Commerzbank

Reference: pages 51, 55-56.

The Board of Managing Directors (seven members as at 31 December 2025) and the Supervisory Board (with an ESG Committee) oversee sustainability. The Group Sustainability Board (GSB) "has firmly embedded the wide-ranging issue of sustainability within the Bank's organisation. It sets the strategic sustainability targets and monitors the actions taken for their implementation and management," chaired by the Chairwoman of the Board of Managing Directors and joined by Executives, the Chief Environmental Risk Officer and the Chief Sustainability Officer.

Since 2022 an external Sustainability Advisory Board, led by the Chairwoman, provides "constructive and critical dialogue with our stakeholders." Group Sustainability Management sits within the Strategy, Transformation and Sustainability division and reports to the Chairwoman. Commerzbank states it "does not currently compile an overview detailing how the skills and expertise of the members of our administrative, management and supervisory bodies relate to the company's material impacts, risks and opportunities."

Reference: pages 57-58.

The Group Sustainability Board (GSB) met four times in 2025, focused on updating climate targets, the 2030 action portfolio, the EU Omnibus initiative's impact on Commerzbank, and revisions to the fossil-fuel guideline (coal phase-out pushed to "no later than 2038," tightened oil-transport exclusions, a new deep-sea mining position).

The Supervisory Board's ESG Committee meets quarterly and in 2025 covered net-zero strategy milestones, SBTi sector controls, the CSRD transition-plan concept, and social topics (Employee Engagement Index results, diversity, equity and inclusion). It "discussed the findings of the audit report on the Group Sustainability Report 2024 and the measures derived for reporting in 2025." Greenwashing-risk internal control results were presented and approved at GSB meetings, cross-referenced to SBM-3.

Reference: pages 58-59.

Since 2023 the Board of Managing Directors' variable remuneration carries a binding ESG sub-target worth 20% of the Group target (12% of total target achievement), composed of: Environmental 60% (50% reduction of carbon intensities across the eight SBTi sector portfolios, 50% a 5% cut in Commerzbank AG's own banking-operations carbon emissions), Social 20% (share of women in management), Governance 20% (promoting corporate values and a culture of integrity). "These data are not reported in E1-6."

From FY2026 a new remuneration structure introduces a three-year Long Term Incentive with the ESG target as a sub-target. Employee satisfaction and audit/regulatory findings also feed individual Board-member targets.

Reference: pages 59-60 (statement on due diligence).

A mapping table links the six core due-diligence elements (embedding in governance/strategy, stakeholder involvement, identifying negative impacts, actions, tracking effectiveness) to GOV-2, GOV-3, SBM-2, SBM-3, IRO-1 and the topical ESRS.

On human rights: "The materiality assessment carried out for this Group Sustainability Report revealed that sustainability matters relating purely to human rights are not considered material in the current reporting period... Commerzbank has no significant impact on compliance with human rights and is not subject to any material financial risks or opportunities in this regard." Human rights are nonetheless embedded via S1-1 (own workforce), G1-1 (Code of Conduct) and E1-2 (exclusion criteria).

Reference: page 60.

"The Bank has established a risk management and internal control system aimed at promoting the integrity and reliability of our reporting processes," identifying and assessing risks in "data integrity, regulatory compliance and transparency," with controls "directly related to data validity" along the data flow.

Key controls include "an annual review to assess compliance with reporting standards and validation of the data collected." Risk prioritisation is qualitative, assessing impact and probability. "The Audit Committee of the Supervisory Board was provided with a detailed overview of the internal control system," and the Board of Managing Directors and Supervisory Board "receive annual feedback on how well the internal control system is functioning."

Reference: page 65 (business model, value chain, workforce table).

Commerzbank AG's business model splits into Private and Small-Business Customers (Commerzbank and comdirect brands) and Corporate Clients, present in 40+ countries. Subsidiaries include Commerz Real AG (leasing, real estate/renewable-energy/infrastructure funds including hausInvest and klimaVest) and Polish subsidiary mBank S.A.

The Centre of Competence Green Infrastructure Finance finances "renewable energies, energy efficiency and green mobility." Group headcount by geography: Continental Europe (incl. UK) 39,333 (2024: 38,862), Asia 1,195 (1,108), America 284 (263); total 40,812 (2024: 40,233).

Reference: page 66.

Commerzbank's "Momentum" strategy "puts customers, investors and employees at the forefront." Stakeholder groups engaged include employees, customers, the capital market, suppliers/service providers, the media, NGOs, politicians, civil society, academics, and regulatory/supervisory authorities.

As part of the materiality assessment, "stakeholders were surveyed both on the disclosure requirements specified by the ESRS as well as on entity-specific topics," working with relevant departments "to identify possible disclosures and sustainability topics relevant to the business model that are not covered by the ESRS or are not covered in sufficient detail," defined as entity-specific disclosures (ESDs, e.g. sustainable finance, data protection, anti-money laundering, tax transparency).

Reference: pages 71-72, with the full IRO table at pages 79-84.

Double materiality (inside-out impact / outside-in financial) was applied Group-wide, including upstream/downstream value chain and non-consolidated companies. "The materiality assessment conducted in 2025 once again identified material impacts, risks and opportunities that are of crucial importance to our business model and operating activities... These affect our banking operations and extend in particular to our banking business in the downstream value chain."

Material environmental impacts sit in financing activities (climate change, biodiversity); social impacts touch employees and customers; governance impacts touch employees and customers. Versus 2024, "only the topic of energy from the perspective of the banking business has been added as a new topic." A tabulated IRO list (Topic / Perspective / IRO type / Actual-Potential) runs environmental, social and governance topics across pages 79-84; see iro.json for the derived counts.

Reference: page 69 (general process); topic processes at pages 69-71.

The materiality assessment "covers the entire Group, including all companies included in the financial statements," plus upstream/downstream value chain activities and non-consolidated companies with potential material impact. The process: define scope of consolidation, value chain and core activities; identify potential IROs against ESRS AR 16 and entity-specific aspects; assign at least one positive/negative impact and one opportunity/risk per topic; consolidate from both a business-department and a risk-management/risk-materiality perspective.

Topical processes (E1-E5, G1 IRO-1, pages 69-71) largely reuse the WWF Biodiversity Risk Filter and the environmental-risk materiality assessment; E2, E3 and E5 concluded no material risk, negative impact or dependency for Commerzbank's direct operations. G1 IRO-1 covers human rights/supply-chain due diligence, whistleblower protection, corruption/bribery and anti-money-laundering/terrorist-financing dimensions.

Reference: pages 90-92 (the "Covered disclosure requirements" table).

Commerzbank publishes an explicit ESRS content index: "The table below contains an overview of all the disclosure requirements and datapoints that derive from the ESRS, cross-referencing the corresponding sections in this report," built from ESRS 1 AR 16's topic list "expanded... to include entity-specific aspects." It lists general-information DRs (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3 and topical SBM-3/IRO-1 variants), then covered DRs under Environmental disclosures (EU Taxonomy, E1-1 to E1-4, E1-6, E1-7, E4-1 to E4-4, E4-6, plus the entity-specific sustainable-finance disclosure), Social disclosures (S1-1 to S1-6, S1-8 to S1-10, S1-12 to S1-17, S4-1 to S4-5, plus entity-specific data protection) and Governance disclosures (G1-1, G1-3, G1-4, plus entity-specific money-laundering and tax-transparency disclosures).

E1-9 carries the comment that it "were not reported as at 31 December 2025 in accordance with the relief provided for phased-in disclosure requirements." This index is the basis for every "reported"/"not_material" classification in this file.

Reference: pages 96-98.

Commerzbank targets net zero in its loan and investment portfolio by 2050 and net zero in banking operations (Scope 1+2) by as early as 2040, SBTi-aligned to limit warming to 1.5C or well below 2C. The plan "covers the banking operations (Scope 1 and Scope 2) and the loan and investment portfolio (Scope 3.15... 'owned financed emissions') of Commerzbank AG"; subsidiary mBank published its own transition plan in 2025.

"The climate transition plan was approved by the Board of Managing Directors on 13 January 2026. The Supervisory Board took note of this on 9 February 2026." In 2025 Commerzbank AG's own Scope 1+2 emissions fell 3,904 tCO2eq while financed emissions rose 13.5 MtCO2eq, "primarily due to the use of publicly available company data instead of proxy data" and portfolio growth.

Reference: pages 98-101.

The ESG framework's environmental pillar sets three targets: net zero loan/investment portfolio by 2050, a sustainable loan ratio of at least 10% by 2040, and net zero banking-operations Scope 1+2 by 2040, benchmarked to the SBTi, GHG Protocol, PCAF (2022) and ISO 14001/50001; audited annually (ISS-Corporate, 2025).

The fossil fuel guideline sets exclusion criteria for coal (phase-out "no later than 2038"), oil (no new oil-transport-project financing, including pipelines and tankers) and gas. Commerzbank's own environmental/energy management is ISO 14001/50001 certified since 2009/2015. On locked-in emissions: "Commerzbank considers the risk of locked-in GHG emissions to be immaterial or not applicable," citing short average loan maturities (~5 years) and portfolio diversification.

Reference: pages 101-103.

Own-operations actions in 2025: transitioning to renewable/green electricity and district heating (~4,700 tCO2eq reduction since 2024, further ~600 tCO2eq expected by 2030); energy-efficiency optimisation (~100 tCO2eq reduced); optimising use of space (~700 tCO2eq reduced, further ~900 by 2030). "Implementing the described actions is dependent on financial resources, which are incorporated into financial planning."

The larger lever is financed emissions: portfolio steering via the ESG Vote process in Corporate Clients (transformation-pathway checks against SBTi targets), an energy-linked pricing component for residential mortgages, and interest-rate discounts for energy-efficient/low-carbon commercial real estate. "The CapEx and OpEx indicators are not suitable for the banking sector... which is why we do not report the KPIs related to CapEx and OpEx."

Back-filled from ESRS 2 SBM-3 (pages 73-74) and E1 IRO-1 (page 69), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The 2025 climate-risk materiality assessment classified both physical and transition risks by time horizon (short <=1yr, medium 1-5yr, long >5yr, at least 10yr considered) using NGFS scenarios: NGFS Net Zero 2050 ("net zero by 2050... limit global warming to below 1.5C"), NGFS Current Policies (no new regulation, ~3.0C warming, "significant physical risks") and NGFS Fragmented World. Credit risk (incl. counterparty) was material for physical AND transition risk in medium/long term, "with the manufacturing sector and the energy sector being among the most affected"; operational, reputational, business and liquidity risk were material for transition risk across all horizons. Scope covers the Commerzbank Group; assessment carried out during the 2025 annual materiality assessment.

Back-filled from ESRS 2 SBM-3 and E1 SBM-3 (pages 73-74, 86), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Commerzbank runs an "annual internal climate risk stress test," with the 2025 exercise focused on "short- and medium-term climate-related physical risks resulting from extreme weather events, the advancing climate crisis and insufficient political action." Results: "The stress tests conducted so far have showed controllable impacts on Commerzbank's risk profile, with Commerzbank's risk-bearing capacity remaining above the underlying regulatory minimum requirements at all times, even in the stress scenario."

Limitations are stated explicitly: "It is not certain that any of the selected scenarios will occur and also possible that scenarios that have not been analysed will occur." Findings feed ICAAP capital allocation and the credit-risk traffic-light system used in individual lending decisions.

Reference: pages 103-104, 108-111.

Banking operations: SBTi-validated target of 42% reduction in Scope 1+2 (market-based) by 2030 vs. a 2021 base year (38,507 tCO2eq base; 22,334 tCO2eq 2030 target); 2025 achieved a 47% reduction (2024: 37%), "validated by the SBTi as scientifically sound... in line with limiting global warming to 1.5C." A climate-neutral supplier sub-target reported last year "was suspended in 2025 as this target is currently being revised."

Portfolio (Scope 3.15): net zero by 2050, using the Sectoral Decarbonization Approach for eight carbon-intensive sectors (energy, aviation, automotive, commercial/residential real estate, cement, iron and steel) and the Temperature Rating Approach for the remaining book (~70% corporate loans, ~30% institutional investments), most aligned to 1.5C or 1.8C (automotive), three sectors moved to more balanced "steering targets" for 2030 given slower sector-wide decarbonisation.

Reference: pages 111-112.

Commerzbank uses the VfU standard (aligned with the GHG Protocol, CDP, GRI), EcoInvent emission factors supplemented by IEA country factors, and distinguishes Scope 1, location- and market-based Scope 2, and voluntarily disclosed selected Scope 3 categories (paper/water, waste, fuel-and-energy-related activities, business travel, commuting/home office).

Reporting-year figures versus the prior year: Scope 1 15,576 tCO2e (-12%); location-based Scope 2 67,529 tCO2e (-8%); market-based Scope 2 12,014 tCO2e (-16%). Financed emissions (Scope 3.15) are the dominant category and are covered in detail under E1-1/E1-4. German consumption data and calculated CO2eq figures are externally verified by DQS GmbH. Commerzbank also separately publishes financed-emissions coverage of its climate transition plan by scope.

Reference: pages 122-123.

"We do not remove or store any greenhouse gases in our own operations or in the upstream and downstream value chain." Commerzbank instead offsets residual emissions from banking operations and selected Scope 3 categories by purchasing and retiring carbon credits, following the principle "Avoid and reduce before offsetting," separate from its GHG reduction targets.

In 2025 Commerzbank offset 66,393 tCO2eq (2024: 96,934 tCO2eq), of which 75% via emission-reduction projects (e.g. Kuamut Rainforests Conservation Project, Malaysia; Turning Farm Waste to Climate Action, India) and 25% via avoidance projects (Reducing Gas Leakages, Bangladesh; CTL Landfill Gas Project, Brazil). All credits meet Verra Verified Carbon Standard, Gold Standard or Plan Vivo, screened against the Core Carbon Principles framework, with a stated focus on Global South project countries.

Reference: page 123.

"Commerzbank wants to play an active role in protecting biodiversity and ecosystems," with policies, actions and targets set out at E4-2 to E4-4, but "Commerzbank does not currently have a comprehensive transition plan in place on this topic. This is mainly due to the fact that the methodological basis and data availability needed to draw up such a transition plan fall short of requirements. Commerzbank is actively working to solve these challenges."

The company states "it is currently not possible to quantify any financial effects due to a lack of available data," while noting it "underpin[s] the resilience of our business model by integrating ESG risks into our capital management." Biodiversity is integrated into strategy analogously to climate (cross-referenced to SBM-3 and IRO-1), with an annual biodiversity-risk materiality assessment feeding the business and risk strategies.

Reference: pages 123-125.

Positions and exclusion criteria sit in the ESG framework: a deforestation position requiring corporate clients in forestry, soy, palm oil and cattle-farming sectors in high-risk regions (Forest 500 list; Amazon-basin countries for beef/soy) to hold recognised memberships/certifications (RSPO, RTRS, GRSB, FSC, PEFC) "by no later than end-2025"; a mining position excluding mountaintop-removal mining worldwide; and, "since December 2025," an exclusion of deep-sea mining financing and related business relationships (screened via the "DSM Company Map").

mBank runs its own position on reputationally sensitive industries and high-conservation-value areas. Commerz Real AG expanded its ESG framework to biodiversity in 2025, targeting binding standards by 2030.

Reference: pages 125-126.

Actions include applying the E4-2 positions/exclusion criteria to lending and asset management (excluding direct investments where UN Global Compact violations on biodiversity/water protection are found); joining the Equator Principles in April 2025 (monitored by the Equator Principles Office, Corporate Clients segment); committing to the TNFD since 2023 and publishing Commerzbank's "first independent Nature and Climate Report aligned with the TNFD" in 2025; and membership of Biodiversity in Good Company (since 2022), VfU and the Sustainable Finance Cluster.

"It is currently not possible to quantify the resources that Commerzbank spends on biodiversity and ecosystems, as these are essentially opportunity costs." No biodiversity-offsetting measures are implemented. Commerz Real AG ran its first portfolio impact/dependency/risk/opportunity analysis in 2025.

Reference: pages 126-127.

The concrete target under the deforestation position: all corporate clients in forestry, soy, palm oil and beef sectors in high-deforestation-risk regions "must demonstrate their commitment to combating deforestation by no later than end-2025," evidenced by recognised memberships/certifications (RSPO, RTRS, GRSB, FSC, PEFC); "these commitments of Commerzbank AG do not have a time limit."

Progress reported under E4-6: when the position was published in early 2024, 15% of relevant existing customers had not met the requirement; by end-2024 this fell to 5%; "by the end of 2025, only one corporate client had failed to fully meet the requirements," with Commerzbank continuing dialogue and withholding new business with that client until requirements are met.

Reference: page 128.

"For the purpose of analysing the relevance of biodiversity risks for our portfolio and the resilience of our business model, as part of our risk inventory each year we conduct a materiality assessment for biodiversity risks and also an impact assessment." Using ENCORE and the WWF Biodiversity Risk Filter, Commerzbank defined the lending volume relevant for biodiversity risk at 34% of the overall portfolio, covering long-term physical and transition risks (analysis as at 31 December 2024; 2025-added subsidiaries such as Aquila Capital Investmentgesellschaft not yet included).

Progress against the E4-4 deforestation target: from 15% of relevant customers non-compliant in early 2024, down to 5% by end-2024, to "only one corporate client" by end-2025. No quantified biodiversity-related financial effects figure is given.

Reference: pages 131-132.

The Commerzbank Group employed 40,812 colleagues worldwide (2024: 40,233) from over 120 nations. Policies include the Code of Conduct ("Yellow Compass"), Diversity & Inclusion Standards, a human-rights position and policy statement under the German Supply Chain Due Diligence Act (LkSG, applicable since January 2023), and adherence to ILO core labour standards and OECD Multinational Enterprise Guidelines.

"We do not tolerate discrimination at Commerzbank," covering gender, nationality, ethnicity, religion, disability, age, sexual orientation and gender identity; the Group operates "a zero-tolerance policy" enforced through labour-law measures and reporting channels including the whistleblowing tool.

Reference: pages 132-133.

Engagement runs through the Central Works Council, Group Works Council and the Senior Staff Spokesmen's Committee, plus employee representation on the Supervisory Board. "An employee survey is conducted regularly for this purpose, at least once a year," feeding the S1-5 Employee Engagement Index and the G1-1 Culture Award.

Seven employee networks support vulnerable/marginalised groups: ARCO (LGBTQ+), Fokus Väter (parenthood/career), Pflege (care), IDEAL (disabilities), Ichthys (Christian network), COURAGE (advancement of women) and CrossCulture (intercultural/social background). Works-council members can also raise "vulnerable groups" interests under the LkSG process, and the Global Whistleblowing Policy underpins reporting-channel protections.

Reference: pages 133-134.

Reporting channels: direct escalation to a supervisor/manager, Human Resources, the works council (statutory co-determination rights), and the whistleblowing tool; suspected criminal offences or serious duty breaches trigger investigation by a specialised Compliance unit under the corresponding Group Works Agreement.

Whistleblowing training is embedded in the mandatory annual "Compliance compact" course (also covering fraud, anti-bribery/corruption and markets compliance) and in "LkSG: Respect for human rights and environmental protection" training, answering "Who can provide information?", "What can be reported?", "What reporting channels are available?" and "How are reports dealt with?" KPIs on reporting-channel usage are tracked to gauge trust in the system (see S1-17).

Reference: page 134.

Actions are set through the annual Group strategy process, discussed with the Board of Managing Directors and Supervisory Board (works-council co-determination applies where relevant). "The 'Momentum' strategy continues to focus on improving employee satisfaction," with resources "earmark[ed]... as part of its annual financial planning" and quarterly implementation reviews to the Board.

A Human Rights Officer under the LkSG monitors human-rights and environmental risk management and "reports directly to the Chief Risk Officer." Detailed actions per sub-topic are set out under S1-8 to S1-16 (collective bargaining, diversity, wages, training, health, work-life balance, remuneration).

Reference: page 135.

Employee satisfaction is one of Commerzbank's "three core strategic steering elements," alongside customer satisfaction and financial results. The Employee Engagement Index (EEI), collected annually since 2024 across four items (work satisfaction, pride, motivation, willingness to recommend as an employer), scored 76 in 2025 (2024: 75), "surpass[ing] the independent RACER benchmark" (a benchmarking group covering 2m+ employees across 70+ countries).

The Board of Managing Directors' 2025 target was to maintain or improve the 2024 EEI level; the index feeds variable remuneration for the Board and management levels 1-2.

Reference: pages 135-137.

Year-end 2025 headcount 40,812 (2024: 40,233); Germany 20,842 (2024: 21,108). By gender: female 21,298 (52%), male 19,513 (48%), diverse 1. By country: Germany 25,299, Poland 10,878. Permanent employees 38,471; temporary 2,341. Fluctuation (terminations, resignations, severance, retirement, death vs. average headcount): 6.1% (2024: 6.4%), with 2,442 departures (2024: 2,568).

Headcount is measured at period-end, differing from the annual-financial-statements average-employee figure, which is explicitly reconciled in the disclosure.

Reference: pages 137-139.

Group-wide, 24.0% of the workforce is covered by a collective bargaining agreement (2024: 25.3%); in Germany 36.8% (2024: 38.3%); "no collective bargaining committee has been formed at the Polish sites to date." Germany applies the private-banking-industry collective agreement (AGV Banken membership) plus in-house agreements on Saturday work, location guarantee and ComTS conditions.

Employee representation at the workplace (EEA): Poland 90.3% (2024: 91.4%), Germany 95.9% (2024: 96.4%). The Group Works Council performs a European-works-council role under an EC-Directive agreement for member states with 150+ Group employees. Commerzbank states there are "currently no policies... within the meaning of the ESRS" for collective bargaining coverage itself, relying instead on continuous union dialogue.

Reference: pages 139-141.

Diversity governance sits with the Global Diversity Council (GDC), chaired by the Board Member for Human Resources, implementing Diversity & Inclusion Standards. Target: 40% of Commerzbank AG management positions held by women by end-2030 (currently ~37% across all levels); a separate target of at least 25% women in the first/second management levels below the Board by end-2026 (2025: 24.4%, up from 22.0% in 2024; 96 women in top management vs. 87 in 2024).

Commerzbank ranked first in the Financial Times/Statista Europe Diversity Leader 2026 Banking & Financial Institutions category (up 8 places) and 12th cross-industry (up 34 places). Age distribution 2025: under-30 13.6%, 30-50 53.4%, over-50 32.9%.

Reference: page 141.

"Commerzbank is committed to fair and living wages for all employees, in line with the principle of equal pay for equal work," including "adequate and on-time remuneration that enables employees to sustain their livelihoods." A quantitative analysis compared each country's lowest paid wage against statutory minimum wage and relevant national/international/sector reference standards.

In Germany, pay-scale employee salaries are set via the collective wage agreement for the private banking industry, "higher than the statutory minimum wage," and non-pay-scale employee conditions are "at least equivalent to the collective bargaining conditions as a whole."

Reference: pages 141-143.

Proportion of employees with disabilities: Commerzbank Group 3.8% (2024: 3.8%); Commerzbank AG Germany 5.6% (2024: 5.5%), above Germany's statutory 5% quota (measured group-wide except the USA, for legal reasons).

Commerzbank was "the first bank in Germany" to publish a voluntary inclusion action plan (2016's "Gemeinsam verschieden"), updated in 2023 to "Inclusion Action Plan 2.0 - Nachhaltig inklusiv" covering communication, workplace design, training, health management, structural parameters, accessibility and social commitment. "No significant operational expenditure or investment is required to implement the described actions." Commerzbank received the Inclusion Award in 2024.

Reference: pages 143-145.

Training runs through works agreements ("Lernzeit+," "Re- and Upskilling," Leadership Training, the cliX learning platform) plus voluntary offerings (Speexx Smart4All language training in five languages, sustainability training for customer-facing staff). The structured "Development dialogue" personnel-development process "was suspended for our employees at Commerzbank AG in Germany during the reporting year due to the numerous changes made to our organisational structure."

Metrics (methodology changed year-on-year): 25.4% of employees took part in regular development programmes in 2025 vs. a corrected 71.1% in 2024 (previously reported as 93.0%, a 21.9pp restatement). Average training hours per employee: 25.4 in 2025 (2024: 21.3).

Reference: pages 145-146; Appendix B table flags one datapoint phase-in relief.

Health management takes "a holistic approach that encompasses preventive measures, situational help as well as aftercare," including the Employee Assistance Programme (24/7 confidential counselling for employees and household family members), the "Horizont" mental-health network, an addiction-support network, and 2025's "Mental Health Week" and "PINK October" breast-cancer-awareness programmes.

"In the area of 'Mental health,' there are currently no targets within the meaning of the ESRS. Due to the sensitive nature and confidentiality of health-related data, these data are neither measured nor set as targets." The Appendix B cross-reference table separately flags the fatality/accident-rate datapoint "Material, not applicable as at 31 December 2025" and the days-lost datapoint "Material, not reported... in accordance with the relief provided for phased-in disclosure requirements."

Reference: pages 146-148.

Work-life balance measures include the "Keep in Touch" parental-leave policy with a return guarantee, "Compatibility of caregiving and work" and "New caregiving modules" policies, job sharing and joint leadership models, hybrid/home-office working, and pme Familienservice childcare/emergency-care services. Commerzbank was recertified under the "Work and Family Audit" in 2025.

Entitlement to family-related leave: 96.4% of employees (2024: 98.7%); take-up among those entitled: 16.3% (2024: 16.1%), by gender female 20.6% (2024: 19.6%), male 11.7% (2024: 12.2%). "There are currently no targets within the meaning of the ESRS" for this topic.

Reference: pages 148-150.

Group unadjusted gender pay gap (average gross hourly wage, male vs. female): 30.2% (2024: 30.5%). Commerzbank AG in Germany: 20.5% (2024: 21.1%), "below the average for the financial sector in Germany, which for purposes of comparison was 25% in 2025" (Federal Statistical Office). "It is not possible to directly derive actions for reducing the gender pay gap from this purely statistical data," attributed to structural/regional and career-choice factors.

CEO pay ratio: annual total remuneration of the highest-paid person is 40.1 times the median employee (2024: 50.8). "The Bank has not set a quantitative target with regard to the gender pay gap at the present time."

Reference: page 150.

Incidents of discrimination (including harassment) reported via the whistleblowing system and consequence-management disciplinary records: 5 in 2025 (2024: 9). Other workplace complaints filed through own-workforce concern channels: 3 (2024: 2). Complaints to OECD National Contact Points for multinational enterprises: 0.

"The 2025 reporting period did not see any significant fines or compensation for damages paid in connection with incidents of discrimination (including harassment)." Significant-fine data are sourced from Commerzbank's OpRisk loss database, capturing losses above EUR10,000.

Reference: pages 151-153.

S4 covers private customers of the Commerzbank and comdirect brands (plus Commerz Direktservice GmbH and Commerz Service-Center Intensive GmbH), structured into "Customer satisfaction and customer service" and "Product responsibility and accessibility." The Customer Barometer (KUBIX) policy measures loyalty via C-Sat and NPS; the "Governance regulations for banking products" policy embeds consumer interests into product design (BaFin Circular 08/2023 target-market/product-governance requirements); a creditworthiness-check directive protects against over-indebtedness (EU Mortgage Credit Directive, EBA LOAM Guideline); and a "Digital Accessibility at Commerzbank" policy applies the German Accessibility Act (BFSG) to digital banking services, e-commerce and self-service terminals.

Complaints-handling rules apply uniformly across Commerzbank AG and comdirect, supplemented by segment-specific procedural instructions.

Reference: page 153.

Commerzbank engages customers "through troubleshooting, idea development and conception to product design and development," using usability tests, qualitative interviews, design thinking and ideation workshops, and quantitative surveys via a dedicated UX studio. The comdirect brand additionally runs online communities where customers discuss products and contribute to development.

"No cases of non-compliance with the guiding principles were reported to the OECD National Contact Points during the reporting period." Human-rights treatment for this stakeholder group cross-references GOV-4.

Reference: pages 153-154.

Customers can raise concerns via email, a complaints form, telephone, letter mail, branch visits and the whistleblowing system, listed on the Group website. All complaints are logged in a central complaints register (see S4-4) and reported to the Segment Board, the full Board of Managing Directors, Sales Management, the BQM Committee, the Safeguarding Officer, Compliance, Audit and relevant IT/specialist departments.

"If a systematic error is identified in our product and service offering due to a large number of complaints received for a particular issue, the responsible specialist or IT department will be informed and instructed to determine and rectify the cause." Whistleblowing-channel anonymity is safeguarded to prevent reprisals.

Reference: pages 154-156.

Actions: the Quality Management Tool (QMT) processes complaints on a "first in, first out" basis via Commerz Direktservice GmbH; creditworthiness-check measures (minimum living-expense thresholds, forecasting of retirement/inflation/interest-rate changes) protect against over-indebtedness, "although the impact of the measure is not directly quantifiable"; and Digital Accessibility actions under the BFSG include contrast adjustment, screen-content scaling, closed captioning, image alt-text and voice output on self-service terminals via a "living style guide," with the Banking App "almost completely digitally accessible" while the web application's accessibility work is ongoing.

"None of the described actions require significant operating costs or capital expenditure. No material negative impacts were caused during the reporting year, so no remedial measures were necessary."

Reference: page 156.

Internal targets cover customer-satisfaction measurement and complaints-management quality, including maximum complaint-processing time. Customer satisfaction (via the proprietary KUBIX loyalty index) "is also factored into the remuneration of the Board of Managing Directors of Commerzbank AG," though KUBIX values and derived targets are not published externally "to avoid the figures being misinterpreted or incorrectly classified by third parties" given the index is proprietary.

"No time-bound or results-oriented targets as defined by ESRS were set in relation to the topics of product responsibility and accessibility."

Reference: pages 159-161.

Commerzbank's Code of Conduct, renamed in 2025 to "Yellow Compass," sets globally binding principles across three corporate values: Integrity ("attentive, trustworthy and reliable"), Performance ("courageous, ambitious and enthusiastic") and Responsibility ("sustainably, purposefully and entrepreneurially"). It extends to service providers and suppliers.

A Consequence Management Policy governs misconduct handling with "zero tolerance... in cases involving deliberate violations of laws, directives or the Code of Conduct," supported by a uniform reporting process, a decision board and an anonymised "evidence board." The "Culture Award" (65 nominations in 2025, first awarded 2023) and the 2025 "Culture of Integrity 2.0" initiative (including an "error culture toolbox") support corporate-culture goals; Commerzbank publishes an annual German Corporate Governance Code compliance declaration.

Reference: pages 163-165.

The Global Anti-Bribery and Corruption (ABC) Policy is updated at least annually and covers all functions under a three-lines-of-defence model, with specific guidance on gifts, invitations, donations, sponsorships and business-partner due diligence (continuous database screening for corruption-related entries). "No violations of anti-corruption and anti-bribery regulations were reported during the reporting period."

All compliance-relevant employees complete mandatory annual web-based ABC training (targeting 100% completion), covering the UK Bribery Act and Wolfsberg ABC Guidance; the Supervisory Board and Board of Managing Directors receive dedicated training from the Chief Compliance Officer. A separate internal-investigations unit, independent of the management chain, handles suspected serious breaches, reporting regularly to the Board of Managing Directors and the Audit Committee.

Back-filled from the G1 business conduct chapter (page 166), where this content is disclosed in the FY2025 report as "Targets and monitoring corruption prevention." This disclosure requirement did not exist as a standalone 2023-ESRS code (it fell under MDR-T in the 2023 ESRS); the report was prepared under the 2023 ESRS.

"Commerzbank's overarching goal is to actively combat bribery and other forms of corruption and to completely prevent incidents of corruption within the Group." The stated, measurable target is 100% completion of mandatory anti-corruption/anti-bribery training for employees in high-risk, compliance-relevant functions, achieved in both 2025 and 2024. "The 100% training rate target is directly related to the policy on preventing bribery and corruption, with target achievement reviewed annually," monitored via ongoing training-programme evaluation and target-group analysis by Group Compliance.

Reference: pages 165-166.

"As in previous years, Commerzbank is not aware of any convictions or fines related to violations of corruption and bribery laws during the reporting period" - 0 convictions and EUR0 in fines in both 2025 and 2024. "Since no violations of corruption and bribery regulations were reported during the reporting period, no actions were required."

Training-coverage metric: 100% of employees in high-risk functions covered by anti-corruption/anti-bribery training in 2025 (2024: 100%), determined from the total ABC-training target-group classification. Consequence management for any future violations sits with the responsible manager and HR under the same Code of Conduct process described at G1-1.