DZ HYP AG

The role of the administrative, management and supervisory bodies

Reference: page 64 (composition/diversity table), also pages 62-64.

DZ HYP applies "a model of dual leadership": a three-person Management Board (CEO, CRO, CFO) overseen by an 18-member Supervisory Board (12 elected by the AGM, 6 employee representatives), which appointed a Nomination Committee, a Remuneration Oversight Committee, an Audit Committee and a Risk Committee (met 15 times in 2025); the Supervisory Board itself convened four times and "is briefed annually in a meeting on DZ HYP's key sustainability activities."

Composition as at 31 December 2025: Management Board 33.3% women (2024: 33.3%); Supervisory Board 27.8% women (2024: 27.8%), 0% independent members on either body (shareholder/employee representatives are not considered independent). The company's own ESRS 2 Appendix B table marks both "Gender diversity in management and supervisory bodies" and "Percentage of independent board members" as Material.

Information provided to and sustainability matters addressed by the AMSBs

Reference: pages 64-65.

Responsibility for sustainability "lies with the Management Board," with Management Board members "also involved in the processes for approving the results of the materiality analysis and in approving the gradual preparation of the report in accordance with the ESRS. The Supervisory Board is not involved separately" in that approval, but "is briefed annually in a meeting on DZ HYP's key sustainability activities" and, by its nature, concerns itself with business and risk strategy, performance and risk management.

A dedicated governance structure feeds information upward: the Sustainability Coordination Committee (monthly), the Sustainability Committee (Management Board, Division Heads and the Sustainability Officer, met twice in 2025) and the Sustainable Products Committee report through the Strategy and Sustainability department, which also informs the Management Board "about any internal and external developments at regular intervals."

Note for review: this DR is not individually coded in the company's own content-index tables (which cross-reference GOV-1, GOV-3, GOV-4 but not GOV-2); this entry rests on the General Disclosures narrative itself.

Integration of sustainability-related performance in incentive schemes

Reference: pages 65-66. Cross-referenced in the company's own "Material topics and assigned ESRS reporting requirements" table as "E1 GOV-3".

"20 per cent of the variable remuneration paid to members of the DZ HYP Management Board is linked to sustainability targets, comprised of environmental (10 per cent), social (5 per cent) and governance (5 per cent) components." The environmental component covers "developing a mobility concept, identifying measures to reduce emissions and undertaking actions to ensure compliance with the Group-wide climate pathway"; the governance component targets raising the women's share in leadership to 25% by October 2025 and 30% by October 2030. A three-year assessment period applies. However, "at present, greenhouse gas reduction targets are not reflected in the remuneration paid to members of the Management Board," and Supervisory Board remuneration carries no variable or sustainability-linked component.

Statement on due diligence

Reference: page 67. The company's own ESRS 2 Appendix B table lists "ESRS 2 GOV-4 - Statement on due diligence" as Material.

DZ HYP presents a dedicated "Due diligence in the Sustainability Report" table mapping the five core due-diligence elements to report chapters: (a) embedding in governance/strategy -> Business model and strategy, Corporate governance; (b) engaging with affected stakeholders -> Business model and strategy, Corporate governance, Materiality analysis, Guidelines and objectives in banking operations, Working conditions and pay, Occupational health and safety; (c) identifying/assessing adverse impacts -> Business model and strategy, Corporate governance, Materiality analysis; (d) taking action -> Guidelines and objectives in banking operations/banking business, Diversity, Occupational health and safety, Skills development; (e) tracking effectiveness -> the same measures chapters plus Greenhouse Gas Emissions.

Risk management and internal controls over sustainability reporting

Reference: pages 67-68.

DZ HYP "uses its existing processes and controls to ensure risk management and internal controls for sustainability reporting," expanded to cover the reporting process itself. Two risks were identified: that reporting "might overlook key issues" (mitigated by the annual materiality analysis) and that "incorrect or incomplete data will be included" (mitigated by a plausibility check, with Division Heads and the Management Board signing off on content). Risks and controls "are recorded systematically in a control inventory," governed by DZ HYP's "Guidelines on the Internal Control System for Sustainability (CSRD ICS Guidelines)," with regular reporting on ICS results to the Management Board and Supervisory Board planned from the 2026 financial year. Compliance and Internal Audit both have defined roles reviewing sustainability-related regulatory compliance.

Note for review: not individually coded in the company's own content-index tables; this entry rests on the General Disclosures narrative, which uses this section's title almost verbatim.

Strategy, business model and value chain

Reference: pages 55-59. The company's own ESRS 2 Appendix B table carries four "ESRS 2 SBM-1" rows (fossil fuel, chemical production, controversial weapons and tobacco involvement), each marked "Not applicable due to business model."

DZ HYP is "a leading real estate finance house and Pfandbrief issuer in Germany," active in three segments (Corporate Clients, Retail Customers, Public Sector) within the Cooperative Financial Network. Its value chain "spans both upstream and downstream activities, as well as DZ HYP's own operations": upstream covers suppliers (e.g. energy suppliers), service providers (IT, training) and the shareholder DZ BANK AG; downstream covers products (real estate loans, loans to local authorities, property valuations, Pfandbrief issuance) and clients (cooperative banks, direct clients, investors). "The full value chain was analysed for the purposes of identifying and assessing impacts, risks and opportunities."

Resilience is addressed qualitatively: "At the time this report was prepared, there was no reason to suggest... that DZ HYP's business model was not resilient" (page 58).

Interests and views of stakeholders

Reference: pages 69-70. Cross-referenced in the content index as "S1 SBM-2" and "S4 SBM-2".

Stakeholder representatives "required to have sufficient knowledge, based on their work at DZ HYP, of stakeholders' sustainability concerns and duties" were involved throughout the materiality analysis, both to identify and assess impacts/opportunities and to validate the resulting IRO catalogue. Stakeholder-facing channels referenced elsewhere in the report include Advisory Boards for banks and for the public sector/housing sector, rating-agency dialogue (ISS ESG, Sustainalytics, Sustainable Fitch for sustainability ratings), investor events, and employee surveys (Pulse Check, mental-health risk assessment) feeding into the Management Board and Works Council.

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

Reference: pages 71-75. Cross-referenced in the content index as "E1 SBM-3", "S1 SBM-3" and "S4 SBM-3".

The 2025 double-materiality update identified as material, split by "banking operations" and "banking business": climate change mitigation and adaptation, energy (E1, banking business only after a change), working conditions, equal treatment, other work-related rights (S1), business conduct, corruption/bribery, anti-competitive behaviour and lobbying (G1), biodiversity and ecosystems (E4, newly material in banking business), consumers and end-users (S4), plus the entity-specific topics Social engagement and Sustainable funding. Pollution, water/marine resources, resource use/circular economy, workers in the value chain and affected communities were assessed not material. A dedicated table maps each material topic to its reference chapter (e.g. "ESRS E4 - Biodiversity and ecosystems -> Biodiversity and Ecological Diversity").

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

Reference: pages 69-71. Cross-referenced in the content index as "E1 IRO-1", "E4 IRO-1" and "G1 IRO-1".

A five-step process: (I) compiling 19 ESRS sub-topics plus 2 entity-specific topics (Social engagement, Sustainable funding); (IIa) deriving impacts/opportunities via stakeholder representatives into an "IRO (impacts, risks and opportunities) catalogue"; (IIb) assessing them against EFRAG-recommended thresholds (impact materiality >=8 on a 1-15 scale; financial materiality >=3 on a 1-5 scale), validated by a quantitative "SDG demonstrator" portfolio analysis; (III) deriving material risks from the DZ BANK Group's ESG risk-driver analysis; (IV) preparing results, overseen by a single named function in Corporate Strategy and Development, with Management Board acknowledgement of the annual results.

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

Reference: pages 76-79.

DZ HYP presents this disclosure as a two-part table: "Material topics and assigned ESRS reporting requirements," which lists, per material topic and dimension (banking operations / banking business), the specific cross-cutting and topical DRs covered (e.g. "E1 GOV-3, E1 SBM-3, E1 IRO-1, E1-1, E1-2, E1-3, E1-4, E1-6[, E1-7]"; "S1 SBM-2, S1 SBM-3, S1-1 through S1-17"; "G1 GOV-1, G1 IRO-1, G1-1, G1-3, G1-4, G1-5"; "E4-1, E4 IRO-1, E4-2, E4-3, E4-4"; "S4 SBM-2, S4 SBM-3, S4-1 through S4-5"); and "Datapoints in ESRS 2 Appendix B," which rates each EU-legislation-derived datapoint as Material / Not material / Not applicable.

Note for review: the table does not self-reference "IRO-2" by code, but its content and heading ("ESRS disclosure requirements covered in the Sustainability Report") are exactly this disclosure requirement.

Transition plan for climate change mitigation

Reference: pages 81-84 (banking operations) and 87-90 (banking business).

Banking operations: DZ BANK Group's Competence Centre Environment set an objective of "climate neutrality for controllable emissions by 2045," using 2024 as baseline, with Group interim targets of -9% (2030), -24% (2035) and -47% (2040); DZ HYP-specific interim targets were derived as -9%/4,185 t CO2e (2030), -24%/3,518 t CO2e (2035) and -47%/2,437 t CO2e (2040) from a 4,623 t CO2 starting point, using active (heating, electricity, fleet) and passive (external/regulatory decarbonisation) levers under a "neutral-conservative" Scenario 2. Locked-in emissions (existing heating/cooling systems, commuter mobility) are identified; residual emissions are to be offset from 2030.

Banking business: a transition plan for the real estate focus sector, approved by the Management Board, targets -36% (Corporate Clients) and -41% (Retail Customers) portfolio intensity by 2030 against a 2023 baseline, aligned to CRREM pathways and "the 1.5-degree Celsius target... to achieve climate neutrality in the banking business by 2050, as required under the ESRS." "No clearly defined financial resources were allocated specifically to the implementation of decarbonisation measures in the business portfolio.

Policies related to climate change mitigation and adaptation

Reference: pages 80-81 (banking operations) and 87-89 (banking business).

Banking operations: environmental management "focuses on optimising the use of energy and resources... and on using renewable energy sources," under the DZ BANK Group Competence Centre Environment's "Climate Strategy for Operational Ecology," with overall responsibility at DZ HYP resting with the CEO and implementation by Corporate Strategy and Development.

Banking business: DZ HYP is guided by the DZ BANK Group's climate and environmental strategy (first issued 2018), anchored in the UN Global Compact, the SDGs and the Paris Agreement, and applies Group-wide exclusion criteria (e.g. certain arms trading, the sex trade, human-rights or environmental breaches) specified under "Business model boundaries." The Green Bond Framework (first published January 2022, updated December 2024 to match the vdp's 2025 minimum standards) governs Green Pfandbrief classification and is explicitly aligned with EU Taxonomy climate-mitigation criteria.

Actions and resources in relation to climate change policies

Reference: pages 84-85 (banking operations) and 89-90 (banking business).

Banking operations measures in 2025: expansion of the Hamburg photovoltaic system; an eco-friendly kitchen refrigeration system and removal of outdated hot-water systems; DGNB "Silver" certification for the energy-efficient refurbishment of the Hamburg building; a revised company-car policy lowering the CO2 limit to 150 g/km (37 of 86 cars now electric/plug-in hybrid, up from 30/85); the EcoVadis supplier-sustainability rating platform; electronic signatures for commercial real estate loans; and a mobility carbon calculator with quarterly divisional reporting planned from 2026. "The resources associated with the individual measures have not been quantified explicitly."

Banking business: switching financed buildings from fossil to renewable heat/power, efficiency-driven refurbishment, and a decarbonisation-pathway monitoring system; "DZ HYP has no plans to introduce any new technologies to achieve its GHG emission reduction targets.

Targets related to climate change mitigation and adaptation

Reference: pages 81-83 (banking operations interim targets) and 87-89 (banking business CRREM-aligned targets).

Banking operations: Group-level interim targets of -9% (2030, 103,404 t CO2e), -24% (2035, 86,913 t CO2e) and -47% (2040, 60,216 t CO2e) against a 2024 baseline, converging on climate neutrality by 2045 via offsetting; DZ HYP-specific figures of 4,185 / 3,518 / 2,437 t CO2e for the same years, developed "without reference to a particular scientific methodology or a 1.5 degree reference pathway," though DZ BANK's pathway is said to converge with the SBTi cross-sectoral pathway by 2045.

Banking business: physical-intensity targets (kg CO2e/m2/year) for Corporate Clients and Retail Customers property portfolios, set against CRREM reference pathways, with 2026/2030/2040/2050 milestones; as at 31 December 2025 the approach covers 38.7% of total scope 3 category 15 (financed) emissions.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 / the climate-DMA section, where this content is disclosed in the FY2025 report (pages 57-58). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

DZ HYP's own scenario analysis is performed only at DZ BANK Group level (no standalone disclosure at entity level, due to an own-funds waiver). Physical risks: flood, wildfire and drought scenarios "based on climate pathway scenarios developed by the Network for Greening the Financial System (NGFS) that correspond to at least the Current Policies scenario." Transition risks: the NGFS Delayed Transition scenario, "expanded to include additional Bank-specific transition risks as well as physical risks... a sudden transition phase is initiated to limit global warming to below 2 degrees C. The maximum global warming expected in this scenario is 1.7 degrees C or 1.8 degrees C as a model average." "No scenario analysis is performed for banking operations within this context" -- only for the banking business (real estate portfolio).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 57-58). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

DZ HYP does not describe a formal, ESRS-defined resilience analysis. Instead it states qualitatively: "at the time this report was prepared, there was no reason to suggest, from DZ HYP's perspective, that DZ HYP's business model was not resilient" (page 58), drawing on the DZ BANK Group's ECB climate stress test (first undergone 2022, since incorporated into the internal stress test), an annual ESG risk-driver inventory, and DZ HYP's own climate targets for managing decarbonisation of the financed real estate portfolio. The Corporate Strategy and Development division "regularly reviews the resilience of DZ HYP's strategy and business model" (page 57).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 93-98.

GHG emissions are calculated using the VfU indicator system and ecoinvent factors (version 3.10). For FY2025 (with FY2024 comparatives in the "Baseline year"/"Comparison" columns): gross Scope 1 emissions 2,146 t CO2e (+38.3%); gross location-based Scope 2 2,415 t CO2e (+17.2%); gross market-based Scope 2 477 t CO2e (-28.8%); total gross Scope 3 (operational categories 1-14) 2,372,673 t CO2e (+25.8%), dominated by financed emissions; Total GHG emissions (location-based) 2,377,234 t CO2e (+25.8%), (market-based) 2,375,296 t CO2e (+25.8%). Financed emissions (scope 3 category 15) are broken out separately: Scope 1 876,627, Scope 2 426,019, Scope 3 1,065,887 t CO2e, with a PCAF data-quality score of 3.7. Intensity: 0.000763 t CO2e/EUR net revenue (location-based), up from 0.000482 in 2024.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 98. Cross-referenced in the content index as "E1-7" (banking-business row).

"DZ HYP has not launched any specific projects aimed at storing or removing greenhouse gases in its own operations or in the upstream and downstream value chain. No carbon credits were purchased either." This is a nil return for the 2025 financial year, consistent with the offsetting of locked-in/residual emissions only being planned from 2030 onward under the decarbonisation pathway described under E1-1.

Transition plan on biodiversity and ecosystems

Reference: page 98.

DZ HYP has no separate biodiversity transition plan; instead it states: "all climate-related targets, measures and guidelines described in the 'Environment' chapter are also of relevance for the protection and promotion of biodiversity," noting the IPBES finding on the central role climate plays for biodiversity. The company's own content index nonetheless lists "E4-1" as a covered requirement for the biodiversity topic, alongside E4-2 through E4-4.

Policies related to biodiversity and ecosystems

Reference: pages 98-99. The company's own ESRS 2 Appendix B table marks "ESRS E4-2 - Policies to address deforestation" as Material.

DZ HYP "applies the same exclusion criteria as the DZ BANK Group," including a deforestation criterion that "prohibits the financing of trading activities that are directly linked to illegal logging, slash-and-burn practices and/or the conversion of tropical and/or primary forests and other protected areas" (including UNESCO World Heritage Sites and IUCN category I/II natural habitats), and a "significant environmental hazards" criterion excluding projects posing substantial environmental risk. During the year, DZ BANK undertook "an in-depth sector-specific examination of biodiversity and ecosystems within the 'Nature' module of its existing sustainability programme," focused on land take from construction projects. Sustainable-land and sustainable-oceans policy datapoints are marked "Not applicable due to business model.

Actions and resources related to biodiversity and ecosystems

Reference: pages 99-100.

DZ HYP is part of the ECORE initiative, which collects biodiversity parameters (e.g. greening-measure data) when assessing clients and projects, and its municipal sustainability ranking incorporates biodiversity metrics such as the proportion of green versus sealed areas, forest coverage and water quality. The Bank "is currently in the process of implementing the requirements for a biodiversity risk measurement methodology set out in the European Banking Authority's (EBA) guidelines on the management of ESG risks," with completion scheduled for the 2026 financial year. Compliance with the German Federal Nature Conservation Act is mandatory for clients and reviewed through building permits.

Targets related to biodiversity and ecosystems

Reference: page 99.

"The areas of biodiversity and ecosystems are still being finalised at DZ HYP, which is why no quantitative targets have been set so far." This explicit, dated statement of the absence of targets is itself the disclosure for FY2025; the company's own content index lists E4-4 as a covered requirement.

Policies related to own workforce

Reference: pages 108-109 (Human Rights Guideline, Code of Conduct), 110-111 (Diversity Policy), 113-114 (remuneration strategy).

HR work "is based on the labour and social standards of the International Labour Organization (ILO), as set out in the DZ BANK Group's Code of Conduct and the DZ BANK Group's Human Rights Guideline," adopted by the Group Sustainability Committee, with the HR Division Head responsible for implementation at DZ HYP; adherence is monitored at divisional level. DZ HYP "adopted a Diversity Policy in this context in 2024," covering work-life balance, respectful communication, anti-discrimination and generational diversity. The company's own Appendix B table marks as Material: human rights policy commitments; due diligence on ILO Conventions 1-8; trafficking-prevention processes; and workplace-accident-prevention policy (page 78-79).

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

Reference: page 117.

Engagement runs through the intranet (process/development updates), anonymous online employee surveys (the "Pulse Check," most recently run November 2023, and a 2025 mental-health risk assessment), events where employees interact directly with the Management Board, and regular Works Council dialogue (bi-weekly in Münster, weekly in Hamburg). "DZ HYP's employees play an active part in the Bank's decision-making processes," and decisions affecting employees are communicated via the intranet.

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

Reference: pages 117-118.

An AGG complaints office within HR handles incidents under the German General Equal Treatment Act; Compliance separately operates "a whistleblower system for reporting breaches of legal norms or internal regulations" ("No reports were submitted via the system during the year under review"). Employees can also raise concerns directly with local Works Council members, with contact details published on the intranet.

Taking action on material impacts on own workforce

Reference: pages 111-112 (Diversity measures), 120-122 (occupational health and safety measures), 123-124 (skills development measures).

Actions span: diversity measures (inclusive job-ad wording, AGG training every two years, AGG certification, the Group Inclusion Agreement); a 2025 mental-health risk assessment covering over 60% of the workforce, with department-level follow-up workshops where an imbalance between stress and resources was found -- "the findings... are overall positive: there is... no urgent need for action"; the Bank-wide Committee for Occupational Safety (ASA), meeting twice yearly in Hamburg and Münster; and skills programmes including the "ZukunftsFit!" initiative and a dedicated AI Masterclass introduced in 2025.

Targets related to own workforce

Reference: page 111 (diversity targets), 114-115, 120, 123 (other S1 target statements).

Quantitative targets exist for gender diversity: a women's-quota target for Division/Department Heads of 25% each, introduced November 2020 for October 2025 -- achieved at 25.0% for Division Heads as at 31 December 2025 (Department Heads reached 22.9%, missing the 25% target "because the share of female candidates in the internal talent pool was not high enough"); new targets of 31.25%/30% were set in October 2025 for October 2030. By contrast, for working conditions and pay, occupational safety, and training and skills development the company states plainly it "did not have any measurable targets... during the reporting period," in each case because "quantitative targets have not been deemed necessary to date" given high employer-review rankings or existing safety/training performance.

Characteristics of the undertaking's employees

Reference: page 109.

994 employees (2024: 938) at 31 December 2025: 420 female, 574 male, all based in Germany (head offices in Hamburg and Münster, plus ten other locations; no staff outside Germany). 952 on permanent contracts (2024: 899), 42 on fixed-term contracts (2024: 39); no employees without guaranteed working hours. Staff turnover was 4.1% (2024: 3.6%), on 40 departures (2024: 33).

Characteristics of non-employee workers

Reference: pages 108-109.

"During the 2025 financial year, the group of external workers includes ten agency workers as defined by the German Act on Temporary Agency Work (Arbeitnehmerüberlassungsgesetz - “AÜG”)." These individuals are employed by a third-party agency but work under DZ HYP's instruction for a specified period; the Act requires they receive benefits comparable to permanent staff (remuneration, holiday/Christmas bonuses, communal-facility access, on-site childcare). All other employee-facing policies and procedures in the report apply only to employees, not to this external-worker group.

Collective bargaining coverage and social dialogue

Reference: pages 115-116.

"665 members of staff (2024: 623) were not covered by a collective agreement as at 31 December 2025, while 329 (2024: 315) were employed at DZ HYP based on a valid collective pay scale agreement," a collective bargaining coverage rate of 33.1% (2024: 33.6%). All DZ HYP employees are represented by employee representatives under the German Works Constitution Act, giving social-dialogue coverage of effectively 100% of the German (EEA) workforce.

Diversity metrics

Reference: page 112.

Top-management gender split at 31 December 2025: 75.0% men, 25.0% women (2024: 87.5%/12.5%), 16 individuals in total. Age breakdown: under 30 -- 9.5% (94 employees); 30-50 -- 50.5% (502); 50+ -- 40.0% (398). Employees with a recognised disability or equivalent status: 3.2% overall (2024: 2.9%) -- 4.0% of female staff and 2.6% of male staff.

Adequate wages

Reference: page 114.

"DZ HYP ensures that its employees receive fair pay and that any applicable statutory benchmarks are adhered to," implementing the German Pay Transparency Act (EntgTranspG) including employees' individual right to information. Fixed remuneration for collectively-agreed staff follows sector collective bargaining agreements; for others it is set by status, market conditions and qualifications. "None of DZ HYP's employees are paid below the applicable benchmark for adequate wages (industry or collective pay scale comparison).

Social protection

Reference: page 116.

Employees subject to German social security are covered against loss of earnings from illness (statutory health insurance), retirement (statutory pension insurance), unemployment (statutory unemployment insurance) and workplace accidents/disability (statutory accident and disability insurance); parental-leave employees receive statutory parental allowance. Occupational benefits on top of this statutory floor include group accident insurance, financial support for surviving dependants, a company pension scheme for permanent staff, and tax-free capital-formation grants for all employees.

Persons with disabilities

Reference: page 112.

"The proportion of severely disabled employees and employees with equivalent status at DZ HYP came to 3.2 per cent (2024: 2.9 per cent) in the 2025 financial year. 4.0 per cent of our female members of staff and 2.6 per cent of our male employees were disabled." The 2002 German Social Code (SGB IX section 2(1)) definition applies; a representative body for severely disabled employees and an Inclusion Officer represent their interests, under the 2022 DZ BANK Group Inclusion Agreement.

Training and skills development metrics

Reference: pages 123-124.

"DZ HYP employees completed an average of 27.9 hours of training per person in the reporting period (2024: 20.6 hours)." By gender: male employees averaged 29.4 hours (2024: 21.7) and female employees 25.9 hours (2024: 19.2). Seven trainees completed the programme in 2025 (with permanent-position offers) and seven new trainees started across Real Estate Finance, IT, Finance, Risk Controlling and Data Analysis/Process Management.

Health and safety metrics

Reference: pages 121-122. The company's own Appendix B table marks "fatalities and rate of work-related accidents" and "days lost to injuries/accidents/fatalities/illness" as Material (page 79).

For 2025 (2024 in brackets): 100% of employees covered by statutory OHS requirements (100%); 0 fatalities (0); 8 reportable workplace accidents (11); accident rate 4.9 (7.3); 0 cases of recordable work-related ill health (0); 0 days lost to work-related injuries/fatalities (0); 0 cases of work-related ill health (0).

Work-life balance metrics

Reference: pages 111-112 (flexible/mobile working arrangements), 115-116 (family leave).

Working-hours and mobile-working arrangements are governed by employer/works-council agreements covering sabbaticals, flexible hours and hybrid working. "In the year under review, 7.1 per cent of female employees (2024: 7.3 per cent) and 3.0 per cent of male employees (2024: 2.8 per cent) -- or 4.7 per cent of employees in total (2024: 4.6 per cent) -- took advantage of" family leave (parental leave, care leave).

Compensation metrics (pay gap and total compensation)

Reference: pages 118-119. The company's own Appendix B table marks both datapoints Material (page 79).

"The unadjusted pay gap at DZ HYP is 16.9 per cent (2024: 18.9 per cent), while the adjusted pay gap is 4.0 per cent," the adjusted figure controlling for organisational unit and level of responsibility. "The ratio of the remuneration paid to the highest-paid individual and the median remuneration within DZ HYP's workforce was 12.9 in the year under review (previous year as per updated method: 12.9; previous year as per previous method: 12.4)," with Management Board members included in the numerator and excluded, along with the highest-paid individual, from the median.

Incidents, complaints and severe human rights impacts

Reference: page 118. The company's own Appendix B table marks "Incidents of discrimination" as Material and "Non-respect of UNGPs/OECD Guidelines" as "Not applicable" (page 79).

For 2025 (2024 in brackets), all nil: work-related discrimination/harassment incidents 0 (0); complaints received via DZ HYP channels 0 (0); fines/penalties/compensation paid EUR 0 (EUR 0); severe human rights incidents involving the workforce 0 (0); violations of the UNGPs/OECD Guidelines 0 (0); complaints filed through OECD National Contact Points 0 (0). No AGG (equal treatment law) violations or complaints were registered in 2025.

Policies related to consumers and end-users

Reference: pages 127-128. The company's own Appendix B table marks "ESRS S4-1 - Policies related to consumers and end-users" Material (page 79).

The DZ BANK Group Human Rights Guideline extends to "employees, suppliers, clients, society and the environment," aligned with the UN Global Compact and the ILO. A dedicated internal data protection policy applies to all staff; the Management Board is responsible for GDPR compliance, with effectiveness evidenced through internal audits by Internal Audit or the Data Protection Officer and ongoing incident management.

Processes for engaging with consumers and end-users about impacts

Reference: page 128.

Creditworthiness for Retail Customers is largely assessed by intermediating cooperative banks under DZ HYP's provisions; borrowers can apply to adjust repayments up to three times during the fixed-interest period and can make individual arrangements if facing financial difficulty. DZ HYP checks customers' financial status and sustainable debt-servicing capacity under the EU Mortgage Credit Directive. "To date, no standardised procedure has been established for assessing whether clients are aware of the ways in which they can voice their concerns or needs.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: pages 128-129.

Clients can lodge complaints via "the central complaints address shown on the DZ HYP website"; Compliance forwards retail, corporate-client or public-sector complaints to the relevant Sales department for resolution. "No serious problems or incidents related to clients were reported to DZ HYP during the reporting period.

Taking action on material impacts on consumers and end-users

Reference: pages 128-129.

DZ HYP applies DZ BANK Group exclusion criteria, sector principles and the Group ESG lending standard to financing and investment decisions, refusing to finance activities illegal under target-country or international law, including breaches of child/forced-labour standards. It assesses sustainable mortgage lending values and debt-servicing capacity to protect retail customers from over-indebtedness, finances affordable-housing projects for housing companies in the Corporate Clients segment, and runs a standardised ESG ranking of municipal public-sector clients built on the 17 UN SDGs.

Targets related to managing material impacts, advancing positive impacts and managing risks/opportunities (Clients)

Reference: page 128.

"DZ HYP did not have any measurable targets for managing material impacts, risks and opportunities relating to its clients during the reporting period. Given perceived high client satisfaction, quantitative targets have not been deemed necessary to date." DZ HYP instead describes qualitative aims: strengthening its Real Estate Finance market presence through joint regional coverage with cooperative banks and increasing use of ESG criteria in lending decisions.

Business conduct policies and corporate culture

Reference: pages 130-132.

Governance is anchored in the DZ BANK Group Governance Policy (GGP), implemented via the Group Risk and Finance Committee, and in the Code of Conduct and Human Rights Guideline prepared with DZ BANK Group companies, covering legally compliant behaviour and sustainability-aware risk management. New Leadership Guidelines, developed with the Akademie Deutscher Genossenschaften through workshops and feedback rounds, were adopted in 2025 "to guarantee a healthy corporate culture and responsible corporate governance." DZ BANK joined the UN Global Compact in 2008 and DZ HYP adopted its ten principles in 2013.

Prevention and detection of corruption and bribery

Reference: pages 133-136.

"DZ HYP has zero tolerance of corruption and does not participate in any business that it suspects of being connected with such activities." The Compliance function, reporting directly to the Management Board, combines MaRisk compliance, capital-markets compliance and the Anti-Money-Laundering/fraud-prevention Central Unit. A whistleblowing system under EU Directive 2019/1937 / the German HinSchG lets internal and external whistleblowers report to an internal reporting unit run by the Compliance Officer; the Whistleblowing Committee "attempts to close the case after 15 workdays," and the Management Board receives written reporting on cases at least annually. Mandatory computer-based anti-corruption/anti-bribery training applies to effectively all employees.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of MDR-T-type disclosures rather than as a numbered requirement; G1-3 became a standalone DR only in the 2025/2026 ESRS.

Reference: pages 135-137.

"DZ HYP did not have any measurable targets for managing material impacts, risks and opportunities relating to compliance during the reporting period. Quantitative targets have not yet been deemed necessary to date, given that the impact regarding compliance has mainly been positive." Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of a target: "As at 31 December 2025, 92 per cent (2024: 100 per cent) of DZ HYP's employees in high-risk functions had completed their training"; "the members of the Management Board are briefed annually by the Head of Compliance on combating corruption and bribery"; and the internal reporting unit provides the full Management Board with written information on whistleblowing cases and outcomes at least once a year.

Incidents of corruption or bribery

Reference: pages 136-137. The company's own Appendix B table marks "Fines for violation of anti-corruption and anti-bribery laws" Material, and "Standards of anti-corruption and anti-bribery" "Not applicable" (page 79).

"In 2025, DZ HYP did not become aware of any corruption incidents and there were no convictions for breaches of anti-corruption and anti-bribery legislation or any fines imposed in this connection (2024: none)." Training completion for employees in high-risk functions (effectively all employees) was 92% (2024: 100%).

Political influence and lobbying activities

Reference: pages 134-135.

"DZ HYP considers itself to be an independent, politically neutral institution." Its lobbying-register entry (no. R002192) lists some sixteen memberships, including the Association of German Pfandbrief Banks (vdp), the National Association of German Cooperative Banks (BVR) and the German Property Federation (ZIA). "DZ HYP does not support any political parties and does not make any donations to political parties or affiliated institutions." During the year DZ HYP notified the lobbying register that it was "terminating its representation of interests activities" and is now listed as "formerly engaged in lobbying activities," with the entry due for deletion after 18 months. No Management Board or Supervisory Board appointee in the reporting period had held a comparable public-administration role in the prior two years.