FMO

Reference: pages 150-152 (the ESRS content index also cites Corporate governance, pages 55-57, and the Report of the Supervisory Board, pages 71-73).

The Supervisory Board "oversees the overall strategy and performance" and has three committees: the Audit and Risk Committee, the Impact Committee, and the Selection, Appointment and Remuneration Committee. The Audit and Risk Committee supervises sustainability reporting "focusing on timeliness, accuracy, and completeness". The Impact Committee prepares Supervisory Board advice on "strategic impact commitments, including policies and targets related to sustainability-related matters".

The Management Board is responsible for strategy, approved the 2030 Strategy in 2022, and approves the outcome of the double materiality assessment. It is supported by the Impact and Sustainability Committee (ISCO), the Non-Financial Risk Committee (NFRC) and the Financial Risk Committee (FRC). The Co-CIO is "the single point of accountability in the Management Board for sustainability-related matters" and chairs ISCO. Both boards follow a Lifelong Learning Plan that includes sustainability topics (page 152).

Reference: page 152 (the ESRS content index also cites the Report of the Supervisory Board, pages 72-73).

The Management Board "is informed and discusses progress on material sustainability-related impacts and opportunities on a quarterly basis via the Integrated Quarterly Reports", which the Strategy department prepares. It also discusses the Risk Appetite Report every quarter and "assesses whether the ESG risk and climate risks are within risk-appetite levels"; if they are not, it discusses ways to steer the portfolio back. The Supervisory Board Impact Committee "acts as a sounding board for the Management Board with regard to sustainability-related matters" (page 152).

For the double materiality assessment, ISCO validated impact materiality and the FRC validated financial materiality, and the Management Board approved both (page 130). For the list of impacts, risks and opportunities addressed by the boards and their committees, the statement points to the impact, risk and opportunity management section in each topical standard.

Reference: pages 152-153 (the ESRS content index also cites Corporate governance, pages 57-58, and the E1 version of GOV-3 on page 164).

FMO states that its "remuneration policy includes no direct relationship between sustainability-related elements such as the avoidance or reduction of GHG emissions and remuneration elements such as a pay-for-performance system". Sustainability goals in the strategy are turned into an annual corporate business plan and goals per department or team, and contribution to those goals "is part of the annual performance and appraisal interviews". Sustainability-related performance therefore "only has an indirect effect on remuneration".

The E1 section repeats the point for climate: "there is no direct relationship between sustainability-related elements, including climate, and remuneration elements" (page 164).

Reference: pages 155-156 (Table 14; the ESRS content index also cites Table 73, pages 239-240).

FMO "conducts due diligence guided by international standards such as the IFC Performance Standards, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises". Due diligence runs through the investment cycle, from ESG risk screening and action planning to monitoring, stakeholder engagement and access to the Independent Complaints Mechanism.

Table 14 maps the core elements of due diligence to report sections: embedding due diligence in governance, strategy and business model; engaging affected stakeholders (S2-2, S3-2, S4-2); identifying and assessing adverse impacts (the impact, risk and opportunity sections of E1, E3, E4, S1, S2, S3, S4 and G1); taking action (E1-3, E3-2, E4-3, S1-4, S2-4, S3-4, S4-4 and the G1 key actions); and tracking effectiveness. Customers must meet these standards, and gaps are closed through Environmental and Social Action Plans (ESAPs) and Corporate Governance Action Plans (CGAPs).

Reference: pages 153-155 (the ESRS content index also cites the Risk Management chapter).

The risk management and internal control system for sustainability reporting "is integrated into FMO's comprehensive risk governance and risk management framework" and follows the three lines model: management monitors key controls, the Operational Risk Management team and Compliance test them, and Internal Audit provides independent oversight. Control monitoring and testing runs twice a year (November and June) and results go to the Non-Financial Risk Committee.

FMO names four key risks: the report is compliant with regulations and standards, it is on time, data is accurate and complete, and narrative is accurate and complete. Controls include manager approvals, four-eye checks and director-level confirmation through the In Control Statement. FMO also says "some HR, Compliance, and Internal Audit data are not yet fully governed but must still meet essential criteria for limited assurance", and that new controls are being introduced (page 154).

Reference: pages 132-136 (the ESRS content index flags phase-in for paragraph 40(b), the breakdown of total revenue by significant ESRS sector, and paragraph 40(c)).

FMO states "We invest in 75 countries across four regions" and focuses on three sectors: Agribusiness, Food & Forestry; Energy; and Financial Institutions. Its activities are providing financing (loans, equity, guarantees), blending and mobilizing finance, helping others innovate, and promoting impact and ESG standards. Long-term outcomes it names are a more inclusive, resilient, responsible and sustainable private sector; improved livelihoods; and a transition toward low-carbon, climate-resilient economies.

On the value chain: "As a DFI, the most material impacts, risks and opportunities occur through our investments by financing and engaging with our customers in the downstream value chain." Upstream, FMO relies on shareholders, public and private investors and suppliers. Its own operations cover origination, impact and risk assessment, monitoring and corporate functions. Key resources are people, networks and partnerships, and financial resources, including AAA credit ratings and a Support Agreement with the Dutch State (page 133).

Reference: pages 136-139.

FMO says "We see stakeholder engagement as a two-way dialogue" and names customers, the State of the Netherlands, shareholders, employees, investors, NGOs, supervisors, other DFIs and regulators as its most important stakeholders. It groups them as external (investment-specific) stakeholders, business stakeholders and corporate stakeholder groups. Engagement outcomes fed the 2030 Strategy, the double materiality assessment, the Sustainability Policy, the Customer Disclosure Policy, the Independent Complaints Mechanism (ICM) policy and the Climate Action Plan. In 2025 FMO, DEG and Proparco started a review of the ICM policy with a public consultation.

The Management Board is informed of the views of project-affected stakeholders "on a case-by-case basis" and the Supervisory Board through periodic briefs, with the Integrity and Issue Management Committee (IIMC) as the escalation forum (page 139). FMO reports one entity-specific metric here: 0 admissible ICM complaints in 2025 (2024: 0) (page 138).

Reference: page 130 (Table 2) and the impact, risk and opportunity tables at the head of each topical chapter: E1 pages 157-159, E3 pages 181-182, E4 pages 184-185, S1 pages 191-193, S2 pages 206-207, S3 pages 214-215, S4 pages 220-221 and G1 pages 225-227. The ESRS content index flags phase-in for paragraph 48(e), anticipated financial effects.

"The DMA identified eight sustainability-related topics as material for FMO covering impacts, risks, and opportunities across three environmental topics, four social topics and one business conduct topic": E1 climate change, E3 water (impact only; its water-scarcity risk is reported under E1), E4 biodiversity (impact and opportunity, not financial risk), S1, S2, S3, S4 and G1. Pollution and circular economy are not on the list.

"Most of the impacts identified through the DMA are in FMO's downstream value chain" (page 128). Only S1 and G1 relate to FMO's own operations; E1, E3, E4, S2, S3 and S4 sit in the customer portfolio and are managed through the investment process (page 139). FMO concludes that climate-related risks to capital and liquidity "do not constitute a risk for the resilience of the business model" (page 163). Climate resilience content is also presented under E1-3 (2025 ESRS numbering).

Reference: pages 127-130.

In 2025 FMO "maintained the results of the 2024 DMA" and only streamlined some IRO descriptions in the E1, E4, S1 and G1 tables. The 2024 process had three phases: a long list narrowed to a shortlist linked to the value chain and investment portfolio; assessment and prioritization; and validation and approval. Inputs included the 2023 impact materiality assessment, stakeholder engagement, ESG data from the investment portfolio, and the climate risk assessments done for the Dutch Central Bank (DNB) in 2023 and updated in Q1 2024.

Scoring used severity (scale, scope and irremediable character) for negative impacts, scale and scope for positive impacts, likelihood for potential impacts, and magnitude and likelihood for risks and opportunities, built on FMO's operational risk matrix. FMO "applied a higher financial materiality threshold" to reflect its higher risk tolerance. Water withdrawals were added as a material impact after further substantiation; pollution was judged not material because the likelihood of a major event is "relatively low". ISCO and the FRC validated and the Management Board approved. Climate-specific risk identification is also presented under E1-2 (2025 ESRS numbering).

Reference: pages 236-241 (Reference tables, "List of material ESRS disclosure requirements", Tables 64-74).

FMO prints a content index that lists each material disclosure requirement with its section and page, plus a Phase-in column. Listed: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2); E1 (E1-1 to E1-4, E1-6, E1-7, E1-9, plus E1 IRO-1 and GOV-3); E3-1 to E3-3; E4-1 to E4-5; S1-1 to S1-11 and S1-13 to S1-17; S2-1 to S2-5; S3-1 to S3-5; S4-1 to S4-5; and G1 (GOV-1, G1-1, G1-3, G1-4, G1-5). Not listed: E2 and E5 in full, E1-5, E1-8, E3-4, E3-5, E4-6, S1-12, G1-2 and G1-6. Phase-in is flagged for SBM-1 paragraphs 40(b) and 40(c), SBM-3 paragraph 48(e), and E1-9. Table 73 maps the statement on due diligence and Table 74 lists data points derived from other EU legislation.

Footnote 28 (page 123) says FMO used "the relevant transitional provisions, as described in ESRS 1 10. Transitional provisions". The statement is prepared under the first set of ESRS (Delegated Regulation (EU) 2023/2772) with the July 2025 "quick fix" amendments (pages 123-124). Page numbers are the folios printed on the pages; the PDF page is one higher.

Reference: pages 164-165.

"FMO does not have a formal transition plan, however, information included in this section is described in other relevant FMO documents and covers elements that describe our approach to climate change mitigation." Two sets of actions are classed as decarbonization levers: aligning the portfolio and investments with the Paris Agreement goals, and increasing climate investments and support to customers.

The one reduction target is the Power Generation Emission Reduction Target: cut financed scope 1 emissions in power generation by 50 percent by 2030, built on a 1.5°C pathway (REMIND-MAgPIE 3.0-4.4, Orderly - Net Zero 2050, electricity). FMO has set an ambition in its 2030 Strategy to be Net Zero by 2050 and piloted a 1.5°C alignment assessment of the portfolio in 2025. On carbon lock-in, FMO says it "does not have a definition of carbon lock-ins related to investments" and points to its fossil fuel position statement and the Paris alignment methodology. The 2030 Strategy was approved by the Supervisory Board in 2022 and the Climate Action Plan by the Management Board in 2022. "FMO is not excluded from the EU Paris-aligned Benchmarks." (page 165).

Reference: pages 159-164.

Back-filled from the E1 impacts, risks and opportunities section and the E1 resilience analysis, where this content is disclosed in the FY2025 report (pages 159-164). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification: the material climate risks are one physical risk (climate hazards on customer creditworthiness) and three transition risks (not reaching net zero, inefficient mitigation innovations, a chaotic transition), per Table 15 and page 162. Physical risk was assessed "using a high-emissions scenario" (page 160): IPCC RCP 8.5, with RCP 4.5 also considered, over 2011-2040, 2041-2070 and 2071-2100, at a minimum 50x50 km resolution. The report lists RCP 8.5's policy, macroeconomic, energy and technology assumptions (page 161). Transition risk is assessed at portfolio level only: "We currently do not perform a climate transition risk assessment for new investments" (page 162), and the ICAAP and ILAAP stress tests use an expert-built "disorderly transition" scenario based on NGFS work (page 163). The report gives no global average temperature projection for any scenario. Climate-specific risk identification is also covered under ESRS 2 IRO-1.

Reference: pages 162-164.

Back-filled from the E1 resilience analysis, where this content is disclosed in the FY2025 report (pages 162-164). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

FMO assesses resilience through the ICAAP and ILAAP stress tests the Dutch Central Bank requires, run every year (deeper in SREP years), over a 2025-2027 forecast on a 2024 base. The tests include physical and transition risks, with a bespoke physical scenario and a "disorderly transition" scenario. Result: "The stress tests show that FMO is resilient to material climate risks", with limited impact on liquidity and capital and results inside the risk appetite. FMO says the risks "do not constitute a risk for the resilience of the business model". Stated limits: ex-ante, model-based, top-down national-level physical risk definitions; no climate tipping points; proxy data; and transition risk assessed mostly on qualitative information (page 163). The upstream value chain is excluded. FMO links resilience to its adaptation and mitigation investments and technical assistance to customers (pages 163-164).

Reference: pages 165-168.

FMO says its material climate IROs are covered by two policies: the Sustainability Policy and the Climate-related and environmental financial risk policy. The Sustainability Policy covers organizational activities and new investments and is backed by position statements, including the Combined Position Statement on Coal and Phasing Out Fossil Fuels, the Position Statement on Hydro Power Plants and the Position Statement on Impact and ESG for financial intermediaries, plus an exclusion list. The Green Label Guidelines classify investments by ex-ante climate contribution, and the Sustainability Bonds Framework covers funding.

The risk policy defines physical and transition risk drivers, sets how climate risks are identified across operations, products and services, and assigns roles. Per Table 16 it applies to the FMO-A portfolio and FMO-managed government funds, is approved by the FRC, was developed in light of the ECB Guide on climate-related and environmental risks, and is internal ("not publicly available"). Mitigation rule: FMO "will not invest in any upstream coal mining activities, transportation of coal, construction or renovation of a coal producing plant" (page 167). Adaptation is addressed through the Green Label and the IFC-MDB adaptation methodology.

Reference: pages 168-171.

Three main actions operationalize the 2030 Strategy on climate: aligning the portfolio and investments with the Paris Agreement goals; increasing climate investments and support to customers; and active management of the climate action. Under the first, a Paris alignment methodology based on the MDB principles has been applied to new transactions since September 1, 2025, and FMO piloted a 1.5°C alignment assessment of the portfolio. Under the second, FMO aims to build a portfolio of at least €10 billion dedicated to SDG 13, offered climate technical assistance to Private Equity and Agribusiness and Food customers in 2025, launched the multi-donor Market Creation Platform, and defined four market creation themes. Under the third, the climate risk framework was operationalized further in 2025: physical climate risk assessments cover all new transactions and annual reviews, and are aggregated in a portfolio dashboard.

Table 17 says the actions cover the value chain with a focus on downstream, run to 2030, and carry "No significant operational expenditures (OpEx) and/or capital expenditures (CapEx)". No actions on own operations are included because they were not material.

Reference: pages 172-174.

FMO has two climate targets. First, the Power Generation Emission Reduction Target: reduce financed scope 1 emissions in the power generation portfolio by 50 percent by 2030 from a 2021 baseline of 624 ktCO2e, an absolute cut of 312 ktCO2e, covering active investments whose main activity is electricity production (NACE 35.11), attributed under the PCAF standard. The reported 2025 figure is 318 ktCO2e, "a 49 percent reduction compared to the 2021 baseline", attributed to lower exposure to operating fossil fuel plants. Second, the €10 billion SDG 13 target for 2030 (2025 Green-labelled new investments: €1,761 million, up from €1,460 million; page 142).

FMO says it has "not yet set other reduction targets for financed scope 1, 2 and 3" because of "many unknowns ahead including how climate change itself will evolve, how our markets and customers will respond, lack of data and what solutions are needed and effective". It also notes that the 2025 power figure combines 2024 customer emissions data with 2025 portfolio data and will be finalized next year. The Power Generation target scenario is the NGFS REMIND-MAgPIE 3.0-4.4 Orderly Net Zero 2050 pathway.

Reference: pages 174-178.

Table 19 (kt CO2e, 2024 to 2025): gross scope 1 fell from 0.06 to 0.03; location-based scope 2 from 0.33 (restated for a wrong emission factor) to 0.24; market-based scope 2 rose from 0.03 to 0.04; total gross scope 3 rose 10 percent from 5,861 to 6,442, of which category 15 (investments) is 5,855 to 6,436 and business travel 5.26 to 5.57. Total GHG emissions are 6,442 kt CO2e in 2025 (location- and market-based). GHG intensity per net revenue rose 17 percent to 10,868 tCO2e per EUR million (Table 21).

Financed emissions (Table 20a, 2025): scope 1 842.0 kt, scope 2 320.3 kt, scope 3 purchased goods and services 1,599.6 kt and scope 3 investments 3,673.9 kt, totaling 6,435.8 kt. FMO follows the PCAF standard and the Joint Impact Model (JIM) for most estimates; the share based on primary data is shown in the tables. FMO says total emissions rose "mainly due to increased exposure and data refinements in the FI sector". Scope 1 and 2 of its own operations are reported "for completeness" though found not material. Several scope 3 categories are marked N/A as not expected to be material.

Reference: pages 178-179.

"FMO does not yet quantitatively report on emission removals through these activities." FMO invests in projects that contribute to GHG removals and storage, including forestry under its 2023 Forestry strategy, and chose not to quantify removals across the portfolio while it awaits "further clarity on global standards", naming the GHG Protocol Land Sector and Removals Guidance.

On operations, FMO offsets business travel emissions with carbon credits: in 2025 it offset 5,615 tons of CO2e with VCS Landfill Gas Pichacay Ecuador credits and 600 tons with VCS REDD+ forestry credits. Credits are retired every year, do not come from FMO's customers, are not counted towards the Power Generation target, and are not deducted from the gross operational emissions reported in E1-6. FMO plans to keep offsetting, with no contractual agreements for future purchases. In the short term FMO "does not utilize emissions removals to reach Net Zero financed emissions".

Reference: page 182 (the ESRS content index lists E3-1 at page 182).

"Our Sustainability Policy and related underlying documents outline how we manage our material water-related IROs." Water is material for FMO through two actual negative impacts in the investment portfolio: degraded water quality and reduced availability from customers and financed projects, and reduced water availability from reservoirs built for hydropower (Table 24, pages 181-182). FMO applies the IFC Performance Standards, with PS3, PS4 and PS6 giving the water guidance, and its Position Statement on Hydropower Plants. Where a project is a significant water consumer, FMO requires customers to adopt measures such as "water conservation measures, the use of alternative water supplies, water consumption offsets, evaluation of alternative project locations".

FMO adds that because own operations were not material in the DMA, policies on water management in own operations are "not relevant for FMO", and none are needed for water stress near its own sites.

Reference: pages 182-183.

"As part of the normal due diligence process, we identify performance gaps against our standards, and we agree with our customers on improvements that are required in relation to negative impacts on water and marine resources". Improvements go into an Environmental and Social Action Plan (ESAP) written into the contract, with deadlines for closing actions. Compliance is monitored in the annual customer credit review, and where incidents occur "a corrective action plan may be required" to mitigate and possibly remediate the impact.

Table 25 says the actions cover all high-risk customers with gaps against IFC PS3 requirements, run on an ongoing basis, and carry "No significant operational expenditures (OpEx) and/or capital expenditures (CapEx) related to implementing actions". It states that "No specific actions were announced in prior periods" (page 183).

Reference: page 183.

"FMO has not adopted targets related to water resources." Water is covered only through the ESG performance target, which "includes but is not limited to water impact from related investments (incl. IFC PS3, 4 and 6)". That target aims for at least 90 percent of ESG risks among high-risk customers to be managed at an adequate level by the customers; the 2025 result was 95 percent (94 percent in 2024) (pages 149-150). The statement is a nil return on water-specific targets, with the portfolio-level ESG target as the only linked measure.

Reference: pages 186-187 (the ESRS content index lists E4-1 at page 186).

"FMO identified material potential positive and negative impacts on biodiversity and ecosystems in its downstream value chain." FMO gives no formal transition plan. It says it is developing a methodology to assess dependencies on nature, applying ENCORE materiality ratings, expected to continue through 2026 (page 185), and concludes: "Therefore, our conclusion from our DMA is that FMO is resilient in terms of biodiversity and ecosystems." No material biodiversity-related financial risks were identified in the DMA, and the DMA covered the upstream and downstream value chain and own operations on ESRS 1 time horizons, with no specific stakeholder engagement on the topic.

In the reporting period FMO "developed the Biodiversity definition and methodology" that sets how it defines and tracks biodiversity finance, which counts toward the SDG 13 target (page 186).

Reference: pages 186-189.

FMO's material biodiversity impacts "are mainly addressed by one policy: the Sustainability Policy" and its supporting documents (the Sustainability Policy Universe). The listed documents are the Position Statement on Hydropower Plants, the exclusion list (no "significant conversion or degradation of critical habitats", with primary forests and high conservation value forests classed as critical habitats), the ESG management process under IFC PS1, PS3, PS4 and PS6, and the Green Label Guidelines.

Customers must identify and avoid impacts such as habitat loss, fragmentation, invasive species and over-exploitation, and primary producers must show sustainable management through independent verification or certification. FMO notes the EU Deforestation Regulation will not affect it directly but is a transition risk for agrifood customers (page 188). It adopted no biodiversity policy for its own operations because none were material, and "Sustainable oceans and sea are not material for FMO and therefore no related policies exist" (page 189).

Reference: pages 189-190.

Operational actions in 2025: increase the Green-labelled share of the portfolio, including biodiversity-positive investments, supported by the Sustainable Finance Advisory team and training; and keep applying IFC PS6 with training and ESAPs at customer level. Strategic actions in 2025: introduce an agreed definition of biodiversity finance and a labeling methodology under the Green Label; continue developing a methodology to assess dependency on nature; update the Green Label attribution method; continue building a biodiversity financing pipeline; and partner with Nature Positive New Zealand, holding capacity-development workshops for renewable energy customers in Cape Town and Istanbul and publishing an online module on IFC PS6.

Table 27 sets the scope as the downstream portfolio, strategic actions as running 2025-2026, and "No significant operational expenditures (OpEx) and/or capital expenditures (CapEx)". "In principle, FMO does not use biodiversity offsets in its action plans", though project-level offsets can be a last resort (page 190).

Reference: page 190.

"FMO currently has no specific biodiversity targets to manage the material IROs, and for the time being, does not intend to set any specific targets." FMO says the evolving topic of biodiversity finance "currently makes it challenging to predict progress and set reliable targets". It points to two portfolio targets with a link to biodiversity: at least 90 percent of ESG risks among high-risk customers managed at an adequate level (this includes biodiversity-related risks through IFC PS6; 95 percent achieved in 2025, page 150), and the SDG 13 portfolio of €10 billion by 2030, which includes investments contributing to biodiversity.

Reference: page 190 (the ESRS content index lists E4-5 at page 190).

The E4-5 section is headed "E4 FMO entity specific metrics". It says FMO "tracks entity specific metrics related to Biodiversity": an ex-ante assessment of potential positive biodiversity impact through the Green Label, and tracking of high-risk customers' performance against the IFC Performance Standards in relation to biodiversity and ecosystems. The section itself gives no biodiversity figures and no ESRS impact metrics such as land use change; it refers to the methodology and performance gap tables in ESRS 2 IRO management (Table 8, page 142, and Tables 11-12, pages 147-149).

Marked reported because FMO's index lists it; a reader should note the content is entity-specific and mostly cross-referenced.

Reference: pages 193-196 (S1 introduction, page 191, covers the human rights commitments).

FMO's employees in the Netherlands fall under Dutch Labor Law and the Collective Labor Agreement for Banks (CLA Banks); regional offices follow local law. Procedures sit in the FMO Personnel Guide and the Code of Conduct. "In 2025 FMO formalized a policy on Diversity, Equity, Inclusion and Belonging (DEIB) in line with the diversity charter." Table 29: the DEIB policy covers all employees and non-employees, the Management Board is accountable, and it is internal and "not publicly available". The ESRS content index notes that paragraph 22 is not material.

The policies cover working conditions and health, safety and wellbeing (preventive checks, emergency response team, sickness absence protocol), purposeful work, learning and development through the FMO Academy, and travel safety, which restricts travel to high-risk areas using the Dutch Ministry of Foreign Affairs color coding and requires a one-day travel safety training. Discrimination, harassment and bullying are not tolerated; employees can use an external confidentiality counselor or the internal Grievance Advisory Committee. Three employee networks are named (BYOU, FMO Femmes, Young FMO). FMO commits to the UN Guiding Principles and OECD Guidelines (page 191).

Reference: pages 197-198.

Key actions: a periodic review of the employee value proposition (EVP), with possible changes to the incentive program and an annual personal budget for development and wellbeing; the Values in Action program and its volunteer Culture Catalyst Network; HR Connect, a Human Capital Management System with go-live "planned for the first half of 2026"; the DEIB action plan (regular surveys, training, flexible work arrangements, diversity days); mitigation of undesirable behavior and discrimination through two internal confidentiality counselors; and measures for the potential negative impact of adverse events on site visits (pre-travel risk checks, mandatory training, FMO emergency pass, the BCM app, registration with AIG Travel Guard, and a travel crisis team).

Effectiveness is tracked through feedback to management, HR and the Works Council and through the biennial engagement survey. Table 30 states "No significant operational expenditures (OpEx) and/or capital expenditures (CapEx) related to implementing actions".

Reference: pages 198-199 (Table 31).

FMO set two targets. Staff gender balance: "approximately 50-50" in 2025 and later years, baseline 2022 (women 52 percent, men 48 percent), with a focus on management roles. 2025 result: women 53 percent, men 47 percent (2024: 53 and 47). Board composition: at least one third men and one third women, in line with the Act on Gender Balance. 2025 result: Supervisory Board 50 percent women and 50 percent men (three and three of six); Management Board 33 percent women and 67 percent men (one woman and two men; 2024: 40 and 60), with two vacancies open at year-end.

Both targets were set with HR representatives and the works council and are tracked through the ADP system from individual input on gender identity. FMO also tracks an entity-specific employee Net Promoter Score (eNPS) and an engagement score (page 205). No milestones or interim targets are set.

Reference: pages 200-201.

At December 31, 2025 FMO had 911 employees by headcount (2024: 866): 427 men (47 percent) and 484 women (53 percent), none recorded as other or not reported. 904 are in the Netherlands (The Hague) and 7 in the regional offices in South Africa, Kenya and Costa Rica. Contract type: 903 permanent and 8 temporary employees; the non-guaranteed hours row has no figures. Employee turnover: 47 leavers in 2025 (19 men, 28 women; 2024: 69), a turnover rate of 5.23 percent on an average headcount of 898 (page 201). Headcount is reported at period end. FMO refers to the staff costs table in the notes to the consolidated statement of profit or loss.

Reference: page 201.

Non-employees include contractors (including self-employed persons), consultants and secondees; third-party contractors (security, catering, cleaning) and interns are excluded. "As of 31 December 2025, non-employees made up 11.7% of our own workforce." Headcount at year-end was 121 (2024: 155), and the average during the reporting period was 136. By type (Table 36, 2025 versus 2024): BAU/operational 38 (54), project 70 (82), and other including secondees 13 (19). Figures come from ADP Workforce and are checked and presented to the Management Board each quarter.

Reference: pages 201-202.

"In the Netherlands, all 904 employees (99.2 percent) are covered by collective bargaining agreements and represented by a Work council reflective of the workforce." Outside the European Economic Area no employees (0.8 percent; South Africa, Kenya and Costa Rica) are covered by bargaining agreements. Table 37 places Netherlands in the 80-100 percent coverage band and shows workplace representation for the Netherlands (99.2 percent). There is no European Works Council, SE Works Council or SCE Works Council agreement because within Europe FMO operates only in the Netherlands.

Reference: page 202.

FMO defines senior management as the Management Board and Directors; the Extended Leadership Team (ELT) adds Managers. Table 38 (December 31, 2025): the Senior Leadership Team has 23 members, 16 men (70 percent) and 7 women (30 percent), versus 15 men (65 percent) and 8 women (35 percent) in 2024. Managers number 66, split 33 men and 33 women (50 percent each). The ELT totals 89, 49 men (55 percent) and 40 women (45 percent). Table 39 gives the employee age distribution for 2025: under 30, 82 (9 percent); 30 to 50, 605 (66 percent); over 50, 224 (25 percent). The 2024 age figures were restated because the age band was changed from 30-49 to 30-50 (page 127).

Reference: page 202.

"As a DFI we strive to stay competitive with our compensation and benefits package and be at least comparable with the median standards of our reference market, being the Dutch financial industry." FMO states that "All employees of FMO, including those working outside of the Netherlands, are paid an adequate wage, in line with applicable benchmarks." No figures or benchmark names beyond the reference market are given.

Reference: page 202.

"At FMO, all employees (including those outside of the Netherlands) are protected against loss of income due to sickness, unemployment, injury, and acquired disability through public programs or offered benefits." In the Netherlands, employees are partly covered for parental leave under the Dutch social security system and the collective agreement, and for retirement under the AOW state pension, and "There are no employees in the Netherlands who lack social protection". FMO adds: "We are currently investigating the status of social protection in our regional offices." Non-employees in the Netherlands are covered by Dutch social security.

Reference: page 203.

All employees join the annual appraisal process with goal setting and mid-year and end-year reviews, except those who joined on or after September 1. In 2025, 862 appraisals (2024: 796) were completed out of 911 employees, which is 95 percent of the workforce (2024: 92 percent) and all employees eligible for an appraisal; 455 were women and 407 men. Table 40 (training, 2025 versus 2024): total training hours 21,938 (27,230), an average of 24.1 hours per employee (31.4); men 21.4 hours (27.9) and women 26.4 hours (34.6).

Reference: page 203.

All 904 employees in the Netherlands (99.2 percent) are covered by the system built on the Dutch Working Conditions Act; employees in regional offices (0.8 percent) and non-employees are not. "We have not identified any work-related fatalities or injuries in 2025." FMO says that, because of employee privacy and confidentiality, it "does not maintain records of ill health attributed to work conditions" and so has no records of days lost to work-related circumstances or work-related mental ill health. The statement is a nil return on fatalities and injuries, with the ill health and lost days metrics not available.

Reference: page 203.

"All employees (100 percent) are entitled to family-related leave in accordance with the respective laws and regulations, the FMO Personnel Guide and/or collective bargaining agreements (in the Netherlands)." Non-employees are not included. Table 41: in 2025, 72 of 427 men (17 percent) and 135 of 484 women (28 percent) took family-related leave, versus 104 of 406 men (25.6 percent) and 101 of 460 women (22 percent) in 2024. Family-related leave covers maternity, birth, full-time parental, bereavement and short-term care leave.

Reference: page 204.

The uncorrected gender pay gap, on gross hourly pay at the April 1, 2025 reference date, is 16.4 percent (2024: 16.4 percent); FMO changed its method slightly and did not restate 2024. A corrected gap using the Oaxaca-Blinder decomposition, run by an external consultant, is 1.7 percent for base salary and 1.5 percent for total cash income, both in men's favor, and "a statistically significant difference". Local office staff (eight employees) were excluded. FMO sets this against corrected gaps of approximately 6.9 percent in the Dutch private sector and 1.8 percent in government (CBS, 2022).

The pay ratio of the CEO's total remuneration to the median total remuneration of other employees, including those outside the Netherlands, is 3.5 (2024: 3.5). The CEO's salary has no variable element, and individual bonuses for other staff are less than 1 percent of total fixed annual remuneration. FMO notes the median is based on total fixed remuneration converted to an annual amount.

Reference: page 204.

"In 2025, no instances of discrimination, including harassment, that resulted in formal complaints or grievances were reported (2024: zero)." One employee filed one grievance with the internal Grievance Advisory Committee that was considered admissible (2024: three); after investigation it was resolved. The external confidentiality agency received no complaint about undesired behavior (2024: one). "The total amount of fines, penalties, and compensation for damages was zero (2024: zero)" (page 204).

Reference: pages 208-210.

S2 workers are employees of FMO's customers and workers in customers' primary supply chains. Policies are set by IRO. For strengthened economic participation (supporting jobs), the Sustainability Policy steers capital toward inclusive development, including the bottom 40 percent of income distribution. For advancing gender equality, the Sustainability Policy (including a Gender Position Statement) and the Reducing Inequalities (RI) Label steer gender-lens investment; "FMO has committed that a third of all Nominee Directors appointed per year to serve on the board of an investee company will be female". For inadequate working conditions, FMO applies IFC Performance Standard 2 (PS2), commits to the International Bill of Human Rights, the ILO Declaration and the UN Guiding Principles, and under its exclusion list "will not finance any investments involving forced or child labor, regardless of sector" (page 206).

Customers contractually undertake to comply with the IFC Performance Standards, must report serious incidents, and FMO tracks them in a Serious Incident Register (pages 209-210). No severe human rights issues were reported through the ICM or the IIMC (page 210).

Reference: pages 211-212 (Table 46).

As part of due diligence FMO identifies performance gaps against IFC PS2 and agrees improvements with customers (working conditions, occupational health and safety), which are written into an Environmental and Social Action Plan (ESAP) in the financing contract with deadlines. Compliance is monitored in the annual customer credit review, and a corrective action plan may be agreed after incidents. Table 46 sets the scope as ESAPs and corrective action plans for all high-risk customers with gaps against IFC PS2, plus ongoing actions as part of making Reducing Inequalities-labelled investments; actions are ongoing; and there is "No significant operational expenditures (OpEx) and/or capital expenditures (CapEx) related to implementing actions".

Performance gaps are summarized by theme in Table 12 (pages 147-149), which includes working conditions and worker relationships, occupational health and safety, and supply chain working conditions under PS2.

Reference: pages 212-213 (Tables 47-49); ESG performance target on pages 149-150.

"FMO has not set a measurable target for impacts related to (value chain) workers." The ESG performance target "includes, but is not limited to, investments with risks related to workers in the value chain": at least 90 percent of ESG risks managed adequately among high-risk customers, with 95 percent reached in 2025 (94 percent in 2024).

Entity-specific metrics (2025, with 2024 in brackets): direct jobs supported, 91 thousand FTE (83); direct jobs supported for women, 36 thousand FTE (29); customers with E&S performance gaps, 52 (54) (Table 11, page 147). Fatalities in financed activities: 120 (70), of which 83 occurred and were registered in 2025 and 37 occurred in 2024 but were registered in 2025; "60 involving workers in the value chain and 23 involving members of the public (affected communities)" (page 213). FMO notes the jobs figures use a Joint Impact Model version that "has not been externally validated" and that some incidents may not have been reported to it.

Reference: pages 215-217.

FMO's policy approach rests on the Sustainability Policy, with the IFC Performance Standards applied to communities: PS1 (assessment and management of risks, consultation, grievance mechanism), PS4 (community health, safety and security), PS5 (land acquisition and involuntary resettlement) and PS7 (indigenous peoples, including Free, Prior and Informed Consent in certain situations), with PS3, PS6 and PS8 addressing impacts indirectly. FMO is committed to the International Bill of Human Rights, the OECD Guidelines and the UN Guiding Principles.

Customers must consult communities, run a grievance mechanism, avoid and minimize displacement and provide compensation where avoidance is not possible. Policies named in Table 50 for the IROs are the Sustainability Policy, the ICM Policy and the Customer Disclosure Policy. FMO keeps a Serious Incident Register, and "No severe human rights issues and incidents were reported to FMO" (page 217).

Reference: pages 218-219 (Table 51).

As part of due diligence FMO identifies performance gaps on community-related topics and agrees improvements with customers, written into an Environmental and Social Action Plan (ESAP) in the contract with deadlines. Compliance is monitored in the annual customer credit review, and a corrective action plan may be required after incidents. Table 51 sets the scope as ESAPs and corrective action plans for all high-risk customers with gaps against IFC PS requirements on communities' rights and impacts, ongoing, with "No significant operational expenditures (OpEx) and/or capital expenditures (CapEx) related to implementing actions" and no actions announced in prior periods. Community-related performance gaps (security forces, land acquisition and resettlement, indigenous peoples, cultural heritage) are summarized in Table 12 (pages 147-149).

Reference: page 219.

"FMO currently has no targets related to affected communities." The ESG performance target "includes but is not limited to affected communities from related investments" (at least 90 percent of ESG risks managed adequately among high-risk customers; 95 percent in 2025, pages 149-150). Entity-specific metrics are the number of admissible ICM complaints (0 in 2025 and 2024, page 138) and fatalities involving members of the public (23 in 2025 and 22 in 2024, page 213), plus tracking of high-risk customer performance against the IFC Performance Standards on local communities.

Reference: pages 221-223.

FMO's investment objective is to develop private sector businesses in developing countries, including improved access to food, energy and financial services. Policies by IRO: for improved access to basic goods and services, the Sustainability Policy and the Reducing Inequalities (RI) Label, which classifies investments ex ante (for example Table 53, last mile delivery of power); for undue financial stress on end-users, the Client Protection Standards (CPSs, eight standards including prevention of over-indebtedness) embedded in the investment process through a Client Protection Risk Review Process, with annual monitoring at the customer credit review. FMO is "committed to acting consistently with the United Nations Guiding Principles for Business and Human Rights and the OECD Guidelines for Multinational Enterprises". "No severe human rights issues and incidents were reported to FMO" through the ICM or the IIMC (page 223).

Reference: pages 223-224 (Table 54).

On an ongoing basis FMO steers toward investments that reduce inequalities within and between countries through the RI Label and its target, supported by the Sustainable Finance Advisory team, investment team training, and technical assistance (including a framework program for gender equality objectives). It also keeps Client Protection Guidelines and a due diligence process with a client protection specialist for complex cases. "In 2025 the Client Protection assessment was reviewed", and updated risk assessment and management processes are to be implemented in 2026, with tools integrated into the SIS system. Table 54 sets the scope as investments in customers in FMO's sectors and markets, a 2025 time horizon, and "No significant operational expenditures (OpEx) and/or capital expenditures (CapEx) related to implementing actions".

Reference: page 224; target details in ESRS 2 Table 9, pages 145-146.

"FMO aims to have developed a total committed portfolio of at least €10 billion in SDG 10 in 2030." The 2030 target has a 2021 baseline of €4.0 billion and a 2025 annual target of €1.46 billion, which was reached (RI-labelled new investments were €2.23 billion, 1 percent lower than in 2024; page 146). FMO says the target does not distinguish RI Label categories, so it covers women in the value chain, underserved consumers and end-users, and access to financial services, energy and food. "Consumers and end-users are not engaged directly in setting or tracking performance against these targets".

Entity-specific metrics: RI-labelled total new investments of €2,231 million in 2025 (€2,250 million in 2024; page 141), and a new metric, gender lens investments total committed portfolio, of €686 million in 2025 (no 2024 figure; Table 55).

Reference: pages 227-228.

FMO describes a culture built on four values (Diversity, Integrity, Making the difference, Quality) with underlying behaviors, and a multi-year program, Values in Action, to embed them through training and leadership development; culture is evaluated through feedback and the biennial employee engagement survey. The Code of Conduct sets shared standards of behavior and is supported by regular training, including an Annual Integrity Awareness e-learning, and by the Speak Up policy and internal grievance mechanisms. All employees have taken the Dutch Bankers' Oath (Wft, article 3.17 b, section 2), introduced on April 1, 2015, under which "their conduct may be subject to disciplinary review". FMO says the corporate culture is cultivated by its Code of Conduct and compliance policies, "which include safeguarding whistleblowers and steering clear of bribery, corruption, and other unethical behaviors". Anti-bribery, whistleblower and related policies are described under G1-3.

Reference: page 234.

The statement was prepared under the 2023 ESRS, where business conduct targets fell under the minimum disclosure requirements for targets (MDR-T). FMO states: "FMO has not set any specific targets. Performance on business conduct related IROs is monitored through various internal procedures (see 'S1 - FMO entity specific metrics'; 'ESRS 2 - IRO management')." Table 56 (pages 225-227) shows "No specific target" against each business conduct IRO. The G1 chapter does describe how effectiveness is tracked in other ways: the 2025 systematic integrity risk analysis, discussed with the Management Board and Supervisory Board (page 234), the annual bribery and corruption training coverage (page 232), and the Compliance function's review of violations (page 228).

Reference: page 234.

"No incidents of corruption or bribery were reported during the reporting period; therefore, the number of convictions and number of fines for breaches is zero and no actions were required to be taken to address breaches." The statement is a nil return. The G1 chapter does not give a prior-year comparison for this disclosure requirement.

Reference: pages 234-235.

FMO says it "needs to comply with the transparency and disclosure requirements set forth by the EU" and that political influence and lobbying activities "are represented by FMO's Corporate Stakeholder engagement team (CSE)". FMO is registered in the EU Transparency Register (number given on page 235), as is EDFI, of which it is a member. In March 2025 it published a position statement on corporate stakeholder engagement and lobbying, which is part of its Sustainability Policy framework. Topics discussed with political stakeholders in 2025: the National Investment Bank initiative with the Dutch Ministries of Foreign Affairs and Finance; input to the EU consultation on Art. 133(5) of the Capital Requirement Regulation; and roundtables on the 2028-2035 Multi-Annual Financial Framework. "During the reporting period no financial contributions or contributions in kind were made" (page 235).