2024

• Description: Global volunteering initiative across the Group
• Participation: 13,500 employees from across the Group
• Scope: Own workforce (global)
• Time horizon: Short-term (2024)
• Link: Detailed in "Volunteer work" section in chapter "Contribution to society"

Solidarity Initiative for Valencia Flash Floods

• Description: Voluntary initiative launched for employees and non-employees to make donations for those affected by flash floods in the Valencian Community in October 2024
• Scope: Own workforce and external stakeholders
• Time horizon: Short-term (2024)

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Actions under strategic principle: A winning team in our businesses

Management Capabilities Assessment and Development Program

• Description: Assessment of more than 18,000 managers across the Group in February 2024 covering their capabilities and NPS assessment by their teams; used as starting point for personalized development plans
• Outcome: 68% of managers have a score equal to or greater than 75 out of 100 (data without Turkey)
• Scope: Own workforce (global management)
• Time horizon: Short-term (2024)

New Talent Acquisition and Mobility Model

• Description: Global model implemented in 2024 to attract the best talent and mobilize talent internally at BBVA, improving experience of stakeholders (candidates, managers) and reducing management times
• Scope: Own workforce (global)
• Time horizon: Short-term (2024)

Generative AI Training Program

• Description: Training of employees in Generative AI capabilities
• Participation: More than 2,600 employees trained (data without Turkey)
• Scope: Own workforce (global)
• Time horizon: Short-term (2024)

Sustainability Skills Training for Business Areas

• Description: Training employees in sustainability skills to support customers in the transition of their businesses
• Participation: More than 35,000 employees of business areas trained
• Scope: Own workforce (business areas)
• Time horizon: Short-term (2024)

Reorganization of Global Customer Area

• Description: BBVA has reorganized its global customer area into corporate and retail segments as a key element in the transformation of customer service and experience
• Scope: Own operations (organizational structure)
• Time horizon: Short-term (2024)

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Actions under strategic principle: The best environment for our talent

Women in Management Target Achievement

• Description: Initiative to increase women representation in management team
• Outcome: Women account for 35.4% of BBVA's management team, exceeding the target of 35% set in 2022; target increased to 36.8% for 2026
• Scope: Own workforce (management level)
• Time horizon: Medium-term (target for 2026)
• Link: Relates to equal opportunities policy and targets

Pension Plans Life Cycle Management Model (Spain)

• Description: Model for managing pension plans based on the employee's life cycle to promote financial well-being
• Scope: Own workforce (Spain)
• Time horizon: Short-term (2024)

Comprehensive Health Program (Mexico)

• Description: Program involving traditional medical examinations plus comprehensive health survey assessing eating habits, sleep quality, mental health and smoking
• Participation: Around 12,000 employees
• Scope: Own workforce (Mexico)
• Time horizon: Short-term (2024)

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Employee Communication and Support Infrastructure

Employee Support Service (SAE)

• Description: Service available to employees at main banks and companies in countries where the Group operates (Spain, Mexico, Turkey, Argentina, Colombia and Peru), responding to operational, administrative and management queries; run by Group's own staff and supported by market-based technological solution tracking query status (Turkey has specific internal tool with similar functionalities)
• Scope: Own workforce (multiple geographies)
• Time horizon: Ongoing

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Note on Resource Allocation

The document includes a footnote stating: "Information corresponding to the management of resources regarding own employees and consumers and end users referred to in the ESRS S1-4.37, S4-4.30, as well as the information required by the ESRS E1-8 63, has been considered confidential or sensitive."

Characteristics of non-employees in the undertaking's own workforce

Self-employed workers in EU Taxonomy reporting

BBVA identifies self-employed workers in its EU Taxonomy disclosure methodology. According to the reporting methodology:

Methodology note: Exposure to individuals includes self-employed workers, in which case the activity code (NACE) is reviewed to determine eligibility. The rest of the exposure corresponding to the individual segment is reviewed for the use of funds to be considered eligible, for example, in the case of housing loans.

Limited disclosure

BBVA's sustainability statement does not provide comprehensive quantitative data on non-employee workers (contractors, agency workers, self-employed) in its own workforce beyond the reference to self-employed workers in the context of EU Taxonomy eligibility assessment.

The statement mentions that BBVA "supported SMEs and the self-employed with more than 715,000 loans to help them grow their business" in 2024, but this refers to clients/customers rather than workers in BBVA's own workforce.

No specific data is disclosed regarding:

• Total number of non-employee workers in own workforce
• Breakdown by type (contractors, agency workers, self-employed)
• Headcount vs FTE methodology
• Multi-year comparisons of non-employee workforce
• Gender or geographical breakdown of non-employees

Collective bargaining coverage and social dialogue

Overall collective bargaining coverage

At the Group, 43% of workers are subject to the provisions of the various collective agreements and conventions, while the remaining 57% are subject to the conditions agreed with the workers themselves.

Country-specific collective bargaining coverage

Spain:

• 100% of the Group's employees in Spain (with the exception of Senior Management) are subject to the provisions of sector-specific collective agreements, which are sometimes supplemented by company-level collective agreements.
• Workers' representatives are elected every four years by personal, free, direct and secret suffrage.

Mexico and Peru:

• The Collective Labor Agreement regulates the working conditions of workers who freely decide to unionize.
• Non-unionized workers are regulated in individual employment contracts and internal company policies.

Colombia:

• Two types of collective agreements regulate working conditions of all bank employees:
  • Collective Agreement: applies to employees who freely decide to join a union
  • Collective Pact: applies to non-unionized employees
• Both agreements run for three years.

Argentina, Uruguay and Venezuela:

• Collective agreement applies to 100% of the workforce (with the exception of members of Senior Management) regardless of whether they are unionized or not.
• In Uruguay, a collective agreement negotiation process was carried out in 2024.

Portugal:

• Collective agreement applies to 100% of the BBVA Portugal workforce.
• At BBVA Institución Financiera CR, working conditions are applied in accordance with employment contracts and internal policy.

Turkey, United States, Chile, Switzerland and Bolivia:

• No union representatives.
• Working conditions applied according to employment contracts and internal policy.

Collective bargaining coverage and social dialogue table

Data coverage note

The information referred to in this chapter covers companies that represent 98.0% of the Group's official workforce, as it does not include the companies BBVA Agencia Insurances Colombia, BBVA Insurances Grales Colombia, BBVA Valores Colombia, Openpay Colombia, Movistar Consumer Finance Colombia, SAS, BBVA Red Exterior de oficinas, BBVA Brasil, BCO. Investimento, BBVA Holding Chile, SA, BBVA Foundation Mexico, AC, Distrito Castellana Norte (DCN), Garantibank International NV, Garanti Bank SA (Romania), Ralfi IFN SA, Motoractive IFN SA, Garanti Bank G, Motoractive Multiservices SRL, Garanti Kultur / SALT.

Diversity metrics

Gender split at top management level

Board of Directors and Senior Management by gender (2024 and 2023):

Percentage representation of women (BBVA Group):

Age band distribution of total workforce

Employee distribution by age stages and geographic area (BBVA Group, Number):

Distribution by professional category, age bracket and geographical area (percentage %)

2024 breakdown:

2023 breakdown:

Note: For executive directors, the breakdown is included in both Board of Directors and Senior Management calculations. The management team excludes BBVA Senior Management for certain breakdowns and includes the highest range of the Group's management.

Social protection

Post-employment benefits

BBVA provides post-employment benefits through both defined benefit and defined contribution plans covering retirement, death, and disability contingencies.

Defined benefit plans: Some Group entities maintain pension commitments with employees who have already retired or taken early retirement, certain closed groups of active employees still accruing defined benefit pensions, and in-service death and disability benefits provided to most active employees. These commitments are covered by insurance contracts, pension funds and internal provisions.

Defined contribution plans: The majority of pension commitments are covered through defined contribution plans where the employer's obligations are discharged by contributions to the fund.

Defined benefit obligations by country (2024)

Death and disability coverage

For in-service death and disability benefits provided to most active employees, the Group pays the required premiums to fully insure the related liability.

Executive director coverage (2024):

Senior Management coverage (2024): Remuneration in kind including insurance premiums totaling €603 thousand collectively paid to members of Senior Management.

Parental leave

BBVA Group family leave usage (2024):

Note: Family leave includes paternity and maternity leave for birth and adoption of children.

Enhanced parental leave provisions by country:

• Spain (BBVA, S.A.): BBVA supplements economic benefits up to 100% of usual salary during maternity or paternity leave. Twenty-two days' leave available in event of birth or adoption of a disabled child.

• Mexico: Parental leave extended by 20 working days for fathers and 28 for mothers. In cases of adoption, extended by 70 days for mothers and 30 for fathers.

• Colombia: Parental leave extended by 10 working days.

• Turkey (Garanti Bank): Paternity leave extended by 5 additional paid days, in addition to 5 statutory days.

• Peru: Paternity leave extended by 20 calendar days.

• Argentina: Paternity leave extended by 30 calendar days. In cases of premature birth, mother entitled to paid leave for same number of days that birth occurred early. In event of birth or adoption of disabled child, paternity and maternity leave extended by 60 calendar days.

• Switzerland: Paternity leave extended by 10 working days.

Health and safety representation

Percentage of Group employees represented on health and safety committees: 99.8%

Work-related incidents (2024)

Sickness and disability benefits

Amounts reimbursed by the state Social Security or other welfare entities in respect of employee illness are deducted from personnel expenses.

Additional benefits

BBVA offers employees the possibility of enjoying certain permits to care for family members for health reasons, with varying degrees of coverage depending on local legislation and public systems. Spain, Mexico, Colombia, Argentina, Peru, Uruguay, Venezuela, Switzerland and Portugal have a range of licenses/leaves with different levels of remuneration, as well as specific financial aid.

Persons with disabilities

Overall metrics

BBVA reported 1,046 employees with disabilities in 2024, representing 0.83% of the official workforce. This represents a 17% increase compared to 2023, when there were 891 employees with disabilities.

Integration approach

BBVA has developed a comprehensive plan for the integration of people with disabilities that rests on three pillars: awareness, accessibility and employability.

Country-specific initiatives

Mexico: Seven job fairs were organized throughout 2024 specifically for the hiring of people with disabilities. More than 1,500 candidates were registered, of whom 124 were hired in 2024.

Methodology

No specific methodology or definition regarding self-identification, official registration, or country exclusions is disclosed in the excerpts provided.

Training and skills development metrics

Average training hours per employee

Overall training hours per employee: 53.4 hours (2024), 49.3 hours (2023)

Average training hours by gender

Note: Data includes the Group's total workforce at the end of the year, with access to the training platform. The management team includes the highest level of management in the Group.

Training data by professional category and gender (2024)

Training data by professional category and gender (2023)

Performance and career development reviews

Performance evaluation of employees by gender (BBVA Group, percentage %)

Note: Data corresponding to evaluations according to the Professional Development Model in the companies in which it is implemented, divided by the number of employees at the end of the year. Of the total workforce at the end of the year, the figures are 89% for men and 91% for women in 2024 and 89% for men and 91% for women in 2023. Performance evaluations according to other models have not been included.

Investment in training

Basic training data (BBVA Group)

Note: Investment in training per employee ratio calculated considering the total workforce of the Group at the end of each financial year. Hours of training per employee ratio calculated by dividing the total training hours for the entire year by the Group's total workforce with access to the training platform at the end of the year.

Additional training information

• Online training accounts for over 59.3% of total training hours (data without Turkey)
• More than 35,000 business employees trained in sustainability (over 83,000 hours)
• More than 400 employees trained in specialized cybersecurity courses
• More than 74,000 employees received generic security training
• 66% of group managers completed at least the access level of "Lidera" program in 2024 (data without Turkey)
• 551 managers completed Leadership Development Program, Polaris and Neuroleadership Program
• Average progress of personalized growth plans is 51% as of December 2024 (data without Turkey)

Health and safety metrics

Coverage of health and safety management system

99.8% of Group employees are represented on health and safety committees.

The occupational risk prevention model complies with OSHAS 18001:2007 standard. Some geographies are certified according to ISO 45001 (e.g., Argentina), while others such as Spain are in the process of certification.

Work-related injuries by gender

Methodology notes:

• Frequency rate: accidents per million hours worked (No. of accidents with medical leave × 1,000,000 / No. of hours worked)
• Severity rate: days lost per 1,000 hours worked (No. of days lost × 1,000 / No. of hours worked)
• Incidence rate: accidents per thousand workers (No. of accidents with sick leave × 1,000 / number of workers)
• In itinere accidents, relapses not considered
• Number of hours worked calculated as average number of employees × hours per year
• 2023 figures recalculated to exclude in itinere accidents in Mexico

Work-related fatalities and occupational illnesses

Absenteeism

Absenteeism rate calculation: (Number of calendar days lost due to illness -except maternity- and occupational accidents (including in itinere) / divided by 365 × number of employees) × 100

Scope

H&S information covers 97.2% of official workforce. Excluded entities are listed in footnote 76 and include smaller operations such as AFP Previsión, BBVA Portugal, BBVA Brasil, Openpay entities, and various other subsidiaries.

Work-life balance metrics

Family-related leave

WORK-LIFE BALANCE (BBVA GROUP)

Notes: (1) Family leave includes paternity and maternity leave for birth and adoption of children. (2) The data is provided as a number and not as a percentage, since the percentage is not significant. (3) In the case of the USA, 100% of the workforce is eligible but there is a minimum length of service of 1 year required.

Maternity and paternity-related leave policies

Spain (BBVA, S.A.):

• BBVA supplements economic benefits up to 100% of usual salary during maternity or paternity leave
• Both mother and non-gestational parent can convert split shift to continuous shift until child is twelve months old
• Option extends to cases of adoption of a child up to five years of age
• In case of birth or adoption of disabled child, employees may have twenty-two days' leave

BBVA Mexico:

• Parental leave extended by 20 working days for fathers and 28 for mothers
• In cases of adoption, extended by 70 days for mother and 30 for father

Colombia:

• Parental leave extended by 10 working days

Turkey (Garanti Bank):

• Paternity leave extended by 5 additional days with pay, in addition to 5 statutory days

BBVA Peru:

• Paternity leave extended by 20 calendar days

BBVA Argentina:

• Paternity leave extended by 30 calendar days
• In cases of premature birth, mother entitled to paid leave for same number of days that birth occurred early
• In case of birth or adoption of disabled child, paternity and maternity leave extended by 60 calendar days

BBVA Switzerland:

• Paternity leave extended by 10 working days

Flexible work model (remote working)

BBVA maintained flexible work model in 2024 where viable, with general model consisting of minimum 60% of working day in person and maximum 40% remotely, with adaptations depending on local legislation and type of function performed.

Compensation metrics

Pay gap

Gross pay gap

The gross pay gap reflects the difference between the pay received by men and the pay received by women. It is calculated as the difference between the gross pay (mean or median) of men minus the gross remuneration (mean or median) of women, expressed as a percentage of the gross pay (mean or median) of men.

The total remuneration considered includes the annual basic remuneration (or base salary), salary supplements (except for mobility, housing and expatriation supplements) and the target variable remuneration (or target bonus).

The gross gender pay gap at BBVA Group for 2024:

Note: The gross pay gap does not allow for a comparison of the remuneration of men and women who perform similar functions, but rather compares the remuneration of men and women in different roles, so it is not representative of gender discrimination.

Adjusted pay gap

BBVA's remuneration policies are gender-neutral, reflecting equal remuneration for the same functions or functions of equal value, and not establishing any difference or discrimination based on gender.

The adjusted pay gap compares the total compensation received by men and women in equal positions in the group. For each position, BBVA calculates the median total remuneration received by all men and women occupying such positions. The adjusted pay gap for each position is calculated as the percentage resulting from dividing the difference in the median remunerations received by men minus the median remunerations received by women by the median remunerations of men. The BBVA Group's adjusted pay gap is calculated as the weighted average of the gaps obtained in each of the positions.

Adjusted wage gap (median) by geography:

Note: The calculation of the adjusted gap includes 90.8% of the Group's employees. The remaining employees cannot be included in the calculation because they are associated with positions in which there is no representation of both genders.

Remuneration ratio

BBVA calculates the annual total remuneration ratio for BBVA, S.A. employees located in Spain, as well as for employees located in Mexico, Turkey, Peru, Colombia, Argentina, Uruguay and Chile, as the ratio between the annual total remuneration (fixed remuneration plus accrued variable remuneration and pension contributions) of the highest-paid person in each geographic area and the median annual total remuneration of all employees in the same geographic area, taking the full-time annualized remuneration and excluding the highest-paid person.

Annual total compensation ratio:

Notes:

• Data for Venezuela is not provided since, in both 2023 and 2024, there was a change in the highest paid person and the position was vacant.
• Turkey, Argentina, and Chile show no data for 2024 due to a new Country Manager taking the position; not provided as the position was vacant.
• Data for 2023 differ from those published in the 2023 Consolidated Statement of Non-Financial Information, as the amount of variable compensation has been updated using the final score applied for its calculation.

Methodology

Gross pay gap: Items included are annual basic remuneration (base salary), salary supplements (except for mobility, housing and expatriation supplements) and target variable remuneration (target bonus). BBVA does not include items such as allowances, social benefits, etc., whose amounts are not very representative of total remuneration and whose granting criteria and amounts are clearly defined without discriminating between men and women.

Adjusted pay gap: Uses the same remuneration items as the gross pay gap. The median is used for this calculation since this statistical indicator is less affected by the presence of biases in the distribution of extreme values and better represents the Group's actual situation.

Remuneration ratio: Includes fixed remuneration plus accrued variable remuneration and pension contributions, on a full-time annualized basis, excluding the highest-paid person from the median calculation.

Scope: The calculations on the gap and on average remuneration have been made taking into account 99.7% of the workforce, as it does not include data from the companies DCN, Banco Provincial Overseas Curaçao, Openpay Peru, Opplus Lima (Peru), Sociedad Peruana de Financiamientos SAC, AFP Previsión, Provivienda (Bolivia), BBVA Bancomer Houston Agency.

Incidents, complaints and severe human rights impacts

Harassment and discrimination protocols activated (2024)

Scope: Covers companies representing 98.0% of the Group's official workforce. Excludes BBVA Agencia Insurances Colombia, BBVA Insurances Grales Colombia, BBVA Valores Colombia, Openpay Colombia, Movistar Consumer Finance Colombia SAS, BBVA Red Exterior de oficina, BBVA Brasil, BCO. Investimento, BBVA Holding Chile SA, BBVA Foundation Mexico AC, Distrito Castellana Norte (DCN), Garantibank International NV, Garanti Bank SA (Romania), Ralfi IFN SA, Motoractive IFN SA, Garanti Bank G, Motoractive Multiservices SRL, Garanti Kultur/SAL.

Fines and sanctions

During the year 2024 there have been no firm sanctions or fines for cases of discrimination or harassment.

Whistleblowing Channel complaints (BBVA Group)

Total complaints received in 2024: 2,283 (10.8% increase vs 2023)

Breakdown by type (2024):

Source of complaints (2024):

• Employees: 67.7%
• Third parties: 6.3%
• Not disclosed: 26%

Total complaints processed in 2024: 2,590

• Approximately 36% resulted in disciplinary measures
• 169 dismissals on disciplinary grounds

Human rights impacts and due diligence

In 2024, complaints received through the Whistleblowing Channel showed no evidence of human rights violations attributable to Group entities.

BBVA has not been informed of potential claims filed at National Contact Points (PNC) where it is present in 2024.

Human rights due diligence scope: BBVA has analyzed aspects including human trafficking, forced labor, child labor, freedom of association and collective bargaining, and equal pay or discrimination through its internal taxonomy assessing 28 human rights issues grouped into 6 thematic blocks.

Customer complaints regarding privacy breaches

Substantiated claims regarding privacy breaches and loss of customer data filed with relevant supra-bank authorities: 0.004% of total claims (0.003% in 2023).

Policies related to consumers and end-users

BBVA has established several policies that govern its relationship with consumers and end-users, with a particular focus on data protection, transparency, and cybersecurity.

General Privacy and Data Protection Policy

• Approval and oversight: Approved by the Board of Directors. The Global Head of Data is in charge of promoting its knowledge.
• Scope: All Group entities and applies to customers, shareholders, suppliers, employees and third parties ("Data Subjects").
• Key principles and content: Establishes the general principles and management and control guidelines that the Group must follow in terms of the protection of personal data. The policy ensures proper identification of risks and promotes transparency and control mechanisms in data processing carried out in BBVA Group entities, complying with applicable regulations and taking into account the interests of main stakeholders.
• Link to international standards: Aligned with the European Union data protection framework and the fundamental right to data protection.
• Public availability: Both the General Privacy and Data Protection Policy and the Corporate Standard on personal data protection are reviewed annually and are available on the corporate intranet for all employees to consult. A summary of these documents has been published on the shareholders' website for the general public to consult.
• Monitoring: The operation of communication channels is periodically monitored by the Regulation & Internal Control area to ensure the quality and adequacy of the responses to data subjects' perspectives and to ensure that the time frames established by applicable law and regulations are met. This process is coordinated with the Customer Service or Complaints Departments where appropriate.

Corporate Standard on personal data protection

• Relationship to policy: Implements the General Privacy and Data Protection Policy.
• Key principles and content: Sets out the principles that must be followed by any process affecting personal data and assigns responsibilities to different roles involved in the cycle of its treatment. Describes the privacy requirements that all Group entities must consider from the time a product, service, functionality, etc. is designed or planned, identifying the risks intrinsic to each personal data processing and defining and incorporating the necessary technical and organizational measures.
• Scope: All Group entities.
• Public availability: Available on the corporate intranet for all employees to consult. A summary has been published on the shareholders' website for the general public to consult.
• Review: Reviewed annually.

BBVA's Code of Conduct

• Scope: All employees must be aware of and comply with it.
• Key principles and content: States that the protection of personal data is a fundamental right and that employees must ensure that the data of data subjects are protected and treated confidentially.

Management measures and monitoring

BBVA has implemented a comprehensive data protection governance structure and monitoring framework:

• Governance: The Data Protection Unit, integrated into the second line of risk management, has defined and developed specific aspects and management elements that allow the prevention, detection and management of risks in the area of personal data protection.
• Management measures (as of 2024):
  • Having a data protection governance structure that includes the involvement of all levels of the organization
  • Conducting periodic assessments to ensure compliance with the rules and procedures associated with the management of personal data
  • Providing regular training on personal data protection to raise awareness among all Group employees
• Monitoring: Management measures are monitored in a global and continuous manner, through data protection indicators that allow identification of the degree of compliance with the Group's corporate personal data protection program, giving BBVA an aggregated view.

Information documents for data subjects

Based on applicable law and regulations, as well as the Policy and Standard, BBVA has drawn up various documents providing information on the processing of personal data addressed to data subjects. These documents:

• Explain the purpose for which personal data are processed, as well as the way in which data are obtained and protected
• Are provided to data subjects and are available on respective websites
• Describe the data controllers, purposes of processing, lawful basis, rules governing assignments to third parties or international transfers and the exercise of rights
• Provide information on various communication channels available to data subjects to make queries, exercise rights or report data protection incidents, including a specific email inbox

Taking action on material impacts on consumers

BBVA's disclosure for ESRS S4-4 is referenced across multiple sections but specific action details are limited:

Customer Experience

• Processes and channels for consumers to raise concerns (referenced in S4-4 mapping)
• Section referenced: NFIS/Social information/Consumers and end users/Customer experience

Accessibility to Services and Products

• Actions to improve accessibility
• Section referenced: NFIS/Social information/Consumers and end users/Accessibility to services and products

Raising Awareness on Sustainability Issues

• Initiatives to raise consumer awareness on sustainability
• Section referenced: NFIS/Social information/Consumers and end users/Raising awareness on sustainability issues

Transparency in Information to Customers

• Actions related to transparency about products and services
• Section referenced: NFIS/Social information/Consumers and end users/Transparency in information to customers about products and services

Responsible Use of Data

• Data protection and responsible data management actions
• Section referenced: NFIS/Social information/Consumers and end users/Responsible use of data

Complaints Channel

• Systems for managing complaints and concerns
• Section referenced: NFIS/Social information/Consumers and end users/Complaints channel

Note on Resources: The document explicitly states in footnote 10 that "Information corresponding to the management of resources regarding own employees and consumers and end users referred to in the ESRS S1-4.37, S4-4.30... has been considered confidential or sensitive." Therefore, resource allocation data for S4-4 actions is not disclosed.

Business conduct policies and corporate culture

BBVA addresses business conduct through a comprehensive compliance framework built around several key policies and governance structures.

BBVA Code of Conduct

Policy name: BBVA Code of Conduct

Scope: All members of the BBVA Group (employees, Senior Management and directors)

Approval and oversight:

• Approved by the Board of Directors (last updated July 2024)
• Supervised by the Risk and Compliance Committee (composed exclusively of independent directors)
• Monitored by the Compliance function within the Regulation and Internal Control area, whose Head reports to the Board of Directors

Key content/principles:

• Establishes that all BBVA Group members must act with integrity and accountability
• Requires respect for applicable laws and regulations
• Requires demonstration of due levels of prudence and professionalism
• Includes specific principles for markets, customers and shareholders
• Prohibits discrimination based on sex, race, age or sexual condition
• Section 5.3 addresses corruption prevention
• Section 4.6.1 requires adequate compliance with tax obligations and avoidance of illicit tax evasion

Public availability: Published on the corporate website (www.bbva.com) and corporate intranet

Links to international standards:

• Not explicitly stated in the Code of Conduct itself, though referenced in related policies

Monitoring implementation:

• Mandatory corporate training course for all employees (must be completed every 3 years)
• By end of December 2024, 92,621 employees completed the course (>98% completion rate in most geographies)
• Application monitored by the Group's Compliance area
• Consultation Channel provided formal responses to 764 individual queries in 2024
• Disciplinary and sanctioning procedures applicable for non-compliance

General Sustainability Policy

Policy name: General Sustainability Policy

Scope: BBVA Group entities in all countries where it operates

Approval and oversight:

• Approved by the Board of Directors

Key content/principles:

• Frames the commitment to respect for Human Rights
• Ensures compliance with all applicable laws and respect for internationally recognized human rights in all relations with employees, customers, shareholders, suppliers and communities
• Promotes corporate culture of social and environmental support
• Enables employees to carry out volunteering activities
• Establishes commitment to operate in compliance with tax obligations and avoid illicit tax evasion

Links to international standards:

• Aligned with the International Bill of Human Rights
• Guidelines of the Organization for Economic Cooperation and Development (OECD) for Multinational Business
• Fundamental conventions of the International Labor Organization (ILO)

General Anti-corruption Policy

Policy name: General Anti-corruption Policy

Scope:

• Applies to the BBVA Group
• Mandatory for all companies in which the Group has a direct or indirect stake of more than 50%
• Applies to employees, Senior Management and directors of the Group's companies

Approval and oversight:

• Updated version approved by the Board of Directors in 2023
• Supervised by the Risk and Compliance Committee

Key content/principles:

• Establishes framework for action to prevent, detect and promote communication of corrupt practices
• Implements principles from section 5.3 of the Code of Conduct
• Establishes specific guidelines for behavior in sensitive activities or areas
• Facilitates identification of scenarios requiring special caution

Public availability:

• Communicated to all employees and governing body members
• Public statement summarizing content available on shareholders and investors website

Links to international standards:

• Aligned with United Nations Convention against Corruption
• Recommendations of international bodies
• International Organization for Standardization (ISO) standards

Monitoring implementation:

• Implemented through specific procedures including Rules for Acquiring Goods and Arranging Services, Corporate Rules on Gifts and Events
• Corporate tool for recording gifts and events in most geographies
• Anti-corruption training course mandatory for all employees (every 3 years)
• 87,704 employees (95.6%) trained by end of 2024
• Corruption Prevention Program includes risk map, governance model, mitigating measures, action procedures, training programs, indicators, whistleblowing channel, and disciplinary regime
• AENOR certificate renewed in 2022, valid for 3 years (annual external audit review)

General Policy for managing communications in the Whistleblowing Channel and protecting whistleblowers

Policy name: General Policy for managing communications in the Whistleblowing Channel and protecting whistleblowers

Scope:

• All BBVA employees
• Employees of main BBVA subsidiaries in Spain and other geographies
• Also accessible to customers, suppliers and any other stakeholder

Approval and oversight:

• Approved by the Board of Directors in 2023
• Management responsibility lies with the Compliance unit

Key content/principles:

• Sets fundamental principles governing operation of Whistleblowing Channel
• Establishes protection measures for whistleblowers and people affected by communications
• Ensures confidentiality and prevents reprisals
• Enables reporting of behavior violating Code of Conduct or breaching legislation, including human rights complaints
• Guarantees fundamental rights including presumption of innocence, data protection, right to honor and defense

Public availability:

• Communicated to all BBVA employees
• Summary available on shareholders and investors website
• Online platform accessible 24/7, 365 days (www.bkms-system.com/bbva)
• Available in Spanish and English

Links to international standards:

• Complies with Spanish Law 2/2023 on protection of whistleblowers and fight against corruption

Monitoring implementation:

• 2,283 complaints received in 2024 (10.8% increase)
• Structured process: acknowledgment within 7 days, independent review, decision and closure
• 2,590 complaints processed in 2024
• ~36% resulted in disciplinary measures (169 dismissals)
• Annual review of the Policy

Customer Conduct and Product Governance Policy

Policy name: Customer Conduct and Product Governance Policy

Scope: All BBVA Group entities when they design or distribute products to customers, provide services or manage collective investment vehicles

Approval and oversight:

• Approved by the Board of Directors on February 9, 2022
• Responsibility for application falls on the Global Head of the Regulation & Internal Control area

Key content/principles:

• Appropriate and responsible offering of products and services
• Transparency in advertising and information provided to customers
• Managing potential conflicts of interest
• Financial inclusion and customer accessibility
• Prompt and diligent attention to customer queries, complaints and claims
• Adequate training of personnel
• Establishes measures throughout product/service lifecycle (design, distribution, post-contracting)

Public availability: Published on BBVA Group's internal website

Links to international standards:

• Aligned with EU Directive 2014/65/EU (Markets in Financial Instruments)
• EU Directive 2016/97/EU (Distribution of Insurances)
• European Banking Authority Guidelines on Governance and Oversight, Internal Governance, and Loan Origination and Monitoring
• Bank of Spain adoption of EBA guidelines

Monitoring implementation:

• Annual review (2024 review conducted with no modifications)
• Communicated to personnel involved in product design/distribution and service provision

Corporate Culture Guide

Policy name: Corporate Culture Guide

Scope: Applies to most BBVA Group entities (96.4% of workforce)

Approval and oversight:

• Formalized in 2024
• Global Head of Culture & Engagement (reports to Global Head of Talent & Culture) responsible for implementation and monitoring

Key content/principles:

• Establishes framework for fostering and consolidating robust corporate culture
• Promotes ethical work environment aligned with BBVA's values
• Describes standards, roles, responsibilities and governance mechanisms
• Ensures achievement of the Purpose

Public availability: Available on internal Culture and Commitment portal in Spanish and English

Links to international standards:

• Based on BBVA's internal Code of Conduct

Monitoring implementation:

• Annual employee engagement survey managed by Gallup
• 95% of workforce participated in 2024
• Results shared with senior management
• Action plans defined at three levels: global, local (area/geography), and team
• 88% of managers recorded action plans in 2024
• Values Index scored 4.66 out of 5 in 2024

Securities Markets Conduct Policy

Policy name: Securities Markets Conduct Policy

Scope: Applicable to the BBVA Group, adapted locally through Internal Code of Conduct (RIC) for more than 8,000 exposed employees

Key content/principles:

• Guarantees integrity and transparency in markets
• Prevents market abuse
• Promotes free competition

Monitoring implementation:

• Compliance supervised more than 57,474 personal transactions in 2024
• Analyzed transactions in markets, reporting suspicious transactions to local supervisors
• Internal regulations reinforced with Standard on short-selling of financial instruments and Standard on Integrity in voluntary carbon markets

Competition Policy

Policy name: BBVA Competition Policy

Scope: Applies across the BBVA Group

Approval and oversight:

• Approved in July 2019

Key content/principles:

• Expands on principle 4.16 of the Code of Conduct on free competition
• Addresses sensitive risk areas: agreements with competitors, agreements with non-competing companies, potential dominant position

Public availability: Communicated to BBVA employees and transposed in main geographies

Monitoring implementation:

• Various training and awareness-raising actions in recent years

Conflicts of Interest Policy

Policy name: General policy on conflicts of interest (name not explicitly stated as such, but content described)

Scope: Applicable to the BBVA Group

Key content/principles:

• Reinforces principles and measures for all BBVA members to identify, prevent and manage conflicts of interest
• Framed within fundamental principles: integrity, prudence in risk management, transparency, achieving sustainable business, compliance with legislation
• Addresses specific measures to prevent conflicts
• General guidelines on how to act if conflict materializes
• Governance and supervision mechanisms at different organizational levels

Monitoring implementation:

• New corporate tool for filing and managing conflicts of interest completed in most geographic areas in 2024
• Various awareness-raising actions carried out in 2024

Data Protection Policy and Standard

Policy name: Data Protection Policy and Standard

Scope: BBVA Group

Approval and oversight:

• Data Protection Unit integrated into second line of risk management

Key content/principles:

• Establishes principles applicable to personal data processing
• Identifies risks intrinsic to each personal data processing
• Defines necessary technical and organizational measures
• Requires privacy by design and privacy by default

Public availability:

• Available on corporate intranet for employee consultation
• Summary published on shareholders' website for public

Links to international standards:

• BBVA Code of Conduct states protection of personal data is a fundamental right

Monitoring implementation:

• Annual review
• Periodic monitoring by Regulation & Internal Control area
• Data protection indicators tracking compliance
• Annual non-financial risk assessment process
• Information documents provided to data subjects on respective websites
• Communication channels for queries, rights exercise, incident reporting

General Procurement Principles and Code of Ethics for Suppliers

Policy name: General Procurement Principles and Code of Ethics for Suppliers of the BBVA Group

Scope: All suppliers with which any Group company or entity has dealings

Key content/principles:

• Ensures compliance with legal requirements regarding human, labor, association and environmental rights
• Commitment to prevent corruption
• Selection of suppliers complies with Group's Code of Conduct values
• Establishes minimum standards of conduct in ethical, social and environmental matters for suppliers
• Based on respect for legality, integrity, competition, objectivity, transparency, value creation, confidentiality, continuous improvement, segregation of duties

Monitoring implementation:

• Contract clauses include supplier obligation to comply with Code of Conduct and Code of Ethics for Suppliers
• Supplier evaluation process reviews financial, legal, labor, reputational, anti-corruption, money laundering prevention, concentration and country risks, sustainability, data protection and customer protection
• 4,616 suppliers evaluated in 2024 (4,475 suitable, 141 unsuitable)
• 99% of contract awards to evaluated suppliers
• Internal Audit conducted risk-based assessments of procurement process in 2024

General Tax Strategy Policy

Policy name: General Tax Strategy Policy (also referred to as BBVA's guiding principles on fiscal matters)

Scope: BBVA Group in all jurisdictions

Approval and oversight:

• Board establishes guidelines for monitoring compliance in General Policy
• Tax strategy also published for UK branch in compliance with UK regulations, subject to third party review and verification

Key content/principles:

• BEPS compliance (aligned with OECD BEPS Project)
• Geared towards social development
• Committed to protecting human rights
• Paying taxes contributes to SDGs (particularly SDG 1, 8, 10, 17)
• Proactive cooperation with tax authorities

Public availability:

• Tax strategy published on shareholders and investors website in Tax Policy section
• Overall tax contribution published annually

Links to international standards:

• OECD Guidelines for Multinational Enterprises (Chapter XI)
• Aligned with G20 and OECD BEPS Project
• UN Guiding Principles on Business and Human Rights
• Aligned with European Economic and Social Committee's opinion ECO/494 of December 11, 2019

Monitoring implementation:

• Tax Control Framework integrated with BBVA Group's control model
• Specific annual plans to identify, mitigate and control tax risk
• Head of Group's Tax Department periodically informs Audit Committee
• Compliance with reporting obligations (FATCA, CRS, QI, country-by-country report, DAC6)
• Code of Conduct (Section 4.6.1) monitored by Compliance area with whistleblowing channel

Diversity Guidelines

Policy name: Diversity Guidelines (described as such in the document)

Scope: BBVA Group employees

Approval and oversight:

• Diversity teams in different areas and geographies responsible for ensuring compliance and proposing updates

Key content/principles:

• Five lines of work: gender diversity, LGBTIQ+ diversity, generational diversity, people with disabilities, cultural and ethnic diversity

Public availability: Communicated through newsletter, Intranet, Diversity Days, and training on Campus (also available in English)

Links to international standards:

• Related to Equality Plan signed in Spain with employee representatives in 2023
• Prevention and action protocols against sexual harassment in main geographies

Monitoring implementation:

• Employee Resource Groups (ERGs) provide feedback and advice
• Periodic meetings with ERG representatives
• Specific question on diversity in Gallup engagement survey (scored 4.75 out of 5 in 2024)
• Various diversity initiatives implemented

Crime Prevention Model

Policy name: Crime Prevention Model (described as such)

Scope: BBVA Group in Spain (with reference to Spanish criminal liability regime)

Key content/principles:

• Based on prevention system, governance structure, and regular reviews
• Identifies activities carrying risk of criminal liability
• Identifies control elements for preventing and mitigating risks
• Develops specific risk management program for each type of crime
• Specialized control areas designated as "assurance providers"

Monitoring implementation:

• Governance structure supervises operation, compliance and effectiveness
• Periodic independent reviews
• AENOR certificate renewed in 2022, valid for 3 years (annual external audit)
• Certifies compliance with Standard UNE 19601:2017

AML/FT Policy

Policy name: General Policy on AML/FT (Anti-Money Laundering and Financing of Terrorism)

Scope: All BBVA branches and subsidiaries

Approval and oversight:

• Approved by the Board of Directors
• Supervised by Risk and Compliance Committee
• Internal Control Body for PBC&FT (prevention of money laundering and terrorist financing)

Key content/principles:

• Integrates local regulations of jurisdictions where BBVA operates
• Provides standard framework for risk management across Group
• Defines common criteria and general framework for action

Links to international standards:

• Financial Action Task Force (FATF) recommendations
• International best practices of financial sector

Monitoring implementation:

• Annual risk analyses allow reinforcement of controls
• Specific program launched in 2024 covering main geographies
• Global financial crime prevention unit created in 2023
• In 2024: 175,303 transactions evaluated for AML/FT risk, 264,303 for internal fraud risk, 4,348 third parties in procurement processes
• Technological infrastructure improvements and advanced analytical techniques
• Development of in-house AML case manager starting in Spain, rolling out in 2025
• No confirmed convictions or sanctions for AML/FT violations in 2024

Incidents of corruption or bribery

Confirmed incidents

BBVA has not disclosed the number of confirmed incidents of corruption or bribery in 2024.

Convictions and fines

There were no final criminal convictions delivered in 2024, and nor were any final fines handed down in court during the year against entities comprising the BBVA Group as of December 31, 2024 under a global consolidation regime or against their employees, for having breached applicable anti-corruption and anti-bribery laws.

Disciplinary actions

BBVA has not disclosed the specific number of employees dismissed or disciplined due to corruption or bribery. However, the company reports that in 2024, a total of 2,590 complaints were processed through the Whistleblowing Channel. Approximately 36% of the complaints processed in the year resulted in the imposition of disciplinary measures, which led to 169 dismissals on disciplinary grounds. The company notes that none of the complaints processed through the Whistleblowing Channel have caused significant economic, criminal or reputational impacts.

Contracts terminated

BBVA has not disclosed the number of contracts with business partners terminated or not renewed due to corruption or bribery.

Investigation procedures and speak-up mechanisms

BBVA has a Whistleblowing Channel available to all stakeholders (employees, customers, suppliers, and others) to report confidentially and anonymously any behavior that violates the Code of Conduct or applicable legislation, including complaints relating to corruption and bribery.

The management of the Whistleblower Channel is the responsibility of the Compliance unit, which follows a structured process:

• Receipt of communication and acknowledgement within 7 days
• Review of reported facts by independent units within BBVA
• Decision issuance and case closure based on findings
• Disciplinary measures determined by an independent committee when necessary

In 2024, 2,283 complaints were received by the Group, up 10.8% from the previous year. The main types of complaints relate to labor relations (49.98%), customer conduct (18.40%), discrimination or harassment (11.87%), fraud (6.96%), conflicts of interest (5.56%), potential money laundering (1.62%), privacy and information security (1.62%), and other types (3.99%).

The Compliance function ensures complaints are processed diligently and confidentially, guaranteeing fundamental rights of both the informant and the person reported, including presumption of innocence, data protection, right to honor and defense, and protection against reprisals.

Anti-corruption risk management

BBVA has a Corruption Prevention Program that includes:

• A risk map
• A specific governance model
• Mitigating measures
• Procedures for action in risk situations
• Training and communication programs
• Indicators for risk monitoring
• A whistleblowing channel
• A disciplinary regime

In 2024, from the ML/FT and Corruption risk dimension, a total of 4,348 (100%) third parties in the Group's procurement processes were evaluated.

Payment practices

Payments made and outstanding balances

The information required by Final Provision second of Law 31/2014 of December 3, which amends the Corporate Law to improve corporate governance modifies Additional Provision third of Law 15/2010, of July 5, amending the Law 3/2004 of December 29, through which measures for combating late payment in commercial transactions are set.

Payments made and pending payments (Millions of Euros)

(1) To obtain these ratios, the total number of registered invoices is taken into account.

Including other BBVA Group companies in Spain, the total payments made for the years 2024 and 2023 amounted to €3,033 million and €3,058 million.

The data shown in the table above on payments to suppliers refer to those which by their nature are trade creditors for the supply of goods and services.

Compliance with payment regulations

As of December 31, 2023, according to Law 18/2022, of September 28, on creation and development of entities, BBVA paid a total of 131,378 invoices (representing 89.6% of the total invoices received) with a total amount of €2,071 million (representing 95.5% of the volume invoiced) in a period less than or equal to the maximum established in the delinquency regulations.