FBD Holdings

Reference: page 113

FBD's Board applies the Irish Corporate Governance Code 2024 and is ultimately responsible for the Group's long-term sustainable success, with ESG included as a dedicated work stream within Group strategy since 2022. The CEO's report to the Board includes a quarterly sustainability update, and the Board and its Committees incorporate ESG considerations into decision-making where relevant. Named committees carry specific roles: the Audit Committee monitors the quality and integrity of the Sustainability Statement, the Board Risk Committee integrates ESG risks into the Risk Management Framework, and the Nomination and Governance Committee includes ESG in the Board Skills Matrix. Executive bodies supporting the Board include the Sustainability Committee, the Executive Risk Committee, the Executive Management Team (five ESG strategy pillars with named owners) and the Sustainability Working Group. Board composition, diversity and sustainability expertise are incorporated by reference to the Board Diversity report on pages 75-78. FBD has been a UNEP FI PSI signatory since 9 January 2024, and specific Board training was provided in 2025 on the entity-specific topic of Farm Safety.

Reference: page 113

The CEO's quarterly report to the Board includes a sustainability update, and Board Committees incorporate ESG considerations into their decision-making where relevant. The Audit Committee is responsible for monitoring the quality and integrity of the Sustainability Statement; the DMA outcome was approved by the Sustainability Committee in May 2024 and by the Audit Committee in October 2024, with an analysis conducted in 2025 to validate its continued appropriateness. The Sustainability Committee reviews and approves all ESG-related activity and oversees the IRO Management approach, including action plans and targets. Risks and negative impacts are reported to the Board Risk Committee for integration into the Risk Management Framework. How the Board is informed about the views and interests of affected stakeholders on sustainability-related impacts is addressed through the Stakeholder Framework and engagement described on pages 67 to 70 and 127 to 129, and through the Audit Committee's review of the DMA.

Reference: page 114

The Remuneration Committee is responsible for ensuring the Group's overall reward structures align with the achievement of Group strategy. Although no specific percentage of variable remuneration is formally allocated to ESG performance or climate-related considerations, the Committee has set ESG objectives for the Group CEO and Group CFO aligned to implementation of the ESG strategy, and FBD states it currently has ESG-linked incentives in place for both roles. The Report on Directors' Remuneration on pages 80 to 102 sets out the key characteristics of incentive schemes, the specific sustainability-related targets used to assess performance, how sustainability-related metrics are considered in remuneration, and the level at which incentive-scheme terms are approved and updated, including the determination of the annual performance bonus for the year ended 31 December 2025. Activities of the Remuneration Committee during the period are detailed on pages 65 to 66.

Reference: page 184

FBD provides a statement on sustainability due diligence in the appendix, mapping where in the Sustainability Statement information about the due diligence process is disclosed against the core elements of due diligence: embedding due diligence in governance, strategy and business model; engaging with affected stakeholders at all key steps; identifying and assessing adverse impacts; taking actions to address adverse impacts; and tracking effectiveness and communicating. The mapping cross-references GOV-2, SBM-2, SBM-3, IRO-1 and the topical policies, actions and targets disclosures for E1, S1 and S4. The insights gained from FBD's ongoing due diligence processes were leveraged to inform the materiality assessment, and the Group has an ESG Due Diligence Framework and IRO Management approach in place, rolled out following the 2024 DMA, that supplements the Risk and Control Self-Assessments completed by business units.

Reference: page 116

Risks relating to ESG matters are managed and reported in line with FBD's Risk Management Framework, using the Group's three lines of defence approach described in the Risk and Uncertainties Report on pages 18 to 27. The main features of internal control supporting preparation of the Sustainability Statement include a comprehensive policy architecture, a defined ESG Sustainability Governance Framework, a skilled cross-functional Non-Financial Reporting Team and working groups, defined targets and metrics, data validation using appropriate software, preparation and review of qualitative and quantitative disclosure checklists, and a controlled process flow from data collection to disclosure with management review. Key assumptions, judgements and estimates are reviewed by senior management and the Sustainability Committee before being presented to the Audit Committee for approval, alongside Board Risk Committee oversight of sustainability-related risks and Internal Audit review of key processes.

Reference: page 16

FBD's business model and strategy are set out in the Management's Review and incorporated by reference into the Sustainability Statement. As a leading Irish general insurer, FBD's significant products and services and its significant markets and customer groups (Farmer, Business and Retail segments) are described on page 16, alongside the inputs FBD gathers, develops and secures (its people, suppliers and partners, investors), and the outputs and outcomes it creates for customers, investors and other stakeholders across product proposition, claims management, capital management and distribution. The disclosure covers the main features of FBD's upstream and downstream value chain and its position within it, spanning supply chain workers and investors upstream, own operations (underwriting, claims, people, workplaces), and customers and wider society downstream. ESG has been a dedicated work stream within Group strategy since 2022, reflecting FBD's commitment to the UN Principles for Sustainable Insurance.

Reference: page 67

FBD's engagement with stakeholders is underpinned by a Board-approved Stakeholder Framework, reviewed annually, that outlines how the Group communicates with and hears from its key stakeholders: investors, own workforce, customers, regulators, government and industry bodies, and wider society and ESG. The Board is regularly updated on stakeholder engagement and its views, and the Audit Committee's review of the DMA is a further channel through which the Board is informed about affected stakeholders' interests regarding sustainability-related impacts. Stakeholders were engaged specifically in the context of the materiality assessment through interviews and surveys, split between affected stakeholders and users of the Sustainability Statement, to help develop an understanding of how employees and consumers with particular characteristics may be at greater risk of harm. No specific amendments to FBD's strategy or business model were required, or are anticipated, as a direct result of this engagement.

Reference: page 117

Following its DMA, FBD concluded that four topical ESRS are material: E1 Climate Change, S1 Own Workforce, S4 Consumers and End-Users, and G1 Business Conduct, with Farm Safety (under S4) and, newly this year, Cybersecurity (under G1) identified as entity-specific sustainability matters. As part of the 2025 validation of the 2024 DMA, the four material topics were confirmed, the S1 sub-topic of Health and Safety was no longer deemed material, and Cybersecurity was introduced as a material entity-specific topic. The number of material IROs reduced from forty to thirty-five, reflecting mergers of similar IROs, removal of impacts already covered by local legislation, and two new IROs added under G1 for societal impact and cybersecurity exposure. Material sub-topics, sub-sub-topics and entity-specific topics are mapped by topic on pages 118 to 124, with individual IROs listed by risk type, time horizon and value chain position; FBD identified no significant risk of a material adjustment to asset and liability carrying amounts within the next reporting period.

Reference: page 125

FBD's DMA followed EFRAG Implementation Guidance, with the initial assessment performed in 2024 and an analysis conducted in 2025 to validate its continued appropriateness. The five-step process comprised: a top-down assessment reviewing the business model, peer reporting and industry insights, which screened out pollution, water, biodiversity, circularity, workers in the value chain and affected communities as not relevant; value chain and stakeholder analysis using EFRAG IG 2 to identify relevant value chain actors based on exposure to impacts and dependency; identification and validation of a longlist of IROs refined into a shortlist; stakeholder engagement and scoring through surveys, interviews and workshops, against an impact materiality threshold of 8 out of 15 (scale, scope, remediability, weighted by likelihood for potential impacts) and a financial materiality threshold of 2 (magnitude weighted by likelihood); and validation and approval. IROs are assessed on a gross basis. The DMA outcome was approved by the Sustainability Committee in May 2024 and the Audit Committee in October 2024.

Reference: page 180

FBD sets out the disclosure requirements covered by its Sustainability Statement in an appendix listing, for each cross-cutting and material topical DR, the report section and page where it is addressed. The Statement is prepared in accordance with Part 28 of the Companies Act 2014 and in compliance with the ESRS issued by EFRAG. Of the twelve binding ESRS, ESRS 1 and ESRS 2 are mandatory cross-cutting standards; of the ten topical standards, four were found material (E1, S1, S4, G1) following the DMA, with Farm Safety and Cybersecurity reported as entity-specific matters. FBD, a first-wave mandatory reporter, continued to avail of the ESRS 1 Appendix C phased-in disclosure concessions where applicable, with the exception of S4, which it elected to keep reporting in full following the 'quick-fix' delegated act. The Sustainability Statement, covering pages 104 to 188, was subject to limited assurance by PricewaterhouseCoopers.

Reference: page 134

FBD does not currently have a climate mitigation transition plan. While it may explore the development and adoption of one in the future, the timelines for this had not been established as at the reporting date, and any consideration of a transition plan would also include examining the feasibility of implementing GHG emission reduction targets. FBD does not currently have GHG emission reduction targets in place; such targets would only be considered as part of a future transition plan, whose creation remains under review into 2026. Instead, FBD manages climate-related exposure through targeted decarbonisation actions (renewable electricity, solar panel installations, energy efficiency upgrades), a portfolio-level carbon intensity reduction target for its Corporate Bond Portfolio, investment exclusions, and a Climate Resilience Analysis using the NGFS scenario framework, described on pages 139 to 141.

Reference: page 139

Back-filled from the E1 IRO table (pages 119-120) and the Climate Resilience Analysis (pages 139-141). FBD's material climate IROs are individually classified as physical or transition risk in the IRO table, for example increased claims and reinsurance cost/availability (physical) versus reduced returns on carbon-intensive assets and shrinking insurable activity (transition). For scenario analysis, FBD selected the NGFS Nationally Determined Contributions (NDCs) scenario as its baseline, alongside two counterfactuals: Net Zero 2050, a 1.5°C-aligned scenario with no or limited overshoot consistent with the Paris Agreement, and Delayed Transition. Mean temperature increases of 1.5°C (short-term), 1.9°C (medium-term) and 2.3°C (long-term) are used under the NDCs scenario. The analysis covers FBD's Irish underwriting and investment operations, with key assumptions drawn from the NGFS framework, physical risk assessment of FBD sites, and a peer-informed 'RO Universe'; it was carried out in 2024 and reviewed for continued appropriateness in 2025, with no revision warranted. Climate-specific risk identification and scenario analysis is also presented under ESRS 2 IRO-1 and SBM-3.

Reference: page 139

Back-filled from the E1 Climate Resilience Analysis (pages 139-141) and ESRS 2 SBM-3. FBD quantified four components under its NGFS-based scenario analysis (premium volume, loss ratio including reinsurance availability, asset shock across bond and risk asset portfolios, and operational resilience to flood risk) at Short Term (2030) and Medium Term (2050) horizons, finding no material short-term impact across scenarios. Political/legal, economic, social and technology risks are assessed as greatest under Net Zero 2050 and Delayed Transition, while environmental risk is greatest under the NDCs baseline due to higher physical risk. Adaptive capacity is described through the reinsurance programme, flood risk modelling feeding into exposure management, the Weather Resilience review launched after Storm Éowyn, and continued monitoring of FBD's 'RO Universe'. FBD has not performed a resilience analysis with a formally defined output metric beyond this exercise; the baseline scenario was reviewed but not revised in 2025. This content is also referenced under ESRS 2 SBM-3 and IRO-1.

Reference: page 135

FBD maintains policies addressing climate change as an insurer, an investor and a company. As an insurer, the Underwriting Policy and Product Oversight and Governance Policy (both owned by the Chief Underwriting Officer) and the ORSA Policy (Group Chief Risk Officer) address climate change adaptation, all approved by the Board at least annually. As an investor, the Investment Policy (Head of Investments) addresses adaptation through ESG exclusions and limits, maximising returns within the Board-approved risk appetite. As a company, the Reputational Risk Policy (Group CEO) covers climate impacts on reputation, and the Non-Financial Reporting Policy (Group CFO) governs how energy consumption and GHG metrics are prepared and controlled. The Capital Management Policy (Group CFO) also addresses climate change adaptation through capital planning principles. Policy objectives, owners and Board approval cadence are set out in tables on pages 135, 137 and 138.

Reference: page 136

As an insurer, FBD completed a Property review and a post-Storm Éowyn Weather Resilience review, remains active in the Insurance Ireland Flood Taskforce, uses specialist flood risk modelling in reinsurance and exposure planning, and carries out annual climate scenario analysis under CBI guidance. As an investor, FBD's external asset managers are selected partly on ESG capability and are signatories to the UN PRI and UK Stewardship Code; it tracks investment portfolio emissions via a third-party verifier and has committed €5m to a private markets Global Impact Fund. As a company, FBD completed installation of solar panels at Head Office, Portlaoise and Tralee (estimated to save 606 tCO2eq over 20 years, c.€150,000 gross cost), upgraded HVAC and heat pump equipment, refurbished or recycled over 300 laptops (15 tCO2eq avoided), reduced compostable cup purchases, and achieved a CDP 'B' rating for 2025, unchanged from 2024.

Reference: page 142

FBD's Investment Policy sets an absolute target of zero investments in controversial weapons, civilian firearms, and companies deriving over 1% of revenue from nuclear weapons, Arctic drilling, oil sand mining, thermal coal extraction or high pollution (over 3,000 tonnes CO2e per $USDm revenue), with a 2023 base year; FBD was in compliance in 2025. A 60% target reduction in the carbon intensity of the Corporate Bond Portfolio is set over the nine years from 1 January 2021 to 31 December 2029, against a 258 tCO2/m$USD revenue baseline; FBD exceeded its yearly targets, with the total reduction versus baseline reaching 79.1% at 31 December 2025 (2024: 74%). ESG rating limits cap allocations to lower-rated securities (0% to F, 5% maximum to E, 20% to D), with which FBD complied in 2025. These targets were set by the Investment Committee, are not directly linked to scientific evidence, and are reviewed annually; FBD does not currently have GHG emission reduction targets.

Reference: page 143

FBD's total energy consumption in 2025 was 2,443 MWh (2024: 2,500 MWh). Fossil sources accounted for 307 MWh, or 12.6% of the total, from natural gas, LPG, heating oil and hydrocarbon oil (2024: 12.9%). Renewable sources accounted for 2,136 MWh, or 87.4% (2024: 87.1%), all from purchased or acquired electricity certified as 100% renewable; FBD produces no energy of its own, so there is no fuel consumption for renewable sources and no self-generated non-fuel renewable energy. Consumption and share from nuclear sources were nil, as FBD does not consume nuclear energy. FBD states it does not have any operations in high climate impact sectors and has therefore not disclosed the additional metrics required of entities with such operations.

Reference: page 144

FBD's gross Scope 1 GHG emissions for 2025 were 62 tCO2eq (2024: 66), with the decrease driven mainly by lower LPG consumption. Gross location-based Scope 2 emissions were 348 tCO2eq (2024: 489), while market-based Scope 2 remained nil, as FBD only purchases energy backed by 100% bundled Guarantees of Origin. Total gross Scope 3 emissions were 29,700 tCO2eq (2024: 37,743, restated), with investments (category 15) the largest contributor at 22,019 tCO2eq, followed by purchased goods and services at 4,574 tCO2eq and employee commuting at 1,577 tCO2eq. Total GHG emissions were 30,110 tCO2eq location-based and 29,762 tCO2eq market-based. GHG intensity per net revenue fell to 0.06 tCO2eq per €'000 on both bases (2024: 0.09). Only 1.8% of Scope 3 emissions were calculated using primary data (2024: 1.6%). During 2025 FBD enhanced its methodology for business travel and employee commuting, restating 2024 comparatives; categories 4, 8, 9, 10, 11, 12 and 14 remain not material.

Reference: page 146

FBD has no GHG removal and storage activities in place. Up to 2025, FBD purchased carbon credits annually from Vita, verified by the Gold Standard and based on avoidance projects, supporting community boreholes and safe water in Ethiopia and Eritrea; the 2025 purchase amounted to €23,000 of operating expenses (2024: €17,000). From 2026, FBD has made a strategic decision to redirect resources previously allocated to carbon credit purchases toward additional advocacy and research projects more closely aligned with its core business and potential for direct impact. Carbon credits cancelled in 2025 totalled 1,943 tCO2eq (2024: 1,446), all under recognised quality standard 1, with 0% from removal projects, EU projects or corresponding adjustments. Given the shift away from future purchases, no further carbon credits are planned to be cancelled beyond 2025.

Reference: page 147

FBD does not have an internal carbon pricing scheme in place, meaning it does not apply an internal monetary value per tonne of GHG emissions to inform its own investment or underwriting decisions. The Group states there are no plans to create such a scheme in 2026. FBD's climate-related financial mechanisms instead take the form of the Corporate Bond Portfolio carbon intensity target and the Investment Policy's ESG exclusions and rating limits described under E1-4, rather than a carbon price applied internally across the business.

Reference: page 155

FBD's key workforce policies include the Equal Opportunities, Diversity and Inclusion Policy and the Safety Statement (both owned by the Group Chief HR Officer), the Professional Development and Education Support Policy, and the Data Protection and Information Security Policies, each with a named owner and approver and reviewed at least annually. Human rights commitments relating to the own workforce sit within the Code of Conduct Policy, owned by the Group Chief HR Officer and reviewed at least annually by the Board, which explicitly addresses freedom of association, the right to collective bargaining, elimination of forced or compulsory labour, effective abolition of child labour, and elimination of discrimination in employment. FBD respects the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. Policies are communicated to all employees during onboarding, apply across every stage of employment, and are refreshed via e-learning.

Reference: page 155

FBD gauges workforce sentiment through its annual employee listening survey (myVoice), managed in 2025 using software from Willis Towers Watson, which benchmarks results against Ireland norms. Ongoing engagement runs through one-to-one meetings between employees and people leaders, team meetings, and business unit and company town halls. FBD engages regularly with Employee Representative bodies, including the trade union Unite and the internal Field Staff Association, for collective bargaining as required and more regularly to share information; during 2025 FBD shared its inaugural FY2024 Sustainability Statement with workers' representatives. An independent Non-Executive Director, Olive Gaughan (appointed February 2025), serves as Director of Engagement with the Workforce, visiting locations including Head Office, the Mullingar Sales Centre and branches, and reporting insights to senior management and the Board. The Group Chief HR Officer oversees engagement with the own workforce.

Reference: page 156

Own workers can raise concerns through the Speak-Up/Whistleblowing process set out in the Speak-Up Policy, with protection against retaliation described further under G1 Business Conduct. Employee grievances and interpersonal-conflict concerns, including bullying or harassment, are addressed through dignity-at-work, recruitment and selection, and disciplinary and grievance policies and procedures. Employees can act with support from an internal support person or progress a formal complaint; complaints are handled confidentially and expeditiously, and employees who complain will not be victimised, though false accusations may lead to disciplinary action. Six incidents were raised through these remediation channels during 2025 (2024: five). Incidents raised are tracked and monitored through designated channels, policies are accessible online, mandatory training on whistleblower reporting and the Code of Conduct is rolled out to all employees, and FBD gains insight into channel effectiveness through the listening survey and wider engagement.

Reference: page 157

Across secure employment, working time and human rights, FBD supports social protection for sickness, employment injury, parental leave and retirement, offers a pension scheme open to employees over 25, and provides paid and unpaid family-related leave including a Fertility Treatment Policy offering up to five additional paid days. On work-life balance, FBD runs a Health and Wellbeing strategy with Mental Health First Aid training (45 certified first aiders in 2025), an Employee Assistance Programme, occupational health support, and a bi-annual Health Screening Programme with annual flu vaccinations. On gender equality and diversity, FBD is a Women in Finance Charter signatory since 2022, a VOiCE founding partner, maintained Investors in Diversity Gold accreditation in 2025, partnered with Back to Work Connect and AsIAm, and produced its fourth gender pay gap report in November 2025. Effectiveness is monitored through targets, the listening survey and ongoing workforce engagement.

Reference: page 159

FBD has interim and headline gender diversity targets for female representation across management levels: 40% at Board by 31 December 2025 (45.5% achieved), 40% at Executive/C-Suite by 31 December 2026 (30.0% achieved), 40% at Senior Management by 31 December 2026 (44.4% achieved, exceeding the interim 35% target), 35% at Middle Management by 31 December 2026 (47.4% achieved) and 55% at Junior Management by 31 December 2026 (45.9% achieved). The Group CEO and Leadership Team are accountable for measuring, monitoring and publicly reporting progress annually. FBD also targets matching or exceeding the Ireland norm for positive Culture sentiment (including work-life balance) in its listening survey, and maintained its Investors in Diversity Gold accreditation target in 2025. No measurable outcome-oriented targets were set for the secure employment and working-time sub-sub-topics, as no measurable target was identified.

Reference: page 164

As at 31 December 2025, FBD reported 1,084 employees on a headcount basis, all located in Ireland, a change in methodology from the FTE basis used in the FY2024 Sustainability Statement (restated 2024 comparative: 1,053 headcount). Of these, 1,045 were permanent employees and 39 temporary, with no non-guaranteed-hours employees. During the reporting period there were 135 leavers against an average of 1,089 employees, giving a total employee turnover rate of 12.4% (2024, restated: 14.8%). Turnover is calculated as the number of employees who left, whether voluntarily or through dismissal, retirement or death in service, relative to the average number of employees during the period. Note 9 of the financial statements presents the average number of people employed on a headcount basis.

Reference: page 157

Coverage of collective bargaining agreements for FBD's EEA employees (Ireland) falls in the 80-100% band; there were no non-EEA employees in scope. Workplace representation for social dialogue (EEA only) is likewise in the 80-100% band for Ireland. Employees covered by collective bargaining agreements are those to whom FBD is obliged to apply the agreement, rather than the percentage of unionised employees. FBD engages regularly with its Employee Representative bodies, the trade union Unite and the internal Field Staff Association, for collective bargaining as required and more regularly to share information and discuss matters important to member colleagues.

Reference: page 161

As at 31 December 2025, FBD's headcount of 1,084 comprised 663 female, 415 male, 1 other (self-reported) and 5 not reported (2024, restated to headcount: 642 female, 400 male, 1 other, 10 not reported). Female representation across management was 45.5% at Board, 30.0% at Executive/C-Suite, 44.4% at Senior Management, 47.4% at Middle Management and 45.9% at Junior Management. By age, 19.6% of employees were under 30, 60.8% were 30-50 and 19.6% were over 50 (2024: 20.2%, 60.9%, 18.9%). Age diversity is calculated on headcount, excludes non-employees such as non-executive Directors, and is determined from date of birth recorded on the HR system.

Reference: page 157

FBD ensures employees' working hours and pay rates comply with national legislation and industry standards. All FBD employees are paid an adequate wage in line with applicable benchmarks, and none are on a non-guaranteed-hours contract. As all employees are based in Ireland, purchasing power adjustments are not relevant to this disclosure. This sits alongside the wider remuneration picture reported elsewhere in the Sustainability Statement, including the pension scheme open to employees over 25, the compensation metrics reported under S1-16, and the paid and unpaid family-related leave entitlements described under S1-4.

Reference: page 162

FBD reports a gender pay gap of 28.5% for 2025 (2024: 29.0%) and an annual total remuneration ratio of 34.6 (2024: 30.6). On 15 November 2025 FBD produced its fourth gender pay gap report, with the primary driver remaining under-representation of women in senior and revenue-generating roles. The gender pay gap is calculated as the difference between average female and male pay expressed as a percentage of average male pay, using gross annual and hourly pay; the CSRD figure includes LTIP share awards and pension contributions, which are excluded from the figure reported under Irish legislation. The annual total remuneration ratio compares the highest-paid individual's remuneration to median employee remuneration, incorporating base salary, variable remuneration, and benefits in kind, calculated across all employees as at 15 June.

Reference: page 156

Six incidents were raised through FBD's remediation channels during 2025 (2024: five). There were no work-related incidents of discrimination reported to Human Resources or via the whistleblower system on grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age or sexual orientation, including harassment, in the current or prior period, and no fines, penalties or compensation for damages arose from the incidents and complaints disclosed. No cases of human rights incidents such as forced labour, human trafficking or child labour were identified during the current or prior reporting period; no significant risk of such incidents was identified given FBD operates only in Ireland, where human and labour rights obligations are reflected in domestic law.

Reference: page 168

FBD's consumer-facing policies span privacy and social inclusion. On privacy, FBD has a designated Data Protection Officer and policies including the Data Protection Policy, Information Security Policy, Data Protection Statements, Cookie Policy, Records Retention Policy and Clean Desk and Clear Screen Policy, all reviewed at least annually and aligned with GDPR and the Data Protection Acts. On social inclusion, FBD does not discriminate on grounds prohibited by the Equal Status Acts 2000-2015, applies robust pricing governance and an annual Pricing Practice Review, and maintains a Customers Requiring Additional Support Policy, owned by the Group Chief Commercial Officer and reviewed annually by the Consumer and Culture Committee, covering customers in vulnerable circumstances. The Code of Conduct Policy addresses internationally recognised human rights relating to consumers, and the Consumer Complaints Policy is owned by the Complaints Steering Group and reviewed at least annually.

Reference: page 166

FBD gains customer insight through ad-hoc market research, regular third-party brand health checks, and website usability testing at least twice a year, supported by targeted user interviews and web analytics. It communicates via Facebook, X and LinkedIn, offers a 'Contact us' channel, and partners with Trustpilot so customers can rate and review their experience, inviting feedback by email after a purchase. Board and Executive Management Team members undertook customer site visits during a dedicated customer day in June 2025, and a Board member's role as President of the Irish Farmers' Association and Vice President of COPA provides a further channel into the farming customer base. The Consumer and Culture Committee, a sub-committee of the Executive Management Team chaired by the Group Chief Commercial Officer, monitors consumer risk appetite metrics from quarterly operational updates to assess engagement effectiveness.

Reference: page 168

FBD operates a complaints process, published on its website, allowing complaints by phone, in person at any sales office or by email. All employees are expected to know the process and aim to resolve complaints at first point of contact; complaints under formal investigation are logged immediately in the complaints database and managed in line with Consumer Protection Code regulations. Unresolved complaints can be referred to the Financial Services and Pensions Ombudsman (FSPO), which investigates once FBD has had a reasonable opportunity to resolve the matter. Service providers acting for FBD submit complaint logs at least quarterly, and the Executive Management Team receives a quarterly overview of all complaints, including those escalated to the FSPO. No cases of non-respect of the UN Guiding Principles, ILO Declaration or OECD Guidelines involving consumers were reported in the downstream value chain during the current or prior period.

Reference: page 169

On privacy, FBD conducts annual reviews of data protection notices, periodic privacy impact and maturity assessments, launched an internal Data Protection newsletter in 2025, and rolls out annual GDPR training. On social inclusion, FBD is progressing web accessibility ahead of the European Accessibility Act, trained content creators, designers and developers on accessibility, and is a member of Age Friendly Ireland. On the entity-specific Farm Safety matter, actions span communications and awareness (9,000 farm safety signs distributed, Farm Safety Week with the IFA, the National Marts Farm Safety Awareness and Remembrance Campaign), accident prevention (a dedicated Risk Survey Team, FSPAC membership, the FBD Health and Safety Awards, Farm Safety Live) and training (Teagasc exhibits, tailored tractor training for 14-16 year-olds, and Champions for Safety seminars across agricultural colleges).

Reference: page 172

FBD targets an average Trustpilot score of 2.8 out of 5 or higher; its actual average score at 31 December 2025 was 4.8. FBD also targets fewer than three upheld FSPO complaints (full or partial) in any given year, and 2025 marked the second consecutive year with no upheld FSPO complaints against FBD. For the entity-specific Farm Safety matter, FBD will continue supporting farm safety initiatives but does not plan to set targets in this area, given the downstream impact of farm safety outcomes lies outside FBD's direct control.

Reference: page 174

FBD considers ethics and adequate governance structures material from a financial perspective, with the Board and senior management setting the ethical tone. Board-approved policies reviewed at least annually shape employee behaviour, including the Code of Conduct, Conflicts of Interest, Speak Up, Reputational Risk, Anti-Fraud, Fitness and Probity, Individual Accountability and Conduct Standards policies. The Code of Conduct sets five standards - Integrity and Honesty, Errors Prevention and Reporting, Confidentiality, Professionalism and Compliance - covering gifts and hospitality and conflicts of interest, with elevated attention on Finance, Claims and Sales functions. A Competency Framework links FBD's values (Respect, Belief, Continuous Improvement, Community, Accountability, Engagement) to behaviours. FBD implements the Central Bank of Ireland's Individual Accountability Framework, including the Senior Executive Accountability Regime, Conduct Standards and Fitness and Probity certification, and whistleblower protection is set out in the Speak Up Policy.

Reference: page 177

FBD identifies penalties and reputational damage from delayed payments to suppliers as a material matter within Management of Relationships with Suppliers. FBD sets high standards for its supply chain through the publicly available FBD Supplier Charter, referenced by hyperlink on all Purchase Orders and, for larger strategic agreements, as a clause whose breach constitutes a material breach of agreement. Suppliers must comply with relevant legislation, respect FBD's Health and Safety culture, and are expected to pay employees at least minimum wage or the prevailing industry wage. The centralised Procurement Policy, owned by the Group CFO and reviewed at least annually by the Executive Management Team, embeds an ESG questionnaire that typically forms 10% of tender scoring, and assigns suppliers to tiers by contract value and risk, with regular due diligence and performance reviews of Critical Outsource Service Providers.

Reference: page 176

FBD's commitment to high ethical and professional standards is set out in its conduct policies, with the Speak Up Policy covering concerns relating to bribery and corruption. The Code of Conduct governs gifts and hospitality, requiring declaration above a minimal threshold. FBD conducts an annual business-wide anti-money laundering (AML) and countering the financing of terrorism (CFT) risk assessment coordinated by its Compliance Function, covering customer identification and verification, ongoing monitoring, suspicious transaction reporting, financial sanction screening, mandatory group-wide training, and compliance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010, with enhanced due diligence for high-risk and politically exposed customers. The AML/CFT Policy is owned by the Head of Compliance (PCF-52) and reviewed at least annually by the Board. Mandatory compliance training reached 100% coverage across functions-at-risk in both 2025 and 2024.

Reference: page 179

FBD has not set time-bound, outcome-oriented targets for managing its material business conduct IROs, including the entity-specific Cybersecurity matter within G1; the report states this reflects the evolving nature of the cyber-threat environment, continued digitisation of the business, and the need to establish a stable baseline first. In place of formal targets, effectiveness is tracked through internal KPIs - including security posture tests, vulnerability scans, P1 security incident records and data breach records - reviewed regularly by senior management and the Board, alongside near-universal (100%) mandatory compliance training coverage on ethics, anti-money laundering, the Code of Conduct and related topics across both 2025 and 2024. FBD states it will keep its readiness to define formal targets for managing these material IROs under review as governance and controls mature.

Reference: page 177

No convictions or fines for violation of anti-corruption or anti-bribery laws were reported during 2025 or the prior period. While FBD continually reviews and enhances its control environment, no specific actions were required to address breaches in procedures and standards of anti-corruption and anti-bribery. Concerns relating to bribery, corruption or fraud can be raised through the Speak Up Policy, and the annual business-wide AML/CFT risk assessment coordinated by the Compliance Function supports FBD's ongoing efforts to prevent and address such incidents. The Anti-Fraud Policy sets out roles and responsibilities for reporting and investigating fraud. Following any formal investigation, the Group Chief HR Officer informs the Group CEO, Group CFO, Audit Committee Chairs and the FBD Holdings plc and FBD Insurance plc Chairs of the conclusion and any action taken, and reports periodically to the Audit Committee on Speak Up activity.

Reference: page 177

FBD does not apply payment terms to supplier invoices and so does not delay payments to match credit terms; payments are made in the next available payment run once an invoice and supplier are fully approved, with standard runs made three times per month and continuous monitoring embedded within the Risk Management Framework. In 2025 suppliers were paid on average 34 days from invoice date (2024: 35 days), within FBD's target of less than 38 days; this excludes amounts paid directly to suppliers linked to individual claims, which are monitored under the Central Bank of Ireland's Consumer Protection Code. There were no legal proceedings outstanding for late payments at either the current or prior year-end reporting date.