BNP Paribas

Reference: page 702

The Board of directors "approves the Group's sustainability strategy" and "validates the objectives and commitments related to sustainability, whether in the dimensions of impacts, risks or opportunities" (page 703). At 31 December 2025 it had 16 members, chaired by Mr. Jean Lemierre, and met 11 times; Board gender diversity was 50% women (pages 703, 782).

Four specialised committees support it: the Corporate Governance, Ethics, Nominations and CSR Committee (CGEN), the Internal Control, Risk Management and Compliance Committee (CCIRC), the Financial Statements Committee (CdC) and the Remuneration Committee. The CGEN "is notably responsible for monitoring the Group's CSR policy (including the management of IRO)" and, with the CCIRC, "reviews progress on the operational integration of ESG risk factors, including climate-related risk factors, into the Bank's risk management framework" (page 703).

Chart No. 1 (page 702) sets out the management layer: General Management and Executive Committee, the Sustainable Finance Strategic, Infrastructure and Regulatory Committees, the Group Supervisory & Control Committee (chaired by the CEO, twice monthly, dealing "in a cross-cutting manner with all the dimensions of operational risk ..., including ESG risks"), the General Management Credit Committee, and the Company Engagement Department (pages 702, 706).

Reference: page 703

"The Board of directors is regularly informed of the progress in the implementation of the Group's sustainability strategy by the General Management" (page 703). The frequency is quantified: "In 2025, the Board of directors raised environmental, social and governance (ESG) issues 32 times in order to take into consideration the impacts, risks and opportunities of BNP Paribas' activities", notably on professional equality between women and men, the 2025 priorities in sustainable finance, and the People Strategy including the quality of life at work survey results (page 703).

General Management "is informed of BNP Paribas' IRO through its above-mentioned committees, as well as through ad hoc meetings with the functions" including the Company Engagement Department and the operating divisions (page 703).

Stakeholder views reach the Board through named routes: in 2025 it was informed of the CSEC's observations on the strategic plan and the HR answers to them, of the diversity and inclusion policy and the 2025 Conduct & Inclusion survey results, and of the Pulse survey results (page 717). An annual report on whistleblowing alerts, "the number of alerts and the measures taken, including sanctions, and their outcomes", goes to the Executive Committee and the CGEN (page 769).

Reference: page 706

"A 15% portion of the annual variable compensation of the Executive Officers (the Chief Executive Officer and the Chief Operating Officers) is linked to the Group's CSR performance, with one third tied to the objectives set by the Group in its CSR dashboard, which take into account, in particular, two indicators related to climate-related issues: the reduction of the carbon footprint on the Group's own operations and the amount of the support enabling clients to transition to a low carbon economy" (page 706). Officer remuneration "is subject to an ex-post vote of the Ordinary General Meeting" (page 706).

Sustainability is also built into long-term loyalty plans. The 2026 CSR dashboard objectives "were set in March 2024 at the time of the allocation of loyalty plans to more than 9,000 key staff of the Group", and "The achievement of these 2026 objectives represents 20% of the amounts allocated in 2024 under the loyalty plan. These objectives also count for one third of the annual variable remuneration that will be awarded to executive corporate officers for the 2027 fiscal year" (page 712).

The detailed GOV-3 datapoints are cross-referenced to chapter 2, section 2.1.3, paragraph "Criteria linked to the Group's CSR performance", page 97 (page 816).

Reference: page 706

The due diligence statement is anchored in French law: "BNP Paribas is subject to Law No. 2017-399 of 27 March 2017 on the duty of care. Each year, it publishes a vigilance plan in response to this legal obligation" (page 706). That vigilance plan is printed at pages 868-889 of the same document.

Table No. 1, "Essential elements of due diligence" (page 706), maps each element to the paragraphs that cover it: embedding due diligence into governance, strategy and business model to chapter 7.1.1 sections 1.a and 2.a; engaging affected stakeholders to section 2.b Interests and views of stakeholders; identifying and assessing adverse impacts to section 3.a Description of the process to identify and assess material impacts, risks and opportunities; addressing adverse impacts to "All the 'Actions' or 'Impact, Risk and Opportunity Management (IRO)' parts of the following chapters 7.1.2 Climate change, 7.1.4 Own workforce, 7.1.5 Consumers and end-users, 7.1.6 Business conduct"; and tracking effectiveness and communicating to sections 1.a and 2.a.

Table No. 51 ties the paragraph 30 due diligence statement to SFDR indicator number 10, Table #3 of Annex 1, referencing chapter 7.1.1 section 1 Governance (page 818).

Reference: page 706

"The internal control framework for sustainability reporting is mainly based on: a matrix of roles and responsibilities; a dedicated control plan applicable to the functions involved in the production of sustainability-related information; a certification by the heads of these functions" (page 706). "The Finance & Strategy Department handles the second line of defence in its area of expertise", and "The risk management system related to the sustainability reporting process follows the same process as the Group's risk management framework" (page 706).

Board-level oversight: "The Audit Committee oversees the process of preparing the sustainability information published under Directive (EU) 2022/2464 ... the Audit Committee examines issues related to sustainability statements, including the double materiality assessment, the results of indicators and any issues that may generate potential risks" (page 706).

For the materiality process itself, "the risk inventory has three levels of validation as well as a second level control" and "the objectives for achieving the strategic plan have the same control framework as BNP Paribas' other information, including three lines of defence" (page 721).

No separately ranked list of sustainability-reporting risks and mitigations is given in the statement; Appendix 2 meets GOV-5 36(b) and (c) by cross-reference to chapter 2, section 2.4 Internal control, page 132 (page 816).

Reference: page 707

The Group presents "a diversified and integrated model" on three operating divisions: Corporate & Institutional Banking (EUR 19bn net banking income), Commercial, Personal Banking & Services (EUR 26.7bn) and Investment & Protection Services (EUR 6.9bn, of which EUR 0.8bn AXA IM) (Chart No. 2, page 707). AXA IM joined on 1 July 2025 and "is excluded from 2025 sustainability report", entering from financial year 2026 (pages 702, 707).

Workforce was 181,510 at end-2025 (EMEA 152,647; Asia Pacific 20,672; Americas 8,191) against 181,618 in 2024 (Table No. 2, page 708). Table No. 3 lists each division's products and services, from deposit collection and life insurance to vehicle long-term leasing (Arval) and brokerage, clearing and custody (page 708).

Chart No. 3 maps the value chain across upstream (suppliers and subcontractors, buildings and data centres, Group workforce), core business (credit institution, capital markets, insurance, operational leasing, real estate) and downstream (investors, clients and counterparties, distributors); it "includes non-bank subsidiaries such as Arval (long-term vehicle rental) and Cardif (insurer)" (page 709).

The CSR dashboard (Table No. 4, page 711) carries ten indicators: 2025 results include EUR 163bn sustainable loans, EUR 144bn sustainable bonds, EUR 252bn of low-carbon transition support and 1.19 tCO2e/FTE. "BNP Paribas has achieved eight out of 10 of its ambitious ... objectives for 2025" (page 713).

Reference: page 714

"Dialogue with its stakeholders is an integral part of BNP Paribas' social and environmental responsibility", aimed "primarily at better identifying and understanding the interests, points of view and expectations of its stakeholders, as well as the impacts of its activity" (page 714). Stakeholders identified are customers, employees and their representative bodies, shareholders, suppliers, rating agencies, regulators and public authorities, and civil society; "Some of these stakeholders, with whom BNP Paribas has direct and regular communication, have been included in the double materiality analysis" (page 714).

Table No. 5 (page 715) names the internal contact and the channels for each group: the Advocacy programme and Net Promoter System for customers; pulse surveys, social dialogue, employee resource groups and the whistleblowing right for employees; the ESG Transparency & Performance team for investors; and a team "dedicated to relationships with advocacy NGOs".

2025 engagement is quantified: 91% of employees surveyed with an 81% engagement score; the quality of life at work survey "reached more than 52,000 employees"; the European Works Council "covered 22 European countries and about 73% of total headcount"; resource groups ran events in 43 countries (page 716).

Reference: page 722

"The double materiality assessment covers all the Group's entities, in line with the integrated business model" (page 722). Table No. 6, the double materiality matrix by sustainability topic (page 722), splits material from non-material. Material: climate change mitigation, climate change adaptation, own workforce, consumers and end-users, customer security including data privacy, business conduct / anti-corruption / whistleblowers, market integrity and financial security, cybersecurity. Non-material: pollution, water and marine resources, resource use and circular economy, biodiversity and ecosystems, workers in the value chain, affected communities, relationship with suppliers.

Table No. 7 (pages 723-725) lists each material IRO with its description and whether it sits in the commercial or operational scope: eight for climate change, nine for own workforce, seven for consumers and end-users, one for business conduct, three entity-specific.

"the impacts identified ... are considered current and therefore have no associated time horizon. Risks are identified in the short term (0 to 3 years), medium term (3 to 10 years) and long term (10 to 30 years) ... Opportunities have been identified in the medium term" (page 725).

Reference: page 719

Four steps: define the value chain and the relevant ESG topics, which "led to the addition of two entity-specific topics ... 'Cybersecurity' and 'Market integrity and financial security'"; identify stakeholders and IROs on the operational scope and commercial activities; assess each topic 1-Minimal to 5-Critical; and set the threshold, "when the rating is 3-Important and above on at least one of the three dimensions, then the topic is considered material" (page 719).

Impact materiality counts stakeholder solicitations: inquiries from clients, investors and NGOs "received between 2023 and 2024, as well as employees' considerations from a 2021 survey", then "an internal expert adjustment ... based on internal documents, reputational risks, regulation ... and an expert assessment of the scale, scope and irremediable character of the impact" (page 719).

Financial materiality uses the Risk ID process, with expected losses "confronted to the Group materiality frontier (calculated annually, notably for internal capital adequacy assessment (ICAAP) purposes)" (page 720). Climate inputs include IPCC SSP126/SSP245/SSP585 and RCP4.5/RCP8.5 analyses for 2020-2100 and an NGFS delayed transition scenario (page 720).

Opportunities are assessed against the strategic plan, the threshold being "an ESG topic related to a strategic commitment followed by a performance indicator" (page 721).

Reference: page 817

"After conducting the double materiality assessment on the topics, BNP Paribas performs a materiality assessment of the information to be disclosed. This assessment is carried out qualitatively ... some information is not relevant due to the nature of the Group's financial activities or strategy, accordingly it is considered non-material for BNP Paribas and not published" (page 817).

Table No. 52, "List of the disclosure requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (content index)", maps each reported DR to a CSRD section (pages 826-827). It covers ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2); E1 (E1-1 to E1-7); S1 (S1-1 to S1-17 in full); S4 (S4-1 to S4-5); and G1 (G1-1, G1-3, G1-4, G1-5), closing with the entity-specific topics "Cybersecurity" and "Market Integrity and Financial Security".

E1-8, E1-9, G1-2 and G1-6 are absent from the index, and no E2, E3, E4, E5, S2 or S3 disclosure requirement appears in it.

Table No. 51 (pages 818-824) separately lists the datapoints deriving from other EU legislation with their SFDR, Pillar 3, benchmark and EU Climate Law references, marking each with a section reference, "Not material information", or "Phase-in application".

Reference: page 727

"BNP Paribas' transition plan's key elements for climate change mitigation ... relate solely to the financial assets of the Group's bank balance sheet" (page 727).

No absolute target is set, and the Group says why: "BNP Paribas activates the provision provided in the ESRS 1 standard paragraph 133 (a) of chapter 10.2 Transitional provision related to chapter 5 Value chain ... and the Group does not disclose any greenhouse gas emission reduction target in absolute value" (page 727), citing data availability on clients' Scope 3 and "the difficulty of projecting decarbonisation trajectories and estimating clients' financing needs due to a lack of consensus on long-term macroeconomic assumptions".

The core is portfolio alignment: "Since 2021, BNP Paribas has also been committed to align the credit portfolio of the most greenhouse gas-emitting sectors with trajectories compatible with the objectives of the 2015 Paris Climate Agreement", with targets in nine sectors (page 729). Upstream oil and gas exposure is to fall 80% and 30% by 2030 versus September 2022, and "By 2030, low carbon energies, primarily renewables, should represent at least 90% of the Group's financings to energy production and a minimum of EUR 40 billion in credit exposure" (page 729).

"BNP Paribas is not excluded from benchmarks aligned with the Paris Agreement" (page 730). "BNP Paribas' Board of directors approved the Group's transition plan on 25 February 2026" (page 730).

Reference: page 719

Back-filled from ESRS 2 IRO-1 (pages 719-721) and the E1 climate risk and stress-testing section (pages 731-734), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risks are classified explicitly: "(i) Physical risks: resulting from the direct impact of climate change on people and property ... and (ii) transition risks: resulting from a change in the behaviour of economic and financial agents in response to the implementation of energy policies, changes in regulations, technological innovations or changes in consumer preferences" (page 725).

Methodology: Risk ID contributors assess current materiality and its three-year evolution, plus "the relative probability and severity (lower, even, higher, far higher) of the risk event if it were to materialise in 10 years (medium-term)" and "in 30 years (long-term)" (page 720).

Scenarios are named. Transition: ICAAP 2025 tested the corporate portfolio against the NGFS "orderly 'Net Zero 2050'", "disorderly 'Delayed Transition'" and "'Too Little, Too Late' / 'Fragmented World'" scenarios on the REMIND-MAgPIE version (page 732).

No global average temperature projection per scenario is given, and "There is no distinction between short, medium and long term due to the lack of available scenarios at the time of testing" (page 732).

Reference: page 731

Back-filled from ESRS 2 SBM-3 (page 726) and section 1.c "Description of the resilience of the Group's strategy and business model to climate risks" (pages 731-734), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Conclusion, stated under SBM-3: "the resilience of BNP Paribas' diversified and integrated model in relation to climate change-related risks has been confirmed during the 2050 horizon resilience tests, carried out by the Group since the 2022 exercice of ECB and by the internal resilience tests as part of the work on Internal Capital Adequacy" (page 726).

Frequency and horizon: the assessment runs "in the context of the stress tests requested by the ECB and the EBA, as well as annually within the Internal Capital Adequacy Assessment Process (ICAAP), carried out over a 30-year horizon in accordance with the recommendations of the ECB's ICAAP Guide" (page 731).

Results feed strategy and capital: "climate-scenario analyses contribute to part of the Group's risk appetite metrics and are used to set their alert thresholds", and results are presented to General Management and the CCIRC (page 732).

Uncertainties listed: climate-scenario modelling and macroeconomic assumptions, portfolio exposure and sectoral distribution over long horizons, "approximations due to missing data", and modelling-technique uncertainty (pages 733-734).

Reference: page 734

"The Group's financing and investment activities are governed by eight sector policies, four of which are directly related to climate change: coal-fired power generation; oil & gas; mining industry; nuclear energy. These policies, by limiting the Group's exposure to the most greenhouse gas-emitting sectors, also reduce its transition risks" (page 734).

Table No. 9 (pages 735-736) gives eight policies with content, scope, accountable level and stakeholder interaction. Each of the four sector policies states that "This policy applies to all BNP Paribas entities and covers all financial products and services provided by the Group"; they are owned by the "Heads of CIB, CPBS and IPS divisions", and are published plus "systematically provided to existing and potential clients as part of the KYC process"; the coal policy "includes the timetable for the complete exit from thermal coal financing". The others are the Sustainable Sourcing Charter, the IMEX Environmental and Energy policy, the Group Travel policy and Business continuity requirements, the last "also addresses, among other aspects, climate change adaptation issues".

Reference: page 737

Effectiveness is measured through four channels: deeper counterparty knowledge via the ESG Assessment; annual tracking of "its credit portfolio's emission intensity in nine particularly greenhouse gas-emitting sectors, oil and gas sector absolute emissions, and the financed emissions"; client support through sustainable products and services; and measures cutting its own operational emissions (page 737).

2025 results by sector are given. Oil and gas actions produced "a EUR 1.1 billion decrease in its credit exposure to oil exploration and production (from EUR 2.1 billion as of 31 December 2024 to EUR 1.0 billion as of 31 December 2025) and a EUR 0.9 billion decrease in its credit exposure to gas exploration and production" (page 738). Power generation intensity fell to 119 gCO2/kWh from 129, with renewables at 73% of financed capacity and coal at 4% (page 738).

Resources: "circa 400 employees dedicating all or most of their time to CSR topics", a Low Carbon Transition Group of "around 250 bankers", the LCTM team for midcaps and SMEs, the MS4U stress-testing team, the Climate Analytics and Alignment team, and the Sustainability Academy, where "close to 71,000 employees completed at least one training course ... with an average of 1.6 training hour per person" (page 742).

Reference: page 743

"In 2021, the Group committed to defining intermediate alignment targets for the most greenhouse gas-emitting sectors that are compatible with net zero emissions trajectories in 2050 ... For each sector, the Group has chosen a baseline year that is no earlier than two years at the time of setting the targets" (page 743). Metrics cover ten sectors, with 2030 targets for nine.

Table No. 10 (pages 744-745) gives baseline, latest value, target and scenario. Oil and gas: financed emissions -70% from 27.3 MtCO2e (Q3 2022) to no more than 8.2 MtCO2e, at 5.3 MtCO2e in 2025. Power generation: 110-125 gCO2/kWh against 122 in 2025. Automotive: 115-136 gCO2/km WLTP against 149. Steel: 1.2 tCO2/t against 1.4. Aluminium: 5.6 tCO2e/t against 5.0. Cement: 0.51 tCO2/t against 0.62. Aviation: 785 gCO2e/RTK against 894. Shipping: 5.6-6.4 gCO2e/dwt.nm against 8.2. Commercial real estate: 16.7-19.5 kgCO2e/m2 against 29.1.

Misses are named: "the portfolio is close to the 2025 target but the objective has not been achieved. The operational target of 25% share of electrified vehicules is not reached, with a result at 19%" (page 738).

Two sectors carry no target with stated reasons: residential real estate (energy-mix dependence, regulatory churn, and a concern "to ensure a balance between a necessary decarbonisation and a just transition", page 748) and agriculture ("the nascent methodologies at this stage and the absence of suitable scenarios", page 748).

Reference: page 750

Table No. 11 reports total energy consumption of 775,474 MWh in 2025 against 778,240 MWh in 2024. Fossil energy consumption, reported only on line 5 (electricity, heat, steam and cooling purchased from fossil sources), was 253,289 MWh or 32.7% of the total, down from 354,632 MWh and 45.6%. Nuclear was 145,945 MWh or 18.8%, against 164,177 MWh and 21.1%. Total renewable was 376,239 MWh or 48.5%, against 259,431 MWh and 33.3%, of which purchased renewable 370,259 MWh and self-generated non-combustible renewable 5,980 MWh against 2,396 MWh. Lines 1-4 (coal, crude oil and petroleum products, natural gas, other fossil) and line 8 (renewable fuels including biomass) are reported "NA" (page 750).

The mix is explained: the renewable share comprises "39.6% represents the Group's voluntary actions based on certified renewable sources (guarantees of origin: 28%; Power Purchase Agreement: 10.8%; direct production on buildings: 0.8%) and 9% represent the share of renewable energy specific to each national energy production" (page 741). The Group also notes that "in 2025 the Group stabilised its energy consumption while absorbing the growth in energy needs related to data centers" (page 741). Table No. 51 marks the E1-5 datapoints on fossil-source disaggregation and energy intensity in high climate impact sectors "Not material information" (page 819).

Reference: page 750

Table No. 14 (page 753) gives gross emissions by scope. Scope 1: 21,516 tCO2e against 23,587 in 2024, -8.8%. Scope 2 location-based: 113,081 tCO2e against 129,336, -12.6%; market-based 51,814 tCO2e against 58,093. Total Scope 3: 94,515,034 tCO2e against 104,265,939, -9.4%, of which category 6 business travel 76,838 tCO2e (-30.6%) and category 15 investments 94,438,196 tCO2e (-9.3%). Total location-based: 94,649,631 tCO2e; market-based: 94,588,364 tCO2e.

Own-operations emissions "amounted to 211,435 tCO2e (location-based approach), a 19.8% decrease compared to 2024 and a 54.1% decrease compared to 2019 ... They represent 1.19 tCO2e per FTE, which is below the maximum target set for 2025 (1.85 tCO2e/FTE)" (page 750).

The Group states the boundary limit plainly: "For scope 3, only emissions related to business travel are reported (category 6). The assessment of scope 3 remains partial given that the level of approximation is still too high" (page 750); categories 1-5 and 7-14 are left blank.

In place of a revenue intensity the Group publishes "the carbon footprint of the portfolio ... 0.21 MtCO2e per billion euros financed as of 31 December 2025, decreasing compared to 2024 (0.23 MtCO2e ...)" (page 753).

Reference: page 754

"Since 2017, BNP Paribas has been purchasing voluntary carbon credits annually for an amount equivalent to the residual greenhouse gas emissions emitted the previous year on its operational scope (emissions related to its scopes 1 and 2 and to business travel). In 2025, the Group purchased the equivalent of 192,431 tCO2, (a 10% decreased compared to last year), the emissions' amount for the year 2024 (market-based approach)" (page 754).

Table No. 15 reports, for the 2025 base year: total 192,431 tCO2e; "Share of absorption projects 0%"; "Share of reduction projects 100%"; "Verified Carbon Standard 100%"; share of projects carried out within the EU 0%; and "Share of carbon credits that can be considered as corresponding adjustments under Article 6 of the Paris Agreement (in %) 100%" (page 754).

The four projects sit outside the Group's value chain and are named: Kasigau in Kenya, supported since 2017, "a programme to protect and restore 200,000 hectares of forest" led by Wildlife Works; an Indian programme with the GoodPlanet Foundation "through the construction of 13,000 biodigesters ... improving the living conditions of nearly 70,000 people"; a Guatemalan project protecting "nearly 60,000 hectares of forest"; and Nii Kaniti in Peru with Indigenous communities in the Amazon.

No GHG removals in own operations or the value chain are reported.

Reference: page 765

"Through the Group's policies, BNP Paribas places particular emphasis on human rights, occupational health and safety, diversity, equality and inclusion. Respect for employees' human rights is a central pillar of the CSR strategy" (page 765). Scope is Group-wide and the Group records an exclusion: "The Group's policies cover all of the Group's employees, bearing in mind that, given the activities, no so-called 'vulnerable' populations within the meaning of the regulations have been identified that could benefit from specific policies" (page 765).

Table No. 20 (pages 765-768) sets out each policy with content, scope, accountable level and stakeholder interaction. The Code of conduct, owned by General Management, is available in 20 languages. The Global Agreement on fundamental rights and global social framework, owned by the Head of HR, covers seven themes: human rights, trade union rights and social dialogue; social and environmental responsibility; employment and skills management; teleworking in a hybrid working environment; Respect for Persons and non-discrimination; equal opportunity, diversity and inclusion; and the Global Social Floor. The Group Policy on Respect for Persons "Describes the BNP Paribas Group's system for preventing and detecting actions that do not comply with the Code of conduct concerning 'Respect for Persons'".

Reference: page 769

"As part of its due diligence process, BNP Paribas engages directly with its employees and their representatives on the material impacts that affect them or could affect them", and "This dialogue is overseen by the Group's governance bodies" as set out in the governance section (page 769).

The anchor is a global collective agreement: "As an extension of the commitments made in 2018 by the Group with UNI Global Union in the Global Agreement, the Group has renegotiated a new agreement which was signed in November 2024 for a period of 4 years", concluded with the European Federation of Executives of Credit and Financial Institutions (FECEC), members of the European Group Works Council Bureau and the representative trade unions at Group level in France. "This agreement covers seven themes relating to fundamental rights at work and the establishment of a global social floor, applicable to all Group employees. In its chapter 1, it deals in particular with Social Dialogue within the Group and, in chapter 2, with the whistleblowing process" (page 769).

The channels themselves are quantified in the ESRS 2 stakeholder section: 91% of employees surveyed in 2025 with an 81% engagement score, a quality of life at work survey reaching "more than 52,000 employees", a European Works Council covering 22 countries and about 73% of headcount, a biennial Conduct & Inclusion survey, and employee resource groups active in 43 countries (page 716).

Reference: page 769

Employees "are required to report any actual or suspected breach of the Code of conduct, the Group's policies and procedures or regulations. They can report their alert via a single secure platform on all subjects, including those relating to respect for persons". The platform is "governed by the Group Whistleblowing System procedure, in compliance with the provisions of the Sapin II and Waserman laws" (page 769).

A dedicated track exists for people-related alerts: "Alerts are treated confidentially and follow a structured analysis and investigation process carried out by HR Conduct referents", and the Group "undertakes to take action, in the event of proven facts, verified after investigations, disciplinary and/or corrective measures, individual and/or collective ... Support and follow-up are provided for victims and if necessary, for the perpetrators" (page 769).

Effectiveness is controlled and measured. First-level controls by Compliance and HR "verify access to whistleblowing channels and compliance with confidentiality and with the alert processing procedure"; second-level controls are "carried out by an independent team to assess the effectiveness of the implementation of the whistleblowing system" (page 769). Trust is surveyed: in the 2025 Conduct & Inclusion survey "87% of respondents say they have 'a good knowledge' of the channels that allow them to report alerts", against 93% in the 2023 survey (page 770).

Reference: page 770

Actions are grouped by IRO: promoting an inclusive culture, preventing discrimination, harassment and violence at work, a social protection framework supported by the We Care programme, and enhanced training and skills development; for risks, We Care and a work environment favourable to detecting psychosocial risks; for opportunities, professional equality, solidarity commitment and training (page 770).

Prevention is specified: a mandatory biennial Conduct Journey awareness module including "Diversity, Equality & Inclusion", "addressing non-discrimination, situations of harassment, unconscious biases and stereotypes"; an annual Code of conduct objective for all employees; and manager training on the Group Management Principles (pages 770-771). Remediation steps run from a trusted person, through immediate analysis and "temporary emergency measures ... such as changing the working environment, changing the reporting line, offering social and/or medical support", to disciplinary and support measures and "follow-up over time and protection against retaliation" (page 771).

Results are quantified. 84% of survey respondents "can be themselves at work without worrying about how they are accepted" and 90% said their manager "treats everybody with dignity, fairness and respect" (page 770). We Care coverage: "98% of the Group's employees are covered by Employee Assistance Programs", up from 93% in 2024 (page 772).

Reference: page 776

"To reduce the negative effects related to psychosocial risks, the Group aims to ensure that all Group employees are covered by psychological support and listening systems. In addition, all Group employees, wherever they are, benefit from the commitments and guarantees made by the Group under the 2024 Global Agreement" (page 776).

Gender targets are set at every management level: "the Group has set ambitious targets of 40% women by 2025 within the Group's Executive Committee (ExCo), the G100, Leaders for Change and Senior Management Position (SMP) populations, as well as 50% women among the Leaders for Tomorrow ('Talents')" (page 776).

Table No. 21 gives the three social CSR dashboard indicators with results and targets (page 776): share of women in the SMP population 39% in 2024, 41% in 2025, against a 2025 target of 40% and a 2026 target of 42%; solidarity hours over two rolling years 1,338,394 then 1,353,529, against a 1,000,000 target; and share of employees completing at least four training courses 99% in both years against a 90% target.

Target setting and monitoring are described: achievement "is monitored by the second line of defence within the RISK Function, and is shared and presented annually to the ... CGEN ..., which includes two employee representatives and one employee shareholder representative" (page 777).

Reference: page 777

Scope is defined first: employees are those on fixed-term or permanent contracts with companies the Group exclusively controls, significantly influences or holds an HR management mandate for, "excluding employees from AXA IM activities" and excluding interns and work-study students; separately there were 1,834 interns and 3,551 work-study students in 2025 (page 777).

Headcount by region (Table No. 22, page 777): EMEA 152,647, Asia Pacific 20,672, Americas 8,191, total 181,510 against 181,618 in 2024. France is the only country above 10% of headcount at 55,867, followed by Italy 9%, India 7% and Belgium 7%; the Group is present in 64 countries (page 777).

By contract type (Table No. 24, page 778): permanent 177,994 headcount / 174,514 FTE; temporary 3,516 headcount / 3,476 FTE; total FTE 177,990. "The vast majority of the Group's employees are on permanent-term contracts (98%). The Group does not have any employees with non-guaranteed hours" (page 778). By working time (Table No. 25): full-time 168,091, part-time 12,817.

By gender (Table No. 26, page 778): men 88,437, women 93,066, not reported 7. "At the end of 2025, 51% of the Group's employees were women and 49% were men" (page 778).

Turnover (Table No. 30, page 780): 8.5% total headcount-based against 9.6% in 2024; voluntary turnover 5.3% FTE against 6.0%. "Of the 14,989 departures in 2025, nearly 11,000 were in Europe, including nearly 3,000 in France" (page 780).

Reference: page 780

"Non-employee workers, i.e. workers who do not have the status of employees within the Company, are those who have either concluded a contract with the company to provide labour ('self-employed workers') or persons supplied by companies mainly engaged in 'employment activities' (NACE code N78). For the Group, they correspond to workers on assignment with a temporary employment agency, working in the Company and present on the last day of the month" (page 780).

The headcount is given: "They represented 1,883 people in FTE at the end of 2025 (2,294 at the end of 2024), including 579 in France (658 at the end of 2024)", data collected by the Group Finance teams in FTE at the end of the period (page 780).

The Group states the basis on which it uses temporary work: "The Group reserves the possibility of using temporary work for the execution of a specific and temporary task. It is only used occasionally to replace employees who are temporarily absent (due to illness, maternity or other reasons) or to cope with a temporary increase in the Company's activity" (page 780).

Non-employee workers are within the own workforce definition for this statement, which covers "employees and temporary workers" (page 725), and they have access to the grievance machinery: "The whistleblowing platform is also accessible to non-employee workers on the BNP Paribas Group's institutional website" (page 769). No breakdown of non-employee workers by type or country is given.

Reference: page 780

"Following on from the 2018 Global Agreement, a Global Agreement was signed on 4 November 2024 between representatives of the BNP Paribas Group Management and UNI Global Union, the global union representing the banking and insurance sectors, with the participation of representatives of FECEC, the European Group Works Council and the two representative trade unions at BNP Paribas Group level in France. This agreement is based on a strong practice of respect for trade union rights, collective bargaining and social dialogue" (page 780).

Coverage is stated at the maximum: "It covers all Group employees, so 100% of the Group's employees are covered by collective agreements" (page 780).

Table No. 31 (page 781) reports collective bargaining coverage and workplace representation in bands, showing France at 100% and the 80-100% band for EEA employees, with EMEA excluding EEA and Asia Pacific shown as the two regions above 10% of headcount. Data were "collected in the Social Reporting campaign, which covers 97% of the Group's employee headcount as of 31/12/2025".

Activity is quantified: "In 2025, 1,907 official meetings (1,768 in 2024) were held with employee representatives, including 1,046 in France ... These meetings led to the signing, in 2025, of 412 collective bargaining agreements within the Group (350 in 2024), including 147 in France, 250 in the rest of Europe and 15 in the rest of the world" (page 781).

Reference: page 781

"The Group has set itself ambitious targets of 40% gender diversity at all levels of the Company's top management, whether at the level of the Board of directors of BNP Paribas SA, the Group's Executive Committee, G100 senior executives, Leaders for Change (LfC) or the Senior Management Position (SMP) population. The SMP population is made up of Group employees holding around 3,000 positions considered to have the most significant impact from a strategic, commercial, functional and expertise perspective" (page 781).

Table No. 32 (page 782) reports gender distribution at top management for 2025 and 2024: Board of directors 8 men / 8 women, 50% women, against 43%/57% in 2024; ExCo 11 men / 8 women, 42% women, unchanged; G100 52 men / 39 women, 43% women, against 41%; Leaders for Change 312 men / 182 women, 37% women, unchanged; SMP 1,757 men / 1,200 women, 41% women, against 39%. The 2025 target of 40% women is shown against each population.

Age distribution is given in Chart No. 7: "In 2025, the Group has 25,953 employees under 30 years old, 101,729 employees between 30 and 49 years old and 47,150 employees aged 50 and over", against 26,573, 108,196 and 45,060 in 2024 (page 782). "The overall average age was 42.4 years in 2025 (42.1 in 2024), 42.5 years for men and 42.2 years for women. The average seniority in the Group was 12.3 years in 2025" (page 782).

Reference: page 782

"The Group complies with the minimum wage applicable in all the countries in which it operates" (page 782).

The Group defines adequate wage and names its benchmark source: it is "the level of salary that is adequate to cover the basic needs of an employee and their family, particularly in terms of housing, food, health, education, transport, means of communication, and precautionary savings", measured on fixed remuneration for full-time equivalent working time excluding overtime (page 782). "In order to determine the adequate wage in all the countries in which the Group operates, the Group relies on a recognised player in this field, Fair Wage Network, which provides adequate wage data calculated according to the local context in relation to the country (or within countries, the major cities in which employees work), and various criteria such as the average household size per country ... and the average number of people receiving income in the household. These adequate wage data are updated annually by Fair Wage Network, they are compared to employees' fixed remuneration" (page 782).

The result is stated at the maximum: "In accordance with the new commitment made in the November 2024 Global Agreement, 100% of the Group's employees receive an adequate wage according to the definition above", calculated "on a basis covering approximately 98% of the Group's employees" (page 783).

Reference: page 783

"Under the Global Agreement, all employees benefit from a generally favourable framework in terms of social protection, in particular with regard to events related to illness and parental leave. For other events such as unemployment and retirement, coverage depends mainly on the existence of state schemes in the countries in which the Group operates" (page 783).

The metric is reported with its gaps named: "In 2025, at least 89% of the Group's employees (at least 88% in 2024) are covered, within the framework of public programmes or benefits offered by the Company, by social protection against loss of income due to all events such as illness, unemployment, work-related accidents/disability, parental leave, retirement." The shortfall is explained precisely: "Only the Group entities present in 4 countries do not cover their employees against loss of income due to unemployment: Hong Kong, India, Singapore and Kosovo. In these 4 countries, all employees are covered against loss of income due to illness, accidents, leave and retirement" (page 783).

The global social floor behind this is described under the actions section: "100% of employees can benefit from paid maternity leave of a minimum of 14 weeks, as well as incapacity, disability, death and healthcare coverage. In addition, 93% of employees can benefit from a minimum of 6 days of paid paternity leave" (page 771).

Reference: page 784

Table No. 33 reports the percentage of employees declared as having a disability by region and gender: EMEA 3.9% (men 2.8%, women 5.0%), Asia Pacific 0.2%, Americas 1.4%, Group total 3.4% (men 2.3%, women 4.4%), against 3.2% in 2024 (page 784). Data were "collected in the Social Reporting campaign, which covers 97% of the Group's employee headcount as of 31/12/2025".

The absolute figures are given: "As of 31 December 2025, the Group had 5,966 employees with disabilities in 30 countries, including 3,713 in France, representing an overall Group employment rate of employees with disabilities relative to the Group's overall headcount of 3.4%, up compared to the previous year (3.2% in 2024). 280 employees with disabilities were recruited in 2025 compared to 248 in 2024" (page 784).

France-specific performance is reported against the national agreement: "In France, as part of the renewal of the Disability Agreement for three years (2023-2025), BNP Paribas SA has recruited 48 candidates with disabilities. 1,998 job retention actions were carried out in 2025 (2,120 in 2024). The employment rate of employees with disabilities reached 6.2% in 2024, compared to 5.3% in 2023 (of which +0.4% due to regularisations of declarations)" (page 784).

Reference: page 784

Table No. 34 reports that 97% of employees participated in regular performance and career development reviews in 2025, for both men and women, against 96% in 2024. The basis is stated: the percentage "was calculated on the basis of the population eligible for a review", that is permanent-contract employees who joined before 1 July 2025, were present at 31 December 2025 and use the About Me tool, and "In relation to the headcount reported in section 3.b Characteristics of employees in this chapter, the percentage of employees who participated in a performance review represents 84% of Group employees" (page 784).

Table No. 35 reports training hours: average 26.7 hours per employee in 2025 (men 25.2, women 28.1) against 27.3 in 2024, and excluding mandatory training 21.7 hours (men 20.4, women 23.0) against 22.8. "The average number of hours of training was stable compared to 2024. Due to the nature of the Group's activities, employees must complete mandatory training courses each year, in particular for regulatory reasons, notably relating to the Code of conduct. At the end of 2025, the total number of training hours was 4,806,434 hours" (page 784).

Supporting detail sits in the actions section: 99% of employees completed at least four training courses against a 90% target (page 776); nearly 71,000 employees completed a Sustainability Academy course (page 775).

Reference: page 785

"At the end of 2025, 97% of the Group's employees were covered by a health and safety management system" (page 785).

Table No. 36 reports: 1 fatality as a result of work-related injuries and work-related ill health in 2025 against 0 in 2024; 526 recordable work-related accidents against 655; a frequency rate of 1.01 accidents per million hours worked against 1.27; and a severity rate of 0.08 days lost per 1,000 total calendar hours against 0.07 (page 785).

The Group flags a comparability issue in the prior-year figure: the 2024 data "sometimes included work-related accidents without leave or commuting accidents. When considering only work-related accidents with leave, excluding commuting accidents, only 538 accidents would have been reported in 2024. On this common basis, the evolution between 2024 and 2025 would be -2%" (page 785).

Absenteeism is reported alongside: "The absenteeism rate for employees related to illness, work-related accidents (excluding commuting) and occupational ill health was 3.5% for the Group in 2025, stable compared to 2024. It was 4.7% in France, slightly up compared to 2024".

France-specific oversight is described: "the Group's autonomous Occupational Health and Prevention Service (OHPS) in France, which provides medical follow-up to 80% of employees, is subject to approval granted by the DRIEETS, the supervisory body that assesses the compliance and quality of the service" (page 785).

Reference: page 785

"Under the Global Agreement, all Group employees are entitled to take at least one of the following family leaves: maternity leave, paternity leave, parental leave, or caregiver leave" (page 785).

Table No. 37 reports: 100% of employees entitled to take family-related leave in 2025 and 2024, for both men and women; and the share who actually took such leave at 11% overall in 2025 (men 8%, women 15%) against 13% in 2024 (men 8%, women 18%). The Group notes that "On a comparable basis (after 2024 adjustment), this figure would have amounted to 12% overall (8% for men and 15% for women)" (page 785). Data were collected in the Social Reporting campaign covering 97% of headcount.

Supporting provisions are described: "the Global Agreement provides for the possibility for employees to take up to five flexibility days per year for personal convenience. Nearly two-thirds of employees benefit from a specific policy in favour of caregivers" (page 785).

Remote working is reported in the same frame: hybrid working principles are "incorporated into the 2024 Global Agreement", the European Remote Working Charter was "renewed and signed in 2025", and "At the end of December 2025, over 70% of employees in Europe were working remotely, as in 2024" (page 773).

Reference: page 786

"The Group's compensation policy is based on the principles of fairness, notably in terms of gender, and transparency, and is mainly reflected in a single annual compensation review process for all employees" (page 786). The gender pay gap "corresponds to the difference between the average pay level of male and female employees, expressed as a percentage of the average pay level of male employees. It is calculated for all Group employees, regardless of their activity, seniority and geographical location" (page 786).

Table No. 38 reports a gender pay gap on total remuneration of 35% in both 2025 and 2024, and on fixed remuneration of 27% in 2025 against 28% in 2024 (page 786). The Group explains the figure rather than softening it: "The 35% gap for the Group calculated on total remuneration is explained in particular by a significant gap in Corporate and Investment Banking businesses where men are more represented than women in front office activities and in more senior technical roles where remuneration levels are the highest".

Table No. 39 reports the ratio of highest to median remuneration by country rather than Group-wide, because "the diversity of the Group's headcount structure ... makes this indicator more relevant when calculated within a country" (page 786). For 2025: France 110, BNP Paribas SA in France 83, Italy 48, India 51, Belgium 19, Poland 38, Turkey 75, United Kingdom 86, Germany 34, Spain 45 (page 787).

Reference: page 787

Table No. 40 reports, for 2025 and 2024: 622 incidents of discrimination including harassment reported during the period against 613; and "Total amount of fines, penalties and compensation for damages resulting from incidents and complaints (discrimination and harassment)" of EUR 78,693 against EUR 43,416 (page 787). The row for complaints about other working-conditions and fair-treatment issues is not separately populated, because of how the Group counts: "The number reported above corresponds to the number of alerts relating to 'Respect for Persons' reported for the Group via the Group whistleblowing platform (covering both incidents of discrimination and complaints related to social issues)" (page 787).

Outcomes are quantified: "in 2025, 622 alerts relating to 'Respect for Persons' were processed during the period, regardless of when they were reported (613 alerts in 2024). Following the analysis of the alerts and the investigations conducted, appropriate measures were taken, including disciplinary actions and support measures. In 2025, 80 sanctions were applied (including 19 dismissals) and 134 accompanying measures were taken. No alerts were raised in 2025 via the OECD's national contact points" (page 787).

On severe human rights impacts: "the topic of serious human rights incidents covering forced labour, human trafficking or child labour is not considered material at the Group level" (page 787).

Reference: page 791

Consumers and end-users are defined as "its direct individual clients (private individuals), in the context of the activities of the Commercial, Personal Banking & Services (CPBS) and Investment & Protection Services (IPS) divisions" and "its indirect individual beneficiaries, through BNP Paribas' financing of Microfinance institutions (MFIs) dedicated to social inclusion" (page 788).

Table No. 42 (page 791) sets out three policies, each covering all consumers and end-users. The Code of conduct, owned by General Management, available in 16 languages. The Group policy on the protection of personal data, which "governs the Group's strategy in this area, defining the rules for all categories of data subjects ... and any personal data processing activity, in all BNP Paribas' distribution models", owned by the Group Data Office and RISK Functions, with a public "Data Protection Notice" in 17 languages. The Group policy on the protection of the interests of clients, which "defines the rules of organisation and conduct that must be applied throughout the relationship with the customer and at all stages of the life cycle of products and services", owned by the Compliance Function.

Reference: page 792

Two engagement tracks are described. First, the general principles of the client-interest policy: "the customer must have access to information that is fair, honest, transparent, understandable and not misleading about the products and services, both in form and content, and regardless of the channel or format"; prior to provision the entity must explain what the customer is buying and "the details of what they are paying"; "the product or service must be easy to explain and be understood by customers in the market for which the product or service is intended".

Second, the Advocacy programme, run "since 2017 ... in all the Eurozone commercial banks, the Europe-Mediterranean perimeter and the specialised businesses", built on annual Net Promoter Score benchmarks, annual relationship surveys and transactional surveys after an interaction or journey (pages 792-793).

Volumes and results are given: "In 2025, in the four commercial banks within the Eurozone (France, Belgium, Italy and Luxembourg), 7.2 million surveys (vs. 7.3 million in 2024) were sent by email to individual customers with a return rate of 8% (vs. 7% in 2024)", plus nearly 600,000 returns via digital channels. "Overall, 62% of the Group's 13 banking entities serving individual customers had an NPS score at or above the average of their market in 2025 (compared to 69% in 2024 and 46% in 2018)" (page 793).

Reference: page 793

Two remediation routes are described. For satisfaction: "An individual remediation approach is implemented with customers who have responded to a survey. Each customer must be called back by an advisor upon receipt of their response (within a maximum of five days), with priority given to dissatisfied customers." Where no immediate solution exists, the branch or relationship centre implements local corrective action ("Innerloop") or escalates a structural pain point to central teams ("Outerloop") (page 793).

For complaints, the client-interest policy sets binding rules: "clients must be clearly informed of the complaint channel and complaint handling process and, if applicable, the mediation protocol. The ombudsman is independent of the operational services"; "complaints must be acknowledged, and customers must be regularly informed of the progress of their complaints"; "a response must be provided to the customer within a maximum delay of two months, unless there is a more restrictive local regulatory obligation"; and "complaints treatment cannot be charged" (page 794).

Independent mediation is available: "In France, iItaly and Belgium, customers can contact the national ombudsman services organised by the relevant regulatory bodies. Furthermore, BNP Paribas Personal Finance uses external ombudsmen in most countries" (page 794).

Reference: page 795

Actions are organised by theme. Training: "All BNP Paribas employees must undergo a mandatory training on the protection of personal data", alongside the Conduct Journey and Sustainability Academy modules on social and financial inclusion (page 795). Data privacy: measures "In coherence with article 32 of the GDPR regulation" including "pseudonymisation and encryption of personal data", resilience of processing systems and restoration of availability; governance rests on a network of Chief Data Officers as first line and Data Protection Officers as second line, with Privacy and Personal Data Protection Committees reporting periodically (page 795).

Social inclusion: accessibility measures for clients "with visual, hearing, motor ... or cognitive ... disabilities", including a sign-language interpreter assistant service at BNP Paribas Bank Polska since 2020 and a sign-language customer service at BNL bc in Italy (page 797). Financial inclusion runs through Nickel and microfinance: Nickel reached "more than 4.9 million accounts opened since its launch (an increase of approximately 600,000 accounts over one year ...) and a network of 13,370 points of sale at the end of 2025"; microfinance support "amounted to EUR 421.7 million in loans and investments (vs. EUR 468.8 million in 2024), reaching 21 MFIs ... across 13 countries", indirectly supporting "more than 520,000 active beneficiaries" (page 797).

Reference: page 798

"As part of its strategic plan, the Group has set itself a quantified target in terms of social inclusion: to serve 6.2 million beneficiaries of products and services supporting financial inclusion by 2026. This indicator is included in BNP Paribas' CSR dashboard" (page 798). The CSR dashboard records 5.0 million beneficiaries in 2024 and 5.5 million in 2025 against the 6.2 million 2026 objective (Table No. 4, page 711).

The indicator's composition and stability are stated: "The indicator consists of the number of Nickel accounts opened since its creation and number of beneficiaries of microloans distributed by microfinance institutions financed by the Group (pro rata to the financing) as of 30 September of the current year. The methodology for calculating the indicator has been stable since its first appearance in the Group's CSR dashboard in 2022" (page 798).

The Group reports the 2025 movement and shortfall against the earlier milestone: "The growth of the Nickel accounts and a lower but strong level in financing for Microfinance Institutions led to an increase (+0.5 million) in the number of beneficiaries of products and services promoting financial inclusion (indicator 7). Overall, the growth has been strong over the past four years, although still less than expected", and indicator 7 is one of the two 2025 objectives "not achieved in full" (page 713).

Reference: page 801

Table No. 44 (pages 801-802) lists the Group-wide business conduct policies: the Code of conduct, "in its revised version in 2024 ... published in April 2025 on the BNP Paribas website" and "available in 16 languages"; the whistleblowing framework Group procedure; the Gifts & Invitations Procedure; the Group Conflicts of Interest Policy; the Global Anti-Corruption Policy; the Global AML-CTF Policy; the Global Sanctions Policy; and the Know Your Client Global Policy. All are accountable to the "Chief Operating Officers of the BNP Paribas Group", except the Code of conduct (General Management).

The Code "is binding on all employees and in all the Group's business lines" and covers customer interest, financial security, market integrity, conflicts of interest, professional ethics, respect for persons, Group protection, commitment to society and the fight against corruption and influence peddling; "The Group Conduct Committee (GCC) ensures and supervises the execution and improvement of the conduct framework within the Group" (page 803).

The whistleblowing framework is governed by a Group procedure under the Sapin II law and is "also open to external third parties, in particular to former Group employees, and to suppliers and subcontractors", with the protection that "No employee who raised an alert in good faith may be disciplined, dismissed or discriminated against" (pages 803-804). Conduct Journey completion was 98.8% in 2025 (page 805).

Reference: page 805

"The BNP Paribas Group has implemented a global framework to prevent and detect corruption and influence peddling ('corruption'). Designed in compliance with the French Sapin II law and in light of the best international practices - such as the French Anti-corruption Agency guidelines, the UK Bribery Act and the U.S. Foreign Corrupt Practices Act - the Anti-Bribery and Corruption (ABC) programme is described in a Global Anti-corruption Policy" (page 805).

The programme's components are listed: a CEO anti-corruption statement "confirming BNP Paribas' zero tolerance for corruption and influence peddling"; a dedicated Group team supervising a network of international ABC correspondents; a corruption risk assessment whose results are "presented to the BNP Paribas Group management body in its executive function for approval, and to the Board of directors"; and a disciplinary regime under which "Any suspicion of corruption or influence peddling involving a BNP Paribas employee is investigated by a specific and independent committee of the management chain involved and sanctioned if confirmed" (pages 805-806).

Training has four tiers with completion rates in Table No. 46 (page 806): the mandatory module for all employees; "Certificate 'Anti-corruption - Advanced'" at 98.5% in 2025 against 96.9% in 2024; ABC Most Exposed Employees at 99% against 99.3%; ACAMS certification for correspondents; and Board training at 93.8%, the last session held in September 2025.

Reference: page 799

Reported as effectiveness tracking in the absence of a target, the second limb of MDR-T. The Group states this explicitly: "With the exception of cybersecurity, for which the Group's Cybersecurity Programme has defined targets, the other topics presented in this chapter are not suitable for the definition of targets or annual action plans. Indeed, the management of these risks is part of the overall operational risk management framework involving, in all Group entities, a periodic risk assessment and a portfolio of improvements and corrective actions that is constantly evolving and adapted to each entity" (page 799). Table No. 43 correspondingly shows "N/A" in the Targets column for the corruption and financial security IROs (page 800).

The metrics used to track effectiveness are named in the same chapter introduction: "the percentage of high-risk functions covered by training programmes on corruption and influence peddling ('corruption')"; "the number of convictions and fines for violations of anti-corruption legislation"; and cybersecurity metrics (page 799).

Those metrics are then reported: Conduct Journey completion of 98.8% in 2025 (Table No. 45, page 805); the Anti-corruption Advanced certificate at 98.5%, ABC Most Exposed at 99% and Board training at 93.8% (Table No. 46, page 806); and "BNP Paribas S.A has not been the subject of any convictions or fines for violating anti-corruption law in the last five years" (page 806).

Reference: page 806

The incidents metric is reported as a nil return over a five-year look-back: "BNP Paribas S.A has not been the subject of any convictions or fines for violating anti-corruption law in the last five years" (page 806).

This is the metric the Group itself nominates for the topic. The business conduct chapter introduction states that among the metrics presented are "the number of convictions and fines for violations of anti-corruption legislation" (page 799),.

The handling of incidents that do arise is described rather than quantified: "Any suspicion of corruption or influence peddling involving a BNP Paribas employee is investigated by a specific and independent committee of the management chain involved and sanctioned if confirmed" (page 805); "analysis of incidents associated with corruption, which results are presented to senior management, is performed regularly at Group level" (page 806); and "All corruption incidents are considered in a general analysis to determine corrective actions at the framework level" (page 806).

No number of confirmed incidents, no breakdown between incidents involving the Group's own workers and business partners, and no count of convictions or dismissals for corruption are separately disclosed beyond the nil statement on convictions and fines.

Reference: page 807

In 2012 the Executive Committee adopted a "Charter for responsible representation with respect to the public authorities", which "includes a series of fundamental commitments in terms of integrity, transparency, social responsibility and respect for the universal democratic values" and states that "BNP Paribas carries out its representation activities in line with its global approach and its public commitments relating to the environment and climate change, in particular its support for the objectives of the Paris Agreement".

Responsibility is named: the Institutional Affairs Department, created at the end of 2012, "is responsible for ensuring, on behalf of the General Management, the coherence of the positions defended on Group-level issues", and "the Group's positions are validated within a dedicated governance" (page 807).

On political donations: "BNP Paribas has memberships with federations and professional associations. However, pursuant to the rules defined by the Group, these are not allowed to make any political donations in the name of BNP Paribas" (page 807).

Registrations are listed: the HATVP register in France (number reported as "N/A"), the EU Transparency Register (78787381113-69), the Bundestag Lobby Register (R001771) and the Belgian Parliament register ("N/A"). "The estimated amounts of annual lobbying expenses incurred by the Group are declared in these publicly accessible transparency registers", not in the statement (page 807).