Belfius Bank

Belfius operates a Belgian two-tier structure: the Board of Directors is the supervisory body on ESG, while the Management Board is the management body responsible for effective management. As at 31 December 2024 the Board of Directors had 17 members (2023: 18), six of whom sat on the Management Board. The gender ratio was 58.8% men / 41.2% women (2023: 66.7% / 33.3%), meeting the legal minimum one-third representation of the underrepresented sex under Article 7:86 of the Companies and Associations Code. Independent directors made up 52.9%, and executive/non-executive members were 35.3% / 64.7%. The Management Board had 6 members with a 66.7% / 33.3% men/women ratio. Belfius does not include employee or worker representation on its bodies. All Board and Management Board members passed the NBB and ECB fit and proper assessment. The Nomination Committee uses a competence matrix scoring directors on business conduct and ESG. Estelle Cantillon, a professor of economics, was appointed specifically to expand ESG expertise, and a two-day ESG seminar was held in February 2024.

The Board of Directors and Management Board of Belfius Bank, including relevant committees, are informed about material impacts, risks and opportunities. The Board defines and oversees strategy, objectives, general policies including business conduct, risk appetite and risk approach, on the proposal of the Management Board or Joint Management Committee (JMC), and this includes ESG. Each year the Board sets the Risk Appetite Framework on the proposal of the Risk Committee, integrating an increasing number of qualitative and quantitative ESG indicators. The Risk Committee holds advisory powers on current and future risk appetite including climate risk; the Audit Committee is responsible for internal control and the integrity of the annual report, and reviewed and validated all material IROs. Recurring reporting flows include Quarterly Financial results, Quarterly Business Reviews, Quarterly Technology Review, HR reports, Quarterly Risk and RAF Reports, half-yearly Compliance Reports and Actualia. A table lists specific 2024 topics discussed per sustainability matter (own climate footprint, own workforce, information security and data protection, customer transparency, innovation, financial inclusion, community involvement, business conduct, resilience, meaningful financing and investing). The JMC manages group ESG strategy, supported by the ESG Central team, ESG Risk Competence Centre, ESG technical methodology desk and ESG Models Steering Committee.

Belfius Bank encourages adoption of its sustainability values by senior and key executives through their annual variable remuneration. The variable remuneration approach is approved by the Board of Directors following the advice of the remuneration committee. ESG indicators determined 9.8% of the performance score of the variable remuneration in 2024 for all key and senior executives. In 2024 the social indicators were the share of women in management (target 42.5%), employee engagement (target 86%) and customer satisfaction (target 48.2% top 1 very satisfied customers). The environmental pillar was a custom-built target to reduce carbon emissions from own operations in line with Paris Agreement trajectories (target of -5.3%), covering scope 1, 2 and part of scope 3 (excluding financed emissions) where Belfius has actionable levers; the part of variable remuneration linked to climate-related considerations is 1.2%. The governance side was covered by timely delivery on recommendations of internal and external auditors, regulators and compliance (target 90% of recommendations timely closed; 85% for the Chief Risk Officer). Depending on business line and function, additional specific ESG objectives can be added.

Belfius provides a statement on due diligence through a table that references the disclosures covering the core elements of due diligence to sections of the sustainability statement. Embedding due diligence in governance, strategy and business model is covered by ESRS 2 GOV-2 and GOV-3 (section 1.5 Integration of sustainability matters into corporate governance) and SBM-3 for E1, S1, S2, S3 and S4. Engaging with affected stakeholders is covered by SBM-2 (section 1.4 Value chain and Stakeholder engagement) and IRO-1 (section 1.6.1). Identifying and assessing adverse impacts is covered by IRO-1, SBM-3 and the topical SBM-3 disclosures. Taking actions to address adverse impacts is covered by E1-3 (operational emissions), MDR-A, S1-4 (health and well-being), S2-4, S3-4 and S4-4. Tracking effectiveness and communicating is covered by S1-9, S1-11, S1-15 (diversity and inclusion), MDR-M and MDR-T, S1-10, S1-14, S1-16 (labour practices and human rights) and S1-13 (talent management). The views of stakeholders inform the due diligence process and the materiality assessment.

The Finance department centralizes the construction of the sustainability statement, with disclosure requirements allocated to different internal responsible parties. Qualitative information is prepared from existing documentation; environmental quantitative information is prepared by the ESG Central team using methodologies applied to databases used for financial reporting. Key methodologies undergo second-line review by Risk, and internal controls ensure completeness, accuracy and appropriate presentation, with procedures and controls in place within each department. Finance is responsible for coordination, aggregation and the ESRS compliance check. Third-line reviews by internal audit were carried out during 2024 covering carbon accounting and Climate Risk Assessments, with results reported to the Audit Committee of Belfius Bank. The main identified risks and mitigations are: inconsistencies with financial reporting (mitigated by starting from financial data and consistency controls); lack of automation (mitigated by standardized data collection, detailed instructions, four-eyes controls and enhanced logical and analytical controls); lack of data availability and quality (mitigated by proxies, estimations, second-line review and governance); risk of greenwashing (mitigated by responsible-department preparation based on existing policies); and regulatory evolutions (monitored via the CSRD implementation project team and Assuralia and Febelfin workgroups).

Belfius is a Belgian banking and insurance group wholly owned by the Belgian federal state through the Federal Holding and Investment Company (FHIC/SFPI-FPIM). Belfius Bank is the parent company of the Belfius Group and is licensed as a credit institution under Belgian Banking Law; Belfius Insurance and its subsidiaries are included in the consolidated statement. Most major commercial subsidiaries operate in Belgium, with specific activities in Luxembourg (Belfius Financing Company; Belfius Insurance Finance) and Ireland (Belfius Ireland, a run-off bond portfolio). At 31 December 2024 the group had 7,198 employees (7,185 in Belgium). Its integrated bank-insurer business model serves individuals (including private and wealth clients), the public and social sector (PSB) and entrepreneurs and enterprises (E&E), cross-selling payments, savings, investments, mortgages, consumer finance and life and non-life insurance. Strategy is set by the stable long-standing Inspire 2020-2025 strategy, articulated around Walk the talk and Customers in the driver's seat, with a 2030 strategy being defined. The group is active in Credit Institution, Insurance and Capital Markets sectors, which ESRS has not identified as climate intensive. Belfius reported one last time on six 2021 commitments, for example a -48% carbon footprint reduction in own operations in 2024 and 96% renewable electricity.

Belfius engages regularly with external and internal stakeholders to understand expectations on its environmental and social impact and to inform them of its sustainability strategy, objectives and risk management. Key stakeholders include customers (downstream), government regulators and supervisors (NBB, FSMA, ECB, EIOPA), employees and their representatives (own operations), independent networks, shareholders (the Federal Holding and Investment Company/SFPI-FPIM), ratings agencies, analysts, investors and press, strategic partners, suppliers (upstream, invited to EcoVadis assessment), reinsurers, asset management counterparties, social and civil society organisations and NGOs, sector federations (Febelfin, Assuralia and others) and supranational sustainability organisations. Belfius reports progress to the UN Global Compact and to UNEP FI PRB, PSI, PRI and PCAF. Internal engagement typically involves the Group Central ESG team, ESG Risk team, Human Resources, key business representatives and Executive Management. A table discloses each stakeholder, the channels of dialogue and the purpose and main topics. The voice of the customer is described as most crucial. Customer feedback on accessibility led to a 2024 recalibration of the distribution strategy (extended branch hours, upstaffing in Belfius Connect, chatbot investment). Stakeholder views inform the due diligence process and the materiality assessment, and reports keep the Management Board and Board informed of key stakeholder activity.

The 2024 double materiality assessment identified the sustainability matters whose impacts, or risks and opportunities, are material, combining ESRS topics with entity-specific topics linked to the most relevant ESRS standard. Material topical standards are E1 Climate change, S1 Own workforce, S2 Workers in the value chain, S3 Affected communities, S4 Consumers and end-users, and G1 Business conduct. Entity-specific material topics are Meaningful Financing, Meaningful Investing and Meaningful Insurance (linked to E1/S2, downstream), Customer Transparency and Financial Inclusion (S4, downstream), Information Security/Data Protection (S4, own operations and downstream), Innovation and digitalization (S1/S4), Community involvement (S3, downstream), Resilience (G1, own operations) and Sustainable Procurement (S2/G1, upstream). Own climate footprint (E1) and Own workforce (S1) and Business Conduct (G1) relate to own operations. E2 Pollution, E3 Water and marine resources, E4 Biodiversity and ecosystems and E5 Resource use and circular economy were assessed as not material. The disclosure narrates the IROs for climate change (own emissions, transition, physical damages, regulatory change, product opportunities), meaningful financing/investing/insurance, own workforce (talent attraction and retention, AI), consumers and end-users (transparency, innovation, data protection, financial inclusion), community involvement and business conduct.

In 2024 Belfius carried out a thorough double materiality assessment covering financial materiality (risks and opportunities from a business perspective) and impact materiality (impacts on society and nature), in accordance with CSRD and ESRS. The process, methodology and outcome were reviewed and endorsed by the Management Board and the Audit Committee. Belfius re-confirmed its key stakeholders, assessed reporting boundaries and executed the assessment across the full value chain: own operations, supply chain, investment activity, financing activity and insurance activity. A longlist of sector-agnostic ESRS topics plus financial-sector and Belfius-specific matters was enriched with peer analysis, desk research on regulatory frameworks (ECB, EIOPA), voluntary frameworks (SASB), UNEP FI and NGFS publications, prior GRI materiality results and media research. Impact assessment used quantitative sector proxies from the UNEP FI Impact Analysis tool and the ENCORE database, with direct exposure focused on Belgium. Financial materiality considered likelihood and magnitude of potential financial effects, aligned with Belfius-specific risk assessment processes, and risks were assessed on a gross basis (before mitigation). Opportunities were tied to the existence of a strategy to exploit them. Material IROs, assessed with a focus on the short-term horizon, were validated by a broader group of internal stakeholders including relationship managers, compliance, HR and Management Board members.

IRO-2 is presented as the content index (list of material disclosure requirements) mapping each ESRS DR to the chapter where it is addressed or noting where it is not material. ESRS 2 general disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, IRO-2) are in Chapter 1. E1 Climate Change DRs (including E1-1 to E1-7 and E1-9) and EU Taxonomy are in Chapter 2. E2 Pollution (E2-4), E3 Water and marine resources (E3-1, E3-4), E4 Biodiversity and ecosystems and E5 Resource use and circular economy (E5-5) are marked Not Material. S1 Own workforce DRs (S1-1 to S1-16, with S1-17 not material), S2 Workers in the value chain, S3 Affected communities and S4 Consumers and end-users are in Chapter 3. G1 Business conduct (G1-1, G1-2, G1-3, with G1-4 not material) is in Chapter 4. Entity-specific topics (Meaningful Investment, Meaningful Financing and Meaningful Insurance in Chapter 2; Information security and data protection, Financial inclusion and Innovation and digitalization in Chapter 3; Resilience in Chapter 4) are covered under minimum disclosure requirements. The index also flags datapoints included by reference and phase-in provisions (E1-9, S1-7, S1-12).

Belfius sets climate targets first on emissions it fully controls, starting with own operations where it has the most leverage. It is in the process of defining science-based targets on emissions related to its financing and investment activities, focusing on the most climate-sensitive sectors and most material portfolio segments; these targets are expected to be validated in the course of 2025. A structured transition plan to achieve these targets will be developed taking into account the Strategy 2030 in the course of next year. Currently, no significant Capex and Opex are allocated to the implementation of Belfius' actions. Operational targets use the SBTi methodology (1.5C scenario where available), are set on a 2022 base year and mostly for 2030, with further 2050 targets and interim milestones to be developed. Belfius is not excluded from the EU Paris-aligned Benchmarks because it does not derive a set percentage of revenues from coal, oil, gas or electricity generation. Through the Transition Acceleration Policy, Belfius does not finance coal extraction and commits to phase out financial support to thermal coal by 2030, with decreasing thresholds for oil, gas and electricity generation.

Belfius' Climate and Environmental Policy (CEP) sets objectives such as using green electricity and fostering renewable energy production by 2030, addressing climate mitigation and adaptation in own operations and with clients, energy efficiency, water, biodiversity, waste and pollution. It applies to all Group subsidiaries under operational control, is implemented by the head of People Brand communication and ESG and approved by the JMC. The Transition Acceleration Policy (TAP) guides the transition to a low-carbon economy: Belfius does not finance coal extraction and commits to phase out thermal coal financing across its value chain by 2030 at the latest, limits oil and gas activities and sets decreasing thresholds for electricity generation. Published January 2024, the TAP's new version excludes, from 1 August 2024, all coal extraction companies and any company with coal mining or coal-based power expansion plans; from 2030 all coal companies are excluded. Companies in unconventional oil and gas extraction (shale gas, shale oil, tar sands, arctic and deep water drilling, coalbed methane, extra heavy oil) are also excluded. The TAP applies to investment, lending and insurance across all entities, is based on the 10 UN Global Compact principles, and integrates criteria on mining, palm oil and soy. Belfius has committed to UNEP FI PRB, PSI and PRI.

Belfius' action plan to manage its own climate footprint rests on three pillars: responsible building management (energy efficiency, clean-energy transition, waste and water), green mobility, and sustainable IT. In 2024, main positive actions were the electrification of the car fleet and switching franchises to green electricity contracts, plus solar panels (Elantis building), a planned heat pump (Rogier Tower head office) and nanogrids in salaried agencies. Since May 2023 only fully electric cars can be ordered; the entire fleet will be decarbonized by end 2029, with 29% fully electric and 34% hybrid at the start of 2025. So far 1,502 employees installed a home charging point (346 in 2024) and 50% of eligible employees chose the federal mobility budget. Sustainable IT actions include extending laptop lifespan from 3 to 4 years and refurbishing more than 1,500 older devices for donation; technology accounts for 0.022% of total emissions. Currently no significant Capex and Opex are allocated to these actions. In risk management, the TAP restricts financing for non-sustainable activities and the Risk Appetite Framework sets limits on fossil fuel exposures and on mortgage collateral with poor energy performance.

Targets, approved by the Joint Management Committee and Board of Directors, use SBTi methodology, a 1.5C scenario where available and a 2022 base year, mostly for 2030. The general absolute reduction target is -42% by 2030 for scope 1 (buildings and company cars) plus scope 3 waste, business travel, employee commuting and franchises, moving from 23,583 tCO2e (2022 baseline) to 14,924 tCO2e in 2024. Two intensity targets apply the sectoral decarbonization approach: Belfius Auto Lease leased car fleet -50% by 2030 (139 gCO2e/km in 2022 to 101 in 2024) and Belfius Insurance leased real estate -64.7% by 2030 (26.7 kgCO2e/m2 to 17.1). A short-term renewable electricity target aims for 100% renewable electricity by 2025 (94.5% in 2022, 96.3% in 2024). Belfius Auto Lease also targets a 50% reduction in average fleet CO2 emissions by 2025 versus 2022. Science-based targets on financing and investment emissions are being defined, with expected validation in 2025. Belfius has not yet quantified potential reduction by decarbonisation lever but expects to do so in 2025.

Total energy consumption related to own operations was 20,294 MWh in 2024 (21,664 MWh in 2023). In 2024, consumption from fossil sources was 6,814 MWh (34%), from nuclear sources 212 MWh (1%), and from renewable sources 13,268 MWh (65%). Fuel consumption from biofuel, biogas and similar was 0 MWh (0%); the entire renewable share came from consumption of green electricity, 13,268 MWh (65%). For comparison, 2023 showed fossil sources 8,209 MWh (38%), nuclear 267 MWh (1%) and renewable 13,188 MWh (61%). Renewable electricity as a share of consumption reached 96.3% in 2024. As a credit institution, insurance and capital markets group, Belfius operates in sectors not identified as high climate impact by ESRS. Belfius aims to use 100% certified green electricity in all buildings it owns by end 2025; in 2024 two buildings still had grey electricity contracts.

Emissions are calculated under the GHG Protocol and PCAF, covering the seven UNFCCC gases. Total carbon footprint (market-based) for 2024 was 26,943,867 tCO2e, up 11% from 24,376,841 in 2023 (2022 restated baseline 22,633,887). Financed emissions (scope 3 category 15, including sovereign) were 26,780,024 tCO2e in 2024 (+11%), dominating the footprint. Operational emissions totalled 163,843 tCO2e (-7%): Scope 1 was 1,873 tCO2e (-12%), Scope 2 market-based 57 tCO2e (location-based 1,545 tCO2e), and Scope 3 market-based excluding category 15 was 161,913 tCO2e. Financed emissions follow PCAF across seven asset classes covering 63% of total loans and investments. The grand total in-scope financed emissions including sovereign debt for 2024 were 8,713 ktCO2e (scope 1 and 2) and 18,067 ktCO2e (scope 3), on a gross carrying amount of 97,537 M euro. GHG emissions intensity (including category 15) was 8.3 kgCO2e per euro, on net revenue of 3,259,288,443 euro. Insurance-associated emissions, assets under management and local public sector exposures are not disclosed pending methodologies.

Belfius' carbon footprint calculations do not include any carbon removals, purchase, sale or transfer of carbon credits, or avoided emissions. In addition to avoidance and reduction efforts, Belfius purchases carbon credits equivalent to the emissions over which it has the highest direct control, namely own operations excluding Belfius Auto Lease activities, financed emissions and DVV franchises. These credits have no impact on total footprint calculations and are treated as a separate voluntary exercise rather than a reduction. Carbon credits cancelled in the reporting year totalled 30,500 tCO2e in 2024 (44,600 tCO2e in 2023). In both years 100% came from reduction projects and 0% from removal projects, 100% were Gold Standard, 0% were from projects within the EU, and 0% qualified as corresponding adjustments. Projects are in developing countries certified to the Gold Standard, and Belfius monitors the Integrity Council for the Voluntary Carbon Market. All carbon credits purchased in the past have been cancelled, so Belfius owns no credits planned for future cancellation. In the future, Belfius will no longer buy carbon credits but carbon removal credits.

Belfius applies a phase-in approach to anticipated financial effects: because methodologies are not fully mature and granular data is often lacking, no precise figures on the anticipated financial effects of climate and environmental risks are provided at this stage. Assessments cover both physical and transition risk drivers over horizons including a 5-year strategic planning horizon and longer. Assets at material physical risk (flood, being loans collateralized by immovable properties) before climate mitigation were 1,622 million euro (2.58%) in 2024, up from 1,370 million euro (2.27%) in 2023, against a gross carrying amount of 62,747 million euro; residual risk is expected to be much lower as around 90% of Belgian households are insured against floods (mandatory for a Belfius mortgage). Assets at material transition risk in the banking book were 1,502 million euro (3.11%) in 2024 (1,512 million euro, 3.29% in 2023), on a gross carrying amount of 48,286 million euro. Mortgage exposures deemed most sensitive (LTV over 80% and energy performance over 400 kWh/m2) represent 3.82% of mortgage loans, on a total of 42,428 million euro. Belfius chose not to disclose chronic physical risk, location of significant assets, or net revenues from activities at material risk.

Belfius sets out its own-workforce policies through its Human Rights Policy and Code of Conduct, which require honest and ethical conduct and are the responsibility of the management board. Guided by Belgian law and ILO conventions, Belfius formally forbids child and forced labour across all activities and respects the right to collective bargaining and freedom of association. An Anti-discrimination Policy prohibits discrimination on grounds such as gender, ethnic origin, colour, age, disability, sexual orientation, religion, political conviction or social origin, and applies a zero-tolerance policy toward workplace violence including verbal, physical and sexual harassment. It covers all permanent and temporary staff, external workers, interns and self-employed persons, plus board and corporate-body members. The Health and Safety Policy, in line with the Wellbeing Law of 1996 and its executive decrees (Codex Wellbeing at Work), aims to prevent accidents at work and occupational illnesses. Belfius also respects employee privacy and GDPR compliance, and its remuneration policy is gender-neutral and non-discriminatory. Policies are available on the Belfius intranet.

Belfius engages with its own workforce and workers' representatives through several channels. For the past decade it has run an annual engagement survey covering all Belfius Group employees, processed anonymously; in 2024 the satisfaction indicator was 91.7% at the Bank and 92.3% at Insurance, engagement was 85.8% (Bank) and 85.2% (Insurance), with response rates of 75.9% (Bank) and 82.6% (Insurance). Survey input is analysed and translated into actions at group and departmental level, with the management board responsible for execution and follow-up. Worker representatives sit on the Committee for Prevention and Protection at Work, representing all white-collar and blue-collar workers, and are elected every four years during social elections. Belfius uses participatory risk-analysis methods allowing every employee to contribute to identifying risks via a broad, anonymous report and to suggest improvements. Social dialogue runs through trade union delegation under CLA No. 5 of the NAR (24 May 1971). The Belfius Young Community engages employees under 36, including an annual Q&A with the Board of Directors.

Grievance mechanisms and remedies are in place so concerns are heard, investigated and addressed in a timely manner. The employee's first point of contact is their hierarchical supervisor, though a member of the Committee for Prevention and Protection at Work or a union representative can also be approached. A specific internal procedure offers a request for informal psychosocial intervention (65 cases in 2024, none related to discrimination) or a request for formal psychosocial intervention (0 cases in 2024), with a confidential advisor or psychosocial prevention advisor meeting the employee within 10 calendar days; consultation time counts as working time. An external route allows employees to turn to the Supervision of Workplace Welfare inspection for psychosocial risks. In line with Directive (EU) 2019/1937, a whistleblowing procedure is available for business-conduct incidents including corruption and bribery, with protection against reprisals. In 2024 there were no human rights incidents or complaints resulting in fines, penalties or compensation for damages.

Belfius took a range of actions on material own-workforce impacts in 2024. On diversity and inclusion, a Diversity Manager and internal Diversity Steering Group embed DEI principles, increasing women's representation in management via quotas, encouraging women in STEM and recruiting young professionals under 30, and reducing recruitment bias through objective selection and D&I training for managers. Belfius signed the Charter of Multicultural Bankers Belgium, the Amsterdam Charter and the Inclusive Panels Charter, participates in the Women in Finance initiative and the Inclusive March Challenge, and launched a Diversity Room. On health and well-being, it runs a dynamic risk-management system across seven wellbeing domains, offers an Employee Assistance Program (available 24/7, used by 133 Bank employees across 193 files in 2024), and is affiliated with external prevention service Idewe. On talent, it opened 1,188 permanent vacancies, recruited 40 Young Professionals, welcomed 84 trainees, and expanded learning through the MyDevelopment portal. Partnerships include BeCode, Passwerk and the 'S.He Goes Digital' program for female employees.

Belfius set a target for women in management functions of 44% by 2025. As of the fourth quarter of 2024 the figure stood at 43.5%. The metric is calculated by averaging three separate averages: women in management positions, women in key executive roles and women in senior executive positions. The 44% target was set by the Diversity Steering Group in 2020 based on the gender balance within Belfius and its ambition, and progress is reported to the Board of Directors and Management Board at least twice a year, allowing additional actions to be taken based on results. Belfius Auto Lease also intends to reduce the CO2 emissions of its vehicle fleet by 50% by 2025 compared with 2019. For innovation and digitalization, Belfius states it has not formalised specific policies, metrics or targets given the rapidly changing technology landscape. No further formal quantified own-workforce targets are disclosed.

In 2024 Belfius Group counted 7,198 staff members (headcount), of which 99% held permanent contracts and 86% a full-time work regime, giving an average of 6,767 FTE. By contract type in 2024: permanent 7,139 (3,629 male, 3,510 female) and fixed-term 59 (39 male, 20 female); total 3,668 male and 3,530 female. This compares with 6,939 total in 2023. By work regime in 2024: full-time 6,205 (3,534 male, 2,671 female) and part-time 993 (134 male, 859 female). Figures relate to active headcount at 31/12/2024, excluding employees on early retirement, long-term sick leave, full-time time credits or secondment. By age in 2024: 20-29 numbered 817 (11%), 30-49 numbered 2,994 (42%), and 50 and over numbered 3,387 (47%), with 47% of employees over 50. Employee departures totalled 428 in 2024 (237 male, 191 female) versus 359 in 2023, with the 60-plus group accounting for 44% of departures. Group churn was 6.1% in 2024 (5.3% in 2023).

Belfius works with contractors, third parties, temporary workers and trainees in addition to its own employees. These persons are considered equal to internal employees under the wellbeing law and therefore have the same rights and obligations, including in health and safety, hazard reporting and protection against reprisals when reporting unsafe situations. For the external workforce, accident investigations are carried out by the third-party employer, and third parties must provide Belfius at least once a year with a list of all incidents that have occurred; in serious accidents Belfius has the right to participate in the root cause analysis. Belfius states that its most significant risks lie in psychosocial and ergonomic considerations for internal employees, while contractors may interact with increased technical installations such as during structural maintenance, and to date there have been no serious industrial accidents involving contractors. Belfius has applied phase-in on the S1-7 disclosure of metrics related to non-employees, so quantitative headcount metrics for non-employees are not reported.

In 2024, 94.6% of Belfius Bank and Belfius Insurance employees were covered by collective bargaining agreements and were represented by workers' representatives, which Belfius states results in all employees working in an establishment where employees are represented by workers' representatives. Belfius affirms absolute respect and compliance for its employees' right to participate in collective bargaining and freedom of association, in line with ILO conventions and local and EU regulations. Social dialogue is governed by CLA No. 5 of the NAR dated 24 May 1971 on the status of trade union delegation of personnel within companies, under which representative workers' and employers' organisations agree that workers recognise the legitimate authority of enterprise heads and perform their work scrupulously, while employers respect workers' dignity, treat them fairly, and undertake not to hinder freedom of association or the development of their organisation within the company. Enterprise representatives and trade union delegates are expected to demonstrate fairness and a conciliatory spirit and to comply with social legislation, collective agreements and labour regulations.

Belfius reports gender diversity across its workforce and management. Of the total 7,198 employees in 2024, 3,668 were male and 3,530 female. By age, 20-29 represented 11% (817), 30-49 represented 42% (2,994) and 50-plus represented 47% (3,387). For management functions in 2024, women held 40.9% of manager positions (303), 41.7% of key executive roles (85) and 47.8% of senior executive positions (89); men held 59.1% of manager positions (437), 58.3% of key executive roles (119) and 52.2% of senior executive positions (97). Belfius publicly tracks women in management, which stood at 43.5% in the fourth quarter of 2024, calculated by averaging women in management positions, key executive roles and senior executive positions, against a target of 44% by 2025. Belfius promotes diversity across gender, generation, sexual orientation, origin and disabilities, and works to increase women's representation in management and in STEM careers.

Each year, all Belfius employees undergo a review to ensure they are compensated at or above the sector's minimum wage, according to their job role and level of experience. A yearly benchmark conducted via an external provider compares all employees to their respective reference market. Remuneration consists of fixed pay, the possibility of variable pay, a package of benefits such as meal vouchers, and a package of insurances (for example group insurance, hospitalization and ambulatory care). Belfius' remuneration policy is gender-neutral and non-discriminatory: all employees are linked to a gender-neutral job description tied to a remuneration policy using an objective grading methodology, ensuring equal access to all positions without gender distinction and applying a uniform remuneration system for the same category of employees. Belfius strives for equal remuneration for equal responsibilities and experience, and discusses, measures and reports evaluations, remunerations and promotions within the competent bodies on an annual basis.

All Belfius employees are covered by social protection, through benefits offered by Belfius, against loss of income due to major life events. The events covered are sickness, unemployment (starting from when the employee is working for Belfius), employment injury and acquired disability, parental leave, and retirement. Belfius states that it offers a significant added insurance package above government obligations. This social protection forms part of the broader remuneration and benefits package, which includes fixed pay, possible variable pay, meal vouchers, and insurances such as group insurance, hospitalization and ambulatory care. As stated in the collective agreement, all employees, regardless of grade or job, are allowed to work part-time, and all employees are entitled to family-related leave through social policy and/or collective bargaining agreements.

Belfius has applied phase-in on the S1-12 disclosure of metrics related to persons with disabilities, so quantitative disability headcount metrics are not reported for 2024. Belfius' Anti-discrimination Policy explicitly prohibits discrimination on the basis of personal characteristics including disability, and its DEI strategy embraces diversity in all its forms, including (dis)abilities. Belfius supports persons with disabilities through partnerships: it has a collaboration of more than 10 years with Passwerk, a company that uses the qualities of people with an autism spectrum profile across various areas of expertise in the regular job market. Belfius also signed a 2024 partnership with BeCode, a school aimed at motivated people in precarious professional situations such as school dropouts, people born outside the OECD and long-term job seekers. Contractors, third parties and other external persons are considered equal to internal employees under the wellbeing law.

Belfius reports training and skills-development metrics for its workforce. The average number of days of training per employee (including on-the-job, e-learning and mandatory training) was 5.1 in 2024, up from 5.0 in 2023; in 2024 this was 5.0 days per female employee and 5.3 per male employee. The percentage of workers who participated in regular performance and career development reviews was 24.3% in 2024 (24.4% in 2023), split 25.6% for female employees and 23.1% for male employees in 2024; these figures are based on reviews of key and senior executives at Belfius Bank and key and senior executives and 'cadre' functions at Belfius Insurance, with formalisation to be industrialised in 2025 following the launch of the Talent=Hub tool in November 2024. A dedicated Learning & Development team manages training via the MyDevelopment portal (Learning Foundations, Learning On Demand, Learning On Invitation). In 2024, 1,188 permanent vacancies were opened, 40 Young Professionals were recruited and 84 trainees welcomed.

In both 2023 and 2024, 100% of workers were covered by a health and safety management system based on legal requirements and/or recognised standards or guidelines. There were 0 fatalities in the own workforce from work-related injuries and ill health, and 0 fatalities among other workers on the undertaking's sites, in both years. The rate of recordable work-related accidents for the own workforce (per one million hours worked) was 1.69% in 2024, up from 1.22% in 2023, corresponding to 19 recordable work-related accidents in 2024 versus 13 in 2023. There were 0 cases of recordable work-related ill health of employees in both years. The number of days lost to work-related injuries, ill health and fatalities was 95 in 2024, down from 257 in 2023. For internal employees a root cause analysis is performed for each accident. In 2024, the Committee for Prevention and Protection at Work held ten meetings for Belfius Bank and twelve for Belfius Insurance.

Belfius reports work-life balance metrics on entitled employees who took family-related leave. In 2024, 13% of entitled female employees and 8% of entitled male employees took family-related leave, for a total of 10%; these figures were unchanged from 2023 (13% female, 8% male, 10% total). All Belfius employees are entitled to family-related leave through social policy and/or collective bargaining agreements. Belfius supports employees across life and career stages with options to organise working hours, including parental leave, caregiving leave, part-time work (from 50% to 90%), the possibility to purchase vacation days, and social Wednesday afternoons, as well as a flexible teleworking policy of up to 3 days of telework. The parental leave policy applies to all employees with at least one year of seniority and falls under the responsibility of the management board.

In 2024, the unadjusted gender pay gap at Belfius was 11%, based on monthly salary. Belfius notes this unadjusted gap is calculated only on the basis of gender, without considering other significant factors such as seniority, job function or educational level that are essential for achieving equal pay for comparable work. The annual total remuneration ratio within Belfius was 13.4:1. This ratio represents the total remuneration of the highest paid individual over the median employee total remuneration, taking into account base salary, variable pay and benefits in kind, but without insured benefits. Belfius states this indicates an equitable compensation structure, keeping the gap between the highest and median earners reasonable. The remuneration policy is gender-neutral and non-discriminatory, using an objective grading methodology, and Belfius strives for equal remuneration for equal responsibilities and experience, discussing, measuring and reporting evaluations, remunerations and promotions within the competent bodies on an annual basis.

Belfius' Human Rights policy commits to respect the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, applies to all subsidiaries and activities of the Belfius Group, and formally prohibits child labour and forced labour. The head of Sustainability oversees human rights matters. Belfius is a signatory of the UN Global Compact Principles, the UNEP FI Principles for Responsible Banking, the UNEP FI Principles for Sustainable Insurance, and the UN Principles for Responsible Investment. For downstream value chain workers, Belfius' Transversal ESG Ambition Policy (TAP) emphasises respect for UN Global Compact principles, including labour rights. For upstream workers it applies the Sustainability Code of Conduct for Suppliers, aligned with the UN Global Compact Principles and covering all procurement and outsourcing activities. Policies were developed with ESG, procurement, legal and communication departments. Workers in the value chain and other external stakeholders were not specifically consulted during drafting, though their interests were considered. All policies are available online in English, French and Dutch and can be consulted by any affected stakeholder.

All parties have the option to report incidents via Belfius' whistleblowing procedure (described in section 4.1.3). The Whistleblowing Policy allows individuals such as employees, directors, customers, suppliers, business associates and the general public to report allegations of financial or legal impropriety. Reporting can be accessed internally or externally, and all reported concerns are viewed and evaluated by the Compliance department. Whistleblowers are protected from retaliation or discriminatory or disciplinary action, in accordance with the applicable law transposing Directive (EU) 2019/1937 of the European Parliament and of the Council. A specific procedure follows up on whistleblower reports; where relevant, the Compliance Officer updates the chairman of the Management Board on progress. In 2024, no Human Rights issues or incidents were identified in relation to value chain workers, and no formal process for remediation has been created.

Belfius identifies the construction sector, a large share of its business, corporate banking and investment banking portfolios, as having the highest potential negative impact on value chain workers (low and irregular wages, toxic products, forced labour, discrimination). Its main action is the Transversal ESG Ambition Policy (TAP): companies found in violation of UN Global Compact labour principles are excluded from portfolios. Belfius states that apart from ensuring TAP compliance there are no further specific actions taken regarding workers in the value chain. For upstream supply chain workers, Belfius applies the Sustainability Code of Conduct for Suppliers and uses EcoVadis to assess suppliers across 21 CSR criteria including Labour and Human Rights. Sustainability criteria are integrated into tendering, with 10% of the total RFP score allocated to sustainability. In 2024, ESG due diligence was conducted on 100% of new critical suppliers, and 80% of suppliers completed the EcoVadis assessment (target met). No Human Rights incidents were identified in 2024.

Belfius has no specific policy describing its community involvement strategy. As a principle, it fosters durable relationships with a few stable, reputable and impactful organisations aligned with its mission and strategy, an alignment regularly evaluated by the Brand Committee (composed of the CEOs of Belfius Bank and Insurance and the directors responsible for business lines). All communications projects such as campaigns, art and sponsorship require Brand Committee approval, as set out in the Reputation Risk Policy, which addresses risk appetite, decision-taking and roles and responsibilities for reputation risk. Belfius recognises its operations are more likely to be linked or contribute to adverse human rights impacts than to cause them directly. To mitigate this, its Human Rights Policy covers the products, customers, employees and suppliers of Belfius and all its subsidiaries. Reputation risk management follows a top-down and bottom-up approach steered from the Board of Directors and Risk Committee to business activities via the Management Board.

Regarding Belfius' complaints mechanism for clients, a tag has been created to distinguish complaints that may concern potential human rights violations. No specific system has been put in place for complaints coming from the Belgian community. Belfius reports that no severe Human Rights issues or incidents were reported in 2024 connected to its affected communities, and consequently no formal process for remediation has been created. More broadly, the Whistleblowing Policy allows individuals including the general public to report allegations, accessible internally or externally, with all concerns evaluated by the Compliance department and whistleblowers protected from retaliation under the law transposing Directive (EU) 2019/1937.

Belfius contributes to the Belgian community by providing financial infrastructure and support, and its Communication department manages relations with chosen charities that retain full autonomy over their projects for children, young people and the disadvantaged. No specific targets have been created. In 2024 it raised EUR 816,170 for Viva for Life (child poverty; sponsor since 2014, principal sponsor since 2016), and 185 institutions were supported with funds collected in 2023. It contributed EUR 75,000 to Telievie (cancer research) and raised EUR 390,263 for the JEZ! youth collective. Through Special Olympics Belgium (main partner since 2019), 3,400 athletes participated in 20 sports at the May 2024 national games in La Louviere. Belfius sponsors Campus 19 (559 active students, 35 internships and 53 job placements in 2024). Since 2019, EUR 11.4 million has been donated through philanthropy investment solutions, and in 2024 Beats customers directed a total of EUR 500,000 to selected charities. The Belfius Art Collection holds over 4,000 pieces, with the gallery open to the public twice a month.

Belfius regards consumer protection as non-negotiable and adheres to sector codes of conduct from Febelfin (good customer relations; Belgian Charter for digital inclusion), Assuralia (claims handling) and BEAMA (asset management fiduciary duty). It is subject to MiFID II (Directive 2014/65/EU), the Insurance Distribution Directive (Directive 2016/97/EU) and Customer Due Diligence under the Anti-Money Laundering Directive (2018/843/EU). Consumers are also covered by Belfius' Human Rights policy. For data protection, the Privacy Charter is published on the public website and an internal Privacy Risk Policy applies across the Belfius Group, validated by the Board of Directors. For information security, an Information Security policy operates within a three Lines of Defence model and ISMS framework, approved by the Information Security Steering and the Risk Policy Committee. Complaint handling follows a Complaints Policy aligned with MiFID II and FSMA rules. Financial inclusion efforts have not been formalised within a centralised policy framework.

Belfius engages with consumers primarily through its annual customer satisfaction survey, run by the Customer Research department with external market research agencies, targeting a 95% satisfaction goal in effect since 2014. In 2024 the survey was sent to 519,201 customers across Belfius Bank business lines and 66,173 answers were received (all Private and Wealth Management and E&E and PSB clients, plus a random Retail sample); responses are communicated to and used by relevant departments. Belfius fosters an "always on" engagement: the Belfius Mobile app's smart digital assistant enables instant self-servicing, customers can opt for a call-back within 30 minutes if agents are unavailable, and in-person appointments are offered within 7 days. Complaints are treated as key moments in the customer journey and systematically monitored. In 2024, Febelfin held 25 information sessions in Wallonia about online banking and fraud, which Belfius participated in to meet clients.

Belfius operates a Complaints Policy aligned with MiFID II and FSMA rules, endorsed by the management board. Customers can submit complaints via their branch, phone, email, a form on the website, in BDN and BM, or by postal mail. Handling has four levels: Level 1 (branches, bankers, Belfius Connect and subsidiaries); Level 2 (Complaints departments); Level 3 (the Belfius Negotiator, a neutral contact, not applicable to DVV); and Level 4 (the Federal Bank/Insurance Ombudsman or the Court). Reporting runs monthly to the CTRO direction, quarterly to NFR and the external auditor, and annually to the Managing Board and Audit Committee. In 2024, Belfius recorded 13,530 complaints, up 1% versus 2023, including 88 discrimination-related complaints (up 159%) and 434 privacy complaints (up 82%). None related to severe Human Rights issues, so no formal remediation process was created. The Whistleblowing Policy is also open to customers, and data subjects can exercise GDPR rights through online and mobile applications.

Belfius took wide-ranging actions in innovation, financial inclusion, data protection and information security. Digital initiatives include the Re=Bel investment platform, the redesigned Belfius Mobile app (over 2 million daily users) with accessibility features recommended by AnySurfer (speech module for visually impaired customers, video subtitles, no continuous animations for neurodivergent users), Belfius E-Sign, digital onboarding, an anti-phishing programme and the CYBERSMART campaign. For financial inclusion: basic banking services (49% market share, 61,000 basic banking account clients), around 163,303 active social accounts at end 2024, the Batopin network (581 sites, 1,459 cash machines), 410 cashless machines, phone banking (1,173,683 calls in 2024), a blind notch added to debit cards in January 2024, braille statements, and an aim to meet WCAG 2.2 AA. Data protection actions include GDPR compliance processes and third-party supplier data privacy assessments. Information security actions include 24/7 monitoring by an external Security Operations Centre, Red Team assessments, penetration tests, vulnerability scans and monthly phishing simulations.

Belfius maintains a customer satisfaction target of 95% (set by the Management Board, in effect since 2014); it achieved a satisfaction score of 94% in 2024. For data protection, targets are set through a yearly self-assessment of risks and controls under the Risk Appetite Framework: no overdue data breach notifications during the year (met in 2024), and fewer than 5 data breaches reported to the Belgian Data Protection Authority per quarter (met, with 9 incidents in total in 2024: 4 in Q1, 3 in Q2, 1 in Q3 and 1 in Q4). For data subject right requests, the target is no late responses, and if any, fewer than 3 late responses per year; there were no late answers in 2024. For information security, the target is to continually score higher than 3 on the biennial external maturity assessment, which was achieved (the specific metric is not disclosed due to sensitivity). No specific targets have been established for innovation and digitalization or for financial inclusion.

Belfius' Compliance Framework sets out its business conduct policies and procedures, including the Compliance Charter, the Integrity Policy, a general Code of Ethics and specific Codes of Conduct, plus policies covering market abuse, anti-bribery, anti-fraud, anti-money laundering and whistleblowing. The Code of Conduct, based on values of respect, honesty and transparency, is validated by the Management Board, with Compliance responsible for implementation. The ESRS index maps G1-1 to the United Nations Convention against Corruption paragraph 10(b) and protection of whistleblowers paragraph 10(d). The Whistleblowing Policy lets employees, directors, customers, suppliers, business associates and the public report concerns internally or externally; whistleblowers are protected from retaliation or disciplinary action in line with Directive (EU) 2019/1937. On corporate culture, new employees must complete training covering the Code of Ethics, anti-corruption, whistleblowing, GDPR and market abuse modules, with anti-corruption training part of the mandatory Code of Conduct training refreshed roughly every five years. Belfius maintains a zero tolerance approach to bribery and corruption. Anti-bribery training reach was 89% for all employees (frequency every 5 years).

Belfius' expectations of suppliers are set in policies published on its corporate website, with the Procurement Policy held on the intranet and the Head of Procurement responsible for implementation. The Sustainability Code of Conduct for Suppliers is aligned with the United Nations Global Compact's 10 principles, covering human rights, health and safety, lawful labour practices, anti-corruption and integrity, freedom of association and collective bargaining, and environmental protection. It applies to all providers of goods and services to Belfius and subsidiaries and requires suppliers to ensure their own suppliers and subcontractors adhere. The General Terms and Conditions of Purchase and the Procurement Policy integrate ESG criteria. For all new key suppliers in an RFP process, 10% of the total score is allocated to sustainability-related aspects. EcoVadis is used as an independent ESG rating provider, scoring suppliers on 21 CSR criteria across four themes (Environment, Labour and Human Rights, Ethics, Sustainable Procurement). In 2024, ESG due diligence was conducted on 100% of new critical suppliers; 80% of existing critical suppliers held a valid EcoVadis scorecard, and the target of 80% of suppliers spend completing the EcoVadis assessment was achieved. Targets include 100% of critical suppliers ESG screened and 80% of total third-party spend ESG screened.

Belfius has a zero tolerance approach to bribery and corruption, is subject to Belgian and European laws, and does not engage in or tolerate any facilitation payment. It considers the commercial departments and the procurement department as more exposed to corruption and bribery risk. The Anti-Bribery Policy prohibits proposing, offering, requesting or accepting unauthorised benefits and applies to all Belfius group entities, board and governing body members and employees, with the same rules expected of customers, suppliers and business partners; the Compliance function supervises adherence. Business conduct incidents, including corruption and bribery, are investigated independently by the Compliance department, Audit Investigations, or both, following a procedure aligned with Directive (EU) 2019/1937. Prevention uses technical barriers programmed in IT tools that monitor suspicious transactions on employees' accounts, and atypical behaviours indicating corruption or bribery are monitored and examined. The general anti-corruption training is part of the mandatory Code of Conduct training, taken at onboarding and refreshed roughly every five years, with reach of 89% for all employees. In 2024, no cases of whistleblowing were reported, and Belfius received no convictions or fines for violation of anti-corruption or anti-bribery laws.