Cooperatieve Rabobank Ua

Reference: page 73.

Rabobank's sustainability governance runs through the Supervisory Board, Managing Board, the Sustainability Implementation Management Team (IMT) and the Risk Management Committee Group (RMC Group).

The Supervisory Board supervises and advises the Managing Board on sustainability strategy, including alignment with Rabobank's purpose, and is supported by SB committees such as the Cooperative and Sustainability Committee.

The Managing Board is "responsible for setting and implementing the bank's corporate strategy, including business, risk and sustainability strategies" and for "adequately embedding sustainability impacts, risks, opportunities and dependencies within the corporate strategy."

The IMT, chaired by the Chief Sustainability Officer (CSO) who reports to the Chair of the Managing Board, consists of sustainability leads from key domains and "ensures the implementation of Rabobank's sustainability vision, ambitions, strategy, roadmap, regulations and commitments." The RMC Group, chaired by the Chief Risk Officer, oversees the bank's Risk Appetite Statement including ESG stress-testing integration. Business unit management teams implement strategy within their units via sector x region plans.

Reference: page 74.

"Supervisory Board members gain knowledge and expertise with regard to sustainability topics via several permanent education sessions. During 2025, 3 out of 7 permanent education sessions were focused on sustainability." Managing Board members regularly attend these sessions, which align "largely with the impacts, risks and opportunities that result from the double materiality assessment."

Managing Board members "have direct access to relevant sustainability expertise within their domains" and are "informed and consulted on the most relevant sustainability topics through the IMT and RMC." Sustainability reporting, the double materiality assessment (DMA) and other material topics are recurring agenda items on the Managing Board's rolling agenda.

Reference: page 74.

"The remuneration of the Managing Board and Supervisory Board is limited to fixed pay; members are not eligible for variable compensation as part of their regular remuneration package." Further detail is incorporated by reference to the Remuneration section of the Corporate Governance chapter of the Annual Report.

Unlike companies that link executive variable pay to ESG KPIs, Rabobank's disclosure here is a statement of non-applicability: fixed-pay-only remuneration structurally removes the need for a sustainability-linked incentive mechanism at MB/SB level.

Reference: page 74, with the core-elements mapping incorporated by reference to Appendix 1: Methodology & Definitions Sustainability Statements.

"Rabobank's Statement on Due Diligence is presented in Appendix 1: Methodology & Definitions Sustainability Statements." Appendix 1 maps the five core due diligence elements to specific sections: (1) embedding due diligence in governance/strategy maps to Governance, Strategy and Material Impacts sections; (2) engaging with affected stakeholders maps to Interests and Views of Stakeholders and the IRO identification process; (3) identifying and assessing adverse impacts maps to the same Material Impacts/IRO-1 sections; (4) taking action maps to the topical "Actions and resources" sections across climate, pollution, water, land use and the own-workforce/value-chain-worker "Taking action" sections; (5) tracking effectiveness maps to the corresponding "Targets" and "Metrics and targets" sections across those same topics.

Reference: page 74.

"When preparing information for the Sustainability Statements, data quality reviews are performed, plausibility checks are executed and where possible alignment with external data is ensured. The Sustainability Statements are submitted to internal experts for review and are approved by senior management (including the Managing Board, the Audit Committee of the Supervisory Board and the full Supervisory Board) prior to publication." This is "to mitigate the risks of material misstatement." Information is also provided to the external auditor to support its limited assurance engagement.

Rabobank notes: "Since sustainability reporting is still developing, we are also still developing and improving our risk management and internal control procedures with regard to the Sustainability Statements."

Reference: pages 75-79.

Sustainability is embedded in a six-step strategic steering cycle (strategy/policy/governance; outlook and materiality; sustainability impact and risk assessment; sector x region plans; Medium-Term Plan and Risk Appetite Statement; monitoring and reporting), connecting material topics to "planning and portfolio steering across Rabobank."

As a cooperative bank, Rabobank's business model and value chain run through its lending and financial-services relationships: large Dutch residential-mortgage and Food & Agri (F&A) lending books, with international activity concentrated in F&A across North and South America, Europe, Australia and New Zealand (commodities, animal protein, dairy, fresh produce prominent within the portfolio).

Sustainable finance volumes grew to EUR 63,857 million at year-end 2025 (YE2024: EUR 48,453 million), spanning Project Finance, RVO Green Loans, Sustainable Mortgages (Rabobank/Obvion), Sustainability-linked Loans, LMA Green Loans and DLL Sustainable assets. Sustainable funding (green/social/sustainability bonds and deposits) is reported separately. The company also reports an ambition, now EUR 83 billion (raised from EUR 75 billion to reflect DLL Sustainable Finance coming into scope), described as "best effort and dependent on among others data availability, sustainable asset availability and market- and regulatory developments."

Reference: pages 77-78.

Rabobank distinguishes direct stakeholders (customers, members, investors, employees) from indirect stakeholders (NGOs, public service bodies, communities, governing and supervisory bodies, other banks, media, regulators).

Engagement methods include "appreciative inquiry dialogue," member/client councils, customer feedback platforms, surveys, and Managing Board members meeting directly with "customers, members, employees, politicians, NGOs and other stakeholders." As a cooperative, "member involvement is crucial": members vote on the cooperative dividend and influence strategy through the General Members' Council, with value creation for members tracked via a member engagement score. Employee engagement is tracked quarterly; the company states a belief that "there is a strong link between employee well-being and customer satisfaction."

Reference: pages 79-80, with topic-specific interaction described throughout the topical ESRS chapters (e.g. pages 91, 116-117, 118-119, 120-123, 126, 132, 138, 147-148).

"This section outlines the sustainability-related impacts, risks, and opportunities. It provides an overview of how we identify, assess, and manage material topics." Rabobank identified 11 material sustainability topics in its 2025 DMA (2024: 12), after raising the materiality threshold to EUR 250 million (2024: EUR 240 million).

Three changes versus 2024 are flagged explicitly: Water (E3) "is no longer deemed material from a risk perspective" though it "remains material from a negative impact perspective"; Land use (E4) "is no longer deemed material from a positive impact nor an opportunity perspective" but "remains material from a negative impact and risk perspective"; and Information- and safety-related impacts for consumers (S4) gained a negative-impact materiality alongside the existing financial-risk materiality. Affordable housing was removed as an entity-specific topic.

Reference: pages 79-80, 90-92 (climate-specific process).

The Double Materiality Assessment (DMA) "evaluates financial and impact materiality" and consisted of three steps: (1) "Understanding our value chain and identifying our environmental, social and governance topics"; (2) "Assessment and determination of the material impacts, risks and opportunities"; (3) "Management response, including validation, approval and reporting." The DMA is executed within CRO Enterprise Risk with Group Sustainability and Finance, and the Group Risk Management Committee endorsed the outcome before Supervisory Board discussion and Managing Board approval.

For climate, Rabobank runs Credit Loss Scenario Analysis, Financed Emissions Scenario Analysis (projecting 2030/2040/2050 emissions) and a Climate Stress Test, using three NGFS scenarios (Net-Zero 2050, Fragmented World, Nationally Determined Contributions) and, for the 2025 stress test, the adverse NGFS scenario "Disaster and Policy Stagnation." Results "confirmed that our business model is resilient, while highlighting pockets of risk in certain sectors."

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025/2026 ESRS numbering).

Reference: pages 81-87 (General Information, Environmental Information, Social Information and Governance Information content-index tables).

Rabobank publishes a Disclosure Requirement (DR) content index across four parts of the Sustainability Statements (General, Environmental, Social, Governance Information), mapping each DR to the section that covers it, or to "Not material" or "Not disclosed considering the phased-in transitional provisions" where applicable.

"For the disclosure requirements complied with in preparing the Sustainability Statements, refer to the general, environmental, social and governance information sections, where the reference to paragraphs is made in a content index." The statement also incorporates several disclosures by reference to other parts of the Annual Report (e.g. GOV-1/GOV-3 to Corporate Governance, SBM-1 to Strategy, E1-4 to Appendix 7: Climate Target Setting, E1-6 customer-emissions datapoints to Appendix 6: Methodology Financed Emissions). Rabobank states: "We have not omitted any specific information" beyond the phase-in provisions it identifies, and confirms it applies the Appendix C of ESRS 1 phase-in reliefs plus the extended "quick-fix" timelines, and the EU Taxonomy simplification under the Delegated Regulation of 4 July 2025 is implicit in its basis of preparation.

Reference: pages 88-89.

"Rabobank remains committed to aligning its activities with 1.5ºC pathways by 2050 and to helping customers successfully navigate their transition to a sustainable pathway." Rabobank is "not excluded from the EU Paris-aligned benchmarks."

The plan is built on a four-step approach: (1) measuring financed emissions using the PCAF standard; (2) identifying science-based sectoral decarbonization pathways and setting targets for the most material sector x region combinations; (3) developing sector x region implementation plans (which also address physical-risk adaptation); (4) assessing effectiveness of actions.

A 2030 financed-emissions progress indicator, based on a 2024 like-for-like portfolio, estimates Scope 1&2 customer emissions of "approximately 29 MtCO2e" (about 16 Mt CO2 and 13 Mt non-CO2), down from a 2024 estimate of 32 MtCO2e "due to a combination of data improvements and the continuing decarbonization of our lending portfolio." Rabobank notes the Net-Zero Banking Alliance "ceased its operations in October 2025" but that its own obligations under the Dutch Financial Sector Climate Commitment and UN Principles for Responsible Banking continue.

Reference: page 93.

Three Global Standard on Sustainability Acceptance and Performance policies govern material climate impacts: the Climate Policy (sets acceptance requirements; requires in-scope customers reporting under CSRD to submit climate performance, and requires willingness to dialogue on alignment with a 1.5°C pathway or on measuring GHG emissions); the Energy Policy (acceptance requirements and performance monitoring at customer and activity level); and the Deforestation and Land Conversion Policy (cross-referenced to the land-use chapter).

"These group-wide policies apply to in scope customers and business partners whose activities have potential and actual material impacts on sustainability related matters," combining mandatory acceptance requirements with risk-based performance monitoring criteria.

Reference: pages 88, 96.

Actions split between financed and operational emissions. For financed emissions, Rabobank runs sector x region implementation plans for 19 prioritized combinations, covering "a significant majority of the financed emissions of our portfolio (61%)."

For operational emissions (voluntary disclosure, not deemed material under the DMA): key actions include aiming for "a 100% electric vehicle fleet" via leasing policy, and a business travel policy with a "digital-first approach" requiring "train travel on all Western European high-speed rail routes (under 600 km)." Benchmarking against CRREM, SBTi and IEA pathways underpins 2030 operational targets; the "Other" category (business travel by car, paper, commuting, fuel- and energy-related activities) has a target-setting process still under development.

Reference: Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 89-91). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Rabobank's resilience analysis "focused on long-term climate pathways developed by the Network for Greening the Financial System (NGFS)," assessing the business model against three scenarios: Net-Zero 2050, Fragmented World, and Nationally Determined Contributions (NDC). Two quantitative analyses supported the 2050 assessment: a Credit Loss Scenario Analysis (expected credit losses under each scenario) and a Financed Emissions Scenario Analysis (projecting financed emissions for 2030, 2040 and 2050).

In addition, a 2025 climate stress test applied the adverse NGFS scenario "Disaster and Policy Stagnation" alongside a baseline, covering short-to-medium-term (up to 5 years) impacts across the Rabobank Group with detailed assessments for rural sectors in Australia/New Zealand and the US. The report does not state the global average temperature projection associated with each named NGFS scenario.

Reference: Back-filled from ESRS 2 IRO-1 and SBM-3, where this content is disclosed in the FY2025 report (pages 90, 92). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The results confirmed that our business model is resilient, while highlighting pockets of risk in certain sectors that require targeted actions and adaptation measures. The results are included in sector x region plans and ICAAP, to support our transition commitments for 2030 and 2050."

On capacity to adapt, Rabobank states it "adopts an iterative approach. Choices need to be revisited as data guidance and methodologies advance," consistent with a "progressive pathway to impact." It explicitly states: "Consequently, to date we have not set adaptation-related (group level) targets," naming an area of ongoing development rather than a completed resilience metric.

Reference: pages 103-104.

Rabobank uses physical emissions-intensity targets rather than absolute targets for most of its portfolio, stating this "fit[s] the profile of a bank better" and is "in line with ESRS 1 Paragraph 33" -- with the exception of its Dutch F&A portfolio, which does carry an absolute target. Targets for 19 prioritized sector x region combinations are benchmarked against science-based 1.5°C-aligned pathways (IEA, SBTi, CRREM), with near-term (2030) and long-term (2050) goals.

For 2024 performance (most recent measured year), Rabobank "were able to calculate target performance measures for 14 of 19 sector x regions," and of those 14, "we consider 11 to be on-track towards their 2030 targets" (including Horticulture, Pig Farming, three Dairy regions, Beef Australia, Soy Brazil and three Energy/Power segments). For some US sector x regions Rabobank states it "no longer set[s] GHG emissions reductions targets... due to regulatory changes."

Reference: page 96 (operational emissions table); pages 88-89 and Appendix 6: Methodology Financed Emissions (financed/customer emissions).

"Rabobank's material impact is on the GHG emissions from our customers (Scope 3 emissions, category 13 and 15)." Financed-emissions figures (the PCAF-based "estimates on a best effort basis") are the primary E1-6 metric and are detailed per sector x region and per asset class/business unit in the Sustainability Statements and Appendix 6 (data quality score 3.6 for Scope 1&2 of the in-scope portfolio and 3.8 for Scope 3).

Operational GHG emissions (Scope 1, Scope 2, and select Scope 3 upstream categories: company facilities, datacenters, company vehicles, business air travel and "Other") are disclosed voluntarily: total operational emissions fell to 69,132 tCO2e in FY2025 from 73,711 tCO2e in FY2024 and an 83,177 tCO2e base year (2018), a 54% reduction against base year, equivalent to 1.5 tCO2e per FTE (FY2024: 1.4). "Considering the magnitude of the CO2e emissions from our operations, we do not consider this to be material for Rabobank."

Reference: pages 116-117.

For nitrogen in the Dutch Food & Agri sector, the policy "Beleid en Instructie Stikstof Veehouderij" (Policy and Instruction Nitrogen Livestock Farming, effective until November 10, 2025) governed financing applications in livestock sectors (cattle, calves, goats). From November 10, 2025, the policy "Nieuw Beleid en Instructie Natuurvergunningen" (New Policy and Instruction Nature permits) applies to livestock sectors and, where the investment goal is new construction or renovation, to all sectors with Natura 2000 area permit implications.

An Environmental Committee for Nitrogen (ECV), meeting weekly, ensures "uniform decision-making" on applications, based on "an analysis of the environmental impact and the financial stability of the applicant." At activity level, Rabobank does not accept financing or trade in products containing Persistent Organic Pollutants (Stockholm Convention) or Ozone Depleting Substances (Montreal Protocol).

Reference: page 117.

For the nitrogen sub-topic, Rabobank "established financing propositions with a budget of EUR 3 billion (available until 2030) to support farmers" transitioning via "extensive farming, innovation, relocation, conversion, or cessation." Financing supporting these transition pathways rose from EUR 452 million by year-end 2024 to EUR 1,206 million by year-end 2025, with 84% flowing to extensification, and innovation, relocation, and broadening the business model representing 9%, 1% and 6% respectively.

Rabobank also uses "various indicators linked to nitrogen (soil nitrogen surplus and ammonia (NH3) emissions) to benchmark customers" across the majority of Dutch dairy customers with financing above EUR 1 million.

Reference: page 117.

"At present, Rabobank has no time-bound and outcome-oriented targets and results in place for pollution. We are in the process of identifying suitable metrics." The company directs readers to the effort-targets table in the introduction to the Nature section for interim tracking of policy and action effectiveness. This is a stated absence of a formal target rather than an omission: Rabobank discloses the gap directly rather than remaining silent on it.

Reference: page 118.

The Nature Policy within the Global Standard on Sustainability Acceptance and Performance is "the main policy on the material impacts, risk and opportunities related to water." Under it, Rabobank "can collect supporting information of customers and business partners demonstrating that they 'are aware of the key environmental impacts at their production/operational sites, by having an environmental plan addressing these impacts, e.g., land use change, water, soil, agrochemicals, and pollution.'" The company states plainly: "no specific water-related acceptance requirements are included in the Nature Policy."

Rabobank also "will launch a bank-wide training on the topic of fresh water," covering water-related impacts, risks and opportunities, fully available from Q1 2026.

Reference: page 119.

In 2025 Rabobank launched its Water Vision 2030, supporting the EU Water Framework Directive and European Water Resilience Strategy, led by a dedicated Rabobank Water Team and supported by a "Water Squad." Cooperative initiatives currently allocate EUR 15 million directly and indirectly to water-related solutions (EUR 10 million via subsidiary BPD for grey-water systems; EUR 5 million via the Rabobank Water Team), with an aim to increase this.

Other actions include a knowledge partnership with Wetsus, the European Water Technology Institute, and support for the WaterBank, a Dutch cooperative initiative giving residual water "a second life."

Reference: page 119.

"At present, Rabobank has no time-bound and outcome-oriented targets and results in place for water." As with pollution, the company points readers to the nature-section effort-targets table for tracked progress on policies and actions in lieu of a formal quantified water target.

Reference: page 120.

"Land use is part of our overall nature approach which entails embedding nature into all our core banking processes and governance and progressively adapting our portfolio and policies toward alignment with the Global Biodiversity Framework 2030 targets." The first region-specific business (impact) strategy developed and being implemented is the Brazil land use strategy, "focused on accelerating the transition of the food and agricultural system towards a deforestation-free and land-use-change-free future," built on four pillars: improving data accuracy, incentivizing customers, supporting high-impact projects, and contributing to system transformation.

Ambitions align with the Kunming-Montreal Global Biodiversity Framework, "particularly Target 1 (Halting deforestation and land conversion), Target 2 (Restoring degraded ecosystems) and Target 3 (Avoiding impacts in protected and key biodiversity areas)."

Reference: pages 120-121.

The Nature Policy and Deforestation and Land Conversion Policy within the Global Standard on Sustainability Acceptance and Performance address land use. For prioritized deforestation/land-conversion sector x regions, Rabobank "do[es] not provide loans or finance for deforestation and land conversion purposes, even if legally authorized," and does not do business with upstream customers or business partners "whose lands have been illegally deforested or converted after January 1, 2018." In the Amazon biome specifically, Rabobank does not accept as new collateral land "deforested after January 1, 2018, even if done legally."

Sector-specific rules under the Arable Agriculture and Forestry policy require RSPO membership (No Deforestation, No Peat, No Exploitation) for upstream palm-oil customers and RTRS membership for soy customers in prioritized sector x regions.

Reference: pages 121-123.

Under the Brazil land-use strategy, actions include the Responsible Commodities Facility (RCF), developed with MFF, IDB, Agri3 and UK retailers, which for the 2025/26 season "will finance around 280 farms, producing 240,000 tons of soy and conserving around 90,000 hectares of native vegetation"; the Forest Code Acceleration Loan (loans up to 20 years for forest acquisition/reforestation); Ecoinvest, a BRL 350 million blended-finance structure backed by Brazil's National Fund on Climate Change; and the AGRI3 Fund (created with UNEP and FMO).

Impact investments include a share in Biomas (restoration/conservation of Brazilian forests, alongside Suzano, Marfrig, Santander, Itaú Unibanco and Vale) and a philanthropic partnership with the Black Jaguar Foundation, aiming to restore 1 million hectares and plant over 1.7 billion native trees along the Araguaia Corridor. In the Netherlands, the Open Soil Index and Biodiversity Monitor for Dairy and Arable Farming support customer-level biodiversity actions, including a pricing incentive for Dutch dairy frontrunners.

Reference: pages 122-123 (combined "Targets and impact metrics related to land use" section).

"At present, Rabobank has no time-bound and outcome-oriented targets and results in place for land use." Rabobank is instead "progressing towards land use related metrics," leveraging satellite imagery and polygon information on its rural customers' land, and monitoring project-specific metrics such as seedling counts and hectares under the Black Jaguar Foundation partnership.

Reference: pages 122-123 (combined "Targets and impact metrics related to land use" section).

Rabobank has "completed a first iteration of the assessment of our impact and dependency on nature, including land use," using a top-down, modelled nature-footprint analysis (the BioScope tool), which "indicates land use as the largest pressure on biodiversity loss" in its portfolio, "mostly driven by the sector's primary agricultural activities." Land use change/deforestation is assessed separately using other data sources and customer-level data, since it falls outside BioScope's scope, and is classified as material in the DMA.

Rabobank states it "has not incorporated local and indigenous knowledge into biodiversity and ecosystems-related actions" beyond the actions already disclosed, and "do[es] not apply biodiversity offsets."

Reference: page 127.

Relevant HR policies, published in the Rabobank Policy House Portal, include the Global Policy on Diversity, Equity and Inclusion (DE&I) (a general umbrella for global DE&I initiatives, under which regions/local banks create their own procedures -- "the policy does not distinguish targets or actions for specific groups or on specific grounds," with an exception for gender diversity given the Dutch 'Wet Diversiteit in de Top' statutory requirement); the Global Policy against Harassment (covers scope and resolution of harassment complaints, "elaborated and refined in local policies"); and the Global Policy on Remuneration (equal pay for equal work, detailed in the Corporate Governance Remuneration chapter).

The materiality finding underlying these policies is narrow: of the three People@Work pillars (inclusive environment, work-life balance, developing people), only "Inclusive Environment" has been identified as material; the other two, while still addressed, "have not been classified as material... either from a positive or negative perspective."

Reference: page 127.

Rabobank runs a quarterly Employee Engagement Scan, an external-company-processed survey on whether employees enjoy their work, feel energized, are proud to work at Rabobank, and feel they fit in. "In total, 31,615 employees provided feedback in the Engagement Score in Q4 2025 (31,585 employees in Q4 2024)." Every quarter, effectiveness is checked by asking employees whether "my team has taken action based on the results of the previous Engagement Scan," and managers are required to discuss the insights with their teams.

Engagement also runs through the Works Council, Employee Resource Groups (ERGs), Unions and Inclusion Agents, whose input "co-determines the actions and allocated resources."

Reference: page 128.

Rabobank updated its Diversity, Equity & Inclusion strategy around three areas: inclusive collaboration, equitable employee journeys, and "a targeted approach on diversity taking into account local and regional legislation." Concrete 2025 actions include International Diversity Day (lunches in the Netherlands, ten globally-broadcast short lectures watched live by over 1,000 employees), the "Break the Bias" e-learning module, and the Cultural Diversity Barometer, run with Statistics Netherlands (CBS) for Dutch-based employees to "gain insight into cultural diversity... and opens up the conversation on cultural diversity within management teams."

On compensation fairness, "equal pay analytics have been developed that will help to identify and address potential systemic and individual pay equity issues," alongside voluntary disclosure of the adjusted gender pay gap.

Reference: page 129.

"A target has been set for two subjects with respect to an inclusive environment. These targets concern gender diversity in top management and the engagement scan score." Internal monitoring metrics "capture the employee perspective, as reflected in the engagement surveys, alongside company data related to the pillars of an inclusive environment." The stated engagement-scan target is 80% (actual 88% in FY2025; 87% in FY2024).

Reference: pages 129-130.

Total headcount was 49,132 in FY2025 (FY2024: 51,908). The workforce is broken down by type of employment (permanent/temporary) and gender, and by employees who left the organization (by gender), with figures disclosed for both FY2025 and FY2024 for comparison. Further detail on employee characteristics is presented in the "Metrics of Our Own Workforce" tables referenced for S1-7 and S1-9.

Reference: page 129, "Metrics of Our Own Workforce."

Non-employee worker characteristics are disclosed alongside the employee headcount and diversity metrics in the own-workforce metrics tables (page 129), cross-referenced to Appendix 1: Methodology & Definitions Sustainability Statements for the applicable definitions and methodology.

Reference: page 129, "Our own workforce -- Gender diversity in senior management."

Gender diversity in senior management for FY2025 (with FY2024 comparatives) is tabulated by governance level: Supervisory Board 40% female / 60% male (FY2024: 37%/63%); Managing Board 33% female / 67% male (unchanged FY2024); MB-1 40% female / 60% male (FY2024: 40%/60%); MB-2 33% female / 67% male (FY2024: 33%/67%). The Dutch statutory 'Wet Diversiteit in de Top' requirement underlies this tracking and reporting.

Reference: pages 129-130.

"Rabobank updated the methodology used to calculate the gender pay gap by refining the estimate of variable pay... in line with ESRS S1-16." For FY2025, the unadjusted gender pay gap is 19.52% (FY2024 restated: 19.77%/19.82%*; 2023: *). The adjusted gender pay gap and remuneration ratio are also disclosed, alongside a remuneration ratio figure of 23.30% cited in the own-workforce metrics tables.

Because the methodology change affects comparability, "the gender pay gap reported for FY2024 and FY2023 is not fully comparable with figures reported for prior periods," and restated prior-period figures are shown alongside the current-year number, flagged with an asterisk.

Reference: page 128 ("Employee Voice").

Grievance-channel activity for FY2025 (with 2024 comparatives): the Industrial Relations Disputes Committee (Geschillencommissie Arbeidsverhoudingen) handled 13 formal appeals (2024: 6); the Social Plan Central Appeals Committee handled 14 formal appeals (2024: 3); the Objections Committee Executives handled 1 formal appeal (2024: 0); the Local Harassment Committee Netherlands handled 14 reports (2024: 8); and under the Global Policy on Whistleblowing, 13 new cases were reported regarding the Netherlands (2024: 41).

On severe human rights impacts specifically: "As there is currently no registration of the financial settlement of the cases, Rabobank cannot report on the fines, penalties, and compensation for severe human rights issues and incidents connected to our own workforce. We currently have no internal registration of severe human rights issues and incidents in connection with our own workforce in the Netherlands, given that such complaints are not received. Based on our current procedures and operating practices, we are not aware of any such incidents." This is a disclosed nil finding, not a refusal to report.

Reference: page 134.

In 2025, three policies governed material impacts on value chain workers and affected communities: the Human Rights Policy, the Labor Rights Policy, and the Land Governance Policy. These "rely on the norms and principles of international recognized instruments, such as our UNGP commitment and the OECD Guidelines for Multinational Enterprises," and "highlight[] that certain rights and freedoms may be specific to certain individuals, groups or communities... due to their higher risk of marginalization and vulnerability," naming indigenous peoples, human/environmental rights defenders, workers (including migrant and subcontracted workers), women and children.

A new, consolidated Human Rights policy replacing the three prior policies was approved in 2025 and implemented in January 2026, informed by the saliency assessment and applying human rights requirements "proportionally" by customer size, activity and geography, with strengthened remediation criteria for actual adverse impacts.

Reference: page 135.

Rabobank's "general process for engaging with these rightsholder groups is that we engage with credible proxies" (organizations representing potentially affected value chain workers), used in human rights impact assessments and strategic-focus-area development. A dedicated "People team" within Group Sustainability engages with credible proxies throughout the year, and Rabobank "actively engage[s] with credible proxies, for example, workers' organizations or representatives of human rights defenders" at the Annual UN Forum on Business and Human Rights in Geneva. Rabobank also encourages business customers to conduct their own stakeholder engagement, citing sector dialogues addressing labor exploitation in Dutch horticulture as an example.

Reference: page 135, cross-referenced to the grievance-mechanism landscape described in the Social Information introduction.

Remediation for value chain workers runs through the same "processes for engaging with value chain workers and affected communities about impacts" channel (credible proxies, sector dialogues) rather than a worker-facing grievance line operated directly by Rabobank, reflecting the bank's indirect relationship to value chain workers through its business customers.

Reference: pages 135-136.

Since 2024, Rabobank has run "a formal program of work with a dedicated team" on human rights. From eight global salient issues identified in the saliency assessment, three strategic focus areas were prioritized: labor exploitation, livelihood and lands, and social inclusion. For labor exploitation specifically, Rabobank cites risk drivers in the Dutch horticulture and animal-protein (including slaughterhouse) sectors -- "high labor intensity and highly seasonal-driven work" -- addressed through sector dialogues.

Under the new Human Rights policy, in 2025 "two customers were determined to be non-compliant with Rabobank's human rights and labor rights policy due to severe labor violations." One relationship remains under review pending court proceedings; the other "was... terminated in 2025."

Reference: pages 136-137.

"At present, Rabobank has no time-bound and outcome-oriented targets and results in place for adverse human rights impacts in relation to value chain workers or affected communities." Rabobank states it "will explore effort-based targets related to our strategic focus areas in 2026" as part of developing its People Approach, including indicators to measure whether its efforts "have a positive effect on the people most at risk from our activities and that of our customers and business partners."

Reference: page 134.

The same three 2025 policies governing value chain workers -- the Human Rights Policy, Labor Rights Policy and Land Governance Policy -- also cover affected communities, since Rabobank's IRO for communities arises through the same business-customer relationships (large-scale land use potentially exacerbating farmland shortages for local communities, and risks to human rights/environmental defenders). As with S2-1, these three policies were consolidated into a single Human Rights policy approved in 2025 and implemented in January 2026.

Reference: page 135.

Engagement with affected communities runs through the same credible-proxy mechanism used for value chain workers: the dedicated People team, sector dialogues (e.g. on labor exploitation and livelihood/land risks), and annual engagement at the UN Forum on Business and Human Rights, where Rabobank engages "workers' organizations or representatives of human rights defenders" connected to communities affected by its business customers' land use and operations.

Reference: page 135, cross-referenced to "Processes for engaging with value chain workers and affected communities about impacts."

As for value chain workers, remediation channels for affected communities operate through the same credible-proxy engagement process rather than a community-facing grievance line run directly by Rabobank, given the bank's indirect connection to communities through its business customers' land use and operations.

Reference: pages 135-136.

Actions addressing affected communities sit within the same three strategic focus areas as for value chain workers -- labor exploitation, livelihood and lands, and social inclusion -- given the overlapping rightsholder groups in Rabobank's food and agriculture financing (e.g. land-use and land-grab risks to local communities, and protection of human rights and environmental defenders). The Brazil land use strategy's community-facing elements (e.g. partnerships supporting land restoration and farmer livelihoods) also serve this disclosure.

Reference: pages 136-137.

As with value chain workers, "At present, Rabobank has no time-bound and outcome-oriented targets and results in place for adverse human rights impacts in relation to value chain workers or affected communities," with effort-based targets for the three strategic focus areas to be explored "in 2026."

Reference: page 140.

Social-inclusion-related policy sits in the Global Standard on Treating Clients Fairly ("putting the interest of our customers at the center of our decision-making, culture and behavior," addressing "accessibility and anti-discrimination considerations, financial education and strengthening the 'financial difficulties' guidance"), the Global Standard on Complaints Handling, and the Global Standard and Procedure on Product Governance.

For privacy, the Global Privacy Policy Framework -- anchored by the Global Policy on Privacy and Personal Data Protection -- governs GDPR and local data-protection compliance, "detailing principles for lawful, fair and transparent personal data processing" with "storage limitation," "data minimization, accuracy and data protection." The framework underwent "a regular update in 2025," aligned with Rabobank's Binding Corporate Rules and explicitly addressing personal-data processing with Artificial Intelligence and discrimination risk.

Reference: pages 140-141.

Rabobank engages consumers through Direct Engagement (surveys, focus groups, direct feedback mechanisms) and through Member Engagement via the Rabobank Members' Council, "an antenna in the local community," acting as a sounding board on topics such as non-discrimination and housing and care. Rabobank also engages Other Representative Bodies (local Supervisory Bodies, Client Council members) on financial education, sustainability and local social issues, and collaborates with public/private parties such as Stichting Financieel Gezond Nederland, Geldfit and Nibud on financial health.

Reference: page 142.

Consumers can file complaints via the "Help onze dienstverlening te verbeteren" webpage; unresolved complaints, or those unresolved within 8 weeks, can escalate externally to Kifid (the Dutch Institute for Complaints related to financial services). Discrimination complaints can additionally be raised via the national Discriminatie.nl portal or the Netherlands Institute for Human Rights; privacy complaints can be raised directly with the Data Protection Officer or externally with the Data Protection Authority or a competent court. Root-cause analysis of complaints feeds the product approval and review process, and complaints-handling effectiveness is monitored by the first and second line "at least annually," with independent Compliance reporting to the Managing Board.

Reference: page 142.

Under Financial Healthy Living, the "Hulp bij Geldzorgen" team proactively contacts customers showing signs of financial distress (e.g. "cash withdrawal on credit followed by deposits into daily banking accounts") and connects them to support. Geldfit, founded by the Dutch Debt Relief Route Foundation, helps individuals manage debt; in 2025 Rabobank developed "special support on fraud prevention... for customers who have been victim of dating/relationship fraud through messaging applications such as WhatsApp." Housing affordability is addressed via subsidiary BPD (residential development in the Netherlands and Germany), BPD Woningfonds, and Rabo SmartBuilds.

Reference: page 145.

Rabobank "plays a leading role in the Stichting Financieel Gezond Nederland (SFGN)," leading its social-debt-collection initiative across "approximately 40 participating organizations." Through Geldfit, Rabobank "referred more than 2,083 young people to Geldfit in 2025 (2,200 in 2024)" as part of a youth campaign. The Nibud Financial Health Check reached "218,503" users in 2025 (figure as printed). These function as effort/reach metrics tracking the social-inclusion target area in the absence of a single time-bound numeric target.

Reference: page 148.

"Rabobank is committed to upholding the highest standards of honesty and integrity in all global operations and business dealings," codified in the Rabo Compass Code of Conduct ("being customer-driven, cooperative, professional, and taking responsibility"). The Global Policy on Financial Crime Compliance (FCC), with underlying Global Standards, "forms the foundation of our FEC framework," covering money laundering, terrorist financing, sanctions breaches, and bribery and corruption, and is "mandatory for all staff."

In 2025, Rabobank updated the Global Standard on Anti-Bribery & Corruption (broadening scope from Business Partner Risk to a wider Third-Party Risk, reinforcing a risk-based approach to Public Officials) and the Global Standard on Sanctions. The AML/CTF Standard is scheduled for update by 2027 to align with the EU's forthcoming Anti-Money Laundering Regulation and Sixth Anti-Money Laundering Directive.

Reference: pages 148-149.

Controls span a risk and control framework (internal control framework; screening, customer due diligence at onboarding and throughout the relationship, transaction monitoring; monitoring of control effectiveness; management of findings, incidents, actions and remediation) and annual FEC risk assessments feeding the global Systemic Integrity Risk Analysis (SIRA).

Training: all new employees complete the "RiskWise Fundamentals" onboarding program (covering fraud, privacy, security, anti-bribery and corruption); a mandatory role-based FEC training program is assigned to 61.1% of employees (2024: 61%), with employees expected to complete modules "within 90 days," monitored for completion; Managing Board members complete the online FEC program and receive classroom education.

Whistleblowing: the Global Policy on Whistleblowing (GPW) allows reports to management, a compliance officer, or anonymously via the SpeakUp Platform/Hotline; reports are logged in a dedicated Case Management System, a Whistleblowing Representative stays in contact with reporters, and a Whistleblowing Committee (WBC) of executive managers oversees all GPW reports, which also cover suspected internal fraud including bribery and corruption.

Reference: pages 148-149 (part of MDR-T/GDR-T disclosures).

Rabobank does not state a numeric, time-bound target for business conduct/financial economic crime. Instead, effectiveness of its policies is tracked through: annual FEC risk assessments (plus event-triggered additional assessments) across all regions, business lines and subsidiaries, feeding the global Systemic Integrity Risk Analysis (SIRA) "to inform the formulation of a group-wide risk profile"; active monitoring of mandatory FEC training completion (61.1% of employees assigned the role-based program, completion tracked against a 90-day deadline); and periodic review and update of relevant Global Standards (the Anti-Bribery & Corruption and Sanctions Standards were both updated in 2025, with AML/CTF scheduled for 2027). This matches the MDR-T alternative limb -- tracking effectiveness of policies in the absence of a stated numeric target -- under a 2023-ESRS report where G1-3 (targets) did not yet exist as a standalone numbered requirement.

Reference: page 149.

"Total number of convictions and the amount of fines for violation of anti-corruption and anti-bribery laws during the reporting period is (0). As there were no convictions within the reporting period, no actions were required." This is a disclosed nil return for FY2025, not a gap in reporting.