CriteriaCaixa

The role of the administrative, management and supervisory bodies

Reference: page 7.

CriteriaCaixa's Board of Directors is "the Group's highest decision-making and supervisory body," supported by four delegated committees: the Executive Committee, the Audit and Control Committee, the Appointments and Remuneration Committee and the Sustainability Committee.

As at 31 December 2025 the Board had 14 members, 10 men (71.4%) and 4 women (28.6%), with one vacancy. No director has executive status. For most of 2025, 43.8% of directors were independent, reaching 50% in Q1. Proprietary directors are selected by the sole shareholder; independent directors go through a suitability assessment under a Board-approved protocol.

InmoCaixa and Caixa Capital Risc have their own boards; Infinitum and Clever Wave are run by a single director plus two joint directors.

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

Reference: pages 8-9.

The Board defines the sustainability strategy and approves it; the Sustainability Committee (set up in 2024) oversees implementation, ESG policy supervision and the quality of non-financial reporting; the Audit and Control Committee (created 2014) oversees the internal-control and risk-management systems behind that reporting. Both committees "generally meet four times a year."

2025 change: "the functions previously performed by the Sustainability Committee and the Risk Committee... have been incorporated into the respective Sustainability and Risk departments," to streamline decision-making while maintaining oversight.

CriteriaCaixa has a dedicated Sustainability Department within its investment area reporting directly to Management; InmoCaixa set up its own Sustainability Committee in October 2025.

Integrating sustainability-related performance in incentive schemes

Reference: pages 9-10.

During 2025, CriteriaCaixa "established a variable remuneration system applicable to all CriteriaCaixa employees... with the aim of incentivising commitment, productivity and alignment with the objectives set out in CriteriaCaixa's 2030 Strategic Plan." The basic conditions were approved by the Board on the proposal of the Appointments and Remuneration Committee.

"At least 18% of variable remuneration by 2025 will correspond to the achievement of sustainability objectives."

The report states explicitly: "Currently, the remuneration of CriteriaCaixa's Board members is not linked to sustainability metrics."

Statement on due diligence

Reference: page 16.

Section 1.2.5 maps the core elements of due diligence to where they are addressed: integrating due diligence into governance and strategy (GOV-2, GOV-3); cooperation with stakeholders (GOV-2, SBM-2, IRO-1); evaluation of negative impacts (SBM-3 across the SRI, Welfare Projects, climate, own-workforce and business-conduct chapters, MDR-P); measures to address negative impacts (IRO-1, SBM-3, MDR-A); and monitoring effectiveness (MDR-M, MDR-T).

For each stage the report gives a short narrative, e.g. "Criteria Group implements mitigation and remediation programmes for the negative impacts identified in its risk assessments, such as reducing carbon emissions in our supply chain," and "Criteria Group performs ongoing monitoring of its sustainability initiatives through key performance indicators and regular reviews."

Risk management and internal controls over sustainability reporting

Reference: page 17.

The Group operates an Internal Control System over Non-Financial and Sustainability Information (SCIINF-S), integrated "transversely into Criteria Group's strategy, risk management and operational processes."

"The main risks identified relate to failures in the identification of material issues, errors or incompleteness in reporting, in connection with the control environment, fraud and cybersecurity." Risk assessment is based on the "material issues" principle developed in the double materiality analysis.

Control activities are "designed by the areas responsible for the risks," with implementation supervised annually by Internal Control and independently reviewed by Internal Audit under the Group's three-lines-of-defence model. Both functions report to the Sustainability Committee and the Audit and Control Committee.

Strategy, business model and value chain

Reference: pages 18-21.

CriteriaCaixa is "the independent and exclusive management instrument for the assets of the 'la Caixa' Foundation." Its 2030 Strategic Plan (adapted October 2025 around the motto "Creating value that serves 'la Caixa' Foundation and society") targets generating >€800 million for the Foundation's annual budget by 2030 (vs €665 million in 2025) via >€8,000 million of net investment capacity and >€4,000 million made available to the Foundation, across four portfolios: Founding stake, Significant investments, Alternative investments, Liquidity.

Value chain: upstream suppliers (mainly InmoCaixa's, 70.0% of Group purchase volume); own operations (portfolio management, real estate via InmoCaixa, leisure via Infinitum); downstream (Foundation welfare-project beneficiaries, InmoCaixa customers, Infinitum visitors). The Group notes it "has no direct control over" investees' management or sustainability performance, only influence through governance participation.

Interests and views of stakeholders

Reference: page 22.

Key stakeholders are the "la Caixa" Foundation (asset preservation serving the Welfare Projects), Criteria Group employees, and investee companies.

Engagement mechanisms: shared trustees/directors and a shared secretary/deputy secretary between the Foundation's Board of Trustees and CriteriaCaixa's Board; multidisciplinary employee working groups on equality/training and technology/AI; InmoCaixa 360º assessments and Business Partner coordination with HR; and, for the investment portfolio, attendance "where appropriate and deemed necessary" at investee general meetings and governing-body meetings, plus regular meetings between sustainability teams. "No new relevant stakeholders have been identified in 2025 compared to the previous year."

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

Reference: pages 33-34, with per-topic detail in sections 2 (SRI), 3 (Welfare Projects), 4.1 (climate), 5.1 (own workforce) and 6.1 (business conduct).

The 2025 DMA found 18 impacts, 7 risks and 3 opportunities material (14, 6 and 3 respectively in 2024), split across two new entity-specific topics created in 2025 - Sustainable and Responsible Investment (10 IROs) and Welfare Projects (1 IRO) - plus climate change/E1 (2), own workforce/S1 (8) and business conduct/G1 (7). "Consumers and end users" was removed as a material topic in 2025 following strategic-plan review.

"No risks or opportunities with a significant financial impact have been identified at present"; the Group "continues to work on quantifying the current and potential financial impacts... in order to progressively include them in the coming years."

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

Reference: pages 26-29.

A phase-based methodology: context analysis, IRO identification, assessment, and results. For 2025, the Group aligned its IROs with "la Caixa" Foundation, benchmarked the material IROs of its significant investees, and created three new entity-specific themes (Sustainable and Responsible Investment, Welfare Projects, and Cybersecurity - the last found not material).

This produced 39 impacts (25 positive, 14 negative; 40 in 2024), 32 risks and 10 opportunities before the materiality threshold was applied. Assessment used magnitude, scope, irremediability and probability (0-5 scale); severity took precedence over probability for impacts on human rights, per the EFRAG implementation guide. Total gross asset value was used as a weighting factor for financial materiality. A footnote records: **"The Criteria Group has not performed a resilience analysis of the strategy and business model."

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

Reference: pages 147-150 (section 7.3, "List of contents related to ESRS disclosure requirements (IRO-2)").

The index lists, with a section/chapter and page reference for each: all of ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), the four MDR items, all nine E1 disclosure requirements, S1-1 to S1-9 and S1-11 to S1-17 (S1-10 is not listed), and GOV-1, IRO-1, G1-1, G1-3 and G1-4 under business conduct.

No E2, E3, E4, E5, S2, S3 or S4 disclosure requirement appears anywhere in the index, consistent with the DMA finding those topics not material (section 1.4.2, pp.30-32).

Transition plan for climate change mitigation

Reference: pages 61-62.

"In 2024, Criteria Group undertook to develop a Transition Plan for climate change mitigation in 2025 and 2026," intended to align the Group's strategy with European and Spanish climate-transition regulation. The first phase began in 2025; the plan is "conceived as a living document."

Three 2025 pillars: (1) updating the climate risk/opportunity analysis with more investee data and fuller scenarios (section 4.1.2); (2) reviewing the carbon footprint, adding new Scope 3 category 3.15 (Investments); (3) starting the Decarbonisation Plan, drawn up in line with Royal Decree Law 214/2025, prioritising energy efficiency, electrification and fossil-fuel substitution.

No Paris-alignment target date or emissions-trajectory commitment is stated at this stage; the plan is framed as a starting foundation to be developed progressively.

Identification of climate-related risks and scenario analysis

Back-filled from section 4.1.2 "Diagnosis of the Group's climate risks" (pages 63-68), the report's own climate-DMA/TCFD section. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risks are classified acute and chronic; transition risks as economic impact, regulation, litigation, market, reputation and technological. The analysis is aligned with TCFD and the IFRS S2 standard. Rather than naming individual scenarios, the Group homogenises each investee's own scenario work into three categories - low, intermediate and high emissions - and three time horizons (to 2030, 2030-2050, beyond 2050).

Coverage: the Founding stake and a selection of Significant investments portfolio companies (CaixaBank, Naturgy, Telefónica, ACS, using their public disclosures), plus an asset-by-asset analysis of InmoCaixa's real estate following UNEP FI guidance and EU Green Taxonomy Appendix A.

Conclusion: "In all cases, these impacts are considered non-material for the Group," rising to medium only for investees in high-emission, long-term scenarios.

Resilience in relation to climate change

Back-filled from footnotes to sections 1.3.4 (p.23) and 4.1.2 (p.63). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report states plainly, twice: "The Criteria Group has not performed a resilience analysis of the strategy and business model in relation to the ability to address its impacts, risks and opportunities related to key sustainability issues."

In its place, the Group describes a risk-management response rather than a formal resilience test: portfolio diversification and "adjustment of exposure to sectors vulnerable to climate change through continuous analysis," monitoring of each investee's own mitigation actions, and for real estate, asset-level measures (efficiency upgrades, renewable self-generation, green certifications) aimed at "strengthening the Group's resilience and sustainability in the long term" (p.68).

Policies related to climate change mitigation and adaptation

Reference: page 60, detailed at pages 67-68.

CriteriaCaixa's Environmental Policy "fosters continuous improvement, raises awareness among employees and suppliers of good environmental practices and contributes to the mitigation of climate change"; InmoCaixa and Infinitum each have their own environmental management policies.

The Sustainable and Responsible Investment Policy integrates climate criteria throughout the investment process: assessing financial and sustainability performance together; periodic monitoring for new risks; positive/negative screening that prioritises better-performing sectors and excludes those below minimum standards; and continuous portfolio-exposure adjustment away from climate-vulnerable sectors.

For InmoCaixa's real estate, climate policy translates into portfolio management away from less-sustainable assets, renewable self-generation, efficiency upgrades, and pursuit of LEED/BREEAM certification.

Actions and resources in relation to climate change policies

Reference: page 60, detailed at pages 69-75.

2025 actions: office renovation (efficient air conditioning, window sealing, sensor lighting/taps); continued vehicle-fleet renewal toward electric/hybrid; encouraging public transport over air travel; expanded videoconferencing to cut travel; sustainability certification of InmoCaixa buildings; and IT-equipment renewal with donation of replaced units.

A national reforestation offsetting project in Teruel, launched in 2025, offsets 2024 emissions: 5,158 trees planted, 5.67 hectares recovered, 1,599 hours of rural employment, an estimated 104,450 m³ in water-service benefits, projected to offset 1,171 tonnes of CO2e over 50 years.

Funding: a footnote states "no specific monetary allocations can be detailed for the implementation of climate change mitigation actions" against financial-statement line items, the EU Taxonomy KPIs or a CapEx plan.

Targets related to climate change mitigation and adaptation

Reference: page 60, with the target itself at page 80.

The Group's Decarbonisation Plan, covering Scope 1 and 2 with 2025 as baseline year, sets: "the Criteria Group's carbon footprint could be reduced by up to 28.4% of Scope 1 and 2 by 2040 (5.7% of the Group's footprint)", with an intermediate target of around 8.5% by 2030 (1.7% of the Group's footprint), defined pro-rata against projected 2040 emissions "against a backdrop of high uncertainty."

No 1.5°C-alignment claim, SBTi validation or net-zero date is stated. Reduction levers are energy efficiency, sustainable mobility (fleet/machinery electrification), reducing high-global-warming-potential refrigerant gases, and renewable energy sourcing - "mainly defined in qualitative terms" at this stage, with quantification expected to progress during 2026.

Energy consumption and mix

Reference: page 69, data at pages 70-72.

2025 total energy consumption: 6,379.4 MWh (+12.2% vs 5,688.0 MWh in 2024) - mainly from the first-time inclusion of the Group's Madrid offices and two temporary Barcelona floors. 75.3% from renewable sources (71.4% in 2024); 24.7% fossil (28.6% in 2024). Like-for-like (excluding the new perimeter), renewable consumption rose 3.2% and fossil fell 3.1%.

Self-generated solar production: 165.2 MWh (+9.6% vs 150.7 MWh). Energy intensity: 28.0 MWh per €million of income from high-climate-impact activities (25.5 in 2024), real estate being designated high-climate-impact under Annex I §L of Regulation 1893/2006; the rise reflects the expanded Madrid/InmoCaixa office footprint and lower income.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 73, data at pages 74-75.

Scope 1: 474.2 tCO2e (+5.6% vs 448.9 in 2024). Scope 2 (location-based): 417.4 tCO2e (+33.4% vs 312.9), driven by higher Infinitum activity; the 2024 figure was recalculated for a location-based correction. Scope 3 (categories 1, 5 and 6 together): 1,883.9 tCO2e (+161.0% vs 721.9) - category 1 purchased goods/services +41.2%, category 5 waste +1,712.3% (disposal of a large volume of lead batteries from Infinitum's golf activity), category 6 business travel -28.4%.

A new category 3.15 "Investments" (financed emissions from the Founding stake and Significant investments portfolio, weighted by ownership share) adds 58,838,820.9 tCO2e, which the company flags as "n.m." (not meaningful) versus 2024 since it is reported for the first time. Total own emissions (market-based, excl. investments): 2,358.1 tCO2e (+101.4% vs 1,170.8), reflecting the wider 2025 reporting perimeter.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 73, detailed at page 75.

A footnote states plainly: "The Criteria Group does not currently have any storage projects or carbon credit projects."

Instead, in 2025 the Group launched its own emissions-offsetting project - a national reforestation initiative in the province of Teruel, developed with a restoration specialist and the local community, offsetting 2024 emissions: 5,158 trees planted, 5.67 hectares recovered, 1,599 hours of rural employment created, an estimated 104,450 m³ benefit in water services, projected to offset 1,171 tonnes of CO2e over the next 50 years. This is the Group's own mitigation project rather than a purchased carbon-credit scheme.

Internal carbon pricing

Reference: page 73, detailed at page 76.

"Criteria Group recognises the value of setting an internal carbon price as a tool for managing climate risk and driving GHG emission reductions." An initial internal benchmark was established for 2025, based on the cost the Company incurred to offset its 2024 CO2 emissions (the Teruel reforestation project).

The Group states it "will assess the feasibility of developing its own internal carbon price framework to gradually integrate this mechanism into the company's decision-making and future planning" - i.e. the 2025 figure is a starting reference point rather than a price applied across investment or capital-allocation decisions yet.

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

Reference: page 63, analysis at pages 63-68.

Disclosed under an explicit ESRS 1 Annex C phase-in election - section 1.1.2 names this exact disclosure among those gradually introduced (p.5) - so only qualitative conclusions are given, no monetary figures.

Findings: physical risks are "considered to have a low or medium-low impact," rising to medium only in high-emission, long-term scenarios via potential effects on investees' operations, assets and commodity supply. Transition risks are "also considered to be low or medium-low impact," reaching medium only in low-emission/intermediate, short-/medium-term scenarios through price, cost and demand shifts. Opportunities are assessed as low or medium-low at holding level, since investee-level gains are "indirect and therefore attenuated." Overall: **"In all cases, these impacts are considered non-material for the Group."

Policies related to own workforce

Reference: pages 11, 101, policy detail at pages 104-105, 108, 113, 121.

The Group's Human Resources Policy "sets the guidelines for people management at CriteriaCaixa, applicable to all employees," covering recruitment, training, talent retention, compensation/benefits and personnel management, "guaranteeing equal opportunities and respect for diversity."

It sits alongside the Labour Relations, Equality and Work-Life Balance Policy, the Diversity and Inclusion Policy, the Anti-Harassment Protocol and the Occupational Health and Safety Policy (see the policy framework table, section 1.2.4). These are approved by the Board of Directors of CriteriaCaixa and the relevant subsidiaries' governing bodies, and are linked explicitly to the material workforce IROs - pay gap, work-life balance, training, and collective-bargaining coverage.

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

Reference: page 106 per the company's content index; engagement activity described at pages 104-105.

2025 actions: a corporate meeting presenting the adaptation of the 2030 Strategic Plan, including "an open dialogue with employees to share challenges and opportunities," with feedback from internal teams feeding back into strategic thinking; and the introduction of a "Sponsor" role linking project managers with management to support the internal Project Map.

Other channels: multidisciplinary working groups (equality/training, technology and AI use); at InmoCaixa, 360º assessments and coordination between area Business Partners and HR. "No new relevant stakeholders have been identified in 2025 compared to the previous year" (p.27).

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

Reference: page 118.

Channels: the Group's internal whistleblowing channel (corporate intranets/public websites, feeding the Crime Prevention Committee), confidentially or anonymously at the informant's choice; a human resources email address and intranet channel for queries; at InmoCaixa, a suggestions channel plus confidential surveys; at Infinitum, a dedicated Works Council email, physical mailbox, telephone line and direct management channel.

"The Criteria Group activates all necessary measures to prevent any type of retaliation against the whistleblower, ensuring a safe and transparent environment." In 2025, one internal investigation into possible discriminatory treatment was closed, the facts not establishing discrimination; no harassment notifications were received.

Taking action on material impacts on own workforce

Reference: page 101, actions detailed across sections 5.1.3-5.1.7.

Of the 8 material own-workforce IROs (6 positive impacts, 1 negative impact, 1 risk), the two with explicit mitigation described are: the gender pay gap, addressed through the new General Remuneration Policy and position-by-position review, which produced average salary increases of 22% for women versus 13% for men and cut the pay gap from 12.1% to 4.98%; and the risk of insufficient professional/specialised skills for portfolio management, addressed through the Annual Training Plan, which the Group considers "reduces the likelihood and impact on corporate performance."

The six positive impacts (training, work-life balance, collective bargaining, health benefits, diversity, gender equality in leadership) are reinforced through the policies and actions described under S1-1 and S1-3.

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

Reference: page 101, detail at page 112.

No forward numeric reduction target is stated for own-workforce metrics; instead the Group's Equality Plans set a process-based goal: "having a management system that controls possible salary gaps and the reasons why they appear" and reviewing remuneration processes "from a gender perspective" (p.112).

Progress against that goal is quantified retrospectively: the pay gap fell from 12.1% in 2024 to 4.98% in 2025, "down by five percentage points," attributed to the position-review exercise and policy rollout described under S1-4. The remaining gap is attributed to "the increased presence of men in management positions," which the Group says "will continue to evolve progressively."

Characteristics of the undertaking's employees

Reference: page 103.

380 employees at year-end 2025 (390 in 2024): 166 women (43.7%) and 214 men (56.3%). 94% on permanent contracts; average age 44.6. The entire workforce is based in Spain.

Permanent contracts are prioritised "to guarantee stability, continuity and specialisation"; temporary contracts and temporary-employment-agency (TEA) staff cover ad hoc needs and, in leisure management (Infinitum), seasonal peaks, using discontinuous permanent contracts during the high season. External personnel (e.g. reception, IT support) are also used, "in all cases" with fair pay and conditions equivalent to permanent staff.

Characteristics of non-employee workers in the undertaking's own workforce

Reference: page 103.

Described qualitatively only: the Group "uses temporary contracts and agreements with temporary employment agencies to cover temporary absences and ad hoc needs" and "employs external personnel in areas such as reception and IT support," with fair pay and conditions equivalent to permanent staff "in all cases."

Quantified figures for non-employee workers are not given. Section 1.1.2 (p.5) lists "quantitative information on self-employed persons" among the disclosures the Group has gradually introduced under the ESRS 1 Appendix C phase-in provisions, explaining the absence of numbers here.

Collective bargaining coverage and social dialogue

Reference: page 118.

"Currently, all job positions in Criteria Group, except senior management positions, are covered by collective bargaining agreements." Staff supplied through Temporary Employment Agencies are covered separately by "the national collective agreement for temporary employment agencies."

This underpins one of the Group's six material own-workforce IROs: "Guarantee of full coverage and extension of trade union rights to workers through a collective agreement," classed as a positive impact currently happening across the Group's own operations (p.33).

Diversity metrics

Reference: page 114.

By age (2025): 10.3% of employees under 30 (9.2% in 2024), 55.5% aged 30-50 (59.7%), 34.2% aged 50+ (31.0%).

By professional category (2025): 5.0% executives (3.8% in 2024), 19.2% managers (14.4%), 42.4% qualified technicians (49.0%), 13.9% unskilled technicians (13.3%), 19.5% clerical staff (19.5%) - each broken down further by gender in the report's charts.

The Diversity and Inclusion Policy "applies to all employees, directors, customers and suppliers" and is paired with company-level Equality Plans; CriteriaCaixa's Equality Plan was registered with REGCON during 2025.

Social protection

Reference: page 118.

A footnote records: "Social protection cases for illness, unemployment, accidents at work and acquired disability, parental leave and retirement are covered by the public social security system" (p.118).

The Group enhances statutory protection in several areas: CriteriaCaixa "has improved the temporary disability allowance, guaranteeing up to 100% of the fixed gross salary for a maximum of 12 months or according to the applicable Collective Bargaining Agreement," and offers specific measures for pregnant employees to adapt their working model (p.108).

Persons with disabilities

Reference: page 114, data at page 115.

7 employees with functional diversity or covered by equivalent alternative measures at year-end 2025 (8 in 2024), 1.7% of the total workforce (2.0% in 2024). Compliance with the General Law on Disabilities is met through direct hiring, dealings with special employment centres (Centros Especiales de Trabajo), and donations to disability-inclusion foundations.

Separately, via the Foundation's Welfare Projects funded by CriteriaCaixa's dividends, "la Caixa" Banking Foundation made contributions to 622 projects aimed at the social integration of individuals with disabilities, for a total sum of €17.3 million" (€14.5 million in 2024).

Training and skills development metrics

Reference: page 106.

6,835 hours of training delivered in 2025 (10,171 in 2024): 56.4% to men, 43.6% to women; 13 hours per employee on average (20 in 2024). The Group attributes the drop to "organisational changes and the adaptation of the Strategic Plan 2030" and the Real Estate business's restructuring, and expects "to return to normal levels of activity in the coming years."

Notable 2025 programmes: training on the use and ethics of Artificial Intelligence, and sustainability training covering carbon-footprint calculation and waste-management documentation. Training is also the Group's stated mitigation for its one material workforce risk - lack of specialised portfolio-management skills.

Health and safety metrics

Reference: page 121, figures at pages 122-123.

CriteriaCaixa has been ISO 45001-certified since 2021 (renewed 2025); 100% of Group employees are covered by the occupational health and safety management system. "The frequency rate of work accidents in 2025 was 7.06 per million hours worked (9.9 in 2024), which is within a reasonable range."

Absenteeism (documented, justified absences) rose to 4.5% in 2025 (3.8% in 2024), equivalent to 31,621 hours (26,810 in 2024), attributed to "a higher number of long-term absences" against a relatively small workforce. A footnote notes the 2024 comparator was corrected from the figure originally reported (4.0%) "due to the correction of an error identified after the reporting date."

Work-life balance metrics

Reference: page 106, detail at pages 108-109.

Measures include flexible working hours; condensed hours (seven-hour days in July/August, six-hour Fridays at CriteriaCaixa); company-provided remote-work equipment with a respected right to digital disconnection; and leave enhancements beyond the collective agreement, including five extra working days of leave in a child's first year and a disability allowance topped up to 100% of salary for up to 12 months.

Family leave (2025): childbirth/childcare leave of 19 weeks (6 compulsory) plus up to 8 unpaid parental weeks usable until age 8. 15 employees (3.0% of the workforce) took parental leave in 2025 (18, 3.5%, in 2024): 5 women (33.3%) and 10 men (66.7%).

Compensation metrics (pay gap and total compensation)

Reference: page 106, detail at pages 109-112.

Average gross remuneration 2025: women €66,012, men €69,452 (overall average €67,950); 2024: women €54,093, men €61,319 (average €58,207). Gender pay gap: 4.98% in 2025, down from 12.1% in 2024 - "the difference between the average hourly pay of men and women, over the average hourly pay of men."

CEO pay ratio: 5.72 (6.91 in 2024). Board remuneration 2025: 10 men (€4,772k), 4 women (€583k), total €5,355k. Senior management (8 people, 1 woman): total remuneration €5,929k - gender split withheld "on the grounds of confidentiality" given only one woman in the category.

Incidents, complaints and severe human rights impacts

Reference: page 116, incident data at page 118.

"In 2025, only one internal investigation was carried out into a possible case of discriminatory treatment, which resulted in the case being closed on the grounds that the facts established did not involve any discrimination. In addition, no notification has been received of any cases of harassment at Group companies nor in relation to working conditions, equal treatment and opportunities."

The Group's Human Rights Due Diligence Procedure identifies actual and potential risk events that could breach human-rights principles, backed by preventive controls (policies, manuals, internal/external whistleblowing channels, training, external certifier reviews). In 2025 "Criteria reviewed the risk assessment, together with the associated controls and action plans, in order to keep them up to date."

Business conduct policies and corporate culture

Reference: page 125, detail at pages 125-127.

The Code of Ethics is "the most relevant corporate reference for business conduct," regulating conduct for employees, managers and directors; accepting a position at Criteria Group "implies adhesion to the Code of Ethics." It is grounded in the UN Universal Declaration of Human Rights and sets out reinforced standards: promotion of free competition, regulatory compliance, professional excellence, avoidance of conflicts of interest, teamwork, asset protection, reputational/ideological neutrality, integrity, confidentiality, and compliance with internal protocols (including those governing relations with "la Caixa" Foundation and CaixaBank).

As a wholly-owned subsidiary of the Foundation, a UN Global Compact signatory, the Group commits to the Compact's ten principles, "including working against corruption in all its forms... (principle no. 10)." InmoCaixa and Infinitum apply an equivalent Code of Business Conduct and Ethics.

Prevention and detection of corruption and bribery

Reference: page 128, detail at pages 128-131.

The Crime Prevention Model comprises the Code of Ethics, the Crime Prevention Policy, a Crime Prevention and Response Manual, the Anti-Corruption Policy, and a Crime Prevention Committee reporting to the Audit and Control Committee. Each company has its own criminal-risk report and a risk/controls matrix, with "control channels for compliance with anti-corruption, anti-money laundering and anti-bribery regulations" tested regularly for effectiveness. The Anti-Corruption Policy was updated in February 2025.

Training coverage: 96% of the workforce and governing bodies completed Crime Prevention Model training in 2025 (100% in 2024), rising to 100% for business functions and 94.4% for management functions, groups judged at higher corruption/bribery risk. A General AML/CFT Policy under Law 10/2010 adds KYC and onboarding controls.

Targets related to business conduct

Back-filled from section 6.1 (the MDR-T equivalent for this 2023-ESRS report). G1-3 Targets is a standalone disclosure only from the 2025/2026 ESRS.

CriteriaCaixa has no quantified target for business conduct yet, and says so directly: "During 2026, within the framework of the definition of objectives of the 2030 Strategic Plan and the Sustainability Action Plan, the Group will assess the feasibility and desirability of establishing specific metrics and targets for business conduct, defining the level of ambition and actions as well as the monitoring indicators that will enable its progress to be measured" (p.124).

In the interim, effectiveness is tracked through process indicators: Crime Prevention Model training completion (96% of the workforce, 100% of business functions, 94.4% of management in 2025), and periodic testing of the "functioning and effectiveness" of the anti-corruption/AML control channels, reported to the Audit and Control Committee and Board (pp.128-131).

Incidents of corruption or bribery

Reference: page 128, statement at page 131.

"During 2025, no company in the Criteria Group has been convicted of committing offences related to corruption or bribery. Additionally, there [were] no reports received in relation to these matters or concerning money laundering."

This nil return follows from the Crime Prevention Committee's ongoing monitoring, supported by Internal Audit assessment of that monitoring, and the training programme described under G1-3: "Periodically, the Criteria Group ensures the correct monitoring of risk behaviours and the Group's Internal Audit function assesses the monitoring through specific work" (p.131).