Cnp Assurances

Reference: pages 52-55.

Oversight structure: Board of Directors chaired by an independent director; CSR Committee and Audit and Risk Committee each chaired by an independent director. Management runs through the Chief Executive Officer, the Executive Committee, and a Sustainability Committee chaired jointly by the CEO and Deputy CEO, which "manages the Company's sustainability strategy." Operational delivery sits with the Sustainability Department (attached to the Financial and Non-Financial Performance Department), the Corporate Mission Committee, and a Sustainability Risks Committee.

Composition: 17 non-executive members, no executive members; two Board members represent employees, plus a non-voting SEC representative. Excluding employee representatives, 40% of Board members are men and 60% women; six independent members (40%). Collective skills coverage in ESG-relevant areas ranges from 70.59% (application of ESG issues in insurance activities) to 96.08% (insurance and financial markets; Company strategy and business model).

Board role: reviews and approves the Sustainability Statement, "in particular the double materiality assessment and the transition plan," and is informed annually of material IROs. In 2025, Board members received CSRD training.

Reference: pages 56-57.

The Executive Committee, CSR Committee, Audit and Risk Committee and Board of Directors are "kept informed of material impacts, risks and opportunities, in particular the implementation of duty of care procedures and the transition plan at least once a year," and exercise ongoing oversight.

In 2025, matters brought to the CSR Committee by the Board included: review and approval of "the first CSRD-compliant corporate Sustainability Statement, including the transition plan"; the 2024 corporate mission report and metrics proposals for 2026-2030; and monitoring of ESG rating agency assessments. A table lists themed items covered in 2025 across sustainability strategy, responsible insurance, responsible investment (including the 2025 Nature policy review and a new deep-sea mining exclusion) and regulatory reporting (duty of care, the double materiality analysis, FSC certification commitment).

Reference: page 57.

For 2025, 17.5% of the CEO's variable remuneration was contingent on sustainability objectives: 10% on quantifiable objectives (an environmental target on total green investments, and a social objective of senior-management gender parity), and 7.5% on qualitative objectives tied to the corporate mission.

For Executive Committee members, 40% of individual variable remuneration in 2025 was linked to non-financial objectives (sustainability-related and managerial criteria, no specific weighting). Employee-level variable remuneration links are described under S1 remuneration disclosures.

Reference: pages 58-59.

CNP Assurances applies the French duty of vigilance law and contributes to La Poste Groupe's duty of care plan. A table maps core due-diligence elements (embedding in governance/strategy, stakeholder engagement, identifying and assessing adverse impacts, taking action, tracking effectiveness) to SBM-1, GOV-1, IRO-1 and SBM-3, with the departments involved at each step.

Supplier due diligence: a compliance score via the Provigis tool is required before any new supplier relationship; standard contract clauses require respect for the Universal Declaration of Human Rights, the UN Convention on the Rights of the Child and ILO principles; a partnership with EcoVadis assesses main suppliers on environmental, social and ethical matters.

M&A due diligence: pre-acquisition sustainability due diligence uses the Caisse des Dépôts Group's assessment grid and covers climate mitigation/adaptation, biodiversity, human rights, and governance, with results feeding into post-acquisition integration of sustainability policies.

Investment due diligence: the responsible investment statement lists main negative impacts (GHG emissions, biodiversity impact, overuse of natural resources, financing of terrorism/money laundering, tax evasion, corruption, human rights and employment-law failures, harm to health and safety) addressed through shareholder engagement, exclusion and ESG-based asset selection.

Reference: pages 59-60.

First-level controls are performed by business-unit teams (including subsidiaries), supplemented by non-financial consolidation team checks; second-level controls are run by the Group Risk Management department via an annual self-assessment campaign requiring documented evidence, reviewed by a validator. The Actuarial Function provides a second-tier independent validation report on quantitative metrics, focused on ESRS E1 (climate), S1 (own workforce) and G1 (business conduct), plus voluntary KPIs, submitted annually to Executive Management.

In 2025 "the internal control system was adapted to the new sustainability data production process: new second-level controls covering the production and validation of sustainability information were put in place." Two main risks are identified: reputational risk from incorrect/incomplete data, and ESG communication/transparency weaknesses, addressed via an automated reporting/consolidation system and first/second-level control reviews. Findings are reported at least annually to the Group Risk Committee, chaired by the CEO.

Reference: pages 61-65.

CNP Assurances is a French insurer, subsidiary of La Banque Postale (wholly owned by La Poste Groupe, itself 66% owned by Caisse des Dépôts and 34% by the French State), operating a multi-partner open distribution model across Europe and Latin America. Corporate mission (in its Articles of Association since 2021): "As a responsible insurer and investor... we work with our partners to create an inclusive and sustainable society."

As insurer: savings/pensions, term creditor insurance, personal risk and long-term care, with inclusion initiatives (e.g. waived medical-history disclosure for breast cancer survivors, Latin American micro-insurance). As investor: over €400 billion in insurance assets directed toward the ecological, demographic and digital transitions, ESG integration since 2006 via Ostrum AM and LBP AM, and commitments to the Global Compact, PRI, Net-Zero Asset Owner Alliance and Finance for Biodiversity Pledge.

Key figures (page 65): 6,266 employees (France 4,064; Europe excl. France 464; Latin America 1,738); premium income €37.1 billion; not active in the fossil fuel sector. A value-chain diagram (page 64) maps impacts, risks and opportunities against stakeholder groups.

Reference: pages 66-67.

Stakeholder dialogue is structured around named groups with specific expectations and dialogue channels: customers (product transparency, service quality; customer relations centres, the "You and Us" community), partners, employees (career management, health and safety, diversity; SEC dialogue, "Let's Talk Ambition" meetings), shareholders/investors/rating agencies, funded companies, civil society (NGOs, patient organisations), suppliers and subcontractors, other insurance companies, and public authorities/regulators.

Key stakeholder groups named: policyholders and beneficiaries; employees and non-employees; banking partners (La Banque Postale, Groupe BPCE, Banco Santander, Caixa Econômica Federal, Banco Ciudad, Banco Credicoop); regulators (AMF, ACPR, EIOPA, ESMA, IVASS, SUSEP, SSN); civil society; financed companies; trade associations; suppliers. The Group Stakeholder Dialogue, Communication and Sponsorship department leads the process in consultation with the Corporate Mission Committee; in 2021, defining the corporate mission involved working groups with policyholders and employees, partner/shareholder/NGO interviews, and an employee-wide online consultation.

Reference: pages 67-71.

Double materiality assessment updated in 2025; IROs assessed gross (before mitigation). Key changes: physical climate risk to insurance activities revised down to non-material after sensitivity analysis of underwriting to climate scenarios; a human-rights-in-own-operations risk (discrimination, harassment) newly identified as material; one new environmental opportunity added.

Confirmed/potential positive impacts (pages 67-68) span E1 (green transition investment), employee wellbeing/training/diversity (S1), value-chain health and safety (S2), customer protection/marketing (S4) and governance culture/whistleblowing/supplier standards (G1).

Negative impacts (page 69) span E1 (own-operations and investment-portfolio GHG emissions, under-insurance of weather losses), E2 (pollution from investees), E3 (water/marine resource depletion), E4 (biodiversity pressure), E5 (resource depletion/waste from investees), employee conditions and privacy (S1), value-chain worker safety and duty-of-care breaches (S2), customer cybersecurity/privacy (S4), and corruption/conflicts of interest (G1).

Risks (page 70) and opportunities (page 71) are tabulated similarly. The topical-standard materiality table (page 71) confirms E1, E2, E3, E4, E5, S1, S2, S4 and G1 as material with ESRS published; S3 (Affected communities) is marked "No" — not material.

Reference: page 73.

Double materiality covers impact materiality (positive/negative, actual/potential impacts on environment and people from own operations and value chain) and financial materiality (risks/opportunities to financial performance), assessed across the entire value chain (internal operations, insurance, investing, upstream and downstream), on a gross basis (ignoring mitigation action).

Impact criteria: scale, scope, irremediable character (negative impacts only), likelihood of occurrence, long-term impact; a human-rights exception gives severity precedence over likelihood. Risk/opportunity criteria: severity, likelihood, long-term financial impact. For investments, an additional method combines the ENCORE® database's sector-level materiality of negative environmental impacts with the breakdown of CNP Assurances' invested amounts by sector (NACE nomenclature), flagging a topic material where investment concentrates in sectors rated "high" or "very high" impact. The assessment was presented to the Audit and Risk Committee and CSR Committee in 2025 and goes to the Board for approval in 2026.

Reference: page 74; the full list of disclosure requirements covered is detailed in Section 6.5.2, pages 184-187.

"The list of reporting requirements is detailed in Section 6.5.2 'ESRS disclosure requirements (IRO-2)'." That table (reproduced in this dataset's iro.json-adjacent review) lists, for each ESRS 2 general disclosure and each topical-standard DR, its category and the page number where it is addressed, or "N/A" where a DR is not covered (E1-9, S1-7, G1-6 payment practices "not material"). The table also notes that some ESRS 1 AR16 sub-sub-topics are merged into a single IRO, e.g. "Pollution generated by the assets in the investment portfolio... covers all types of pollution (air, water, soil, etc.)."

Reference: pages 76-82.

The transition plan covers internal operations and investing activities; property and casualty insurance is "only a very marginal volume" (less than 1% of premium income at 31 December 2025), and personal risk insurance has no market methodology for decarbonisation targets.

Internal operations: target a 50% cut in Scope 1+2 GHG emissions between 2019 and 2030 (IPCC 1.5°C scenario), via building-space optimisation, energy performance, sobriety, decarbonised energy sources, car-fleet electrification and digital sobriety. 2025 value at constant scope: 2,728 teqCO2 vs a 2,723 teqCO2 target (99.8% achievement). Estimated capex €13 million (2019-2030) in France, €10 million incurred by end 2025.

Investments: coal exclusion (zero exposure in EU/OECD by 2030, worldwide by 2040); oil and gas exclusion (IEA Net-Zero 2050 scenario); a 53% carbon-footprint cut target for directly-held equities/bonds/infrastructure by 2029 (37 kgeqCO2/€k reached vs 50 target); a 32% cut target for directly-held property (17 kgeqCO2/m2 reached vs 13 target); portfolio carbon-neutrality by 2050 (Net-Zero Asset Owner Alliance). The plan was approved by the Board of Directors in 2024.

Back-filled from the E1 climate risk sub-section (pages 89-91), cross-referring to ESRS 2 IRO-1. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Climate risks split into physical risks (direct climate-phenomena damage) and transition risks (regulatory, technological, market, legal). In 2025, scoping work assessed exposure across corporate securities, sovereign bonds and directly-held real estate. "The assessment of the transition risk is based on different scenarios compatible with a global warming target of 1.5°C by 2100. The assessment of the physical climate risk is based on the IPCC RCP8.5 scenario," distinguishing chronic hazards (temperature, precipitation) from acute hazards (floods, drought, storms, heat/cold waves, forest fires).

A 2025 climate stress test used an internal scenario built on the NGFS "delayed transition" scenario (no climate policy until 2030, then abrupt action to limit warming below 2°C by 2100), layered with insurance mortality/morbidity shocks from ACPR's 2023 climate stress test. Market/credit tensions were the main driver of own-funds decreases; physical-risk impact "remains limited." The work "is still in its early stages," with higher-temperature scenarios planned. No separately-named 1.5°C model (e.g. IEA NZE) is given beyond the "compatible with 1.5°C by 2100" framing.

Back-filled from the E1 climate risk sub-section (pages 90-91). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"In conclusion, CNP Assurances' climate resilience is reflected in its climate stress testing, which is incorporated into its Own Risk and Solvency Assessment (ORSA) in accordance with Solvency II prudential regulations and submitted to the French Prudential Supervision and Resolution Authority." The ORSA process "generate[s] greater stress than the ones in the specific climate studies."

Results of the 2025 internal scenario (NGFS delayed-transition combined with physical/insurance shocks): market and credit tensions are the main driver of own-funds decreases versus a no-climate-change scenario; physical-risk impact remains limited. Previous stress tests spanning 1.5°C-4°C market scenarios "confirmed CNP Assurances' resilience to climate risk." Significant uncertainty is flagged: results depend on long-term projections and climate modelling, "in particular its socio-economic and systemic political effects," and the internal-scenario methodology "is still in its early stages." Adaptation capacity is evidenced through named action items: climate risk indicators under development, quarterly monitoring of the transition plan by the Sustainability department, and initial climate heatmap studies of business risk.

Reference: page 93 (content set out under E1-1, pages 76-82).

The disclosure requirement is addressed by cross-reference: "CNP Assurances' policies related to climate change mitigation and adaptation are described in Section 6.2.1.1 'Climate change mitigation transition plan (E1-1)'." Substantively, the policy framework is the three-pillar responsible-investment approach (exclusion, ESG-based asset selection, shareholder engagement) applied to climate, together with the internal-operations decarbonisation levers (building optimisation, energy performance, sobriety, car-fleet and mobility, digital sobriety) detailed under E1-1.

Reference: pages 93-95.

Internal operations: premises selected/relocated for environmental certification (HQE Exceptionnel, BREEAM Outstanding, BEPOS at Issy-les-Moulineaux headquarters; LEED Platinum Milan headquarters; LEED-certified Brazilian offices). Energy/digital sobriety: heating capped at 19°C since 2022, EcoWatt participation. Training: "Green Actions" charter to all employees; 2,487 employees (75% of workforce) given sustainable-finance training in 2021; 86% of employees completed an ecological-crisis e-learning course in 2023; "Climate Fresk" and "Digital Fresco" workshops (12 trained "Fresqueurs" leading ~65 tables/480 employees in 2024).

Investments: in 2025, CNP Assurances voted at 82 General Meetings of 80 companies in 11 countries (99% of the directly-held equity portfolio), casting 1,702 votes (77.6% for, 22.2% against, mostly on excessive executive remuneration); conducted 16 direct bilateral dialogues plus 4 via Ostrum AM, covering 35% of GHG emissions from direct holdings. Green investments reached €33 billion at end 2025 (target was €28.7 billion, revised down from an initial €30 billion target after the CNP UniCredit Vita disposal), up from €10.4 billion at end 2018. Forestry assets captured 476,766 tonnes of CO2 in 2025 through natural sequestration.

Reference: pages 76-78 (targets embedded in the E1-1 transition plan).

Internal operations: 50% reduction in Scope 1+2 GHG emissions (constant scope) between 2019 (5,445 teqCO2) and 2030 (2,723 teqCO2 target); 2025 level 2,728 teqCO2, a 99.8% achievement rate.

Investments: a 53% reduction in the Scope 1+2 carbon footprint of directly-held equities/corporate bonds/infrastructure between 2019 (107 kgeqCO2/€k) and end-2029 (50 kgeqCO2/€k target); 2025 level 37 kgeqCO2/€k (123% achievement). A 32% reduction in the carbon footprint of directly-held property (club deals and the Lamartine fund) between 2019 (19 kgeqCO2/m2) and end-2029 (13 kgeqCO2/m2 target); 2025 level 17 kgeqCO2/m2 (33% achievement) — this target replaced an earlier 10% reduction target reached at end-2021. Zero exposure to thermal coal in the EU/OECD by 2030 and worldwide by 2040. Carbon-neutral investment portfolio by 2050 (Net-Zero Asset Owner Alliance). No absolute target is set for Scope 3 of investee companies or for other asset classes, citing unavailable methodologies/data; an electricity-producer carbon-intensity target (-17%) was "widely exceeded" by 2024.

Reference: page 95.

The renewable share fell year-on-year even as total consumption and the absolute renewable total both moved, reflecting growth in fossil and nuclear-sourced consumption at certain sites.

Reference: pages 95-97.

Own operations: Gross Scope 1 GHG emissions 1,956 teqCO2 (2025) vs 1,495 teqCO2 (2024) — the increase attributed mainly to "a major refrigerant renewal linked to one-time maintenance on the CNP Seguradora air conditioning system." Gross location-based Scope 2: 773 teqCO2 (2025) vs 936 teqCO2 (2024); market-based Scope 2: 289 teqCO2 vs 276 teqCO2. Scope 3 from internal operations (purchased goods/services, capital goods, fuel/energy-related, waste, business travel, commuting): 62,830 teqCO2 (2025) vs 76,720 teqCO2 (2024).

Investments (Scope 1+2 of the investment portfolio, within Scope 3 Category 15): 20,131,260 teqCO2 (2025) vs 18,797,214 teqCO2 (2024), a 7% increase "mainly due to new inflows broadening the calculation base and market effects." Carbon footprint intensity (kgCO2/€k invested) fell 18% between 2024 and 2025. €331 billion (80%) of Category 15 exposure is studied; €258 billion (60%) has available emissions data, from S&P Trucost (listed equities/bonds) and UNFCCC/World Bank data (sovereigns).

Totals: location-based 20,196,818 teqCO2; market-based 20,196,334 teqCO2 (2025). GHG intensity per net revenue: 545 teqCO2/€m (location- and market-based), up from 521 teqCO2/€m in 2024.

Reference: pages 97-98.

CNP Assurances voluntarily finances carbon-mitigation projects outside its value chain via a "carbon and biodiversity fund" using an internal carbon price; this contribution "is not intended to enable CNP Assurances to meet its direct or indirect greenhouse gas emission reduction targets." In 2025 it selected two Gold Standard/CCP-Approved projects: the Pernambuco Ecoparque Candeias landfill-gas project in Brazil and a French biochar (pyrolysis of vineyard/agricultural residues) sequestration project.

CNP Assurances states it "does not use the Nature Impact Fund to offset any of its GHG emissions."

Reference: page 98.

Internal carbon pricing uses a "shadow price" applied to direct emissions (1,495 teqCO2 Scope 1), energy-related indirect emissions (936 teqCO2 Scope 2 location-based) and business-travel/commuting Scope 3 (6,181 teqCO2), Group-wide. The price has been €60/teqCO2 since 1 January 2023 for 2025 (up from €10.5/teqCO2 in 2022), set by La Banque Postale's Executive Committee "based on the assumptions and proposals of the Carbon Disclosure Project, the Institut Montaigne report and the Blanchard-Tirole Commission, which recommend an average price of around €65/teqCO2 in the European financial sector."

The price is used for cost-benefit analysis of mitigation projects, as a strategic steering tool for the Carbon and Biodiversity Fund, and to calculate a carbon budget (Group emissions × carbon price) that funds voluntary carbon contributions.

Reference: pages 99-100.

Pollution-related impacts are identified as arising from investee companies and assets, addressed through the uniform three-pillar responsible-investment approach (exclusion, non-financial ESG criteria in asset selection/management, shareholder engagement) that CNP Assurances applies across E2-E5.

Exclusion policy specific to pollution: since 2021, exclusion of new investment in oil and gas companies deriving more than 10% of premium income from non-conventional fossil fuels (tar sands, shale oil and gas, Arctic oil and gas); since that policy's extension, exclusion of companies deriving more than 20% of premium income from manufacturing or selling pesticides (herbicides, fungicides, insecticides). No quantified pollution metrics or standalone pollution policy document is described; the approach is the shared E2-E5 framework described at page 99.

Reference: pages 100-101.

Listed equities/bonds: the "Pollution/Waste" criterion of the GREaT rating methodology (used by Ostrum AM for directly-held equities and corporate bonds) incorporates air and soil pollution elements plus metrics on toxic emissions and electronic/packaging waste, feeding into the non-financial rating used for asset selection.

Real estate: the Green Works property management charter requires real-estate managers to limit local pollution, control water-system contamination/bacterial growth, meet French Health Code water-quality benchmarks, limit VOCs in easy-to-install materials, and follow regulated procedures for asbestos and lead-in-paint during renovation work.

Forestry: the "Forêts CNP – Agir pour l'avenir" sustainable forest management charter (2021-2025 period) commits to banning herbicides and fungicides and limiting insecticides to health emergencies, with related training programmes for Société Forestière de la Caisse des Dépôts.

Reference: page 100.

"CNP Assurances does not have specific targets for ESRS E2, E3 (including water and sustainable oceans and seas) and E5." No pollution-specific quantified target is set; the company does not state an alternative effectiveness-tracking mechanism specific to E2 in this passage beyond the general exclusion and ESG-selection policies described under E2-1/E2-2.

Reference: pages 99-101 (the company's own ESRS index cross-references this DR to the general E2-E5 approach described at page 99).

No quantified figures for air, water or soil pollutant amounts are disclosed. The content available is the general statement that CNP Assurances "considers that its investments could have a negative impact that could result in: damage to ecosystems and public health," addressed through exclusion, ESG-based selection and shareholder engagement, and the specific pollution-reduction criteria described under E2-2 (GREaT "Pollution/Waste" criterion, Green Works Charter pollution rules). No own-operations pollution data (e.g. effluents, emissions to air) is presented, consistent with CNP Assurances' impact on this topic being assessed as sitting in its investment value chain rather than its own operations.

Reference: pages 99-101 (the company's own ESRS index cross-references this DR to the general E2-E5 approach described at page 99).

The definitions section (page 100) states: "'Substances of concern' covers the company's production, use, distribution and/or commercialisation of substances of concern, including substances of very high concern" — framed as a matter arising through investee companies, not CNP Assurances' own operations. No quantities of substances of concern generated, used, procured or released are disclosed for CNP Assurances itself or for its investment portfolio; the applicable policy response is the shared exclusion/ESG-selection/engagement framework, and the pesticide-manufacturer exclusion threshold (more than 20% of premium income) described under E2-1.

Reference: page 100.

"As permitted under the transitional provisions in Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023, CNP Assurances has not estimated the anticipated financial effects of material risks and opportunities in relation to ESRS E2 to E5." This is a declared use of the ESRS 1 Appendix C phase-in relief for anticipated financial effects, applied uniformly across pollution, water and marine resources, biodiversity and ecosystems, and resource use and circular economy.

Reference: pages 99-101.

"CNP Assurances SA and its French subsidiaries implement a uniform approach to responsible investment, detailed in the disclosure requirements covered in other environmental standards E2 to E5" — i.e. the shared exclusion, ESG-asset-selection and shareholder-engagement framework, with water-specific elements described under E3-2. No standalone water policy document is named.

Reference: pages 101-102.

Listed equities/bonds: the "Biodiversity/Water" criterion of the GREaT rating ensures "water resources are used efficiently" across the industrial process and incorporates water-management metrics and water-dependency/shortage indicators for investee companies.

Real estate: the Green Works Charter requires managers to control contamination/bacterial-growth risk in water systems, distribute water meeting French Health Code quality benchmarks, and "take steps to limit water consumption."

Shareholder engagement: CNP Assurances encourages investee companies to assess water impacts/dependencies, disclose direct and indirect water consumption, and set reduction policies "in line with the SBTN Freshwater approach or other such frameworks."

Water-related physical risk (flood, drought) is addressed under E1; water pollution under E2; freshwater ecosystems under E4.

Reference: page 100.

"CNP Assurances does not have specific targets for ESRS E2, E3 (including water and sustainable oceans and seas) and E5." No water-specific quantified target is set. This is a direct, explicit statement in the Sustainability Statement rather than a silent gap: the company names E3 among the topics for which it has deliberately not set a target, distinguishing it from ESRS E4, where targets are set out separately under the biodiversity section (E4-4).

Reference: page 102.

CNP Assurances "plans to map the assets in its various financial portfolios that are located in areas at risk of extremely high and high water stress (in France and internationally), within the limits of available tools and data, by end 2027." Its real estate assets in water-stress zones (France and internationally) will be mapped, within the limits of available tools and data, by end 2026. These are forward-looking commitments rather than current consumption figures; no water-consumption volume (e.g. m3 withdrawn) for own operations or the investment portfolio is currently disclosed.

Reference: page 100.

"As permitted under the transitional provisions in Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023, CNP Assurances has not estimated the anticipated financial effects of material risks and opportunities in relation to ESRS E2 to E5," which covers water and marine resources alongside pollution, biodiversity and resource use/circular economy.

Reference: pages 105-108.

"Sustainability issues relating to biodiversity and ecosystems have been identified as material for CNP Assurances' investment portfolio, but not material for its internal operations." In February 2025 "an initial biodiversity transition plan was formally approved by the Board of Directors" and its first implementation steps completed; governance passed from the Climate Risks and Biodiversity Committee (2021-2024) to the Sustainability Risk Committee (from December 2024).

A 2025 resilience analysis combined (i) a transition-risk assessment of the biodiversity footprint of directly-held equities/bonds via the ENCORE methodology plus controversy screening, and (ii) a physical-risk dependency analysis via the BIA-GBS tool. The work is described as "exploratory" with evolving methodologies; it concluded the dependence of CNP Assurances' investments on ecosystem services "was estimated material." No mature biodiversity stress-testing tool exists comparable to climate; CNP Assurances has not mapped investee-company operations in biodiversity-sensitive areas, citing a lack of tools.

Reference: pages 109-110.

The dual materiality analysis "concludes that CNP Assurances' investment activities have actual or potential material impacts on biodiversity and ecosystems, as well as risks... related to the decline in biodiversity and the dysfunction of ecosystem services." Policy aims: reduce investees' impacts on biodiversity/ecosystems, and reduce investees' dependence on ecosystem services to manage return risk — delivered through the same three pillars (exclusion, non-financial ESG criteria, shareholder engagement).

Exclusion criteria specific to biodiversity: unconventional fossil fuels (as under E1/E2); companies deriving more than 20% of premium income from pesticides; companies trading in deforestation-linked commodities (cocoa, coffee, soya, beef, leather, rubber, palm oil, wood/paper pulp) without a recognised deforestation-prevention policy (effective 2024); companies in deep-sea/seabed mining, pending further scientific research. The company states: "the social consequences of biodiversity loss and the disruption of ecosystem services are not specifically addressed by CNP Assurances' policies. This is a key area of work for the next stages."

Reference: pages 114-115.

Actions relating to sustainable finance are cross-referenced to E1-3. CNP Assurances states it "does not yet invest in nature-based solutions (NbS)" as defined by IUCN, though it has chosen to invest in an unlisted fund (deployed 2025) targeting European/French companies in ecosystem preservation and restoration, alongside ten other institutional investors' "biodiversity initiative" launched spring 2024.

Monitoring: asset managers (e.g. Ostrum AM) report consolidated ESG ratings quarterly to the SRI Committee; property ESG compliance is reviewed six-monthly; the Société Forestière de la Caisse des Dépôts sustainable forestry charter requires annual reporting on biodiversity, water, soil and people objectives. CNP Assurances states it "did not conduct direct consultations with communities that could be adversely affected," though it monitors controversies and, for unlisted assets, works through asset managers with local organisations.

Reference: pages 108, 115-116.

Aligned with the Kunming-Montreal Global Biodiversity Framework (COP15), contributing to 5 of 23 Montreal targets (8, 10, 15, 19, 21). A commitments table tracks progress against the 2021 Finance for Biodiversity Pledge: cooperation on impact-assessment methodologies ("in progress"); inclusion of biodiversity in Ostrum AM's mandate ("in progress"); €120 million invested in the LBP AM/Tocqueville biodiversity fund ("completed"); dialogue with 5 companies on biodiversity strategy by end-2029; biodiversity footprint of all securities measured as of end-2023 ("completed"); 100% of forestry assets measured for biodiversity by end 2025 ("completed"); 3% of woodland set aside for older/natural growth by end 2025 — 4.72% achieved ("completed"); FSC certification of all forests by 2030 ("in progress"); mapping of equity/bond investments and real estate in biodiversity-sensitive/water-stress areas by 2027 ("in progress"); Board oversight/approval of the Biodiversity Transition Plan by end 2024 ("completed").

Reference: pages 103-105.

Biodiversity footprint measured since 2022 using Carbon4 Finance's BIA-GBS™ tool (CDC Biodiversité's Global Biodiversity Score methodology), in MSA.m2 (Mean Species Abundance per square metre; a positive value denotes negative impact equivalent to artificialising that area). For directly-held equities and corporate bonds (98% portfolio coverage): static land-based biodiversity footprint 51.92 MSA.m2/€k; dynamic land-based footprint 3.12 MSA.m2/€k (of which climate change and land-use change are the main pressures); water-based biodiversity footprint 3.49 (static) and 0.04 (dynamic) MSA.m2/€k.

Dependency analysis (ENCORE methodology, 98% portfolio coverage): average ecosystem-services dependence score 9% (own activities/Scope 1) and 10% (upstream value chain/Scope 3); critical dependence score (≥80% on at least one service) 38% (Scope 1) and 42% (Scope 3). Sectors most critically dependent include transport, agri-food (especially beverages), pharmaceuticals/chemicals/cosmetics and telecommunications.

Reference: page 100.

"As permitted under the transitional provisions in Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023, CNP Assurances has not estimated the anticipated financial effects of material risks and opportunities in relation to ESRS E2 to E5," which includes biodiversity and ecosystems.

Reference: page 99.

"CNP Assurances SA and its French subsidiaries implement a uniform approach to responsible investment, which is detailed in the section relating to disclosure requirements covered in environmental standards E2 to E5" — the shared exclusion / ESG-asset-selection / shareholder-engagement framework, with resource-use and circular-economy specific elements under E5-2.

Reference: pages 116-117.

Listed equities/bonds: the "Sustainable management of resources" pillar of the GREaT rating "ensures that the principles of the circular economy are taken into account in the design, production and use of products/services," including waste management and packaging elements.

Real estate: the Green Works Charter requires property managers to use materials/technologies with limited environmental impact, promote recycled/recyclable materials, draft site organisational plans, manage and recycle construction waste, reduce waste at source, implement waste sorting, treat and reuse waste, track collection, and assess deconstruction/material-recovery options "wherever possible for each operation."

Reference: page 100.

"CNP Assurances does not have specific targets for ESRS E2, E3 (including water and sustainable oceans and seas) and E5." No resource-use or circular-economy target is set. This is a direct, explicit statement rather than a silent gap: the company names E5 among the topics for which it has deliberately not set a target, in contrast to ESRS E4, where biodiversity targets are set out separately (E4-4), and in contrast to E1 and S1-S4, where quantified targets do appear.

Reference: pages 99-100 (the company's own ESRS index cross-references this DR to the general E2-E5 approach described at page 99).

No quantified resource-inflow figures (e.g. raw materials or products used) are disclosed for CNP Assurances' own operations or its investment portfolio. The available content is the shared E2-E5 policy framework and the Green Works Charter's requirement that property managers "use materials or technologies with a limited impact on the environment" and "promote the use of recycled or recyclable materials" (E5-2), consistent with resource-use impacts for an insurer/investor sitting mainly within its investment value chain rather than its own operations.

Reference: pages 99-100 (the company's own ESRS index cross-references this DR to the general E2-E5 approach described at page 99).

No quantified resource-outflow figures (e.g. products, materials or waste generated, by category) are disclosed at Group level. The Green Works Charter requires real-estate managers to "assess the amount of waste produced" and "promote the use of recycled materials from wherever possible" (E5-2); specific, smaller-scale outflow data points are captured under the dedicated Waste entry (E5-5-Waste) rather than as a consolidated Group resource-outflow metric.

Reference: page 100.

"As permitted under the transitional provisions in Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023, CNP Assurances has not estimated the anticipated financial effects of material risks and opportunities in relation to ESRS E2 to E5," which includes resource use and circular economy.

Reference: pages 87, 93-94, 117.

No consolidated Group waste-tonnage table (hazardous/non-hazardous/radioactive) is presented. Disclosed waste activity is qualitative and site/initiative-specific:

• World Clean Up Day (page 87): for the fifth consecutive year, "550 employees of CNP Assurances Group collected 3,836 kg of waste worldwide."
• Youse (Brazil), car-repair-shop waste recycling pilot (pages 93-94): launched end-2024, "already avoided the emission of 8 tonnes of CO2 in the first half of 2025. In addition to the emissions avoided, Youse recycled 11 tonnes of waste, depending on the composition of the materials, helping to promote the circular economy in the car insurance sector."
• Green Works property management charter (page 117, cross-referenced from E5-2): requires real-estate managers to "reduce waste at source," "implement waste sorting," "treat and reuse waste and track its collection," and "assess the amount of waste produced" on managed sites.

No own-operations office waste tonnage (e.g. paper, general waste) is quantified.

Reference: pages 133-135.

"The Group has ensured that it has a policy (according to CSRD terminology) for each of its IROs and for its entire scope. Wherever CNP Assurances does not have a Group policy, framework agreements are negotiated with local players." No major policy differences exist between CNP Assurances SA and its French/international subsidiaries.

Internal mobility: 44% of new permanent positions at CNP Assurances SA in 2025 were filled internally (7.4% internal mobility rate); 1,115 new hires in 2025, 68% permanent contracts.

Remuneration policy: governed by labour law, collective bargaining and workforce-representative agreements, ensuring "adequate rate of pay." A three-year discretionary profit-sharing agreement (signed 2023) weights non-financial criteria at 50%. 2025 sustainability criteria for variable pay include employee physical-activity engagement, participation in at least two training sessions (one on sustainability), and Customer Effort Score improvement. In 2025, 30% of employee and 40% of manager variable remuneration was linked to non-financial/managerial objectives.

Skills development: the 2024-2026 GEPP agreement encourages 3% of working hours (six days, the "CAP 6 days" initiative) devoted to continuous learning via the BOOST training platform.

Reference: page 139.

The Human Resources department "maintains regular, high-quality dialogue with the SEC (Comité social et économique) and union representatives." The 2020 Quality of Life and Working Conditions (QVCT) agreement introduced an annual QVCT Barometer — a ~60-question, 15-topic engagement/wellbeing survey deployed across the Group.

Additional channels: breakfast meetings, plenary "Let's Talk Ambition" sessions and live chats with Executive Management; dedicated "management circles" for peer discussion; annual performance interviews, career-development interviews and people reviews; a voluntary mentoring scheme (no reporting relationship between mentor/mentee); committees overseeing workforce agreements, meeting "at least three times a year to track and assess the implementation of the commitments."

Reference: pages 139-140.

Channels for raising concerns: direct to a superior or compliance liaison officer; ethics matters to the Ethics Officer via the Integrity Line platform (received by the Group Ethics Officer and Head of Ethics and Compliance); grievances to the HR mediation scheme by email or phone, "processed by the mediator via an encrypted file." The whistleblowing system covers workplace health and safety, "notably the fight against discrimination and harassment."

Employees may submit reports anonymously "where permitted by local law." In Italy, CNP Vita Assicura additionally operates an "Organisation and Management Model ('MOG 231')" under Legislative Decree 231/2001. In 2025, 20 matters were submitted to the internal mediation system (MSI).

Reference: pages 140-143.

Discrimination/inclusion: mandatory training for all CNP Assurances SA employees; recruiter training every 5 years on non-discriminatory hiring (Law 2017-86); new-hire e-learning on stereotypes; whistleblowing guidelines on the intranet.

Gender equality: CNP Assurances SA committed to a minimum score of 97/100 on the gender-equality index; 99/100 achieved for 2025.

Health: an autonomous occupational health service; 2025 absenteeism rate (excl. maternity/paternity) 2.15%; the Lyfe platform offers 24/7 online medical consultations since 2018; the Ulteam prevention platform (2024) covers stress/concentration/eyestrain.

Disability: employment rate of 6% achieved in 2025 (30th anniversary of the Group's disability-inclusion commitment); a €20,000 solidarity-challenge donation to TDAH France; dedicated committee for job-retention solutions.

Personal data: a GDPR-aligned framework with lawfulness, minimisation, retention limits and Privacy by Design; biennial privacy-impact-assessment campaigns; no leasing or sale of personal data to third parties.

Reference: pages 143-144.

Two target categories: agreement-based targets and corporate-mission targets. PAQTE initiative: offer internships/work-study to at least 200 young people from disadvantaged neighbourhoods (2022-2025) — 334 welcomed in 2025 (vs 243 in 2024). Gender parity: raise the proportion of women on the Executive Committee to 50% and in senior management to at least 45% by end 2025 — 42% average achieved in 2025. Employee wellbeing: maintain an engagement/wellbeing score of at least 80/100 by end 2025 — 96/100 achieved (vs 94/100 in 2024, 91/100 in 2023). Targets were "defined jointly by CNP Assurances SA and workforce representatives" during QVCT/GEPP negotiations and are reviewed annually by Tracking and Assessment Committees.

Reference: pages 145-146.

Headcount is calculated as of 31 December of the year in question.

Reference: page 145.

Percentage of employees covered by collective bargaining agreements: 97.1% (unchanged from 2024). A breakdown table (S1-8) sets out coverage rate bands (0-19% through 80-100%) and social-dialogue presence for the EEA and non-EEA employee populations, with France and Brazil identified as the countries with more than 50 employees representing over 10% of total headcount. "CNP Assurances has a European Works Council comprising at least one representative of each of its host countries."

Reference: page 146.

Gender distribution at senior management level (Executive Committee): female 41% (2025) vs 40% (2024); male 59% (2025) vs 60% (2024). Age distribution of permanent employees: within 30 years 14.67% (2025) vs 13.35% (2024); 30-50 years 55.11% vs 57.01%; over 50 years 30.22% vs 29.64%.

Reference: page 146.

"An adequate wage is one that enables workers to meet their basic needs and live in dignity," accounting for local cost of living. CNP Assurances' subsidiaries apply the legal minimum wage of their operating country plus any higher minimum set by the applicable collective bargaining agreement. "In 2025, all employees of CNP Assurances and its subsidiaries are paid an adequate wage."

Reference: page 146.

"All employees of CNP Assurances are covered, under internal agreements and collective bargaining agreements, by social protection against loss of income due to a major life event (sickness, unemployment starting from when the employee is working for the Group, employment injury and acquired disability, parental leave and retirement)." No percentage-coverage figure below 100% is disclosed, i.e. full-workforce coverage is asserted.

Reference: page 146.

A dedicated annual budget of €135,000 (page 144) covers workplace-adaptation measures for employees with disabilities.

Reference: page 146.

The GEPP agreement (2024-2026) targets 3% of working hours (six days) devoted to continuous learning via the "CAP 6 days" initiative and the BOOST training platform.

Reference: page 147.

Footnotes: apprentices in Brazil are not covered by the H&S management system under local law; travel accidents are excluded from the accident count.

Reference: page 147.

All employees are entitled to maternity, paternity, family, carer and parental leave. Breakdown by gender taking family-related leave (2025 vs 2024): maternity leave 3.74% women (3.25% in 2024); paternity leave 3.04% men (3.86% in 2024); family leave 17.38% women / 11.57% men (16.69%/12.04% in 2024); carer leave 1.07% women / 0.90% men (1.82%/0.89% in 2024); parental leave 1.01% women / 0.17% men (1.22%/0.50% in 2024).

Reference: page 147.

Gender remuneration gap: 15.86% (2025) vs 15.95% (2024). Annual total remuneration ratio (highest-paid individual to median, excluding the highest-paid individual, weighted Group average): 7.39 (2025) vs 7.79 (2024) — broken down as France (CNP Assurances SA) 6.68 vs 7.66; Latin America (Caixa Vida e Previdência) 11.10 vs 10.40; Europe excl. France (CNP Vita Assicura) 5.80 vs 5.05. These three subsidiaries represent 78% of the Group's workforce and have "the highest [ratios] among entities in the same geographical area."

Reference: pages 147-148.

Complaints are lodged via the in-house mediation system (MSI, France) and the Integrity Line whistleblowing tool (all subsidiaries); MSI referrals via the managerial line "reflect the constant efforts to raise awareness of psychosocial risk prevention among managers."

Reference: pages 149-150.

Value-chain workers covers those directly employed by suppliers, subcontractors or partners, and those on CNP Assurances' premises or in management-delegate roles. The Responsible Supplier Charter requires suppliers to comply with the UN Global Compact, the Universal Declaration of Human Rights, ILO core conventions and applicable regulation, to cascade the charter to their own suppliers/subcontractors, accept external audits, and take corrective action on identified shortcomings; it takes effect January 2026 and rolls out progressively to international subsidiaries.

Investment-value-chain workers are covered by the exclusion policy (over 100 countries excluded for democracy/human-rights/corruption failings, using Freedom House and Transparency International lists) and non-financial ESG asset-selection criteria (the GREaT methodology's working-conditions and human-rights social pillars). "No cases of human rights violations have been reported in 2025."

Reference: pages 150-151.

Since obtaining the Supplier Relations and Responsible Procurement (RFAR) label in September 2023, CNP Assurances has run "a process to improve its relationship with suppliers by introducing a culture of dialogue and mediation." Channels: tender interviews; the e-purchasing platform for escalating questions; a mediation mechanism for contractual disputes; the Integrity Line whistleblowing platform (accessible to all partners); and periodic service-monitoring committees.

Effectiveness is assessed via an annual review with the French Insurance Ombudsman — "the conclusions at the last meeting were that no referrals had been received." Channels for vulnerable workers' viewpoints are also described, without a named mechanism beyond the general reporting channels.

Reference: pages 151-152.

The general approach mirrors G1 reporting channels, extended to value-chain workers: the CNP Integrity Line whistleblowing platform; a Regular Monitoring of Services Committee; occupational health services for on-site supplier employees; trade-union notice boards; a contractual mediation clause; the Ivalua sourcing-platform messaging system; and supplier questionnaires. Handlers of alerts operate under "a strict obligation of confidentiality" and may not reveal the whistleblower's identity; an external mediator is available on request. Monitoring includes an annual review of mediator-reported remediations and tracking of Integrity Line alert volumes. "To date, CNP Assurances has not received any complaints made to the Insurance Ombudsman."

Reference: pages 152-153.

Two defined actions: the Responsible Supplier Charter (effective January 2026) and the mediation system's extension to suppliers' employees since 1 January 2025. RFAR-certification steps (September 2023) include "reducing payment times for SMEs" as a preventive cash-flow measure.

Positive impacts: inclusive purchasing represented 29% of CNP Assurances' expenditure in France in 2025 (adapted companies, sheltered workshops, integration-through-economic-activity structures, non-profits, SMEs). CSR criteria (e.g. ethics/anti-corruption training of consultants, hardware/software CO2 data, Global Compact compliance) will be weighted at a minimum 10% of supplier tender scores from 2026. Buyers receive training in detecting/escalating negative impacts to Compliance, HR, Purchasing and Legal. "CNP Assurances has not reported any severe issues or incidents relating to human rights in its value chain in 2025."

Reference: page 154.

Two targets: maintain 100% of service providers with a completed preliminary inspection and prevention plan (a legal requirement at ICV, Angers, the Beaucouzé data centre, Garges and regional sites, "in place for more than ten years"); and roll out the Responsible Supplier Charter to CNP Assurances' international subsidiaries from January 2026, "gradually... while taking account of specific local regulations." Targets were "defined with regard to the issues assessed as material in the materiality analysis and are intended to be reviewed annually."

Reference: pages 155-156.

CNP Assurances commits to the Universal Declaration of Human Rights, the UN Global Compact, UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises. As a signatory of the Global Compact and, per the Principles for Sustainable Insurance, CNP Assurances "refrains from developing any commercial activity in 118 countries due to corruption, absence of tax transparency and breaches of democracy or freedoms."

Commitments: offer products accessible to as many people as possible, including vulnerable consumers; provide accurate information enabling informed decisions; provide a complaints mechanism and mediation; protect consumers' personal data lawfully, transparently and fairly. "There were no serious human rights incidents to report during the reporting period."

Reference: pages 156-157.

CNP Assurances runs qualitative and quantitative customer research to capture "perceptions, experiences, needs and expectations." Example: electronic-signature process improvements from self-care satisfaction feedback; a repeated study on French people's understanding of insurance (run again in 2025). The You&Us online community (France) provides a direct-discussion space involving customers in product development.

Satisfaction is tracked via three metrics: Customer Effort Score (CES), Net Promoter Score (NPS) and Customer Satisfaction Score (CSAT), monitored across all subsidiaries and reported quarterly via the "customer cockpit" (covering recommendation, effort, satisfaction, complaint rate, cancellation rate, call-centre pick-up). 2025 NPS for France: +32.4 (vs +28 in 2024, +22 in 2023), against an internal benchmark of +20.

Reference: pages 157-158.

A complaint is defined as "the expression of dissatisfaction with CNP Assurances... for which a response or solution is explicitly or implicitly expected"; complainants need not have a contractual relationship with the Group. Channels: online complaint form, postal address, telephone advisors, and social media (where the message meets the complaint definition).

CNP Assurances "endeavours to respond to complaints as quickly as possible, within a maximum of two months, in accordance with ACPR recommendations," with acknowledgement of receipt within 10 days if a longer response time is needed; communications state how policyholders can appeal, including contact details for the French Insurance Ombudsman. A quantitative/qualitative annual complaints report is sent to the supervisory authority. In Brazil, subsidiaries use Reclame Aqui/Procon/consumidor.gov channels; CNP Seguros Holding Brasil earned the platform's maximum RA1000 quality seal in 2024.

Reference: pages 157-158.

Actions taken include periodic committee reviews of complaints/mediation with Legal and Compliance; France-specific tests of complaint-handling processes (response times, notification letters) by the Risk Management department, plus periodic Audit department reviews. Proactive outreach to dissatisfied ("detractor") customers is described for France (automated CRM feedback loop in life insurance), Brazil ("Close the Loop" approach) and Argentina (100% of detractor calls analysed, contributing to a +50 average NPS in 2025).

Effectiveness evidence: France 2025 NPS +32.4 (up from +28 in 2024); France 2025 Customer Effort Score range 1.66-2.14 across geographies (target <2 by 2025); Argentina's CES reached its best-ever score of 1 out of 5 in 2025 "thanks in particular to efforts to simplify and automate processes, with artificial intelligence (AI) helping to manage the flow of responses to customers."

Reference: page 158.

Customer Effort Score target: achieve a CES of less than 2 out of 5 by 2025 — the 2025 range across France, Europe excl. France and Latin America was 1.66 to 2.14, i.e. mixed achievement (some geographies inside, some outside the target). Net Promoter Score benchmark: an overall level of +20 is treated as satisfactory — the 2025 France NPS of +32.4 exceeds this. Both metrics are tracked quarterly via the "customer cockpit" reporting used across all CNP Assurances subsidiaries.

Reference: pages 167-169.

The CNP Assurances Code of Conduct ("C@pEthic") applies to all executives, employees and stakeholders and is public on the institutional website. It covers conflict-of-interest prevention, anti-corruption, personal data protection, AML, financial sanctions compliance, anti-fraud, inside-information management, competition, complaints handling, gifts/invitations/benefits, CSR, responsible lobbying, responsible purchasing, and alert collection/processing. All employees receive onboarding and recurring Code of Conduct training, most recently updated online from Q4 2025.

AML-CFT: a ~50-person specialist Group Compliance team; strict exclusion of high-risk/sanctioned/uncooperative jurisdictions; biennial AML-CFT training (new module Q4 2025); "as of 2025, no known or suspected cases of money laundering had been reported or observed within CNP Assurances SA or its subsidiaries."

Conflicts of interest: mandatory declaration by all employees on joining and annually for Executive Committee members and (from 2025) Solvency II key functions; "no conflicts of interest were identified, reported or addressed within CNP Assurances SA in 2025."

Reference: pages 172-173.

Supplier selection weighs financial performance and CSR criteria (employment, work organisation, regional/social/environmental impact). The RFAR label (obtained September 2023) evidences continuous-improvement commitments in supplier relations; a supplier mediation service (since May 2023, extended to suppliers' employees from 1 January 2025) resolves disputes.

Assessment: France uses an EcoVadis partnership (CSR questionnaire required if unassessed); Italy (CNP Vita Assicura) applies IVASS/DORA-based critical-supplier CSR questionnaires with on-site, risk-based visits; Brazil (CNP Seguros Holding, Youse) developed a 2025 sustainability questionnaire mapping suppliers against ESG/inclusion criteria, with immediate-termination clauses for breaches. Anti-corruption training for purchasing staff has been mandatory since 2019. From January 2026, suppliers must formally accept the Responsible Supplier Charter's CSR obligations.

Reference: pages 173-175.

The anti-corruption system includes a proportionate risk-based framework, internal rules distribution, business-relationship risk mapping, proportionate due diligence, the Integrity Line whistleblowing channel, permanent/periodic controls and mandatory employee training — governed by the Sapin II law and validated by CNP Assurances' governing bodies. Reinforced due diligence applies to public officials/politically-exposed persons and to M&A targets (aligned with French Anti-Corruption Agency recommendations).

An internal-investigation procedure separating investigators from the whistleblowing management chain is due to join CNP Assurances' alert-processing procedure in Q1 2026.

Back-filled from the G1-3/G1-4 corruption-prevention disclosures (pages 174-175), following the 2023 ESRS's MDR-T treatment of business-conduct targets. This standalone disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No single stated numeric target for business-conduct outcomes is disclosed. Effectiveness is instead tracked through recurring metrics: percentage of at-risk functions covered by anti-corruption training rose from 94.73% in 2024 to 96.64% in 2025; the number of exposed employees enrolled fell from 1,765 to 1,334; Administration, Management and Supervisory Body (AMSB) training participation was 63.16% in 2024 (the training runs on a biennial cycle, so 2025 shows "N/A" pending the next session, scheduled with mandatory 2026 AMSB inclusion). Outcome tracking also includes the confirmed-incidents metric under G1-4: "no known or suspected cases of corruption or insider trading have been reported or observed within CNP Assurances SA or its subsidiaries" as of the 2025 report's publication date.

Reference: page 175.

"At the date of publication of this sustainability report, it is confirmed that no known or suspected cases of corruption or insider trading have been reported or observed within CNP Assurances SA or its subsidiaries. As a result, no corrective action plan relating to non-compliance with internal procedures was deemed necessary, and no fines for non-compliance with anti-corruption legislation were paid by CNP Assurances. In addition, as of the same date, no legal proceedings related to corruption were ongoing or foreseen."

Reference: pages 176-178.

Lobbying activity is governed by a public Charter for the Responsible Representation of Interests, covering the interest-representation activities of CNP Assurances Holding's French subsidiaries. In 2025, CNP Assurances SA took positions on the Omnibus I simplification of CSRD/CS3D/Taxonomy/ESRS requirements, the SFDR revision, the Retail Investment Strategy, the EU's Savings and Investments Union strategy, FIDA (financial data sharing), the AI Act's implementation, the Solvency II revision (LTEI, EPIFP, securitised-asset capital charges), and the Insurance Recovery and Resolution Directive transposition.

"CNP Assurances SA and its French and international subsidiaries did not make any direct or indirect financial or in-kind political contributions with any monetary value, in any of the Group's host countries." CNP Assurances Holding is registered in the EU Transparency Register (No. 019519094351-45); CNP Assurances SA is registered in France's HATVP lobbyist register. The Group Administrative Officer supervises lobbying activity.