FBD Holdings

FBD describes how the Board applies the UK Corporate Governance Code 2018 and the Irish Corporate Governance Annex, with roles and responsibilities set out in the Corporate Governance Report. The Board is ultimately responsible for the long-term sustainable success of the Group, and since 2022 ESG has been a dedicated work stream within Group strategy. The CEO report to the Board includes a quarterly sustainability update. Board committees carry defined 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, the Nomination and Governance Committee includes ESG in the Skills Matrix, and the Investment Committee oversees ESG exclusions and limits. Executive bodies include the Sustainability Committee, the Executive Risk Committee, the Executive Management Team with five ESG pillars, a Sustainability Working Group and a CSRD Project Steering Committee. Numbers of executive and non-executive members, board diversity and sustainability expertise are incorporated by reference. FBD became a UNEP FI PSI signatory on 9 January 2024.

FBD discloses how its governance bodies are informed about and address sustainability matters. The CEO report to the Board includes a sustainability update on a quarterly basis, and the Board and Board Committees incorporate ESG considerations, where relevant, as part of their decision-making. On behalf of the Board, the Audit Committee is responsible for monitoring the quality and integrity of the Sustainability Statement, and it approved the DMA approach and outcome in October 2024. The Sustainability Committee reviews and approves all ESG related activity, oversees the IRO Management approach including action plans and targets, and approved the DMA in May 2024. Risks and negative impacts are reported to the Board Risk Committee for integration into the Risk Management Framework. Information on how the Board is informed about the views and interests of affected stakeholders regarding sustainability-related impacts is provided through stakeholder engagement and the Audit Committee review of the DMA, disclosed by incorporation by reference.

FBD confirms that incentive schemes linked to sustainability matters exist for members of its governance bodies. The Remuneration Committee is responsible for ensuring the Group's reward structures are aligned with achievement of Group strategy. Although no specific percentage of variable remuneration is allocated to ESG performance or climate related considerations, the Remuneration Committee has set ESG objectives for the CEO and CFO aligned to implementation of the ESG strategy. FBD states it currently has ESG-linked incentives in place for the CEO and CFO, which it views as having a positive impact on prioritising the ESG agenda. The key characteristics of the incentive schemes, the specific sustainability-related targets used to assess performance, how sustainability-related performance metrics are considered in remuneration, and the level at which the terms of incentive schemes are approved and updated are all incorporated by reference to the Remuneration Policy, the Role of the Remuneration Committee, and the determination of the annual performance bonus for the year ended 31 December 2024.

FBD provides a statement on sustainability due diligence. A mapping of the information in the Sustainability Statement about the due diligence process is included within the appendix titled 'Statement on sustainability due diligence'. FBD explains that the insights gained from its ongoing due diligence processes were leveraged to inform its materiality assessment. As part of future-proofing its Impact, Risk and Opportunity management process, in the fourth quarter of 2024 FBD approved an ESG Due Diligence Framework and rolled out an IRO Management approach to supplement the Risk and Control Self Assessments that business units complete on an ongoing basis. FBD also notes it has designed governance processes to incorporate climate risks into its overall due diligence framework, with these governance processes to be implemented in 2025.

FBD describes its risk management and internal controls over sustainability reporting. Risks relating to ESG matters are managed and reported in line with the Risk Management Framework, using FBD's three lines of defence framework described in the Risk and Uncertainties report. FBD lists the main features of internal control for non-financial reporting, including a comprehensive policy architecture, the defined ESG Sustainability Governance Framework, a skilled cross functional CSRD reporting project team and working groups under experienced management, 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 before being presented to the Audit Committee for approval. Additional controls include Audit Committee review of the Sustainability Statement, Board Risk Committee oversight of sustainability-related risks, and Internal Audit review of key processes. The scope, risk assessment approach and main risks are incorporated by reference to the Risk and Uncertainties Report.

FBD discloses its strategy, business model and value chain, with the detailed Business Model and strategy incorporated by reference to the Management's Review section of the Annual Report. As an Irish general insurance group, FBD's significant groups of products and services, and the significant markets and customer groups served, are described in the Business Model. The disclosure covers inputs and the approach to gathering, developing and securing them, outputs and outcomes in terms of current and expected benefits for customers, investors and other stakeholders, and the main features of the upstream and downstream value chain together with FBD's position within it. Since 2022 ESG has been included as a dedicated work stream within FBD's overall Group strategy, reflecting its commitment to the UNEP FI Principles for Sustainable Insurance. FBD's value chain overview shows where material sustainability-related IROs arise across upstream, own operations and downstream, and states that all IROs are connected to its strategy and business model.

FBD discloses the interests and views of its stakeholders. Engagement is underpinned by a Board approved Stakeholder Framework, and the Sustainability Statement sets out how the Board is informed about the views and interests of affected stakeholders, including sustainability-related impacts, through stakeholder engagement and the Audit Committee review of the DMA. FBD identifies stakeholder groups as consumers, its people, investors, suppliers, communities, government and industry bodies, and regulators, and for each describes how engagement is organised, the purpose of engagement and examples of outcomes. Examples include product and service improvements for consumers, internal policy updates for employees, and farm safety workshops for communities. Stakeholders are split into affected stakeholders and users of the Sustainability Statement, and were engaged specifically in the context of the materiality assessment through interviews and surveys. FBD states that no specific amendments to its strategy and business model were required during the period or are anticipated as a direct result of this stakeholder engagement.

FBD discloses its material impacts, risks and opportunities and their interaction with strategy and business model. Following the DMA, FBD concluded that four topical ESRS are material: E1 Climate Change, S1 Own Workforce, S4 Consumers and End-Users, and G1 Business Conduct. Farm safety was identified as an entity-specific sustainability matter under S4. The material sub-topics, sub-sub-topics and the entity-specific topic are mapped on a double materiality matrix in order of impact and financial materiality, and individual IROs are listed by topic with risk type, time to impact and value chain position. Time horizons follow ESRS 1, with short being within one year, medium term one to five years, and long-term greater than five years. FBD states that all IROs are connected to its strategy and business model, with key inputs, activities and outputs set out in the Business Model. FBD identified no significant risk of a material adjustment to the carrying amounts of assets and liabilities within the next annual reporting period.

FBD describes the process used to identify and assess material impacts, risks and opportunities, following EFRAG Implementation Guidance in its first DMA. The approach had five steps: a top-down assessment reviewing the business model, peer reporting and industry insights; value chain and stakeholder analysis using EFRAG IG 2 to determine relevant actors based on exposure to material impacts and dependency; identifying and validating IROs across upstream, own operations and downstream, refining a longlist into a shortlist; stakeholder engagement and materiality scoring via surveys, interviews and workshops; and validation and approval. Impacts were scored against scale, scope, remediability and likelihood, with a materiality threshold of 8 out of 15. Risks and opportunities were scored against magnitude and likelihood, with a threshold of 2 aligned to the Risk Management Framework. IROs are assessed on a gross basis. Topics including pollution, water, biodiversity, circularity, workers in the value chain and affected communities were screened out as not relevant. The DMA was approved by the Sustainability Committee in May 2024 and the Audit Committee in October 2024.

FBD sets out the disclosure requirements covered by its Sustainability Statement, with a full list of disclosure requirements complied with provided in an appendix. As a first wave mandatory reporter, FBD prepares the statement in accordance with Part 28 of the Companies Act 2014 and in compliance with the ESRS issued by EFRAG. There are twelve binding ESRS, of which ESRS 1 and ESRS 2 are mandatory cross-cutting standards, while the ten topical standards are subject to the DMA. Four topical standards were found material, being E1, S1, S4 and G1, with farm safety reported as an entity-specific matter under S4. FBD availed of the phased-in disclosure concessions in Appendix C of ESRS 1 to the extent applicable, with details in an appendix, and did not use the option to omit information on intellectual property or impending developments. Comparative information is not required in the first year. The Sustainability Statement has been subject to limited assurance review by PricewaterhouseCoopers. Certain data points are incorporated by reference from the Management's Review section.

FBD does not currently have a transition plan for climate change mitigation. The company states that it may explore the development and adoption of a transition plan in the future, but as at year end 2024 the timelines for this had not yet been established. FBD notes that any consideration of a transition plan would also include an examination of the feasibility of implementing GHG emission reduction targets. This item is classified as a medium term action relating to its own operations, with no GHG reductions or resources allocated recorded against it. The creation of a transition plan will remain under review in 2025.

FBD maintains several policies that integrate climate related issues into the Group's wider business strategy, covering its own operations across Underwriting, Investments and Risk Management. Key policies include the Underwriting Policy and the Product Oversight and Governance Policy (both owned by the Chief Underwriting Officer), the Reputational Risk Policy (Group Chief Executive Officer), the Investment Policy (Head of Investments), the ORSA Policy (Group Chief Risk Officer), the Capital Management Policy (Group Chief Financial Officer) and the Non-Financial Reporting Policy (Group Chief Financial Officer). Most address climate change adaptation, while the Product Oversight and Governance Policy and the Investment Policy also address climate change mitigation. These policies are approved by the Board or, for the Non-Financial Reporting Policy, the Audit Committee, at least annually, and are monitored by committees and teams such as the Pricing and Underwriting Committee, Risk Committee and ESG Reporting Team.

During 2024 FBD took several actions on climate change adaptation and mitigation. It decarbonised its investments, remaining ahead of its target to reduce the carbon intensity of the corporate bond portfolio and reducing the carbon intensity of the risk asset portfolio below its benchmark. FBD committed 1.5 million euro towards new agricultural research and education facilities at UCD Lyons Farm, with construction due to begin in 2025. It continued to purchase all electrical energy from renewable sources, pursued building energy efficiency upgrades, and undertook a climate resilience analysis (45,000 euro allocated). FBD completes voluntary annual CDP disclosure, scoring a 'B' for 2024, unchanged from the prior year. Planned actions into 2025 and beyond include an asset improvement plan for the Head Office (129,000 euro allocated, short term), installing solar panels at head office and two sales offices, a Supplier ESG project (medium term), and continued reporting under the UNEP FI Principles for Sustainable Insurance and the CDP.

FBD's Investment Policy sets an absolute target of zero investments in listed excluded activities, including controversial weapons, civilian firearms, and companies deriving more than 1 percent of revenue from nuclear weapons, Arctic drilling, oil sand mining or thermal coal extraction, with a base year of 2023. It also sets a 60 percent target reduction in the carbon intensity of the corporate bond portfolio over the 9 year period from 1 January 2021 to 31 December 2029, from a baseline of 258 tonnes CO2 per million USD revenue. FBD has exceeded its yearly targets, with total reduction versus baseline at 74 percent as at 31 December 2024. ESG rating limits cap allocations to lower rated securities (0 percent to F, 5 percent maximum to E, 20 percent to D). These targets were set by the Investment Committee and are not directly linked to scientific evidence. FBD does not currently have GHG emission reduction targets in place.

FBD's total energy consumption in 2024 was 2,500 MWh. Fossil sources accounted for 323 MWh, or 13 percent of total energy consumption, consisting of energy from natural gas, liquified petroleum gas, heating oil and hydrocarbon oil. Renewable sources accounted for 2,177 MWh, or 87 percent, all of which was purchased or acquired electricity certified as 100 percent renewable. FBD does not consume any energy from nuclear sources, so consumption and share from nuclear sources were nil. FBD does not produce any energy, so there was no fuel consumption for renewable sources and no self-generated non-fuel renewable energy. FBD states it does not have any operations in high climate impact sectors and has therefore omitted all metrics required for entities with such operations.

For 2024 FBD reported gross Scope 1 GHG emissions of 66 tCO2eq, with no biogenic Scope 1 emissions. Gross location-based Scope 2 emissions were 489 tCO2eq, while gross market-based Scope 2 emissions were nil, in line with 2023, as FBD only purchases energy from renewable sources supported by bundled Guarantees of Origin. Total gross indirect Scope 3 emissions were 37,020 tCO2eq, with investments (category 15) the largest contributor at 29,913 tCO2eq, followed by purchased goods and services at 4,858 tCO2eq and employee commuting at 806 tCO2eq. Total GHG emissions were 37,575 tCO2eq on a location-based basis and 37,086 tCO2eq on a market-based basis. Only 1.57 percent of Scope 3 emissions were calculated using primary data. GHG intensity per net revenue was 0.09 tCO2eq per thousand euro on both bases, based on net revenue of 444,671 thousand euro. Categories 4, 8, 9, 10, 11, 12 and 14 were assessed as not material.

FBD states that no GHG removals and storage activities are currently in place. FBD purchases carbon credits annually from Vita that contribute to community boreholes and safe water in Ethiopia and Eritrea. All carbon credits purchased are verified by the Gold Standard and are based on avoidance projects. The carbon credits purchased in 2024 amounted to 17,000 euro of the operating expenses disclosed in Note 4 of the Financial Statements. Carbon credits cancelled in the reporting year totalled 1,446 tCO2eq, with a 0 percent share from removal projects and 0 percent from reduction projects, 100 percent under recognised quality standard 1, 0 percent from projects within the EU, and 0 percent qualifying as corresponding adjustments. Carbon credits planned to be cancelled in the future, until 2025, total 1,943 tCO2eq.

FBD does not have an internal carbon pricing scheme in place and states that there are no plans to create one in 2025.

FBD's key workforce policies include the Equal Opportunities, Diversity and Inclusion Policy, the Safety Statement, the Professional Development and Education Support Policy, the Data Protection Policy and the Information Security Policy, each with a named owner and approver and reviewed at least annually. Human rights commitments relating to the own workforce are set out in the Code of Conduct Policy, owned by the Group Chief Human Resources Officer and reviewed at least annually by the Board. This policy was updated to explicitly highlight FBD's dedication to internationally recognised human rights, including 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 and occupation. FBD respects the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. In 2024 FBD also launched an internal Fertility Treatment Policy, owned by the Head of HR Operations.

FBD gauges its workforce through an annual employee listening survey (myVoice), managed in 2024 using software provided by the independent consulting firm Willis Towers Watson, allowing benchmarking against Ireland norms. Ongoing engagement runs through individual One to One meetings between employees and people leaders, team meetings, business unit town halls and company town halls. In line with the Safety, Health and Welfare at Work Act 2005, FBD operates a policy of consultation and participation with all employees and recognises the role of the safety representative. FBD has regular engagement with its Employee Representative bodies, including the trade union Unite and the internal Field Staff Association, meeting for collective bargaining as required and more regularly to share information and discuss matters important to member colleagues. An independent non-executive Director is designated as responsible for workforce engagement, acting as a bridge between the workforce and the Board, while the Group Chief Human Resources Officer oversees engagement with the own workforce.

FBD provides channels for own workers to raise concerns and processes to remediate negative impacts. Concerns can be raised through the Speak-Up / Whistleblowing process, outlined in the Speak-Up Policy, with further information on whistleblower protection against retaliation covered in section G1 on business conduct. Employee grievances and concerns about interpersonal conflicts, including bullying or harassment, are addressed through dignity at work, recruitment and selection, disciplinary and grievance policies and procedures. All employees can take action with full support from an internal support person or progress a formal complaint. Complaints are treated seriously and handled confidentially and expeditiously as far as reasonably practicable, and employees who make complaints will not be victimised, though false accusations may result in disciplinary action. Incidents raised are tracked and monitored through designated channels with appropriate policies and procedures. Policies are easily accessible online and mandatory training on whistleblower reporting and the code of conduct is rolled out to all employees. FBD gains insights on effectiveness through its listening survey and wider engagement.

FBD takes action on material impacts across its workforce topics. On social protection it supports circumstances such as sickness, employment injury, parental leave and retirement, with a pension scheme open to all employees over 25, and offers various paid and unpaid family-related leaves. In 2024 it launched a Fertility Treatment Policy offering up to five additional paid leave days and increased flexibility. On health and safety it runs a comprehensive Health and Wellbeing strategy, Mental Health First Aid Training with 45 certified first aiders since 2022, an Employee Assistance Programme, occupational health support, a bi-annual health screening programme and anti-flu vaccinations, alongside risk assessments, emergency drills and safety training. On diversity and gender equality FBD is a signatory of the Women in Finance Charter since 2022, a founding partner of the VOiCE industry collaboration, and was awarded Investors in Diversity Gold accreditation by the Irish Centre for Diversity in 2024. Effectiveness is monitored through targets, the listening survey and workforce engagement.

FBD has set gender diversity targets for female representation across management levels, with interim and headline targets. Headline targets require 40% female representation on the Board by 31 December 2025, 40% for Executive / C-Suite top management by 31 December 2026, 40% for Senior Management by 31 December 2026, 35% for Middle Management by 31 December 2026, and 55% for Junior Management by 31 December 2026. As at 31 December 2024 female representation was 45.5% at Board, 30.0% at C-Suite, 44.4% at Senior Management, 47.4% at Middle Management and 45.9% at Junior Management. FBD's CEO and Leadership team are accountable for measuring, monitoring and publicly communicating annual progress against the targets. FBD also set and achieved the target of Investors in Diversity Gold accreditation, which it will now maintain. No measurable outcome-oriented targets were set in relation to the sub-sub topics of secure employment and working time, as no measurable target was identified.

As at 31 December 2024 FBD had 1,026 employees measured in full-time equivalents, with all of the Group's operations located in Ireland. By gender, the workforce comprised 399 male, 617 female, 1 other (as defined by the employee) and 9 not reported. By contract type there were 985 permanent employees and 41 temporary employees, with no non-guaranteed hours employees. During the reporting period there were 152 leavers (FTE) against an average of 1,016 employees (FTE), giving a total employee turnover rate of 15.0%. The turnover rate is calculated as the number of employees who left, whether voluntarily or due to dismissal, retirement or death in service, relative to the average number of employees during the reporting period. The number of employees is determined as headcount converted to full-time equivalents, where FTE measures equivalence to full-time as recorded in the Contract of Employment. Note 9 of the financial statements presents the average number of people employed on a non-FTE basis.

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

FBD reports gender and age diversity metrics as at 31 December 2024. By gender the workforce of 1,026 FTE comprised 399 male, 617 female, 1 other (as defined by the employee) and 9 not reported. Female representation across management levels was 45.5% at Board (headcount), 30.0% at Executive / C-Suite top management, 44.4% at Senior Management, 47.4% at Middle Management and 45.9% at Junior Management. By age, 20.6% of employees were under 30 years old, 58.7% were 30 to 50 years old and 20.7% were over 50 years old. Age diversity is calculated using FTE and excludes non-employees such as the non-executive Board of Directors, with age determined based on the date of birth recorded on the HR system.

FBD ensures that employees' working hours and pay rates comply with national legislation and industry standards. All of FBD's employees are paid an adequate wage, in line with applicable benchmarks. None of FBD's employees are on a non-guaranteed hour contract. As all employees are based in Ireland, purchasing power adjustments are not relevant.

FBD reports health and safety metrics for the reporting period. Its Health and Safety Management system covers 100% of employees. During 2024 there were 7 total recordable incidents, a total recordable incident rate of 0%, and 0 fatalities. Total recordable incidents is the total number of workplace accidents recorded on the Health and Safety Management System, including any fatalities. A work-related accident is defined as an unexpected and unplanned event or incident occurring in the course of work that results in injury or harm to an employee, including physical injuries, ill health or fatalities caused directly by tasks performed as part of the employee's responsibilities. The total recordable incident rate is calculated as the number of injuries per one million hours worked, and fatalities are the number of employees who lost their lives as a result of a work-related incident.

FBD reports a gender pay gap of 29% and an annual total remuneration ratio of 30.6 for 2024. On 15 December 2024 FBD produced its third gender pay gap report, noting the primary driver of the gap continues to be female under-representation in senior and revenue-generating roles. The gender pay gap is calculated as the difference between the average pay of female and male employees expressed as a percentage of the average pay of male employees, where pay means gross annual pay and corresponding gross hourly pay. The gap reported under CSRD includes LTIP share awards granted and pension contributions, which are excluded from the gap reported under Irish legislation. The annual total remuneration ratio is the ratio between the remuneration of the highest paid individual in the Group and the median remuneration for all employees, with pay incorporating base salary, variable remuneration, benefits in kind and cash benefits. The calculation is based on all Group employees on 15 June.

During the reporting period five incidents were raised through FBD's remediation channels. During 2024 there were no work-related incidents of discrimination reported to Human Resources or via the whistleblower system on the grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of discrimination involving internal or external stakeholders across operations, including incidents of harassment as a specific form of discrimination. No cases of human rights incidents such as forced labour, human trafficking or child labour were identified during 2024. No significant risk of incidents of forced, compulsory or child labour was identified, given the Group is a financial services provider operating only out of Ireland where the duty to respect human and labour rights is reflected in domestic law. No fines, penalties, or compensation for damages arose as a result of the incidents and complaints disclosed.

FBD maintains a range of policies protecting consumers and end users, focused on privacy and fair, inclusive treatment. On privacy, FBD has a designated Data Protection Officer and policies including a Data Protection policy, Information Security Policy, Data Protection Statements, Cookie Policy, Records Retention Policy, Clean Desk and Clear Screen Policy, and Business Continuity and IT Disaster Recovery arrangements, 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 to 2015, and applies robust pricing governance, Product Oversight and Governance, and an annual Pricing Practice Review to support fairness under the Consumer Protection Code. A Vulnerable Customer Policy governs identification and management of vulnerable customers, and the Code of Conduct was updated to explicitly recognise internationally recognised human rights relating to consumers. A Consumer Complaints Policy, owned by the Complaints Steering Group, is reviewed at least annually.

FBD engages with consumers through research, digital monitoring and dedicated governance. It carries out ad-hoc market research to gain insights into consumer preferences and conducts regular brand health checks through third party providers. Website usability testing is undertaken at least twice a year by observing consumers completing specific tasks, supported by targeted user interviews, third party web analytics and a website usability monitoring tool used to improve the online experience. FBD communicates through social media channels including Facebook, X and LinkedIn, offers a Contact us section on its website, and partners with Trustpilot so consumers can rate and review their experience, inviting customers by email after a purchase. The Consumer and Culture Committee, a subcommittee of the Executive Risk Committee, monitors consumer risk appetite metrics and trends, with operational functions providing quarterly updates so the committee can assess engagement effectiveness. FBD is also working to establish a clearer consumer engagement process involving direct engagement with customers and end users.

FBD operates a comprehensive complaints process designed to let customers share their experience and to help FBD learn and improve. Its complaints procedure is available on the website and explains how complaints can be made by phone, in person at any nationwide sales office, or by email. All employees are responsible for knowing the process and aim to resolve complaints at the first point of contact. Complaints under formal investigation are handled by designated employees, 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, which investigates independently once the provider has had a reasonable opportunity to resolve the matter. Service providers acting on FBD's behalf submit complaint logs at least quarterly, and the Executive Management Team receives a quarterly overview of all complaints, including those escalated to the FSPO. During the period, no cases of non-respect of the UN Guiding Principles, ILO Declaration or OECD Guidelines involving consumers were reported in the downstream value chain.

FBD takes action across privacy, social inclusion and the entity-specific farm safety matter. Privacy actions include annual review of data protection notices, an annually reviewed record of processing activities, periodic privacy impact and maturity assessments, security awareness training for all employees, malware protection, device and user authentication, and risk assessments with Non-Disclosure Agreements before engaging third parties. On social inclusion, FBD updates policy booklet wordings into plain language, works towards a AAA accessibility rating ahead of the European Accessibility Act in 2025, and participates in Age Friendly Ireland with employee training. Farm safety actions span communications and awareness, accident prevention and training, including distributing 10,000 farm safety signs, promoting Farm Safety Week with the IFA, the National Marts Farm Safety Awareness and Remembrance Campaign, monthly media adverts, a dedicated Risk Survey Team, free mart risk management surveys, and training such as the Grange open day with Teagasc, Champions for Safety seminars, the UCD Health and Safety Awards and Farm Safety Live. No specific action plans were deemed necessary to address customer service related impacts, risks and opportunities.

FBD has not set time-bound and outcome-oriented targets that meet the criteria for effectively reducing negative impacts, advancing positive impacts, or managing material risks and opportunities related to consumers and end users, as the work on determining impacts, risks and opportunities is a relatively new exercise for the Group. FBD recognises the importance of establishing robust targets to drive meaningful progress and is working to establish a clear consumer engagement process that will involve engaging directly with customers and end users. In the meantime it is focused on gathering data and assessing current practices to ensure future targets are effective and aligned with stakeholder needs. In relation to the entity-specific farm safety disclosure, FBD will continue to support farm safety initiatives but does not plan to set targets in this area, given the downstream impact is outside of FBD's direct control.

FBD considers ethics and adequate governance structures material from a financial perspective in its own operations, with the Board and senior management setting the ethical tone. A suite of Board-approved policies, reviewed at least annually, shapes 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 overarching standards: Integrity and Honesty, Errors Prevention and Reporting, Confidentiality, Professionalism and Compliance, and covers topics such as gifts and hospitality and conflicts of interest. A Competency Framework links values (Respect, Belief, Innovation, Community, Ownership and Communication) to behaviours. The Board and Executive Management Team promote the desired culture through strategy, town halls, leadership development, accountability in objectives and reward, ESG-linked incentives for the CEO and CFO, accessible online policies, and compulsory conduct e-learning through annual compliance passports. FBD has implemented the Central Bank of Ireland's Individual Accountability Framework, covering SEAR, Conduct Standards, enhanced Fitness and Probity and increased enforcement powers. Whistleblower protection is articulated in the Speak Up Policy.

FBD identifies penalties and reputational damage owing to delayed payments to suppliers as a matter within Management of Relationships with Suppliers in its G1 impacts, risks and opportunities. In managing supplier relationships, FBD conducts risk assessments and uses Non-Disclosure Agreements before engaging any third party for services that allow access to FBD information assets, with the process for IT security assessment defined in its IT Security Supplier Policy, owned by the Group Chief Technology and Operations Officer and reviewed at least annually by the Security Steering Committee. The Code of Conduct governs both the giving and receiving of gifts and hospitality, requiring every employee to declare and record where gifts and hospitality above a specified minimal threshold have been offered by suppliers or other bodies of interest, and whether they were accepted or declined.

FBD's commitment to operating responsibly to high ethical and professional standards is set out in its conduct policies, with the Speak Up Policy and procedures covering concerns relating to bribery and corruption. The Code of Conduct governs the giving and receiving of 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. AML/CFT policies and procedures cover identifying and verifying customers, ongoing monitoring, reporting suspicious transactions internally and to authorities, financial sanction screening, mandatory group-wide training and compliance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010. Enhanced due diligence applies to high-risk customers, including Politically Exposed Persons. The AML/CFT policy is owned by the Head of Compliance holding the PCF-52 role and reviewed at least annually by the Board. An Anti-Fraud policy sets out reporting and investigation responsibilities. Annual mandatory compliance training reaches all employees, with 100 percent of functions-at-risk covered; functions such as Finance, Claims and Sales pose elevated risk.

FBD reports that no convictions or fines for violation of anti-corruption and anti-bribery laws were reported during the period, and that 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 procedures, and the annual business-wide AML and CFT risk assessment coordinated by the Compliance Function aids FBD's ongoing efforts to prevent and address such incidents. The Anti-Fraud policy outlines roles and responsibilities for the reporting and investigation of fraud, and suspicious transactions are reported internally and to the relevant authorities as required. Following any formal investigation, the Group Chief Human Resources Officer informs the Group Chief Executive Officer, Group Chief Financial Officer, 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.

FBD reports that it understands how important prompt payment is and does not apply payment terms to supplier invoices, so it does not delay payments to match credit terms. Payments are made in the next available payment run once the invoice and supplier are fully approved, with standard payment runs made three times per month to allow timely payment, and continuous monitoring of payment timing embedded within FBD's Risk Management Framework. In 2024 suppliers were paid on average 35 days from invoice date, 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. As at the year-end reporting date there were no legal proceedings outstanding for late payments. FBD's centralised Procurement Policy, owned by the Group Chief Financial Officer and reviewed at least annually by the Executive Management Team, embeds an ESG questionnaire that typically forms 10 percent of tender scoring, and assigns suppliers to tiers based on contract value and associated risks.