BBVA

The role of the administrative, management and supervisory bodies

Reference: pages 49-57, 208-210. Listed in the ESRS content index under ESRS 2 and again under ESRS G1 Business conduct (pages 272, 278).

As of 31 December 2025 the Board of Directors is composed of fifteen directors, two executive and thirteen non-executive (page 49). Ten are independent, "representing 66.7% of the total Board members and 76.9% of the total non-executive directors", and the Board "is composed of 46.7% women and 53.3% men, meeting the target of 40% representation of the least represented gender established in the Board of Directors' Selection, Suitability, and Diversity Policy" (pages 49-50). Directors come from seven countries and 40% are non-Spanish. BBVA notes that Spanish law "does not require the representation of workers as part of the board of directors in listed companies" (page 49, footnote 10).

Sustainability responsibilities are allocated across six Board committees (page 51):

• Executive Committee - decision-making and ongoing monitoring of the sustainability strategy and objectives.
• Risk and Compliance Committee - integration of sustainability into financial and non-financial risk analysis, planning and management.
• Audit Committee - oversight of the preparation process and content of sustainability information for publication.
• Appointments and Corporate Governance Committee - sustainability competencies in Board composition.
• Remuneration Committee - strategic indicators linked to variable remuneration.
• Technology and Cybersecurity Committee - technology risk and cybersecurity.

At executive level the Global Sustainability Area head "reports directly to both the Chairman, regarding transformation and sustainability strategy, and the CEO, regarding business matters" (page 56). For business conduct, the Head of Regulation & Internal Control "reports monthly to the Risk and Compliance Committee and quarterly to the Board of Directors" (page 208).

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

Reference: pages 52-53.

The Board approved the Strategic Plan 2025-2029, which includes "Boost sustainability as a growth engine" as one of its six strategic priorities, and a Sustainability General Policy whose oversight "falls to the Board itself" (page 52). Specific Board decisions in 2025 include "the establishment of a strategic sustainable business channeling indicator, setting a target of €700 billion for the 2025-2029 period", following achievement of the €300 billion target set for 2018-2025, and "portfolio decarbonization targets in certain sectors, aligned with the objective of achieving net zero emissions by 2050" (page 53).

The Corporate Bodies "rely on periodic reports received from both the Global Sustainability Area and the various areas of the Group", submitted "either on a regular basis or on an ad hoc basis" (page 53). BBVA states that "most of the impacts, risks and opportunities arising from Sustainability related in the 'Double materiality analysis' section of this Report, have been reported to the Corporate Bodies throughout the year".

The IROs subject to recurring monitoring by the Board and its Committees in 2025 are named: climate change mitigation, climate change adaptation, working conditions, equal treatment and opportunities for all, incidents related to information, corruption and bribery, whistleblower protection, money laundering, cybersecurity and data protection (page 53).

BBVA qualifies the coverage in footnote 12: "not all of the impacts, risks, and opportunities related to sustainability and included in the 'Double materiality analysis' chapter of this Report are analyzed through specific presentations to the corporate bodies. In some cases, they are monitored in an integrated manner within presentations on broader issues within their respective areas (e.g., Risks, Compliance, Talent & Culture, etc.)."

On competence, the Board's continuous training programme "since 2021 has covered both the Group's progress in Sustainability (decarbonization strategy, sustainable transition, inclusive growth and natural capital) and sustainability-related compliance matters (e.g., natural capital, global trends, greenwashing risk, etc.)" (page 54).

Integration of sustainability-related performance in incentive schemes

Reference: pages 49-58, 157-158. Cross-referenced in the index to Sustainability governance and to Own workforce / Competitive remuneration (page 274).

BBVA's corporate annual variable remuneration model "in general, applies to all employees, based on their roles, including executive directors" (page 157). Group-wide achievement in 2025 was 115% (126% in 2024).

Annual (short-term) indicators, 2025 weights (page 157): RORC 35%, net attributable profit 15%, enterprise fee income 10%, Net Promoter Score 15%, target customers 15%, and sustainable business channeling 10% (goal €114,740 million, result €133,778 million, attainment 122%).

Long-term indicators for the Identified Collective, measured to year-end 2028 (page 158): Tangible Book Value per share 40%, Relative TSR 40%, decarbonization of the portfolio 15% and percentage of women in management positions 5%.

Quantified linkage (page 158):

• Non-financial or sustainability-related indicators "represent, both in 2025 and 2024, 32.8% of the executive directors' target annual variable remuneration".
• Assuming 150% achievement of the long-term incentive, the share of granted annual variable remuneration linked to those indicators "amounts to 38.0% in 2025 and 38.6% in 2024".
• The portfolio decarbonization indicator alone "represents 3.9% and 3.7% of the Chair's total remuneration in those respective years, and 3.1% and 3.0% of the Chief Executive Officer's total remuneration".

Executive directors' annual variable remuneration is weighted 64% short-term and 36% long-term in 2025. The Remuneration Committee "analyzes the selection and monitors the evolution of strategic indicators linked to variable remuneration, including those related to Sustainability" (page 51).

Statement on due diligence

Reference: pages 58-60.

BBVA "views due diligence as a continuous, proactive and integrated process aimed at identifying, assessing, mitigating, and monitoring adverse impacts, whether actual or potential, that its businesses and activities may generate" (page 58). It states it is "systematically incorporating its relationship with social factors - customers, employees, suppliers, and society - as a potential risk vector within its overall non-financial risk management framework", consolidating the Human Rights Action Plan 2021-22 & 2023.

The statement maps the due-diligence elements to sections of the management report (pages 59-60):

• Integration into governance, strategy and business model - the general risk management and control model covers financial and non-financial risks under the supervision of the Board and the Risk and Compliance Committee.
• Engagement with affected stakeholders - stakeholder dialogue, complaints and customer service channels, the Group Whistleblowing Channel "accessible to employees, suppliers and third parties", and employee channels (Employee Service SAE, Talent & Culture Advisor Channel).
• Identification and assessment of adverse incidents - ESG assessment and monitoring of customers supported by the Environmental and Social Framework, the Equator Principles and the ESG controversy management procedure; anti-corruption and AML/CFT; supplier assessment; transparency and access to products; cybersecurity and responsible data use.
• Adoption of measures to address adverse impacts - initiatives and action plans "detailed throughout this NFIS".
• Monitoring the effectiveness of these efforts and communication - mechanisms "for monitoring, reporting and escalation of risks to the relevant corporate bodies".

BBVA applies "integrated Operational Risk Assessment, Non-financial Risk Assessment and Climate Risk Assessment exercises, which identify and assess risks arising from emerging factors, including climate change" (page 58), and says it "is making progress in the gradual integration of the essential elements of due diligence into its risk identification, management and prevention processes".

Risk management and internal controls over sustainability reporting

Reference: pages 22-23.

The NFIS "is prepared under an Internal Information Control Model that supports its reliability", based on "the same methodological, governance, and control components that operate within the Financial Information Internal Control System" (page 22). Internal Control units sit within the Regulation & Internal Control area, "whose head reports to the Board of Directors through its Committees", and the model "is structured around three lines of defense".

Main risks associated with the NFIS disclosure process (page 22): "The interpretation and application of the regulations concerning non-financial and sustainability information; the completeness and integrity of the data from multiple internal and external sources; the availability of information; the processing of both qualitative and quantitative data and the inherent complexity of its validation, as well as the accuracy of estimates used."

Mitigating controls: monitoring, updating and documentation of applicable regulations; coordination of the preparation process; identification of key processes, roles and responsibilities; data validation; cross-checking; documentation of estimation methodologies; and monitoring and review by Committees and Corporate Bodies (page 22).

The common corporate methodology has five steps: identifying risks with the greatest potential impact, analysing risk situations and errors, defining and operationalising controls, evaluating design and operation, and developing remediation action plans (page 23). Results of the internal evaluation "will be reported to the Audit Committee".

BBVA states the limitation plainly: "even effective information preparation and disclosure controls and procedures have limitations in providing assurance that all of their control objectives will be achieved" (page 22).

An executive-level ESG Reporting Committee, led by the Finance area, coordinates disclosure quality (page 57).

Strategy, business model and value chain

Reference: pages 23-28, 37-48.

BBVA structures its value chain in three phases (pages 23-24):

• Upstream - "relationships with technology providers, cloud service providers, information systems providers, financial service providers, professional services providers (amongst others, legal or consulting services), and general suppliers".
• Own operations - "BBVA's own assets and internal processes", employees and owned real estate.
• Downstream - customers of banking, insurance and asset management, retail and corporate.

An explicit scoping statement limits the downstream disclosure: "no material impacts, risks, and/or opportunities associated exclusively with insurance and asset management activities have been identified. Consequently, specific policies, actions, targets, and metrics covering these aspects are not disclosed, other than those which by their nature encompass these activities" (page 24).

The Group had more than 127 thousand employees (127,174 at year-end 2025, page 172) and channelled €134 billion into sustainable business in 2025, a record and 44% growth, of which €104 billion environmental and €30 billion social (pages 40-41, 63). Breakdown by segment: corporates €68bn, enterprises €50bn, retail €15bn (page 41). By geography: Spain 35%, Mexico 30%, Turkey 9%, South America 16%, other 10%.

The Strategic Plan 2025-2029 carries six strategic priorities, including "Boost sustainability as a growth engine" and "Embed a Radical Client Perspective in all we do" (pages 51-52). BBVA identifies three growth levers: differentiated advice tailored to each segment, development and financing of innovative solutions (cleantech, home and mobility, natural capital, social initiatives), and integrating sustainability into risk management, noting that "By 2025, 88% of the loan portfolio in emissions-intensive sectors already has a Transition Risk Indicator (TRi)" (page 39).

The report does not disclose participation in fossil-fuel, chemical, controversial-weapons or tobacco activities, marking each of those SBM-1 datapoints "Non material" (pages 263-264).

Interests and views of stakeholders

Reference: pages 23-28. Listed in the index under ESRS 2 and again under E1, S1 and S4 (pages 272, 275, 277).

BBVA "maintains an active dialogue through specific channels with its main stakeholders - shareholders and investors, customers, employees, suppliers, regulators and supervisors and society - who can affect and be affected by business activities and relationships throughout the value chain" (page 25). It states that "This listening process with the different stakeholders constitutes a key element of the Group's strategy, as it enables the identification of impacts, risks, and opportunities associated with its activities."

Channels and topics are tabulated per group (pages 25-28):

• Shareholders and investors - General Shareholders' Meeting, conferences, webcasts, Shareholders' Office; topics include solvency and profitability, shareholder remuneration, corporate governance, sustainability strategy and business.
• Customers - customer service (SAC), personalised advisors, digital channels, complaint and whistleblowing channels; topics include sustainability and energy transition, access to credit and sustainable solutions, transparency and service quality. Satisfaction "is regularly measured using the Net Promoter Score (NPS) methodology".
• Employees - RCP survey, "Moment that Matters", intranet, Employee Support Service (SAE), Talent & Culture Advisor Channel, Whistleblowing Channel.
• Suppliers - Supplier Portal, supply surveys, Whistleblowing Channel, periodic evaluations.
• Society - social and inclusion programmes, educational digital channels, volunteering, philanthropy.
• Regulators and supervisors, and ESG analysts and rating agencies.

More than 31,000 employees participated in the 2025 internal RCP survey (page 145). The dialogue "aims to integrate their views and interests, a commitment reflected in the Group's various policies, and especially in the Sustainability General Policy" (page 25).

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

Reference: pages 31-36. Listed in the index under ESRS 2 and repeated under E1, S1, S4 and (via IRO-1) G1.

The 2025 DMA found four material topics: climate change, own workforce, consumers and end-users, and business conduct, the last "Includes entity-specific: Money laundering, Cybersecurity and Data protection" (page 30). Pollution, water and marine resources, biodiversity and ecosystems, resource use and circular economy, workers in the value chain and affected communities are non-material (page 30).

Climate change (page 32) - six IROs across mitigation, adaptation and energy, all downstream: sustainable business channelling toward decarbonisation (opportunity); "Increase in portfolio GHG emissions due to the financing of companies, sectors, or operations with high emissions or lacking transition strategies" (negative impact); "Financial risks arising from financing customers affected by changes in legislation, market conditions, technology, and consumer preferences; linked to the transition to a low-carbon economy (transition risk)" (risk, long term); contribution to customers' adaptation (positive impact); channelling into energy efficiency, transition and innovation (opportunity); contribution to customers' energy transition (positive impact).

Own workforce (page 33) - four potential short-term positive impacts in own operations: adoption of a strong corporate culture; employee satisfaction and productivity from a high-quality employment offering; the same from competitive compensation; and promotion of equal opportunities.

Consumers and end-users (page 34) - one risk ("Risk of legal or regulatory sanctions, financial losses, social risk ... stemming from insufficient transparency regarding the products and services offered"), three opportunities and two positive impacts, all downstream.

Business conduct (page 35) - three potential short-term risks: corruption and bribery (own operations); "Risk of an increasing scope of third-party exposure linked to technological evolution and the growing use of cloud services, other ICT services, and the adoption of generative artificial intelligence services" (upstream); and inadequate or inaccessible complaint mechanisms (own operations).

Entity-specific (page 36) - nine further IROs on money laundering, cybersecurity and data protection.

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

Reference: pages 29-30, 249-251. Listed in the index under ESRS 2, E1, E2-E5 and G1.

The DMA "carried out in accordance with the ESRS, consolidates the approach initiated in 2024" and "is conceived as a dynamic process subject to periodic reviews" (page 29). BBVA updated the 2024 analysis "based on progress made in internal processes, alignment with the institution's new strategic cycle, and the changing market environment" (page 21).

Three-phase methodology (pages 249-251):

• Phase A - context analysis. External inputs include "market information, public and sector sustainability standards, specialized methodologies such as UNEP-FI (UNEP-FI Impact Analysis Tool), benchmarks, trends and the regulatory framework", strengthened by "the review of reports from other companies that also used the CSRD framework"; internal inputs include corporate strategy, policies, procedures and action plans.
• Phase B - identification and definition of IROs. Built on the context analysis and the previous DMA; "The outcome of the Climate Change Risk Assessment in effect at the time of the evaluation has been taken into account", and "In 2025, some of the risks identified stem from the Non-Financial Risks exercise". IROs are classified as current and/or potential, by value chain phase, and against ESRS sub-topics, with entity-specific IROs added.
• Phase C - evaluation. Applies "an internal methodology following the guidelines set out in the EFRAG Implementation Guidance on Double Materiality Assessment and in ESRS 1".

Impact materiality is assessed on severity (scale, scope and, for negative impacts, irremediability) and likelihood; "the protection and respect of human rights are a priority ... prioritizes the severity of negative human rights impacts, regardless of their likelihood of occurrence" (page 251). Current impacts are material where severity is medium-to-high; potential impacts where medium-to-high severity combines with medium-to-high probability.

Financial materiality uses "a hybrid methodology that combines internal quantitative metrics, scenario analysis, and qualitative criteria", integrating the Climate and Environmental Risk Assessment and the Non-Financial Risks assessment (page 251).

Time horizons were realigned in 2025: short term 1 year, medium term 1 to 5 years, long term beyond 5 years, "aligned with those proposed by the ISSB" (page 250).

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

Reference: pages 263-278.

BBVA prints a genuine ESRS content index in two parts within section 6.4 "Tables of contents of the ESRS":

1. "LIST OF DATA POINTS INCLUDED IN CROSS-CUTTING RULES AND IN THEMATIC RULES DERIVED FROM OTHER EU LEGISLATION" (pages 263-271), mapping each SFDR / Pillar 3 / Benchmark / EU Climate Law datapoint to a section and page range, or marking it "Non material".
2. "TABLE OF CONTENTS OF MATERIAL DISCLOSURE REQUIREMENTS INCLUDED IN THE STATEMENT OF NON-FINANCIAL INFORMATION" (pages 272-278), listing each covered DR against a section of the management report.

The second table covers: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2 and MDR-P/A/M/T); ESRS E1 (GOV-3, SBM-3, E1-1, IRO-1, E1-2 to E1-9); an "ESRS E2, E3, E4, E5" heading carrying only ESRS 2 IRO-1; ESRS S1 (SBM-2, SBM-3, S1-1 to S1-6, S1-8, S1-9, S1-12, S1-13, S1-16, S1-17); ESRS S4 (SBM-2, SBM-3, S4-1 to S4-5); and ESRS G1 (GOV-1, IRO-1, G1-1, G1-3, G1-4).

Two footnotes qualify the table (page 278):

• "Selected ESRS 2 disclosure requirements have been applied to the material entity-specific IROs identified in the double materiality analysis."
• "Given its activity, BBVA does not consider the requirements established in ESRS E1-1, paragraphs 16c, 16e and 16f, ESRS 1-3 (CapEx and OpEx, alignment with the EU Taxonomy and fossil fuel activities), ESRS E1-5, paragraph 38 (on sectors with a high climate impact), and ESRS E1-6, paragraph 50b (on the separate disclosure of emissions of certain entities) to be material and therefore they are not reported in this report."

Basis of preparation: the CSRD "had not been transposed into Spanish law as of December 31, 2025", so BBVA reports under Law 11/2018 and Law 7/2021 while "taking as a reference the new ESRS regulatory framework and making use of the new 'Quick-fix' transitional framework", following a joint CNMV/ICAC statement of 19 November 2025 (pages 19-20).

Transitional reliefs taken under Commission Delegated Regulation 2025/1416 cover certain value-chain quantitative aspects, anticipated financial effects, financial effects from transition and physical risks, and "Certain employee-related information" (pages 20-21). Confidentiality is claimed for E1-8.63 internal carbon pricing, and sensitivity for S1-4.37, S4-4.30, MDR-A69 and cybersecurity MDR-M77/MDR-T80 (page 20, footnote 4).

Transition plan for climate change mitigation

Reference: pages 46, 70-111.

The BBVA Group Transition Plan "constitutes the backbone instrument of the climate strategy, structuring the Group's response to the challenges derived from decarbonization" (page 70). It covers both the financed portfolio and own operations, with "financed emissions (Scope 3 - category 15) represent[ing] approximately 99% of the Group's total footprint" (page 70).

Financed portfolio strategy rests on five pillars: measuring the financed carbon footprint, a decarbonisation strategy, decarbonisation objectives, progress tracking, and decarbonisation of investment products (page 71). The alignment strategy is "focused on the progressive alignment of its portfolio with the objectives of the Paris Agreement, contributing to limiting global warming to 1.5°C" (page 75) and has three elements: sector alignment plans with 2030 interim targets for eleven emissions-intensive sectors following "the Guidance for Climate Target Setting for Banks of the United Nations Environment Programme Finance Initiative (UNEP-FI)"; assessment of customers' transition plans via the Transition Risk Indicator; and integration into the annual customer review and operations admission process (pages 75-76).

Approval: "the various elements that make up the Transition Plan are approved by the corresponding committees" (page 71). 2030 targets are "presented by the Global Head of Sustainability & Corporate Investment Banking for approval by the BBVA Executive Committee and Board of Directors" (page 77) after review by the Sustainability Alignment Steering Group (SASG), created in 2022 and led by the Global Head of Sustainability & CIB with the Global Heads of Global Risk Management, Commercial Client Solutions and Strategy & M&A.

Locked-in emissions are addressed explicitly (page 75): the metric "is not material regarding its own assets (scope 1 and 2) nor Category 3.11 ('Use of sold products'), with the relevant impact being concentrated in scope 3.15". BBVA acknowledges "limitations regarding the availability of counterparty data that preclude a reliable estimation" and instead reports "the weighted average maturity of its financing to high climate impact sectors, which stands at approximately 4 years".

Own operations are managed through the Global Eco-efficiency Plan; the 2021-2025 plan concluded in 2025 and a new Plan 2026-2030 was designed during 2025 (page 71).

BBVA states the requirements of "ESRS E1-1, paragraphs 16c, 16e and 16f" are not considered material given its activity (page 278). It also records that "the success of decarbonization also depends on governments, regulators, and supervisory bodies, through their public and/or sectoral policies" (page 71).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 chapter "Management of risks associated with climate change" (pages 112-131), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification (physical / transition). BBVA maintains "internal taxonomies for transition climate risks, physical climate risks, and other environmental risks (natural capital), understood as common definitions of the risk drivers and their transmission channels with potential impacts on traditional prudential risks" (page 113). A matrix on page 114 maps transition, physical and environmental drivers onto credit, real estate, market, liquidity, business and strategy, operational and reputational risk.

Methodology and exposure. The transition taxonomy ranks sectors very high to low. High Transition Risk sectors are "energy or fossil fuel producers (oil and gas, power generation, coal mining); basic industries with high emissions intensity (steel, cement); and end-user energy-consuming activities that generate emissions through their products or services (auto, aviation, and shipping)" (page 114). In 2025 the perimeter was widened to include oil and gas midstream and gas transport, distribution and supply. At 31 December 2025, 13.84% of wholesale portfolio exposure (11.7% in 2024) was HTR, equal to 7.16% of the Group, on a €291,540 million wholesale portfolio out of a Group total of €563,583 million (page 115). Physical risk: 23% of wholesale exposure (23% in 2024) is at high or very high exposure (page 117). The most relevant natural hazards "are tropical cyclones, heatwaves, wildfires, riverine and coastal floods, and drought" (page 115).

Scenarios used. Physical risk uses "sets of climate trajectories consistent with the Shared Socioeconomic Pathways (SSP) developed by the Intergovernmental Panel on Climate Change (IPCC) in its Sixth Assessment Report (AR6)": SSP2-4.5 as baseline, "leading to ~2.7 °C (2.1-3.5 °C) by the end of the century", and SSP3-7.0, "projects an average warming of ~3.6 °C (2.8-4.6 °C)". "The SSP5-8.5 scenario is considered unlikely given current policies and is therefore reserved for stress tests" (page 116). Transition risk uses "reference scenarios from the Network for Greening the Financial System (NGFS) (Net Zero, Delayed Transition, and Current Policies)" (page 118). Target setting uses IEA NZE, ISF-NZ, IMO, IAI & MPP and PNIEC scenarios (page 79).

Timing and results. "The climate risk assessment is updated semiannually and is supported by an internal scenario analysis tool that projects the financial evolution of sectors and counterparties under alternative climate pathways across different time horizons" (page 118). Transition risk is "low in the short term, medium-low in the medium term, and medium in the long term"; physical risk is "low in the short term and medium-low in the medium and long term, with geographic heterogeneity", material in the wholesale portfolios of Spain and Mexico (page 118). Horizons: short term up to 3 years, medium 3-5, long beyond 5 (page 119).

Limitations are stated: scarce and heterogeneous historical data, "structural uncertainty" in scenarios, incomplete damage functions, and methodological heterogeneity across TCFD/ISSB/NGFS (page 116).

Cross-reference: this material is also presented under ESRS 2 IRO-1 and SBM-3 in the report's own index.

Resilience in relation to climate change

Back-filled from the E1 subsection "Assessment of business model resilience" (pages 119-120) and ESRS 2 SBM-3, where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Definition and approach. "BBVA understands climate resilience as the ability to adapt in order to manage both transition and physical risks, while simultaneously capturing opportunities linked to decarbonization. In line with the option considered by the ESRS and following TCFD recommendations, BBVA evaluates its strategy on two complementary levels: (i) an orderly transition scenario that allows for opportunity capture, and (ii) scenarios with greater severity of climate risks, against which the robustness of the business model is tested" (page 119).

Integration with capital planning. "Climate scenarios are integrated into the Group's scenario governance and incorporated into the ICAAP." For transition risk the Group "includes an adverse 'climate fragmentation' scenario as a structural element of the capital plan, using a top-down approach that combines macroeconomic projections and sectoral impacts, based on NGFS scenarios, and includes potential asset valuation shocks associated with the transition (e.g., corrections in green assets)". For physical risk "a economic capital add-on is estimated for droughts in the main geographies of the footprint (Spain, Mexico, and Turkey)" (page 120).

Two analytical levers (page 120): top-down disaggregation of NGFS scenarios by sector to calibrate PD pathways and Stage 2 provisioning impacts and Stage 1 to Stage 2 transfers; and bottom-up assessment of collateral value deterioration translated into LGD.

Results and uncertainty. "The results of this calculation show that the impacts continue to be immaterial for both transition and physical risks. However, it is important to consider that methodological limitations, particularly in terms of data and scenario design, may be underestimating expected losses for the financial system" (page 120). BBVA says it "will continue refining the models to more accurately reflect the effects of climate risks as information and data evolve, applying a bottom-up scenario analysis approach".

Strategic exit stress test. "a stress test exercise has been carried out to assess the robustness and resilience of the business strategy in the event of a potential strategic exit of relationships with certain customers, assuming that they do not meet the milestones set in the developed engagement plans ... The outcome of this exercise under the most adverse scenario (considering a complete exit of these customers) highlights the strength of the business strategy" (page 120).

Capacity to adapt. Resilience "is reinforced by the fact that BBVA has established sustainability as one of its six strategic priorities", with 2030 interim targets across ten named sectors plus real estate "alongside an eco-efficiency plan to reduce its operational footprint" (page 120). Adaptation is also pursued through the BBVA Adapta tool launched in 2025 (page 116) and, in the retail book, through the High Physical Risk metric within the Risk Appetite Framework (pages 121, 126).

Policies related to climate change mitigation and adaptation

Reference: pages 49-58, 61-62, 112-131.

The anchor policy is the Sustainability General Policy, "revised and approved by the Board of Directors in September 2022" (page 55) and, per the environmental chapter, "updated in 2022 ... which establishes the processes for managing impacts, risks, and opportunities related to climate change mitigation and adaptation. This policy encompasses areas such as sustainable business channeling, the management of physical and transition risks, decarbonization, and the use of renewable energy" (page 62). It unifies the former Corporate Social Responsibility Policies, identifies the Group's main stakeholders, and sets six principles, the first three of which are climate-relevant: supporting customers' transition; "Progressively integrating sustainability opportunities and risks into its strategy, business, processes, and risk management"; and "Ensuring the direct and indirect environmental and social impact ... by managing the impact of GHG emissions from the financed portfolio and the services offered to customers" (page 55). "The Board of Directors, as BBVA's highest supervisory body, oversees the implementation of this Policy" and it is published on bbva.com (page 56).

Supporting policies and standards named in the climate chapter (pages 122-123):

• Environmental and Social Framework, applicable to CIB customers and, since December 2024, to Business segment customers, covering mining, agribusiness, energy, infrastructure and defence; during 2025 "257 companies, both existing and new customers, were assessed" (page 128).
• Wholesale Credit Risk Management Policy and Standard, which "incorporates the identification, management, and monitoring of risks and opportunities associated with environmental aspects as a core part of its risk management strategy".
• Retail Credit Risk Management Policy and Standard, covering transition and physical risk in mortgage, SME and auto loan portfolios.
• Collateral Standard, which treats "the potential loss of value of real estate collateral due to climate risk - both transition and physical - as well as the adequacy of associated insurance coverage".
• Measures extended to Market and Counterparty Risk, Interest Rate Risk, Banking Book Equity Risk and Liquidity and Funding Risk policies.
• The ESG controversy management procedure implemented in 2024 for CIB and Enterprise customers, and adherence to the Equator Principles since 2004, applying EP4 to five product types (pages 128-129).

Coal is addressed by an exclusion commitment: BBVA will eliminate exposure "to customers belonging to corporate groups with thermal coal mining or thermal coal-fired power generation activities by 2030 in developed countries and by 2040 globally" under the Environmental and Social Framework (page 80).

Actions and resources in relation to climate change policies

Reference: pages 37-48, 63-68, 70-111, 112-131.

Financed portfolio actions. BBVA operationalises decarbonisation through named tools (page 76): the Transition Risk Indicator (TRi), which "allows for the evaluation of each customer's current emissions profile and the maturity of their decarbonization strategies"; a Sustainability client toolkit; a management dashboard for sectoral Transition Plans using the PACTA methodology; and a "What if" simulator that "allows for the real-time evaluation of the potential impact of transactions on both each customer's decarbonization curve and the BBVA Group's portfolio curve". By 2025, "88% of the loan portfolio in emissions-intensive sectors already has a Transition Risk Indicator" (page 39), and EPC coverage in the Spanish mortgage book reached "84.8% of the portfolio's EAD with actual or estimated data" (page 124).

Customer engagement. The support model combines strategic dialogue, specialised advice, a sustainable value proposition and sectoral participation; progress is "submitted to the relevant supervisory body (CIB Engagement Oversight Group - CEOG)" and "In cases where progress does not align with established objectives, mitigation measures may be considered, ranging from limiting the growth of exposure" (page 77).

Business channelled. €134 billion in 2025 (+44%), of which €104 billion environmental (pages 40-41, 63). Within the environmental total: corporates €63bn (+37%), enterprises €37bn, retail €4bn (page 64). Corporate financing and transactional banking channelled €49 billion, capital markets €9 billion, and sustainable project finance around €4 billion including "€3 billion in renewable energy projects, mainly solar and wind" and "€500 million in new clean technology projects ... carbon capture and storage projects, as well as the financing of a gigafactory for batteries" (page 65).

Own operations actions (pages 106-108): renewable electricity procurement through PPAs in Spain, Mexico, Turkey and Argentina, Guarantees of Origin in Spain and Portugal, IRECs in Mexico, Turkey, Peru, Colombia and Argentina, and on-site photovoltaic and solar thermal generation; energy saving measures in property management; fleet renewal "with traditional fuels by hybrid and electric fleets"; and ISO 14001:2015 and Zero Waste certification. In 2025 BBVA purchased Sustainable Aviation Fuel certificates through Iberia's 'Círculo SAF', acquiring "656 tons of SAF in 2025, equivalent to 2,367 tCO₂e" (page 109), and operates 465 charging points for electric and plug-in hybrid vehicles at Group buildings.

Resources. Sustainability-related projects under the Single Development Agenda "totaled €42 million in 2025 (€52.5 million in 2024)", spanning transformational initiatives in sustainable sectors, physical and transition risk controls, financed-emissions reduction, positive social impact, ESG reporting requirements and sustainability-based growth (page 58).

BBVA states that "ESRS 1-3 (CapEx and OpEx, alignment with the EU Taxonomy and fossil fuel activities)" is not considered material given its activity (page 278).

Targets related to climate change mitigation and adaptation

Reference: pages 46, 78-80, 100-111.

Financed portfolio: 2030 interim targets for eleven sectors, applied at consolidated Group level except real estate, which applies only to Spain (page 78). The table on page 79 gives metric, emissions scope, scenario, base year, 2030 objective, target reduction, 2024 and 2025 market data, reduction versus base year, methodology and attributed value-chain emissions. Selected rows:

• Oil and Gas (upstream) - absolute scope 1+2+3 emissions, IEA_NZE, target 5.7 MtCO2e, a (59)% reduction; 2025 reduction versus base year (30)%.
• Power (generation) - kg CO2e/MWh, IEA_NZE, 221 to 107, (52)%; 2025 market data 103.
• Auto (manufacturers) - g CO2/v-km, IEA_NZE, 205 to 110, (46)%.
• Steel - kg CO2e/t steel, ISF-NZ, 1,270 to 984, (23)%.
• Cement - kg CO2e/t cement, IEA_NZE, 700 to 579, (17)%.
• Coal (thermal) - no reduction target; "BBVA has set the goal of phasing out its exposure to coal customers by 2030 in developed countries and by 2040 globally". Coal-weighted loan portfolio €1,341 million at 31 December 2025, of which €81 million with customers "that have limited expectations of making the transition in time".
• Aviation, Shipping, Aluminium, Residential and Commercial real estate each carry their own metric, scenario (ISF-NZ, IMO, IAI&MPP, PNIEC) and pathway.

Coverage: "As of December 2025, the emissions coverage achieved is 37.6 million tons of CO2e of scopes 1 and 2 for all sectors with alignment metrics ... This represents 52.14% of total financed emissions. In terms of exposure ... the coverage percentage is 31.96%" (page 74). The comparable 2024 figures were 38.6 MtCO2e, 58.28% and 43.36%.

Own operations: the Global Eco-efficiency Plan 2021-2025 (2019 base year) reported 2025 achievement of 99.5% renewable electricity against a 77% target, electricity per employee (22)% against (10)%, water per employee (36)% against (11)%, and scope 1 and 2 emissions 41,386 tCO2e, (83)% versus 2019 against a (67)% target (page 106). The new Plan 2026-2030 (2024 baseline) targets 100% renewable electricity, (7)% electricity and energy per employee, (8)% water, (10)% paper, (23)% net waste, (8)% scope 1, (100)% scope 2 market-based, (30)% scope 3.5 and 67% environmentally certified area (page 108).

Ambition caveats. For own operations, "the definition of targets has not been based on explicit climate scenario methodologies", though the aggregate "reflects an ambition that, in its outcome, is consistent with the general criteria associated with the global pathway to limit the increase in temperature to below 1.5°C", underpinned by "a cumulative reduction in scope 1 and 2 emissions of over 80% by 2030 compared to 2019" and net zero by 2050 (page 108). For the portfolio, "the baseline for these metrics may change" and "achieving these targets is not expected to be a linear process in the short term" (page 80). No absolute Group-wide financed-emissions target is set, and BBVA "has not yet set targets for the agricultural sector due to the lack of a universal framework" (page 80).

Energy consumption and mix

Reference: pages 100-111 (table page 105).

ENERGY CONSUMPTION AND COMBINATION (BBVA GROUP), page 105:

Fossil consumption "includes non-renewable electricity consumption and the consumption of fossil fuels (natural gas, liquefied petroleum gas (LPG) and diesel), as well as fuels consumed by vehicle fleets". In 2025 self-generated renewable energy was 2,608 MWh "while self-generated non-renewable energy totaled 59,075 MWh" (page 105, footnotes 2-3).

Electricity mix. "99.5% of the electricity consumed by BBVA is renewable ... of the total renewable electricity, 12.8% is purchased via IRECs, 31.0% via PPAs, 55.9% through guarantees of origin and 0.4% comes from self-consumption installations" (page 103). Electricity is "100% renewable in Colombia, Spain, Mexico, Peru, Turkey, Portugal, Uruguay and Argentina, 90% in the Netherlands and Venezuela, and 75% in Romania" (page 103, footnote 24).

Intensity. Electricity consumption per employee fell to 5.17 MWh (5.29 in 2024) and energy consumption per employee to 6.05 MWh (6.12), reductions of (22)% and (19)% against 2019 (page 106).

Perimeter. Energy data cover "Spain, Mexico, Turkey, Peru, Colombia, Argentina, Uruguay, Portugal, Venezuela, Romania, and the Netherlands"; Chile, Bolivia, Switzerland, the United States, Brazil and BBVA branches outside Spain are excluded, representing "3% of the total BBVA Group workforce" (page 105). 2024 figures were restated "because the estimates included at the close of the 2024 financial year have been replaced with the actual consumption data available after the publication of that report".

BBVA states the "ESRS E1-5, paragraph 38 (on sectors with a high climate impact)" requirement is not considered material and is not reported (page 278).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 71-99 (financed emissions) and 100-111 (own operations).

Own operations and other scope 3, page 101 (2019 base year):

The rises in 3.6 and 3.7 reflect scope expansion: business travel now includes "travel on modes of transport not previously included (other than air and rail) and hotel stays", and commuting now includes teleworking (page 100). "99.4% of the emissions generated by BBVA are CO2, while CH4 and N2O emissions represent 0.1% and 0.5% respectively" (page 101).

Financed emissions (scope 3.15), calculated on the PCAF methodology using financial control: 214.3 MtCO2e in 2025 (190.6 in 2024), of which scope 1+2 73.2 Mt and scope 3 141.1 Mt (pages 72-74). Loans to companies account for 201.00 Mt. Geographic split of total financed emissions: Spain 32%, Mexico 25%, Turkey 25%, Colombia 5%, Peru 3%, Argentina 3% (page 72). Intensity was 735 tCO2e/€M (690 in 2024) on a scope 1+2+3 basis and 251 on scope 1+2, with a PCAF data quality score of 3.7 (3.8 in 2024).

BBVA explains the increase: "The increase in financed emissions in 2025 (12.4%) is due both to the growth in lending (accounting for approximately 45% of the increase) and to a rise in the intensity of financed emissions as a result of improvements in the processes for capturing customer-reported emissions data" (page 73). The perimeter covers BBVA S.A. (excluding Portugal), BBVA Mexico, Colombia, Peru, Argentina and Garanti BBVA.

Methodologies and emission factor sources (MITECO for Spain, DEFRA, IEA, IPCC, CEDA, European Residual Mixes, EPA) are set out on pages 102-104, including that supplier-specific factors covered 26% of category 3.1 emissions (16% in 2024) and 15% of category 3.2 (12%).

BBVA states that "ESRS E1-6, paragraph 50b (on the separate disclosure of emissions of certain entities)" is not considered material and is not reported (page 278).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 109-110.

BBVA discloses no GHG removals within its own operations or value chain. Instead it "contributes to the decarbonization of the economy, in a complementary way beyond its value chain, through the purchase and retirement of carbon credits", buying and retiring credits "in an amount equivalent to its reported CO2 emissions from the categories over which it has direct control (scopes 1 and 2, and scope 3 categories 5, 6, and 7)", after deducting the reduction from Sustainable Aviation Fuel certificates (page 109). Venezuela is excluded.

Quality criteria: credits must be "certified under the highest quality standards, such as VCS (Verra's Verified Carbon Standard), Gold Standard, American Carbon Registry (ACR), Climate Action Reserve (CAR), or Plan Vivo", issued "five years ago or less", and "since 2023, the projects must be carbon capture or removal projects". An internal Voluntary Carbon Market standard assesses "additionally, permanence, and other environmental and social aspects" (page 109).

CARBON CREDITS CANCELLED (BBVA GROUP), page 110:

"All removal credits retired are for nature-based solutions projects." Credits retired in 2025 relate to the 2024 footprint plus outstanding 2023 and 2022 balances, across six named projects: Atopixco Ejido (15,050), Zacualtipán Ejido (12,894), Forest Carbon Project La Catedral (43,836), X-pichil Forest Restoration (53,345) and Santa Elena Forest Restoration (37,179) in Mexico, and Cumare Carbon Project in Colombia (5,190), plus 38 credits for the 2024 General Shareholders' Meeting (page 110).

Forward commitments: 247,348 credits are estimated to be retired in 2026 for the 2025 footprint plus pending Mexican and AGM balances (page 110). In 2025 BBVA Mexico "formalized a long-term agreement with a local provider for the development of a reforestation project in the state of Campeche" with credits retired annually from 2026 (page 109).

BBVA also participates in EU ETS auctions, is an investor in the trading platform Carbonplace, sat on the VCMI Finance Advisory Group between January and August 2025, and is a member of the EEX Global Carbon Index Family Advisory Board and of LIFE COASE (pages 110-111).

Internal carbon pricing

Reference: page 111.

BBVA operates an internal carbon price tied to its carbon-credit budgeting. "The cost of purchasing carbon credits annually is assumed locally in the Group's various geographies (including the Holding) based on their individual carbon footprints, generating an internal carbon pricing mechanism and thus creating incentives for emissions reductions at the local level" (page 111). The geographies covered are Argentina, Colombia, Spain (including Holding), Mexico, Peru, Portugal, Turkey, Netherlands, Romania and Uruguay (footnote 35).

Each unit "must include a line item in its annual budget for the purchase of carbon credits based on: The estimated annual carbon footprint for scopes 1 and 2 and categories 5, 6, and 7 of scope 3" and "The estimated market price of a carbon credit for CO2 capture in the regions where BBVA operates".

Price: "For 2025, the internal carbon price was maintained at €32 per ton, based on expected growth in voluntary carbon markets. This amount represents the budgeted price per carbon credit to be purchased. The final price depends on the market price at the time of purchase." BBVA adds in footnote 36 that "The actual purchase price is not specified due to confidentiality agreements".

The scope of the mechanism is therefore the operational footprint only. It is not applied to the financed portfolio, where the Group instead uses the Transition Risk Indicator, sector alignment metrics and Risk Appetite Framework limits (pages 121-123).

Limitation on the disclosure. BBVA states that "the information required by ESRS E1-8.63 regarding the internal carbon pricing system has been considered confidential" (page 20, footnote 4), so the full datapoint set for this DR is withheld on confidentiality grounds even though the DR is listed in the ESRS content index (page 275).

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

Reference: pages 112-131. The ESRS content index lists this DR with the note "Phase-in for monetary amounts requirements" alongside the section reference (page 275), and the datapoint table maps E1-9 paragraphs 66, 66(a), 66(c) and 67(c) to pages 112-131 while marking paragraph 69 (degree of exposure of the climate-related opportunities portfolio) as "Phase-in" (page 265).

Physical risk exposure. The table "POTENTIAL PHYSICAL RISK INDICATORS LINKED TO CLIMATE CHANGE: EXPOSURES SUBJECT TO PHYSICAL RISK" (page 126) gives gross carrying amount and amounts subject to chronic, acute, and combined chronic and acute risks by sector for 2025 and 2024. Examples: manufacturing industry gross carrying amount €60,653 million with €10,994 million subject to physical risk; loans secured by residential real estate €101,583 million with €11,613 million; loans secured by commercial real estate €32,113 million with €5,346 million; accommodation and catering €10,382 million with €5,278 million; electricity, gas, steam and air conditioning €20,418 million with €7,405 million.

A High Physical Risk (HPR) metric within the Risk Appetite Framework "allows for the quantification and monitoring of the exposure of mortgage portfolio assets to climate-related physical risks with a forward-looking approach ... considering the SSP2-4.5 scenario and a time horizon up to 2040", applied to retail mortgages in Spain, Mexico, Colombia, Peru and Turkey (page 126).

Transition risk exposure. HTR sectors represent 13.84% of wholesale portfolio exposure (7.16% of the Group) on a €291,540 million wholesale portfolio, versus 11.7% and 5.9% in 2024 (page 115). Small business exposure at high or very high transition risk is "approximately 2.80% of the total small business portfolio (2.10% in 2024)". Sector detail is charted on page 115 (oil and gas 4.87%, electricity generation 3.79%, auto 2.62%, transport 0.79%, steel 1.01%, cement 0.56%, agrochemicals 0.33%, coal mining 0.02% of wholesale EAD).

Energy efficiency of collateral. Spanish mortgage portfolio coverage by EPC rating is charted on page 125, with A-rated exposure at 3.6% in 2025 and total coverage of 84.8% of EAD with actual or estimated data (page 124).

Monetary amounts of anticipated effects are not quantified. The Group states it takes the transition periods in Commission Delegated Regulation 2025/1416 for "The anticipated financial effects related to the material impacts, risks, and opportunities identified in the double materiality analysis" and "The financial effects related to revenues derived from activities affected by transition and physical risks" (pages 20-21). Its own capital modelling concludes that "the impacts continue to be immaterial for both transition and physical risks", while warning that "methodological limitations, particularly in terms of data and scenario design, may be underestimating expected losses for the financial system" (page 120).

Policies related to own workforce

Reference: pages 49-58, 148-171. The index maps S1-1 to Sustainability governance and to all six own-workforce sections (page 276).

The Sustainability General Policy commits the Group to "Respecting the dignity of persons and the human rights inherent to them in accordance with various widely recognized national or international commitments to which it has adhered" (page 55). Workforce-specific instruments named in the chapter are:

• BBVA Code of Conduct, approved by the Board and last updated in July 2024, which "expressly prohibits any type of discrimination based on sex, race, age, or sexual orientation" (pages 163, 208, 211).
• Corporate Culture Guide, applicable to entities covering 96.3% of the workforce at year-end 2025, which "establishes the framework for fostering and consolidating an organizational culture aligned with the Group's values" (page 148).
• BBVA Diversity Guidelines, published in 2022 and approved by the Global Head of Talent & Culture, applicable to 98.0% of the official workforce. They "explicitly prohibit discrimination based on race, sex, age, or any other grounds" and define five diversity groups: gender, LGBTQI+, generational, people with disabilities, and cultural and ethnic diversity (page 163).
• Equality Plan, "signed in Spain with employee representatives in 2023", plus "prevention and action protocols against sexual harassment in the main geographies where it operates" (page 163).
• General Remuneration Policy of the BBVA Group, approved by the Board on 29 March 2023, and BBVA's Directors' Remuneration Policy, approved by the AGM on 17 March 2023 for 2023-2026 (pages 154-155). Both are "gender-neutral, reflecting equal compensation for the same or equal value of work" (page 156).
• Occupational Risk Prevention Plan, "integrated into the Safety, Health and Wellbeing Standard, which establishes global principles and is adapted in each country to local regulations and needs" (page 169).
• General Policy for managing communications in the Whistleblowing Channel and protecting whistleblowers, approved by the Board in 2023 (page 212).

BBVA states it has "carried out two global Human Rights Due Diligence exercises as part of its commitment to compliance with applicable laws and to respect for internationally recognized Human Rights, taking the United Nations Guiding Principles on Business and Human Rights as its reference framework" (page 182, footnote 56).

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

Reference: pages 26-27, 148-171.

Employee channels named in the stakeholder section are the RCP survey, "Moment that Matters", the corporate intranet, the Employee Support Service (SAE), the Talent & Culture Advisor Channel and the Whistleblowing Channel, "which support communication, allowing each person to freely share their concerns or ideas at any time" (page 27). Main topics engaged on are corporate values, professional development and mobility, health, well-being and work-life balance, and diversity and inclusion.

In 2025 the internal RCP survey was launched globally "to assess how employees interact and connect across the value chain", with over 31,000 employees participating and a consolidated score of 4.35 out of 5; "the survey's main objective is to enable each team to identify improvement plans" (pages 145, 149). At the eighth Values Day in October 2025, "More than 53,000 employees (43.5% of the workforce) accessed the internal Values Day website", around 25,000 completed the activities and "more than 13,000 teams registered their 'radical manifesto'" (page 149).

The global culture team "fosters active employee participation in the design and monitoring of initiatives through workshops, interviews, and ad hoc surveys, from the design phase (using customer-centric methodologies such as Design Thinking) and testing to continuous improvement after implementation. In parallel, metrics or indicators are defined for each initiative to track its progress" (page 148).

Worker representation. Employees' right to consultation and participation on health and safety "is exercised and developed through union representation or stakeholder groups on the different existing committees", and "The percentage of Group employees represented on health and safety committees amounts to 99.2%" (page 169). In Spain "Employee representatives are elected every four years by personal, free, direct, and secret ballot" (page 167). BBVA also runs Employee Resource Groups across all five diversity areas, which "work in coordination with BBVA's diversity teams, providing them with peer feedback, advice, and specialized support" (page 164).

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

Reference: pages 144-180, 212-213. The index maps S1-3 to Own Workforce and to the Business conduct / Whistleblowing Channel section (page 276).

The Whistleblowing Channel is the Group's principal grievance mechanism. Employees, "as well as customers, suppliers, or members of other stakeholders, can confidentially, and anonymously if they wish, report any behavior that violates the Code of Conduct or applicable law, including human rights abuses" (page 212). Since 2021 BBVA has run "a global Whistleblowing Channel tool, implemented across most of the geographies where it operates and managed by an external provider", available on the intranet and to third parties at a public link, "24 hours a day, 365 days a year, in Spanish and English".

The governing General Policy for managing communications in the Whistleblowing Channel and protecting whistleblowers, approved by the Board in 2023, "defines the operating principles of the Channel, the protection measures for both whistleblowers and those affected, and regulates its management in compliance with Law 2/2023 of February 20, on the protection of individuals who report regulatory violations and the fight against corruption in Spain", with "specific measures designed to strengthen confidentiality and prevent retaliation". It "is reviewed annually and published on the internal website" (page 212).

Case handling is formalised in phases; "Once the investigation has been completed, a reasoned conclusion is issued as to whether or not breaches have occurred, and the corresponding measures are promoted, which may include disciplinary actions adopted by an independent committee. Whistleblowers and affected persons are informed of the resolution of the case" (page 212). The Compliance function guarantees "the presumption of innocence, protection of personal data, the right to honor, defense, information and to be heard, as well as protection against retaliation or other adverse consequences for reports made in good faith" (page 213).

Employee-specific channels are the Employee Support Service (SAE) and the Talent & Culture Advisor Channel, "to raise queries, concerns or suggestions" (page 59). Harassment protocols provide a further remediation route: in 2025 the sexual harassment protocol "was activated on 70 occasions (63 in 2024), with sexual harassment being confirmed in 26 cases (19 in 2024), all of which resulted in the dismissal of the individuals reported" (page 163).

Taking action on material impacts on own workforce

Reference: pages 144-171.

BBVA's four material own-workforce IROs are all potential short-term positive impacts (page 33), so the actions described are directed at realising them.

Cultural transformation (pages 145, 149): the global RCP survey with over 31,000 participants; the eighth Values Day ("Radical Edition"); manager workshops "designed to consolidate a Radical Client Perspective (RCP) mindset"; and an evolved appraisal process "incorporating empathy and service excellence as key competencies, which will be assessed annually for all employees".

Strategic talent planning (page 145): reskilling and upskilling for an AI-transformed organisation, with "over 280,000 hours of training in Gen AI and more than 105,000 employees trained through the Gemini Express course".

Attracting and developing top talent (page 145): a personalised value proposition for sustained outstanding talent; "a personalized development plan" available to all employees; and international mobility, in which "370 employees took part in international mobility programs this year".

Quality employment (pages 149-152): a corporate professional development model implemented across all Group banks and certain subsidiaries covering 93.2% of the official workforce, structured around Know Yourself, and an annual 360° review delivering "a report that integrates competencies, performance, potential, and talent map, along with a personalized growth plan for each employee". Voluntary turnover "stood at 4.3% at the end of 2025" (page 146).

Equal opportunities (pages 164-165): the "I Am Female Talent" programme; LGBTQ+ visibility initiatives; the fourth "Added Value" Awards for people over 55; disability inclusion including "the hiring of professionals with autism and Asperger's syndrome in technology areas", internship programmes for people with Down syndrome, an agreement with the ONCE Foundation in Spain "through which it will integrate people with disabilities into its retail network over the next five years", and five job fairs in Mexico; and self-identification and specialised training for employees of ethnic origin in Colombia.

Health and wellbeing: the "You Move Us" programme with "Work Better" and "Enjoy Life" pillars, including a psychological support programme for employees and their families, cancer prevention campaigns and cardiovascular risk campaigns (pages 170-171). Effectiveness is measured by satisfaction surveys and outcomes; the obesity prevention campaign for participants with BMI above 35 "achieved an average weight loss of 8.3 kg" within three months (page 171).

Limitation: BBVA states that the information on the management of resources for own employees "referred to in ESRS S1-4.37 ... has been considered sensitive" and is therefore not disclosed (page 20, footnote 4).

Targets related to own workforce

Reference: pages 145, 165, 157-158.

The principal quantified own-workforce target is on gender balance in management. Having achieved 40% women on the Board in 2023 and surpassed a 35% management-team target in 2024 (35.4%), "in February 2024, a new target of 36.8% women in the management team was set for the end of 2026" (page 165). BBVA describes the governance around it: "As this is a strategic objective of Talent & Culture, it is monitored monthly by BBVA's diversity team and reported quarterly to senior management. The Chairman and CEO of the Group regularly review the data on the evolution of this indicator at different levels of the organization to assess whether the measures implemented are yielding positive results."

Progress: "As of year-end 2025, the percentage reached 36.1%, confirming a growth trajectory aligned with the achievement of the 2026 target" (page 165), up from 35.4% in 2024 (page 145).

The target is reinforced through remuneration: "an indicator measuring the evolution of the percentage of women in management positions across the BBVA Group is included" among the long-term incentive indicators for the Identified Collective, weighted 5% and measured to year-end 2028 (page 158).

The Board diversity target is also stated as met: at the close of 2025 the Board "is composed of 46.7% women and 53.3% men, meeting the target of 40% representation of the least represented gender established in the Board of Directors' Selection, Suitability, and Diversity Policy" (page 49).

Beyond gender balance, the chapter reports monitored indicators rather than numerical targets - voluntary turnover (4.3%), training hours per employee (57.5), employees receiving training (99.6%) and performance-evaluation participation (97% of men and women) - with Talent & Culture teams "responsible for its regular implementation, monitoring, and subsequent feedback collection, supported by activity metrics shared monthly in internal forums" (pages 146, 149, 152). No target is stated for the pay gap, health and safety or turnover.

Characteristics of the undertaking's employees

Reference: pages 172-180.

Headcount at 31 December 2025: 127,174 (125,916 in 2024) (page 172). By country: Spain 29,479; Mexico 47,745; Turkey 21,725; South America 24,511 (Argentina 6,739, Colombia 6,516, Peru 7,864, Chile 862, Uruguay 555, Venezuela 1,867, Bolivia 35, Brazil 73); other 3,714, of which the United States 667, Romania 1,192, Portugal 408, United Kingdom 375, Netherlands 286 and China 193.

By gender (page 173): female 65,425, male 61,749; "Other" and "Not reported" both nil. By geography, women outnumber men everywhere except Spain (14,635 female to 14,844 male).

By contract type (page 174):

Group averages by contract type are 96.9% permanent full-time, 0.1% permanent part-time and 3.0% temporary (page 173). Temporary contracts are concentrated in Mexico (4.7%) and South America (5.2%).

By age (page 174): average age 38.1 (37.8 in 2024); under 30, 28,286; 30-50, 81,599; over 50, 17,289. Spain has the oldest workforce (average 44) and Mexico the youngest (35).

By professional category (pages 175-176): management team 4.9% of employees, managers 35.6%, other employees 59.6%. In headcount terms, 6,196 management team, 44,866 managers and 72,131 other employees on permanent full-time contracts.

Departures in Spain (page 178) are broken down by type: retirement and early retirement 139, voluntary redundancies 20, resignations 387, dismissals 78. Total turnover rate and distribution by gender are given on page 180.

BBVA notes that "The most relevant line item in the BBVA Group's Consolidated Profit and Loss Accounts containing financial data related to its employees is 'Personnel expense' which is included within 'Administrative costs'" (page 172). Several breakdowns carry the note "Information provided to comply with explicit requirements of Law 11/2018".

Collective bargaining coverage and social dialogue

Reference: pages 166-168.

"Within the Group, 42.7% of the workforce is covered by collective bargaining agreements (corresponding to what is described in points two and three of the regulatory framework above), while the remaining 57.3% are governed by conditions individually agreed upon" (page 166). The framework has four tiers: local labour regulations; sectoral agreements with unions (in Spain, the Banking Collective Bargaining Agreement, which applies to BBVA, S.A.); bilateral company-union agreements; and unilateral measures by each entity.

The COLLECTIVE BARGAINING COVERAGE AND SOCIAL DIALOGUE table (page 167) bands coverage by geography: Spain 80-100% for both employees and workplace representation in the EEA; South America 40-59%; Mexico 20-39%; Turkey 0-19%.

Country detail (pages 167-168):

• Spain - "all BBVA workforce has the recognized right to freely join and participate in union activities, without any discrimination based on membership or participation. Employee representatives are elected every four years by personal, free, direct, and secret ballot." Senior Management is excluded from the sectoral agreement.
• Mexico and Peru - the collective agreement "regulates the working conditions of employees who freely choose to unionize", with non-unionised staff on individual contracts and internal policies.
• Colombia - a collective bargaining agreement covers unionised workers and a Collective Pact covers the non-unionised; "The benefits of both agreements are equivalent, arise from a negotiation process based on social dialogue, and the decision to belong to one group or the other depends on the employee."
• Argentina, Uruguay and Venezuela - the agreement "applies to 100% of the workforce (except for members of senior management), regardless of whether they are unionized or not". Portugal - 100% at BBVA Portugal.
• Turkey, the United States, Chile, Switzerland and Bolivia - "there are no union representatives, so the working conditions of workers are applied according to what is agreed in the employment contracts and the internal policy of each company."

To govern this, "BBVA has local Labor Relations and Advisory teams in each geography. In companies without dedicated teams, specialized external lawyers are hired", supported by "a global team with a comprehensive view of labor issues" (page 166). The chapter covers entities representing 98.7% of the official workforce (footnote 52).

Diversity metrics

Reference: pages 163-165, 173-176.

Governance bodies (page 165):

Executive directors are counted in both rows. The Board meets "the target of 40% representation of the least represented gender established in the Board of Directors' Selection, Suitability, and Diversity Policy" (page 49); it also includes members from seven countries with 40% non-Spanish directors (page 50).

Management team: women reached 36.1% at year-end 2025, up from 35.4% in 2024 and progressing toward the 36.8% target for end-2026 (pages 145, 165).

Workforce gender split (page 173): 65,425 women (51.4%) and 61,749 men; women are the majority in Mexico, Turkey and South America.

Age distribution across categories (page 175): in the Group average, the management team is 0.1% under 30, 64.1% aged 30-50 and 35.8% over 50; managers 9.8% / 75.2% / 15.0%; other employees 31.5% / 57.6% / 10.9%. The management team is 4.9% of the workforce (4.6% in 2024).

Persons with disabilities: 1,169 employees, 0.9% of the workforce (page 164).

Discrimination and harassment: the sexual harassment protocol was activated 70 times in 2025 (63 in 2024) with 26 confirmed cases, all leading to dismissal; the workplace harassment protocol was activated 111 times (54) with one confirmed; the protocol for harassment based on sexual orientation, identity and gender expression was not activated (once in 2024). "During 2025 and 2024, there were no final sanctions or fines imposed for cases of discrimination or harassment" (page 163).

Persons with disabilities

Reference: pages 163-165.

"In 2025, the BBVA Group had a total of 1,169 employees with disabilities (1,046 in 2024), representing 0.9% of its total workforce, a 0.1% more than in 2024" (page 164). The figure is disclosed within the Equal opportunities section, which the ESRS content index maps to S1-12 (page 277).

People with disabilities are one of the five diversity groups defined in the BBVA Diversity Guidelines, alongside gender, LGBTQI+, generational, and cultural and ethnic diversity (page 163). The Guidelines "explicitly prohibit discrimination based on race, sex, age, or any other grounds" and apply to 98.0% of the official workforce; the Group's diversity teams "are responsible for ensuring compliance with these guidelines and proposing updates when necessary".

Actions in 2025 (page 164): "BBVA reaffirms its commitment to the employment inclusion of people with disabilities and has implemented various initiatives to facilitate their integration into the organization, both in Spain and in other geographies of the Group. These initiatives include the hiring of professionals with autism and Asperger's syndrome in technology areas, as well as internship programs for people with Down syndrome. Furthermore, BBVA has signed an agreement in Spain with the ONCE Foundation through which it will integrate people with disabilities into its retail network over the next five years. In Mexico, the bank also has an ambitious program to incorporate people with disabilities into its offices, and throughout 2025, five job fairs were organized specifically for hiring people with disabilities."

An Employee Resource Group exists for people with disabilities, one of five such employee-driven communities that "work in coordination with BBVA's diversity teams, providing them with peer feedback, advice, and specialized support in their areas of expertise" (page 164).

Accessibility also extends to product design: a simplified version of the BBVA App has been launched for seniors, and the Group states that digital solutions must meet "the needs of people with disabilities or technological barriers" (pages 190, 192). No breakdown of employees with disabilities by country or category is given, and BBVA notes the calculation perimeters excluded from its diversity reporting in footnote 49 (page 163).

Training and skills development metrics

Reference: pages 149-153.

BASIC TRAINING DATA (BBVA GROUP), page 152:

Investment per employee uses the total year-end workforce; hours per employee divide total training hours by "the Group's total workforce with access to the training platform at the end of the year". BBVA Campus "is available to employees of all banks and most subsidiaries, which together represent 99.8% of the Group's official workforce at the end of 2025" (footnote 48). Average training hours by gender are tabulated on page 153.

Performance reviews (page 152): 97% of male and 97% of female employees "participated in performance evaluations" under the Professional Development Model in the entities where it is implemented; "Based on the total workforce at year-end, the figures are 90% for men and 92% for women in 2025, and 89% for men and 91% for women in 2024."

Content focus in 2025 (page 152):

• Sustainability - "the training catalog has been updated and expanded, enabling teams to integrate environmental, social, and governance (ESG) criteria into their daily operations", delivered through regional plans "with a total of over 66,000 hours of training delivered. In addition, 287 professionals have completed certification in this area."
• Artificial intelligence - "more than 105,000 employees trained in the Gemini Express initiative - the most successful course in BBVA's history in its first week of launch - in addition to other AI programs that together exceed 280,000 hours of training."
• Radical Client Perspective - a cross-functional programme for all employees, complemented by "specific, localized training sessions for specialized groups who have accumulated more than 120,000 hours of training."

The model is personalised: "A Personalized Growth Plan has been created for the entire BBVA Group, which, based on data from each employee's performance review report, offers individualized learning pathways designed to accelerate their growth." The underlying professional development model is implemented across entities representing 93.2% of the official workforce (page 149, footnote 46).

Compensation metrics (pay gap and total compensation)

Reference: pages 154-162. Titled "Remuneration parameters (pay gap and total remuneration)" in the index (page 277).

Gross pay gap (page 159): calculated as the difference between men's and women's gross pay as a percentage of men's, including base salary, salary supplements (excluding mobility, housing and expatriation) and target variable remuneration.

Calculated on 99.7% of the workforce. BBVA qualifies the measure: "the gross gender pay gap does not allow for a comparison of the remuneration of men and women performing similar functions, but rather compares the remuneration of men and women in different roles, and therefore is not representative of gender discrimination."

Adjusted pay gap (median, page 160), comparing men and women in the same positions and covering 89.4% of employees: BBVA Group 0.3% (0.6% in 2024); Spain 1.0%, Mexico (0.6)%, Turkey 0.9%, Colombia 2.2%, Peru 0.5%, Argentina 3.3%, Venezuela 1.2%, Chile (3.0)%, Uruguay 3.3%.

Annual total remuneration ratio (page 162), the ratio of the highest-paid person to the median in each geography, including fixed pay, accrued variable pay and pension contributions: Spain 119.1 (124.5 in 2024), Mexico 210.9 (210.9), Turkey 130.9 (142.2), Colombia 80.1, Peru 118.4, Argentina 49.7, Chile 42.3, Uruguay 5.0, Venezuela 176.4. The 2025 figure uses "an estimate of the variable remuneration corresponding to 2025".

Senior management: "The average total remuneration of BBVA's senior management (excluding executive directors) in 2025 was €2,426 thousand for men (€2,442 thousand in 2024) and €2,053 thousand for women (€1,953 thousand in 2024)" (page 161).

Average remuneration by professional category, gender, age and geography is tabulated on pages 160-161. BBVA attributes remaining differences to "the varied composition of each professional category, as well as other factors, such as seniority ... [and] the unequal distribution of men and women in higher-paying positions or the higher proportion of women in countries with lower average compensation", and notes that falls in Argentina reflect "the depreciation of the Argentine peso against the euro" (pages 161-162).

Incidents, complaints and severe human rights impacts

Reference: pages 163-165, 166-168, 212-213.

Harassment and discrimination protocols (page 163): "In 2025, the sexual harassment protocol was activated on 70 occasions (63 in 2024), with sexual harassment being confirmed in 26 cases (19 in 2024), all of which resulted in the dismissal of the individuals reported. During the same period, the workplace harassment protocol was activated on 111 occasions (54 in 2024), with harassment being confirmed in 1 case. The protocol for harassment based on sexual orientation, sexual identity and gender expression was not activated on any occasion (1 in 2024)." BBVA adds: "During 2025 and 2024, there were no final sanctions or fines imposed for cases of discrimination or harassment", on a perimeter covering 97.3% of the official workforce (footnote 50).

Whistleblowing Channel outcomes (page 213): the Group "received a total of 2,467 communications (complaints) admitted for processing, representing an 8% increase compared to the previous year (2,283 reports)". Categories: labour relations or labour complaints 55.9%, customer conduct 17.6%, conflicts of interest 7.7%, discrimination or harassment 6.5%, fraud 5.5%, privacy and information security 1.7%, potential money laundering 1.1%, other 4.1%. Reports came from employees (67.7%) and third parties (6%), with 26.3% not stating.

"In fiscal year 2025, a total of 2,359 complaints were processed within the Group (2,590 in 2024). Approximately 37.6% of the complaints processed during the year resulted in disciplinary action, which materialized in 169 disciplinary dismissals (same number as in 2024). None of the complaints processed through the Whistleblowing Channel caused significant economic, criminal, reputational, or human rights impacts." A further 1,093 communications unrelated to Code of Conduct or legal breaches were rejected and redirected where possible.

BBVA also records that "According to the data published in the OECD database as of the date of this report, no cases related to BBVA have been handled by the National Contact Points" (page 213, footnote 66).

The Group states that it "has carried out two global Human Rights Due Diligence exercises ... taking the United Nations Guiding Principles on Business and Human Rights as its reference framework" (page 182, footnote 56). No fines or compensation figures for severe human rights incidents are disclosed.

Policies related to consumers and end-users

Reference: pages 49-58, 190-201.

The governing instrument is the Customer Conduct and Product Governance Policy, which "sets out the principles governing BBVA's relationship with its customers" (page 194):

• "Appropriate and responsible offering of products and services."
• "Transparency in advertising and in all information provided to customers about products and services."
• "Effective management of conflicts of interest that may arise and negatively affect the interests of customers."
• "Financial inclusion and accessibility of customers to the products and services offered by BBVA, considering their personal circumstances and avoiding unjustified discrimination."
• "Prompt and diligent handling of customer inquiries, complaints and claims."
• "Adequate training of personnel involved in manufacturing, distribution and customer service."

Its purpose is "to define and establish the principles and provisions necessary to adequately address customer interests during the provision of services or the offering and recommendation of products, through any distribution channel and considering the full life cycle of the product or service" (page 194). Provisions divide into customer conduct provisions, applicable generally, and product governance provisions, covering "the entire product life cycle: from its design and distribution to the post-contractual phase, including monitoring and after-sales service" (page 195).

The Policy develops the BBVA Code of Conduct, under which "all employees are required to direct users to the official resolution channels, thereby reinforcing the traceability and effectiveness of the process" (page 184). The Sustainability General Policy identifies customers as a principal stakeholder group (page 55).

BBVA states that the Group "has established policies, procedures, and, in certain cases, objectives" for all the material consumer IROs, "which are detailed in their respective sections of this document. Specific teams are responsible for their implementation" (page 182). It also records that its two global Human Rights Due Diligence exercises addressed "issues related to customer well-being, prioritizing elements such as accessibility and service, as well as safety and respect" (page 182, footnote 56).

Processes for engaging with consumers and end-users about impacts

Reference: pages 182-193.

BBVA's engagement rests on the Net Promoter Score methodology, applied "for more than a decade", which "allows for the comprehensive measurement and management of the experience of customers and non-customers alike by continuously gathering their opinions throughout the year" (page 183). In 2025 the model was extended: "an advanced, real-time listening model for retail banking customers, which preserves the robustness of the traditional approach while expanding its reach and depth ... This model enables the continuous measurement of positive word of mouth and satisfaction directly through the mobile app ... This approach makes it possible to reach the entire base of mobile retail customers at least once a year, providing daily and qualitative data on their perceptions, concerns and areas for improvement."

Governance of the metric is explicit: "The NPS is part of the Group's strategic indicators, monitored monthly by Senior Management at both the corporate and local levels. Furthermore, they are subject to a global governance model and are integrated into the variable remuneration system for all employees" (page 183). NPS carries a 15% weight in the 2025 annual variable remuneration indicators, with attainment of 91% against target (page 157).

For the Enterprise segment, "in 2025 BBVA launched a Customer Experience model centered on the customer journey - identifying the Key Moments that define customers' relationship and experience with BBVA. Based on interviews with customers, relationship managers, and product leads, six Key Moments have been prioritized" (page 183), each translated into basic, differentiating and memorable experience levels and measured through objective "Voice of Data" variables including "customer visits, number of incidents, claims and channel unavailability" (page 184).

On digitalisation, retail feedback is gathered continuously through the App, which "requests customer feedback on ease of use after completing key transactions, such as transfers or the contracting of financial products", and "has been adapted to address the needs of the most vulnerable groups" (page 191). Enterprise engagement runs through "Workshops, co-creation sessions and meetings with key customers across different geographies" and analysis of digital platform usage. Responsibility "lies with the global heads of Retail Client Solutions, as well as with the local managers in the geographic areas where BBVA operates" (page 191).

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

Reference: pages 184-189.

BBVA "maintains a network of customer service and complaints-handling channels designed to provide both customers and non-customers with an effective, accessible and needs-adapted means of communication", covering "onsite, telephone and digital" routes that are "continuously updated and made available on the main page of the online banking platform in each geography" (page 184). Contracts "include a dedicated section detailing the mechanisms available and the procedure to be followed for submitting complaints".

Handling rests on "two essential principles: swift resolution and root-cause analysis of the incidents reported", enabling "the extraction of insights to prevent recurrence" (page 184). "All claims are handled with diligence, impartiality, and respect for privacy ... The Group reaffirms its commitment to the protection of customers' rights, ensuring that no person will be subject to adverse consequences for making use of this complaint mechanism."

A Customer Care Service operates in each geography "endowed with the autonomy necessary to ensure that its decisions remain free from conflicts of interest" (page 185). Reporting runs upward: volumes, root causes, response times and reasons are "reported periodically to the Group's corporate bodies, including the Board of Directors (through the annual report), the Senior Management of each geography and the competent regulators and supervisors, such as the Bank of Spain and the European Central Bank".

MAIN CLAIMS INDICATORS (BBVA GROUP), page 185:

"In 2025, 96% of the Group's claims were handled in a timely and proper manner, with an average resolution time of 7.43 calendar days. At Group level, this average time increased by 6% (0.4 days) compared to 2024, mainly due to upticks recorded in Turkey and Peru. By contrast, improvements were observed in Uruguay and Romania" (page 185). Country tables give claims to the supra-banking authority (Colombia 139.00 per 10,000 active customers, Mexico 9.76, Turkey 8.24, Spain 2.31) and total claim volumes (page 186).

The Whistleblowing Channel is also open to customers and third parties (page 212), and is cross-referenced in the index under S4-3.

Taking action on material impacts on consumers and end-users

Reference: pages 182-201.

Transparency and information (the material risk). The Customer Conduct and Product Governance Policy applies "across all distribution channels and encompass[es] the entire lifecycle of each product or service" (page 194), with provisions split between customer conduct and product governance. BBVA states that "Insufficient, ambiguous or inaccurate communication about the products and services offered may give rise to risks, in addition to negatively affecting customer trust and the Group's perception" (page 181).

Customer experience. Three AI-based initiatives are named (page 182): "Blue, BBVA's digital assistant, is evolving towards a new hyper-personalized service model, providing conversational and multimodal support with 24/7 availability"; sales support tools "with the aim of enhancing the customer relationship model and increasing bankers' proactivity"; and "risk management assistants that allow for faster response times and greater accuracy in handling customer loan applications".

Access and inclusion. In 2025 the Group "set a target of acquiring 11.3 million new customers, a goal that was exceeded by two hundred thousand customers, reaching a total of 11.5 million new customers during the period", with digital channels "accounting for 66.2% of new customer acquisitions", equal to 7.6 million (page 193). Digital channels account for "around 79% in terms of units sold and 57% of the total product relative value". A simplified App version has been launched for seniors, "improving readability and ease of use for its most frequently used features" (page 192). Enterprise initiatives include BBVA Directa, the SAP/BBVA Embedded Banking Agreement, virtual accounts and virtual cards for travel agencies (page 190).

Social business channelled (pages 198-201): €30 billion in 2025, 52% growth on 2024, split corporates €6bn, enterprises €13bn, retail €11bn. Enterprise financing included "€6 billion to finance customers whose activity generates social impact", "€5 billion allocated to the financing of social infrastructure", "€700 million in financing to promote entrepreneurship" and "€500 million aimed at financing entities that promote financial and social inclusion" (page 200). Corporate channelling of €6bn included €3 billion in "inclusive infrastructure projects related to health, education, housing, or transport" and €2.23 billion in third-party bond placements.

Effectiveness is measured through NPS and claims KPIs "monitored on a regular basis, in some cases even daily" (page 191), and "Joint plans were developed with business areas to eliminate recurring reasons for claims and anticipate emerging scenarios" (page 185).

Limitation: BBVA states the information on management of resources for consumers and end-users "referred to in ... S4-4.30 and MDR-A69 ... has been considered sensitive" (page 20, footnote 4).

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

Reference: pages 37-48, 190-193, 198-201.

The principal quantified consumer-facing target is the Group's €700 billion sustainable business channelling objective for 2025-2029, set in the Strategic Plan and approved by the Board, which "represents more than doubles the previous target of €300 billion for the 2018-2025 period and is more ambitious, as it is planned for a shorter timeframe" (page 38). It spans climate, natural capital and social opportunities, including "Financial inclusion. Entrepreneurship. Social infrastructure" (page 38).

Progress in 2025: €134 billion channelled, a record and 44% growth, of which €30 billion social, up 52% on 2024 (pages 40-41, 198). Social activities break down as entrepreneurship and microenterprises 31%, social sustainable client 23%, social infrastructure 21%, financial and social inclusion 9%, social and KPI-linked bonds 8%, other 7% (page 198).

The target is embedded in pay: sustainable business channelling carries a 10% weight in the 2025 annual variable remuneration indicators, with a goal of €114,740 million and a result of €133,778 million, an attainment of 122% (page 157).

A second quantified objective is customer acquisition: "In fiscal year 2025, the Group set a target of acquiring 11.3 million new customers, a goal that was exceeded by two hundred thousand customers, reaching a total of 11.5 million new customers during the period" (page 193). Alongside it, Net Promoter Score and target customers each carry a 15% weight in the annual variable remuneration indicators, with 2025 attainment of 91% and 112% respectively against targets of 100 (page 157).

BBVA is explicit that the target framework is still being built out: "These objectives are measured and monitored through KPIs, which enable BBVA's management to assess progress and make adjustments when necessary. These objectives are established by the directors of BBVA's business lines, taking into account the views and interests of customers. As of the date of preparation of this information, the Group is in the process of defining objectives for future application" (page 193). No target is stated for claims volumes, resolution times or transparency-related indicators.

Business conduct policies and corporate culture

Reference: pages 207-213.

The compliance system's "core pillars are the Code of Conduct (published on BBVA's corporate website, www.bbva.com), the internal control framework, and the Compliance function" (page 207). The Code "establishes that all members of the BBVA Group must act with integrity and responsibility, respecting applicable laws and regulations, and demonstrating the prudence and professionalism befitting the trust placed in BBVA by its customers and shareholders" (page 211). Approved by the Board, it was updated in February 2022 and revised again in July 2024 "to adapt and update certain provisions in accordance with evolving case law and BBVA's internal regulations", and is published in Spanish and English on the intranet and website.

Training and reach (page 211): a mandatory corporate course, taken "generally every three years", was completed by 107,365 employees by end-December 2025 (92,621 in 2024), "achieving completion rates exceeding 99% in most regions". Content covers "customer conduct, leadership style and harassment, conflict of interest management and supplier relations, as well as the proper use of the Whistleblowing Channel".

Advisory activity: the Compliance function "formally address[ed] 939 individual queries of different nature through the Consultation Channel (764 in 2024)", concerning gifts, personal benefits and promotional or leisure events (32.1%), conflicts of interest (14.1%), other professional activities (12.8%) and staff selection, hiring and promotion (3.5%) (page 211).

Whistleblower protection is one of the three material G1 subtopics. The General Policy for managing communications in the Whistleblowing Channel and protecting whistleblowers, approved by the Board in 2023, implements Spanish Law 2/2023 and includes "specific measures designed to strengthen confidentiality and prevent retaliation"; the channel is available "24 hours a day, 365 days a year, in Spanish and English" through an externally managed global tool (page 212).

Governance: the Risk and Compliance Committee, "composed exclusively of independent directors", oversees regulatory compliance; the Head of Regulation & Internal Control "reports monthly to the Risk and Compliance Committee and quarterly to the Board of Directors" (page 208). In 2025 BBVA renewed "AENOR certification for the criminal risk prevention and management model" (page 210).

Prevention and detection of corruption and bribery

Reference: pages 214-217.

The General Anti-Corruption Policy, "the update of which was approved by the Board of Directors in 2023, constitutes a fundamental pillar in the management of Conduct risk at BBVA" and "serves as the basis for the Corruption Prevention Program" (page 214). It applies to the whole Group and to companies in which it holds a stake above 50%, binding "employees, Senior Management and directors", and is "aligned with the spirit of national and international anti-corruption standards, taking into account the recommendations of international bodies such as the United Nations Convention against Corruption, as well as the standards established by the International Organization for Standardization (ISO)". A public summary is on the shareholders and investors website.

Implementing procedures include "the Standard on the Procurement or Goods and Services, the Corporate Gifts and Events Standard, and the regulations governing donations and commercial sponsorships", applied in higher-risk areas covering customers, suppliers, agents, intermediaries and business partners, donations and sponsorships, personnel selection and hiring, and transaction accounting (page 214). "as a general rule, BBVA includes in its contracts with suppliers a clause under which they undertake to comply with applicable anti-corruption legislation."

The Corruption Prevention Program comprises "a risk map; a specific governance model; a set of mitigating measures ...; procedures for action in the event of risk situations; training and communication programs and plans; indicators aimed at understanding the risk situation and its mitigation and control framework; a whistleblowing channel; and a disciplinary regime" (pages 214-215).

Risk assessment volumes in 2025 (page 215): 231,182 transactions assessed for AML/CFT risk (99.33%; 175,303 in 2024); 322,799 for internal fraud risk (100%; 264,303); and 5,199 procurement transactions assessed from the AML/CFT and corruption perspective (100%; 4,348), excluding Chile, the United States and Turkey. "The overall results of this analysis conclude that the BBVA Group's corruption risk control framework is adequate."

Training (pages 215-216): the mandatory recurring corporate course covers "100% of those areas identified as having a higher risk of corruption". At the end of 2025 93,278 employees (98.8%) had been trained, from 94,414 enrolled, broken down by geography and occupational category; the equivalent 2024 figures were 87,704 of 91,784 (95.60%). Work was still ongoing "to make this corporate course available in Turkey". Separately, "the total number and percentage of members of the Boards of Directors of the main entities that make up the BBVA Group who have received anti-corruption training from fiscal year 2022 through the date of publication of this report amount to 97 (100%)" (page 217).

Investigations are independent of the areas involved, being run through the Whistleblowing Channel procedure (page 215, footnote 67).

Targets related to business conduct (part of MDR-T/GDR-T disclosures)

Reference: pages 209-211, 273. Recorded here because BBVA's statement was prepared under the 2023 ESRS, in which business-conduct targets fell under MDR-T rather than a standalone G1 targets requirement. The ESRS content index lists MDR-T, "Tracking effectiveness of policies and actions through targets", against "NFIS/Governance information/Business conduct" (page 273).

BBVA does not publish a numerical business-conduct target. It discloses the MDR-T alternative limb, describing how effectiveness is tracked in the absence of one.

Named key indicators of the compliance model (page 210):

• "Indicators related to the management of complaints received."
• "Integrity-related indicators, including corruption and bribery, subject to periodic monitoring at the executive level."
• "Indicators of money laundering prevention linked to the monitoring of customer documentation and alerts generated by unusual transactions and application of the international sanctions regime."

Annual cycles. "the Compliance model envisages annual cycles of risk identification and assessment, which allow the Group to adjust and strengthen its management strategy, define lines of action and bolster, where appropriate, existing mitigation and control measures" (page 210). Separately, "an annual review process is carried out for the Compliance risk and control map (Risk and Control Self-Assessment - RCSA). The purpose of this exercise is to ensure the relevance and effectiveness of the controls, identify potential weaknesses, and promote their remediation, thereby providing a consolidated and updated view of the risk profile."

Assurance activities in 2025 included "Running regular checks through internal and external audits and inspections by supervisory authorities, together with Compliance Testing activities", data quality processes in compliance reporting, and "The renewal of AENOR certification for the criminal risk prevention and management model" (page 210).

Quantified performance measures that function as effectiveness tracking: Code of Conduct course completion of 107,365 employees with "completion rates exceeding 99% in most regions" (page 211); anti-corruption training completion of 93,278 employees, 98.8% (page 216); 100% anti-corruption training of the 97 directors of the main Group entities (page 217); and whistleblowing outcomes, with 37.6% of processed complaints resulting in disciplinary action (page 213).

The report does not state a target value, date or baseline for any of these measures, nor a blanket statement that targets are absent.

Incidents of corruption or bribery

Reference: pages 214-217. Titled "Confirmed incidents of corruption or bribery" in the index (page 278).

"No final criminal convictions or final fines at a judicial level have been identified in financial year 2025 against entities of the Group under global consolidation, or against their employees, for acts classified as corruption or bribery under the laws in force in each jurisdiction. In the 2024 financial year, there were likewise no convictions or fines in these terms" (page 217).

BBVA defines the terms it is using in footnotes: "conviction" follows "the definition of the term 'conviction' set out in Regulation (EU) 2019/816. Civil liability arising from the offence is therefore excluded, given its civil nature"; for fines, "The criterion established by the competent authority that has decided on the non-publication or the deferral of the publication of a sanction shall be applied"; and the scope "includes cases of which the entity has become aware by being a party to the proceedings" (page 217, footnotes 71-73).

The Group adds the qualification that the nil return does not stand alone: "Notwithstanding the above, and as detailed in the 'Corruption risk management model' subsection of this section, BBVA runs an Anti-Corruption Program that includes, among other elements, procedures on how to act in the event of a risk situation."

Related incident data are reported through the Whistleblowing Channel (page 213). Of 2,467 complaints admitted for processing in 2025, fraud accounted for 5.5% and potential money laundering 1.1%. Of the 2,359 complaints processed, "Approximately 37.6% ... resulted in disciplinary action, which materialized in 169 disciplinary dismissals (same number as in 2024)", and "None of the complaints processed through the Whistleblowing Channel caused significant economic, criminal, reputational, or human rights impacts."

The datapoint table maps the ESRS G1-4 fines datapoint (paragraph 24(a), Indicator No. 17 of Table 3 of Annex 1) and the anti-corruption standards datapoint (paragraph 24(b)(1), Indicator No. 16) to the "Corruption and bribery" section at pages 214-217 (pages 270-271).