Belfius Bank

The role of the administrative, management and supervisory bodies

Reference: page 182; pages 182-184.

"In line with their duties as defined by law, Belfius Bank's Board of Directors and Management Board are the respective supervisory and management bodies on ESG" (page 182). The Board "defines and oversees the implementation of the strategy, objectives..., general policies including business conduct, risk appetite and risk approach..., This includes ESG" (page 182). The Risk Committee holds "advisory powers and responsibilities... for the setting of current and future risk appetite and strategy (including those relating to ESG and, more particularly, climate risk)" (page 182).

ESG expertise: "Estelle Cantillon was specifically appointed... to considerably contribute to the expansion of the expertise of the Belfius Bank Board of Directors in the field of ESG as she combines a strong academic background as a Professor of Economics with extensive knowledge of climate and environmental aspects related to banks and financial institutions" (page 183).

Composition, 31 December 2025: Board of Directors 16 members (62.5% male / 37.5% female, 43.8% independent); Management Board 6 members (83.3% male / 16.7% female) (page 184).

Information provided to the administrative, management and supervisory bodies

Reference: page 184.

"Belfius Bank's Board of Directors and Management Board, including relevant committees, are informed of material impacts, risks and opportunities" through recurring reporting flows (Quarterly Financial Results, Quarterly Risk and RAF Reports, half-yearly Compliance Reports) and ad hoc topics (page 184). The disclosed topics table shows the Management Board and Board of Directors both reviewing, among others, "Belfius ESG Action Plan 2025", "Climate and Environmental Risk Materiality Assessment 2025", "Belfius Decarbonization Targets", "Transition Acceleration Policy (TAP)" and "New Sustainable Investment Approach" (page 184).

Integration of sustainability-related performance in incentive schemes

Reference: page 185.

"ESG indicators determine 9.8% of the performance score of the variable remuneration in 2025 for all key and senior executives" (page 185). "In 2025, the social indicators were the share of women in management (target 44%), Belfius' employee engagement (target 86%) and customer satisfaction (target 48.2% top 1 - very satisfied customers). A custom-built target to reduce Belfius' carbon emissions from own operations in line with the Paris Agreement trajectories represents the environmental pillar (target of -5.3%)" (page 185). "The part of variable remuneration linked to climate related considerations is 1.2%" (page 185).

Statement on due diligence

Reference: pages 185-186.

Belfius provides a due-diligence core-elements table mapping each element to the relevant section of the statement (page 185-186): embedding due diligence in governance/strategy maps to section 1.4; engaging with affected stakeholders to 1.3 and 1.5.1; identifying and assessing adverse impacts to 1.5.1 and 1.5.3; taking actions to address impacts to 2.1 (climate change), 1.6 (Meaningful activities) and 3.1.3/3.2 (health & safety, consumers); and tracking effectiveness/communicating to 1.6, 3.1.2 and 3.1.1. No separate narrative paragraph is provided beyond this referencing table.

Risk management and internal controls over sustainability reporting

Reference: page 177.

"The Finance department coordinates the preparation of the sustainability statement, consolidates information from internal disclosure owners and ensures consistency and compliance with ESRS requirements" while "the ESG department collaborates with the Finance department for the Sustainability Statement's 2nd line review" (page 177). Internal controls include "independent reviews ('four-eyes checks'), standardised templates, greenwashing review, analytical reviews and consistency checks" (page 177). A risk table names five risk categories (reporting integrity, data availability & quality, operational, greenwashing, regulatory) each with a stated mitigation strategy (page 177).

Strategy, business model and value chain

Reference: pages 178-179.

"Belfius is a Belgian banking and insurance group that is fully owned by the Belgian Federal State through the Federal Holding and Investment Company (FHIC)" (page 178), with 7,171 employees on 31 December 2025, mostly in Belgium. Belfius serves two segments: "Retail, Private & Wealth" and "Wholesale" (Corporate Banking and Public & Social sector) (page 179). "Belfius is active in the sector of Credit Institution, Insurance and Capital Markets. These sectors have not been identified as climate intensive by ESRS" (page 179).

On the EU Paris-aligned benchmark exclusion datapoint: "Belfius is not excluded from the EU Paris-aligned benchmarks due to the fact that it does not derive a set percentage of its revenues from coal, oil, gas or electricity generation" (page 206).

Interests and views of stakeholders

Reference: pages 180-182.

Belfius sets out a stakeholder table covering Customers, Government regulators/supervisors, Employees, Shareholders and Suppliers, each with its engagement channel and the main topics discussed (pages 181-182). For example, employees are engaged through "an annual engagement barometer" and "representation in social bodies and linked subcommittees and a network of union representatives" on topics including "fair and competitive remuneration" and "welfare, physical and mental health" (page 181). "The views of stakeholders inform our due diligence process and the materiality assessment" (page 180).

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

Reference: pages 187-189.

"Belfius has identified the following material topics": Climate change (E1), Own workforce (S1), Consumers & end-users (S4) and Business conduct (G1), plus the entity-specific topics Resilience and Meaningful Activities (page 187). "Compared to the prior reporting period, the 2025 update did not lead to the identification of additional sustainability matters, nor to the removal of previously material matters. The update primarily focused on the consolidation and clustering of certain IROs" (page 187): customer transparency, financial inclusion and data protection moved under S4; information security, innovation & digitalization and resilience were consolidated into the entity-specific topic Resilience; and meaningful financing/investing/insuring plus community involvement became the entity-specific topic Meaningful Activities (page 187).

For each material topic the statement describes impacts, risks and opportunities in narrative form, e.g. for climate change: "Belfius could have an impact by participating in climate change through the emission of greenhouse gas (GHG) emissions in its own operations" and "a positive impact by participating in the transition to sustainable energy sources" (page 187).

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

Reference: pages 186-187.

"Belfius applied a structured scoring methodology aligned with ESRS requirements and informed by EFRAG guidance" (page 186). Impact materiality scored severity (scale, scope, irremediability) 1-5 and, for potential impacts, likelihood; financial materiality scored magnitude 1-5 and likelihood (page 186). "A sustainability matter is considered material if it is assessed as material from either an impact or financial perspective" (page 187). The longlist was built from "peer analysis", "sector-specific voluntary non-financial reporting frameworks (SASB)", ECB/EIOPA frameworks, and quantitative screening using "UNEP FI Impact Analysis tool" and the "ENCORE database" (page 186). "In 2025, this assessment was subject to a targeted update building on the 2024 results" via internal stakeholder workshops rather than a full repeat (page 185). Material IROs were "validated by a broader group of internal stakeholders" (page 187).

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

Reference: pages 241-243.

Belfius publishes an "Index table disclosure requirements" in Appendix 5.1: "Cfr the requirements of ESRS 2, this table includes the list of disclosure requirements, including the datapoints derived from other EU legislations as listed in Appendix B of ESRS 2, and the placement within the document" (page 241). Each disclosure requirement is listed against the chapter of the statement where it is addressed, or flagged "Not Material" where the double materiality assessment found it not material. This index is the basis used throughout this entry for classifying each disclosure requirement as reported or not material.

Transition plan for climate change mitigation

Reference: pages 195, 200-206.

Belfius has no section headed "transition plan"; the index assigns this DR to Chapter 2 and its content is built from the Climate and Environmental Policy (CEP) and the decarbonization targets. The CEP "aims to limit adverse environmental impacts and supports the transition to a low-carbon, resilient and environmentally sustainable society" (page 195), operationalised through the Transition Acceleration Policy (TAP), which "excludes investment and lending to certain sectors (phasing out for example coal or unconventional oil and gas extraction)" (page 195).

For own operations, Belfius targets a 42% absolute reduction of scope 1, 2 and part of scope 3 emissions by 2030 from a 2022 baseline (page 200), reaching 13,909 tCO2e in 2025 versus a 23,583 tCO2e 2022 baseline (page 200). For financed emissions, "Belfius defined Paris-aligned decarbonization targets" for its five most carbon-intensive sectors (coal, oil & gas, power generation, automotive, residential real estate) using the PACTA methodology (page 205). "Belfius is not excluded from the EU Paris-aligned benchmarks" (page 206). "In 2026, Belfius intends to consolidate these targets along with all elements related to the transition... into a formal document" (page 206) - i.e. a single consolidated transition plan is still in progress.

Policies related to climate change mitigation and adaptation

Reference: page 195.

The Climate and Environmental Policy (CEP) "deals with": climate change mitigation and the energy transition (GHG accounting and decarbonization targets, plus the TAP); climate change adaptation (measuring and disclosing climate risks and opportunities); and environmental sustainability (page 195). "The CEP is implemented by the Head of People Brand Communication and ESG and is approved by the JMC" and "applies to all subsidiaries of the Belfius Group over which it holds operational controls" (page 195).

The policy explicitly scopes out the other environmental topics: "Given the nature of its activities however, Belfius does not have specific targets and policies on the topics of pollution, water and marine resources, circular economy, and biodiversity" (page 195).

Actions and resources in relation to climate change policies

Reference: pages 200-203.

Belfius' action plan for own operations "focuses on two pillars" (page 201): (1) Responsible building management, including "optimization of monitoring systems... using nano-grids... installing solar panels and heat pumps, performing EPC analysis" and a commitment to "100% certified green electricity" (98% achieved) (page 201); and (2) Green mobility, where "employees have been required to order only fully electric cars since May 2023 with the commitment of reaching a fully decarbonized car fleet by end 2029" and Belfius Auto Lease targets a 50% cut in leased-fleet emissions per km by 2030 through electrification, smart charging (CenEnergy) and a Mobility-as-a-Service offer (Skipr) (page 202).

Targets related to climate change mitigation and adaptation

Reference: pages 200, 205-206.

Own operations: an absolute target of -42% (scope 1, and scope 3 categories 3/5/6/7/14) by 2030 from a 2022 baseline, set using "the Science-Based Target initiative (SBTi) methodology", plus two intensity targets (leased cars -50% gCO2e/km, leased real estate -64.7% kgCO2e/m2 by 2030) and a 100% renewable-electricity target for 2025 (reached 98.2%) (page 200).

Financed emissions: "Belfius has defined... 5 Paris-aligned group-level targets" for coal, oil & gas, power generation, automotive and residential real estate, using PACTA with IEA decarbonization scenarios; controversial sectors (coal, oil & gas) get absolute phase-out targets from a 2022 baseline, the others get intensity targets from a 2024 baseline with a 2030 range between a "well-below 2 degrees" scenario and a 1.5 degrees "Net Zero Emissions by 2050" scenario (page 205). "Decarbonization levers as well as progress over these targets will be disclosed in the next CSRD report" (page 205).

Energy consumption and mix

Reference: pages 201-202.

Total energy consumption related to own operations was 19,595 MWh in 2025 (down from 20,492 MWh in 2024), of which 68% came from renewable sources (13,310 MWh, almost entirely green electricity) versus 32% from fossil sources (6,284 MWh) (page 201-202). "As a financial institution, Belfius has no energy consumption from dedicated biofuel or giogas installations, nor does it derive a predetermined amount of its energy from nuclear sources"; nuclear-source consumption is estimated "by applying the share of nuclear sources in the Belgian electricity mix to Belfius' grey electricity consumption" (page 202). The data "covers Belfius' direct operations (Scope 1 and 2) and excludes the energy consumption and mix of the clients (Scope 3)" (page 202).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 196-199.

Belfius calculates emissions under the operational-control approach across the GHG Protocol's three scopes, with "own operations emissions (Scope 1, Scope 2 and Scope 3 Categories 1-14)" calculated per the GHG Protocol and "financed and insurance associated emissions (Scope 3 Category 15)" calculated per PCAF methodology (page 196). All 15 Scope 3 categories are mapped to specific sources (e.g. Category 11 "use of sold products" covers "the use of Belfius Direct Net, Belfius Mobile and Belfius.be by Belfius' customers"); Categories 9 and 10 are marked "Non applicable, not material for Belfius" (page 197).

GHG emissions intensity for 2025 was 4.43 kgCO2e/€ of net revenue (both location- and market-based), calculated on net revenue of EUR 3,284,231,922, and "takes into account Scope 3 Category 15" (page 198). "In 2025, Belfius reported its insurance-associated emissions according to PCAF's Insurance Associated Emissions Standard for the first time" (page 197).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 207.

"Belfius purchases carbon credits with the purpose of maximizing its positive impact on the environment... These credits have no impact on Belfius' total footprint calculations and are not considered as a reduction, but as a separate voluntary exercise" (page 207). Belfius cancelled 2,198 tCO2eq of carbon credits in 2025 (down from 30,500 tCO2eq in 2024), of which 79% from removal projects and 21% from reduction projects, 100% ISO 14064-2 certified and 100% sourced within the EU; 0% qualify as corresponding adjustments (page 207). "In 2025, Belfius took a step forward... by updating its purchasing process... transitioned towards acquiring removal credits from Soil Capital, a Belgian startup specializing in carbon removal credits derived from nature-based solutions within Belgium" (page 207).

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

Reference: pages 176, 208-211.

Belfius explicitly invokes relief for this DR: "Belfius has applied phased-in quick-fix extended relief to the following disclosures: E1-9 Climate change: anticipated financial effects of climate change - Belfius partially discloses the required information in Chapter 2" (page 176). Consistently, "no precise figures regarding the anticipated financial effects of C&E risks are provided at this stage (phased-in approach)" (page 208).

What is disclosed is qualitative: the 2025 CERMA (Climate and Environmental Risks Materiality Assessment) "confirms that credit risk and strategic risk are expected to be the most impacted risk dimensions", while "liquidity and market risk are not considered to be materially impacted" and, "even if deemed material, C&E risk drivers are not, under the selected scenarios, expected to pose a significant threat to Belfius Bank's solvency, liquidity or profitability - even in the longer term" (page 210). Quantified disaggregation by acute/chronic physical risk, location of at-risk assets, and a real-estate energy-efficiency breakdown (the Appendix B datapoints under paragraphs 66(a), 66(c) and 67(c)) were not located in the statement.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the C&E risk management section (2.2), where this content is disclosed in the FY2025 report (pages 208-210). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Belfius classifies climate risk drivers as "Physical risks, which refer to acute and chronic climate-related hazards" and "Transition risks, which arise from the process of adjustment towards a low-carbon and environmentally sustainable economy" (page 208) - satisfying the mandatory risk-classification core of this DR.

The CERMA methodology covers "lending portfolios..., the investment portfolio and trading book, as well as its funding, assets, strategies and own operations" (page 209) and runs through "an exhaustive list of 46 climate and environmental-related risk drivers" (page 210). Scenario analysis is used: for physical risk, the "Hot House Scenario" (NGFS), which "aligns with a temperature increase of +3 degrees C or more by 2100" - a high-emission scenario; for transition risk, "Current policies and Delayed Transition" (NGFS), which "aims to keep global warming below 2 degrees C by 2100, but often misses 1.5 degrees C target" (page 209) - this is not itself a 1.5-degree-aligned scenario with no or limited overshoot, which is a gap against paragraph 17(a)(ii). Both scenarios are applied across short, medium and long-term horizons for Belfius Bank, and short/long-term only for Belfius Insurance's 2024 exercise, extending to all three horizons going forward (page 209). The assessment is run annually ("updated on a yearly basis", page 209; "2025 CERMA", page 210).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the C&E risk management section (2.2), where this content is disclosed in the FY2025 report (pages 210-211). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Belfius' resilience conclusion is stated directly: "Overall, even if deemed material, C&E risk drivers are not, under the selected scenarios, expected to pose a significant threat to Belfius Bank's solvency, liquidity or profitability - even in the longer term" (page 210). For Belfius Insurance, a long-term climate stress test to 2050 found that "while the risks are assessed as low or manageable, there are substantial uncertainties, particularly in non-life claims and transition impacts on asset yields, necessitating ongoing monitoring and adaptation" (page 211).

Capacity to adjust: Belfius names concrete mitigation levers - sectoral policy restrictions (the TAP), ESG-linked risk-appetite limits, new sustainable-finance products, and "active engagement with clients, investees and suppliers to advocate change" (page 211) - though no quantified flexibility-of-capital figure is given.

Policies related to own workforce

Reference: pages 217-218.

"Belfius upholds the rights of its employees and requires adherence to its Human Rights Policy and Code of Conduct" (page 217), which "prohibits child labour and forced labour across all activities" (page 217) and "fully respects employees' rights to collective bargaining and freedom of association" (page 217). The Anti-Discrimination Policy covers "gender, ethnic origin, skin colour, age, disability, sexual orientation, religion, political beliefs, or social background" and applies "a zero-tolerance policy towards violence in the workplace" (page 218). The Health and Safety Policy "applies to all internal employees as well as external employees such as contractors, third parties, temporary workers, and trainees" (page 219).

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

Reference: page 222.

"For the past decade, Belfius has been measuring the satisfaction and engagement of its employees through its annual anonymous engagement survey" with a response rate of "75.9% [Belfius Bank]... and for Belfius Insurance 82.6%, making the survey representative and actionable" (page 222). "The Management Board is responsible for the execution and follow-up of the engagement survey" (page 222). Separately, employees are represented through "a network of union representatives" and "representation in social bodies and linked subcommittees" (page 181).

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

Reference: page 218.

"Grievance mechanisms and remedies are in place to ensure that concerns are heard, investigated and addressed in a timely matter" under the Anti-Discrimination Policy (page 218). In 2025, the "Number of complaints filed through channels for people in own workforce to raise concerns" was 0 (page 218) - a nil return rather than an absence of a channel, since the mechanism and its reporting line are described directly above the figure.

Taking action on material impacts on own workforce

Reference: pages 217, 219-222.

Actions cut across the workforce programme described in this entry's related disclosures: health and safety (section 3.1.3, page 219-220), diversity, equity and inclusion initiatives such as signing "the Charter of Amsterdam 2024" and the "Inclusive Panels Charter" (page 221), work-life balance provisions (flexible hours, parental and caregiving leave, part-time work from 50% to 90%, page 222), and remuneration actions including an annual benchmark review to ensure pay "at or above the sector's minimum wage" (page 219). No single consolidated "actions" table is provided; actions are described within each sub-section.

Targets related to own workforce

Reference: page 185.

Own-workforce targets sit in the incentive-scheme disclosure: "the share of women in management (target 44%)" and "Belfius' employee engagement (target 86%)" (page 185), both tied to senior and key executive variable remuneration. Women in management stood at 43.6% in 2025, up from 42.3% in 2024 (page 221), close to but not yet at the 44% target.

Characteristics of the undertaking's employees

Reference: page 216.

"In 2025, Belfius counted 7,171 internal employees of which 99% had permanent contracts" (page 216), of whom 7,121 on permanent contracts and 50 on fixed-term contracts; 6,215 full-time and 956 part-time (page 216). "48% of staff members at Belfius Bank & Insurance are aged 50 or more" and "the 60+ age group represents 15.4% of the active population" at year-end 2025 (page 216).

Characteristics of non-employee workers

Reference: page 176.

Belfius applies relief rather than omitting this disclosure: "Belfius has applied phased-in quick-fix extended relief to the following disclosures: ... S1-7 Own workforce: metrics related to non-employees" (page 176). Qualitatively, "Belfius also works with contractors, third parties, temporary workers and trainees which are not included in the tables below. These persons are considered equal to internal employees under the wellbeing law and therefore have the same rights and obligations" (page 216), and the Health and Safety Policy explicitly extends to this group (page 219). No headcount figures for non-employees are disclosed, consistent with the stated relief.

Collective bargaining coverage and social dialogue

Reference: page 217.

"In 2025, 94% of employees were covered by collective bargaining agreements and represented by workers' representatives, ensuring that all employees work in establishments with formal representation" (page 217). Representation operates through "a network of union representatives" and dedicated social bodies and subcommittees (page 181).

Diversity metrics

Reference: page 221.

"The representation of women in management positions has increased from 42.3% in 2024 to 43.6% in 2025" (page 221). At top management level in 2025, women held 48.0% of positions (95 of 198); in management roles generally, women held 43.6% (369 of 847) (page 221). Board of Directors gender split at year-end 2025 was 62.5% male / 37.5% female (page 184).

Adequate wages

Reference: page 219.

"Each year, all 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 via an external provider is conducted to compare all employees to their respective reference market" (page 219). "Belfius strives for equal remuneration for equal responsibilities and experience" (page 219).

Social protection

Reference: page 219.

"Belfius' collective bargaining agreement states that all employees are allowed to work part-time and are covered by social protection. Belfius provides income protection for employees in the event of sickness, economic or technical unemployment as foreseen by Belgian law (from the start of employment), work-related injury or acquired disability, parental leave, and retirement. Belfius offers a comprehensive supplementary insurance package that exceeds legal obligations" (page 219).

Persons with disabilities

Reference: page 176.

Belfius applies relief rather than omitting this disclosure: "Belfius has applied phased-in quick-fix extended relief to the following disclosures: ... S1-12 Own workforce: metrics related to persons with disabilities" (page 176). The Anti-Discrimination Policy names disability among the protected characteristics (page 218), but no headcount or percentage figure for employees with disabilities is disclosed, consistent with the stated relief.

Training and skills development metrics

Reference: page 217.

"Workers who participated in regular performance and career development reviews" held at 25% in 2025 (up from 24% in 2024): 26% of female employees and 23% of male employees (page 217). "Evolution of average number of days training per full-time equivalent increased compared to 2024": 5.9 days in 2025 versus 5.1 in 2024, including "on-the-job, e-learning & mandatory training" (page 217).

Health and safety metrics

Reference: pages 219-220.

"Percentage of workers who are covered by health and safety management system based on legal requirements and (or) recognised standards or guidelines" was 100% in both 2024 and 2025 (page 220). "Number of fatalities in own workforce as result of work-related injuries and work-related ill health" was 0 in both years (page 220). Root-cause analysis is performed for each accident via an insurance-declaration tool, with the external workforce covered through the third-party employer's own investigation process (page 219).

Work-life balance metrics

Reference: page 222.

"Belfius provides support through a range of options, including flexible working hours, parental leave, caregiving leave, part-time work (50% to 90%), the ability to purchase additional vacation days, and social Wednesday afternoons" (page 222). "All Belfius employees are entitled to family-related leave under Belfius' social policy and/or collective bargaining agreements" covering "maternity leave, paternity leave, parental leave, and careers' leave" (page 222); the parental leave policy applies "to employees with at least one year of seniority" (page 222).

Compensation metrics (pay gap and total compensation)

Reference: page 219.

"The unadjusted gender pay gap is based on monthly salary and is only calculated on the basis of gender, without consideration for other significant factors such as seniority or role (level)" (page 219). The gender pay gap was 10% in 2025 (down from 11% in 2024); the total remuneration ratio was 13.3:1 in 2025 (versus 13.4:1 in 2024) (page 219). Separately, "the unadjusted pay gap stood at 14% for Belfius Insurance and 10% for Belfius Bank" (page 182, risk-mitigation paragraph).

Incidents, complaints and severe human rights impacts

Reference: page 218.

Belfius' 2025 figures are a full nil return: "Number of incidents of discrimination" = 0; "Number of complaints filed through channels for people in own workforce to raise concerns" = 0; "Number of complaints filed to National Contact Points for OECD Multinational Enterprises" = 0; "Number of severe human rights issues and incidents connected to own workforce" = 0; and the related fines/penalties figures are likewise 0 (page 218).

Policies related to consumers and end-users

Reference: pages 223-224.

Data protection: "The approach to personal data for customers and employees is publicly communicated through the Privacy Charter. The Privacy Risk Policy provides an overview of the privacy risk landscape and the applicable risk governance framework" (page 223). Financial inclusion: "Belfius implements actions on multiple levels: improving digital and app accessibility, maintaining physical cash points and providing tailored products such as basic banking accounts and social accounts" (page 224), including "a payment account and the most essential operations" under the legally required basic banking service and social accounts opened via CPAS/OCMW for beneficiaries without a bank account (page 224).

Processes for engaging with consumers and end-users about impacts

Reference: page 225.

"Overall, Belfius Bank obtained a satisfaction score of 94% in 2025 - stable compared to 2024. The head of Customer Research is in charge of supervising the annual satisfaction survey. Responses from the survey are communicated to and utilized by the relevant departments" (page 225).

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

Reference: pages 225-226.

"Customers have the flexibility to choose their preferred channel for submitting complaints, be it via their branch, phone, email, a form on the website, in BDN and BM, or through postal mail" (page 225). Belfius "distinguishes four handling levels for complaints": first-level branches/bankers, second-level Complaints departments, a third-level independent Negotiator, and a fourth level via "the Federal Bank/Insurance Ombudsman, or the Court" (page 226).

Taking action on material impacts on consumers and end-users

Reference: page 226.

"Belfius recorded 13,058 complaints in 2025 compared to 13,530 complaints in 2024 which leads to a decrease of 3.5%" (page 226). "In 2025, Belfius recorded 77 complaints related to a sense of discrimination, a 13% decrease versus 2024", including cases "related to the discontinuation of the Belfius Phone Banking service affecting clients with disabilities as well as elderly clients" (page 226). "Belfius recorded 355 complaints related to privacy, representing an 18% decrease compared to 2024" (page 226). "Of these complaints, none were related to severe Human Rights issues, therefore no formal remediation processes were launched" (page 226).

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

Reference: page 185.

The consumer target sits within the incentive-scheme disclosure: "customer satisfaction (target 48.2% top 1 - very satisfied customers)" is one of the social indicators determining 9.8% of variable remuneration for key and senior executives in 2025 (page 185). No separate numeric target for complaint volumes or data-breach rates is stated outside the privacy KRI noted under S4-1 ("fewer than five reported breaches per quarter per entity", page 224).

Business conduct policies and corporate culture

Reference: pages 226-227.

The Belfius Compliance Framework comprises the Compliance Charter, Integrity Policy, Code of Ethics, Market Abuse Policy, Anti-Bribery Policy, Anti-Fraud Policy, Anti-Money Laundering Policy and Whistleblowing Policy (pages 226-227), each with a named owner (e.g. "The Management Board validates the Code of Ethics while the Compliance function is responsible for the implementation of the policy", page 226). "New employees are required to follow training including Belfius' Code of Ethics, anti-corruption, whistleblowing, GDPR and market abuse modules" (page 227). "Belfius has a zero-tolerance approach to bribery and corruption" and "does not engage in nor tolerate any form of facilitation payment" (page 227).

Management of relationships with suppliers

Reference: pages 228-229.

"The Code of Conduct for Suppliers is fully aligned with the United Nations Global Compact's Ten Principles and establishes mandatory obligations for all third parties", including "respecting internationally recognized human rights, ensuring safe and healthy working conditions and adhering to lawful labour practices" and "strict compliance with anti-corruption standards" (page 228). "Compliance is a prerequisite for entering into, or maintaining, any contractual relationship with Belfius" and its scope "extends to third party parent companies, subsidiaries and subcontractors" (page 228). Suppliers are also invited to take "ESG sustainability assessment by third party EcoVadis" (page 181).

Prevention and detection of corruption and bribery

Reference: pages 227-228.

"89% of employees have completed required trainings across all key topics: anti-bribery, market abuse and anti-money laundering (AML)", with anti-bribery and high-risk market-abuse training refreshed every five years and AML training every two years (page 227). Detection relies on "secured whistleblowing channels and GDPR-compliant transaction controls" (page 227); "whistleblowers are protected from any kind of retaliation or discriminatory or disciplinary action" under the law transposing Directive (EU) 2019/1937 (page 227). "No cases of whistleblowing were reported in 2025" (page 228).

Incidents of corruption or bribery

Reference: page 228.

"Throughout 2025, Belfius successfully maintained its standard of ethics. Belfius received no convictions or fines for violation of anti-corruption or anti-bribery laws in 2025" (page 228) - a nil return, consistent with the "no cases of whistleblowing" finding on the same page.

Targets related to business conduct

Back-filled from the business conduct chapter (4.1), where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Belfius states no numeric business-conduct target; instead, effectiveness is tracked through training coverage and monitoring cadence: "89% of employees have completed required trainings across all key topics: anti-bribery, market abuse and anti-money laundering (AML)... Among high-risk functions, 89% have completed the training", with anti-bribery training "scheduled every five years" and AML training "updated every two years to maintain awareness and compliance" (page 227). Detection is tracked on an ongoing basis: "No cases of whistleblowing were reported in 2025" and "Belfius received no convictions or fines for violation of anti-corruption or anti-bribery laws in 2025" (pages 228), both monitored and reported annually through the Compliance department's investigation and reporting process described on page 227.