Hamburg Commercial Bank AG

The role of the administrative, management and supervisory bodies

Reference: pages 126-131.

Management Board: "temporarily consisted of six members as at December 31, 2025"; since 1 January 2026 it has four: Luc Popelier (CEO), Marc Ziegner (CFO and Deputy CEO), Jens Thiele (CIO) and Reinout van Riel (CRO) (page 126). Supervisory Board: 18 members, twelve appointed by the Annual General Meeting and six elected by employees (page 126). At 31 December 2025 the Management Board had six men and the Supervisory Board six women and twelve men, 33.3 % women (page 128).

Independence: "33 % (four out of twelve) of the members of the Supervisory Board elected by the shareholders are currently independent" (page 129).

Oversight: the Management Board as a whole is responsible for sustainability management. The Supervisory Board approves the medium-term plan, including the Sustainable and Transformational Finance Framework, and the Audit Committee "monitors the implementation of the CSRD" (page 130). Each board has a qualification matrix with a sustainability (ESG) row (pages 127-128, 131).

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

Reference: pages 131-132.

The Management Board "bears overall responsibility for sustainability issues" and acts through the Sustainability Committee (SC), which "comprises the entire Management Board", is chaired jointly by the CRO and the CIO, and "meets quarterly or more frequently if needed" (page 131). From 1 October to 31 December 2025 the Chief Commercial Officer co-chaired in place of the CIO (page 131).

In 2025 the SC discussed the material IROs, the ESG strategy, the EBA Guideline on ESG Risks, "short-, medium-, and long-term decarbonization targets within the HCOB portfolio transition plan", GHG emissions, EU Taxonomy and CSRD/ESRS requirements, STFF-aligned new lending and the EBA climate risk scenario analysis (page 132). The Management Board formally acknowledged the IROs in its review of the combined management report, and the findings went to the SC for validation (page 132). The "Sales Management & ESG" department prepares the SC's decisions, with dialogue to the Management Board also through quarterly management reporting (page 132).

Integration of sustainability-related performance in incentive schemes

Reference: pages 132-133.

Supervisory Board: fixed remuneration only, so "no targets are set with regard to sustainability-related aspects" (page 132).

Management Board: "A share of 7% of the variable remuneration (previous year: 10%) depends on sustainability-related targets". These are STFF new business (see E1-4) and the share of the underrepresented gender in business unit head, management and senior expert roles (see S1-5) (page 132). The climate element is the Sustainable and Transformational Assets indicator, "4% of variable remuneration (previous year: 5%)" (page 132). The report states: "The variable remuneration is not linked to the GHG emission reduction targets, but only to further climate targets for new STFF business." (page 132).

The Supervisory Board sets the total remuneration of each Management Board member and decides whether annual targets were met (page 133).

Statement on due diligence

Reference: page 133.

A table maps the core elements of due diligence to sections of the statement (page 133):

• Embedding due diligence in governance, strategy and business model: GOV-1, GOV-2, GOV-3, SBM-1.
• Engaging with affected stakeholders in all key steps: SBM-2.
• Identifying and assessing adverse impacts: IRO-1.
• Taking actions to address adverse impacts: E1-3, E1-4, E2-2, E3-2, E4-3, E5-2, S1-3, S1-4, S1-5, S2-4.
• Tracking effectiveness and communicating: E1-4, E1-6, S1-5.

The statement introduces the table as showing "where the due diligence obligations related to sustainability and the processes for identifying impacts, risks and opportunities as well as the measures to avoid negative impacts are described".

Risk management and internal controls over sustainability reporting

Reference: pages 133-134.

HCOB runs a Group risk management system and an internal control system (ICS). For sustainability reporting it ran a risk analysis rated on "risk severity, probability of occurrence and potential damage" and named three material risks (pages 133-134):

• Business process risk: delayed, incomplete or incorrect publication through interrupted data delivery; mitigated by folding the Sustainability Statement into the financial reporting process, scheduled standard checks, and the Workiva reporting tool.
• Compliance risk: mitigated by running the double materiality analysis early and a four-eyes review of legal compliance.
• Reputation risk: mitigated by processes, work instructions and scheduled review loops by department heads.

Responsibility lies with the Finance & Bank Steering business unit. A central ICS office reports quarterly to the committee responsible for non-financial risk, the Management Board and the Supervisory Board, and Internal Audit carries out process-independent audits (page 134).

Strategy, business model and value chain

Reference: pages 134-139.

HCOB is "a private commercial bank and specialist finance provider headquartered in Hamburg", with 862.4 full-time equivalents at 31 December 2025 (previous year: 930.4) (pages 134-135). Its segments are Real Estate, Global Transportation (shipping and, "for the last time in 2025", aviation), Project Finance (including renewable energies and digital infrastructure) and Corporates. The aviation portfolio was sold in the fourth quarter (page 135).

Voluntary commitments: Principles for Responsible Banking (2020), PCAF (2021) and the Responsible Ship Recycling Standard (2020) (page 135). The Bank aims for net-zero emissions by 2050 at corporate and portfolio level and sells no products explicitly labeled green (page 136).

Value chain (pages 138-139): upstream suppliers and service providers (business, IT, building and consulting services, office supplies); own operations (locations and employees); and the downstream loan and investment portfolio, where "The material impacts were identified for the downstream value chain, focusing on the loan and investment portfolio".

Interests and views of stakeholders

Reference: pages 139-142.

HCOB splits stakeholders into internal groups (Management Board, employees) and external groups (clients, investors, owners, supervisory authorities, the public, NGOs, media, rating agencies, associations, suppliers, and nature as a "silent stakeholder") (page 139). Engagement runs through bilateral discussions, client dialogues, investor meetings and committee meetings. Results are used "to validate the materiality analysis and to further develop the ESG strategy, whereby stakeholder interests with a major financial impact on the Bank are given more weight" (page 139).

A table (pages 140-142) lists expectations, engagement formats and results per group. Examples: client surveys every two years, works councils and employee surveys, "€ 500,000 in donations to 11 organizations" under Public & Media, and joint projects with NGOs on biodiversity and equality.

ESG ratings (page 142): Sustainalytics 12,0 (Low ESG Risk, 09.2025), MSCI A (04.2025), ISS C, prime (05.2025).

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

Reference: pages 142-146.

The "Results of the materiality analysis" table (pages 143-146) lists 24 material IROs (counted by row; the company states no total), each tagged to the Corporate dimension (own operations and upstream) or the Portfolio dimension (downstream):

• E1 climate change: 9 (five actual negative impacts, three actual positive impacts from financing renewable energy, one risk of loan default from physical and transition climate risks in Real Estate and Shipping).
• E2 pollution: 2 (air and water pollution from financed ships). E3 water: 1. E4 biodiversity: 1 (marine ecosystems). E5 waste: 1.
• S1: 3 (high workload, insufficient equal opportunities, violations of employee rights). S2: 2 (working conditions on financed ships and at suppliers).
• G1: 5 (Code of Conduct violations, endangering whistleblowers, political influence, unfair treatment of service providers, corruption susceptibility).

"No opportunities were identified" (page 142) and "No actual financial impacts were identified as part of the materiality analysis" (page 146). There are "no changes compared to the previous reporting year" (page 146).

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

Reference: pages 146-149.

The double materiality analysis "has now transitioned into regular operations, in the form of an annual validation and confirmation process", building on the initial 2024 analysis (page 146). Inputs were stakeholder mapping, external data from ENCORE and UNEP FI, and the HCOB risk inventory and ESG Scoring for financial materiality (page 147). The loan and investment portfolios were grouped into IRO drivers by NACE code and exposure at default (EaD); drivers below 5 % of EaD were assessed in full only if ENCORE or UNEP FI showed "at least a high materiality" (page 147).

Scoring covers severity (scope, scale, irremediability) and likelihood over short, medium and long term on a 0 to 5 scale; "a threshold value (> 3)" on that scale marks an impact as material (page 147). The 2025 validation found no material changes and "no new material topics have been added" (page 148). The method was applied to climate, pollution, water, biodiversity, resource use and business conduct, and "No further exchange with affected communities took place" beyond the stakeholder dialogue (page 149).

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

Reference: page 149; pages 226-230 (Appendices 1 and 2).

Appendix 1 (page 226) is an ESRS index in two blocks, Corporate and Portfolio, with no page numbers; the DRs sit in "the sections of the same name". Corporate: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1-1 to E1-9, E3-1 to E3-4, E5-1, E5-2, E5-3, E5-5, S1-1 to S1-17, S2-1 to S2-5, G1-1 to G1-6. Portfolio: ESRS 2 as above, E1-1 to E1-4, E1-6, E1-8, E1-9, E2-1 to E2-3, E4-1 to E4-5, S2-1 to S2-5. S3 and S4 "were not listed" as they were not relevant.

Appendix 2 (pages 227-230) lists datapoints from other EU legislation with a Relevant, Not relevant or Not material marker, for example E2-4 and the S3 and S4 rows marked "Not material". The list comes from an internal "CSRD Compliance Cockpit" built on EFRAG Implementation Guidance 3 (page 149).

Transition plan for climate change mitigation

Reference: pages 156-157; targets on page 169.

Portfolio: "in the reporting year the Bank adopted a transition plan for the first time" (page 156). HCOB aims for net-zero across its credit and investment portfolio by 2050, with 2030 and 2050 targets for Shipping, Real Estate and Energy (power generation), which "together account for more than two-thirds of the financed emissions" (page 156). 2030 targets: Real Estate 29.1 kgCO2e/m2/a (2025 base 47.7), Shipping alignment delta 15.0 % (2025: 19.8 %), Energy 70.0 gCO2e/kWh (page 169). Levers: financing renovations and efficient buildings, efficiency of existing ships, and CO2-neutral energy projects; short loan terms avoid long-term binding of emissions (page 156).

Corporate: energy efficiency, renewable electricity and a 2026 move to a heat-pump headquarters aiming for WELL and LEED Platinum; net-zero for banking operations by 2050 (page 156).

Approval: targets were "adopted by the Management Board as part of the mid-term plan" (page 156). As a first publication, "there is no progress report" (page 157). The Bank discloses no investments or financing supporting the plan (page 157).

Identification of climate-related risks and scenario analysis

Reference: pages 157-163.

Back-filled from ESRS 2 IRO-1 (E1) and ESRS 2 SBM-3 (E1), where this content is disclosed in the FY2025 report (pages 157-163). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Corporate: "The Bank has not identified any material climate-related physical or transition risks in its own business operations" (page 157). Exposure of office locations to physical risk was assessed with insurance data (page 159).

Portfolio: the annual risk inventory covers acute and chronic physical risks and transition risks (CO2 price, green regulations, green technology, market sentiment, client ESG reputation) over 0-1, 1-5 and 5-30 years (page 160). CO2 price, green regulation, green technologies and market sentiment were the most relevant drivers, particularly for Shipping and Commercial Real Estate (page 161).

Scenarios: a 1.5 °C stress scenario "based on the Network for Greening the Financial System (NGFS) scenarios" plus HCOB-specific elements, run over a three-year horizon and reported quarterly (page 158). Physical risk for real estate, wind and solar farms and offices uses IPCC scenarios SSP1-2.6, SSP2-4.5 and SSP5-8.5 via insurance data; shipping uses Clarksons and EMSA data (page 163). No global average temperature projection per scenario is stated.

Resilience in relation to climate change

Reference: pages 157-159.

Back-filled from ESRS 2 SBM-3 (E1), where this content is disclosed in the FY2025 report (pages 157-159). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Resilience is tested with the 1.5 °C stress scenario, which "describes an abrupt and unforeseen political change and a subsequent sharp drop in demand for fossil fuels" with sharply higher CO2 costs (page 158). Result: "The Bank's business model is resilient in the 1.5 °C stress scenario, with declining but still positive earnings overall due to higher refinancing costs and a decline in new business", with total assets falling and a slight, quickly recovered dip in the CET1 ratio (page 158).

Segment effects: older, less efficient Real Estate buildings; tankers and bulkers in Shipping; Project Finance for renewables benefits; Corporates hit by slowdown and CO2 costs (page 158). Responses include "short credit periods in order to avoid lock-in effects" in Shipping and exclusion of ESG scores of 5 and 6 (page 159).

"The resilience analysis underpins the management's assessment that HCOB's business model can withstand the effects of climate change and the resulting transformation of the economy towards carbon neutrality" (page 159).

Policies related to climate change mitigation and adaptation

Reference: pages 163-165.

A table (pages 163-164) links each material climate IRO to its policies, measures and targets.

Corporate: the internal environmental policy covers energy, electricity, heat and fuel, their conversion to CO2e, and data collection and validation. Facility Management is responsible, and the policy "applies to the entire business operations of HCOB AG" (page 165). Emissions are recorded with the VfU calculation tool, in use since 2021 (page 165).

Portfolio: "ESG in the lending and investment process" (the Compliance Assessment and Sector Restrictions check, which limits or excludes financing in many carbon-intensive industries), the "Credit Manual" (ESG scoring) and the STFF classification, covering all of HCOB AG (page 165). The ESG E score is weighted 50 % and a transaction answers 18 climate and environmental questions; "An overall score of at least '4' is required for a positive lending decision" (page 165).

Actions and resources in relation to climate change policies

Reference: pages 166-168.

Corporate: Hamburg and Kiel electricity was fully renewable and heat comes from combined heat and power district heating (page 166). A subsidized Deutschlandticket was used by 749 employees (2024: 783), and the fleet is nine vehicles (ten in 2024). HCOB buys MoorFutures certificates in the amount of its own Scope 1 and 2 emissions plus business-flight Scope 3 (page 166). "It is not possible to quantify the reduction in GHG emissions achieved at the level of the individual measures" (page 166). The next step is the 2026 move to a certified building (page 166).

Portfolio: each loan gets the Compliance Assessment and Sector Restrictions check, ESG scoring, STFF classification (Sustainable, Transformational or Other) and an SDG appraisal (pages 166-167); "only transactions with an overall score of at least '4' were concluded" (page 167). New lending contributed to SDG 7 (8 %; 2024: 4 %), SDG 9 (43 %; 34 %), SDG 11 (4 %; 5 %) and SDG 13 (20 %; 15 %) (page 168). The Bank discloses no information on investments and financing supporting its transition plan (page 157).

Targets related to climate change mitigation and adaptation

Reference: pages 168-170.

Corporate: "HCOB has currently no specific target related to climate protection and adaptation to climate change at the operational level" (page 168).

Portfolio: net-zero by 2050 for the loan and investment portfolio and for Real Estate, Shipping and Energy (page 169). 2030 targets with a 2025 base year: Real Estate 29.1 kgCO2e/m2/a (from 47.7), Shipping alignment delta 15.0 % (from 19.8 %), Energy 70.0 gCO2e/kWh. "The targets listed in the table are science-based" and depend on no material change in portfolio composition (page 169).

STFF target: at least 20 % of net new business in 2026 (raised from 18 %), described as "not science-based" (page 169). Result: new business of EUR 5,026 million, of which EUR 1,439 million (29 %) sustainable or transformational (2024: EUR 1,542 million of EUR 6,069 million, 25 %); sustainable 1,001, transformational 438 (pages 169-170).

Energy consumption and mix

Reference: page 170.

Corporate only. Total energy consumption was 7,847 MWh in 2025 (2024: 7,970). Fossil sources supplied 4,209 MWh, 54 % (2024: 4,413 MWh, 55 %); renewable sources 3,638 MWh, 46 % (2024: 3,557 MWh, 45 %). Nuclear is nil. "100 % of the electricity comes from renewable energies and accounts for 46 % of the Bank's total energy consumption"; the other 54 % is district heat and fuel for a few pool vehicles and emergency-power diesel.

Hamburg and Kiel are measured from invoices and meter readings (7,017 MWh); other locations (830 MWh) are extrapolated per FTE because of tenancy. The report states: "The Bank is not associated with any high climate impact sectors." Renewable shares include the EEG-subsidized portion set by law.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 171-179.

Own operations (2025 vs 2024, t CO2e): Scope 1 25 (33); Scope 2 location-based 1,713 (1,814), market-based 374 (500); the four significant Scope 3 categories 1-14 sum to 2,991, led by purchased goods and services 2,119 (cloud and data centers 2,112) and business trips 364 (201) after an RFI of 1.7 was used for the first time (pages 171-172). Total (market-based) 4,806,845 (5,646,599); GHG per net revenue 3,079.3 (3,047.3), using interest and commission income (pages 171, 173).

Financed emissions (PCAF, pages 174-176): Scope 1 and 2 "2,188 (2024: 3,369) thousand tonnes of CO₂e", Scope 3 2,616 (2,275); Global Transportation 72 %; intensity 135 t CO2e per EUR million (2024: 178). "Financed emissions account for more than 99.9 % of the Bank's carbon footprint." Coverage is 56 % of total assets; client-reported emissions cover only 12 % (page 178). Primary data rate for categories 1-14 is 27.9 % (page 171).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 180.

Corporate only. HCOB buys MoorFutures certificates each year from Ausgleichsagentur Schleswig-Holstein GmbH, a subsidiary of the Stiftung Naturschutz Schleswig-Holstein. Each certificate "represents the prevention of one tonne of CO₂ through the rewetting of upland moor habitat in Schleswig-Holstein". In the reporting year HCOB bought certificates "in the amount of its own Scope 1 and Scope 2 emissions as well as Scope 3 emissions due to business flights". The section gives no tonnage.

The certificates "do not serve to reduce the Bank's own remaining emissions" but contribute to Germany's climate protection; the stored emissions are guaranteed for 50 years and recorded in the Stilllegungsregister held by the Schleswig-Holstein ministry (page 180). No GHG removals by HCOB are reported.

Internal carbon pricing

Reference: page 180.

E1-8 is listed in both blocks of the Appendix 1 index (page 226) and has its own section, which is a nil return: "HCOB does not use an internal carbon pricing system." (page 180). No internal carbon price, shadow price or carbon fee is described elsewhere in the statement.

Policies related to pollution

Reference: pages 181-182.

Portfolio only. Two material impacts sit in the Shipping segment: "Emission of pollutants through the combustion of fuels" and "Leakage of oils and chemicals" (pages 144, 181). Operation of financed ships emits "gaseous pollutants such as CO₂ and sulphur dioxide as well as soot particles and particulate matter", and oils or chemicals can reach the marine environment (page 181).

The policies build on IMO guidelines, strengthened in June 2025 by the Hong Kong Convention on ship recycling, and on HCOB's membership of the Responsible Ship Recycling Standard initiative since 2020. Clients must report compliance through the lending process, mainly the ESG scoring (page 181). The "Credit Manual" governs ESG scoring, whose E score, weighted 50 %, "explicitly takes into account air, water and soil pollution", with questions on pollution of air, water and sediments and on noise (page 182).

Actions and resources related to pollution

Reference: page 182.

Portfolio only. The policies were put into practice through ESG scoring of each loan, in which specific pollution questions must be answered to assess compliance with environmental standards (page 182). The report states that scoring "was fully applied in the lending and investment process during the reporting year", that only transactions with an overall score of at least 4 were concluded, that loans scored 5 and 6 were excluded, and that "This approach is also planned for 2026" (page 182). The section names no separate budget, capital expenditure or other resources, and refers to the E1 chapter for details of the scoring process.

Targets related to pollution

Reference: page 182.

Portfolio only. HCOB has no pollution target and gives its reason: it "has not currently set a specific target for reducing air and water pollution, as banks can only influence this topic indirectly through their financing activities" (page 182). It adds that policies and measures were implemented "as far as possible" through the ESG scoring and exclusion mechanisms described under E2-1 and E2-2 to address the two material negative impacts (page 182). The E2 impact table likewise records "no targets defined" for both air pollution and water pollution (page 181).

Policies related to water and marine resources

Reference: page 183.

Corporate only. Water consumption, use and procurement are regulated by the environmental policy. The Bank "obtains drinking water exclusively from the public water network and does not treat or reuse any water itself" and consumes only what office operations need (page 183). Five premises are in areas of high water stress: Piraeus (12 employees), London (21), Berlin (7), Frankfurt (7) and Stuttgart (1); their impact on regional water availability is judged low, so there is no separate policy for those regions (page 183). "As marine resources have not been identified as material, HCOB does not pursue any specific policies in this regard" (page 183). The "Sales Management & ESG" department designs the measures and Facility Management implements them.

Actions and resources related to water and marine resources

Reference: page 183.

Corporate only. HCOB reads the water meters at its Hamburg and Kiel locations monthly and has done so for many years. The report is explicit that "The primary purpose of this measure is not to reduce consumption, but rather to ensure transparency", so that consumption can be monitored, irregularities caught early and countermeasures taken on deviations (page 183). The Bank "does not currently have any specific measures in place with regard to locations in areas of high water stress" (page 183). The E3 impact table lists "Creation of transparency through monthly meter readings" as the only measure and "no targets defined" (page 183).

Targets related to water and marine resources

Reference: page 184.

Corporate only. The section reads: "HCOB strives to keep water consumption low in the course of its office activities." No explicit reduction targets were formulated; the stated reason is that the Bank already considers its water use to be at its lowest practical level (page 184). The E3 impact table records "no targets defined" for the single material E3 impact, water consumption by banking operations (page 183). The Bank sets no targets for marine resources, which it has not identified as material (page 183).

Water consumption

Reference: page 184.

Corporate only. Water consumption at Hamburg and Kiel totaled 15,350 m³ in 2025 (2024: 17,779 m³), based on monthly meter readings consolidated annually (page 184). Including the other locations, which are extrapolated per full-time employee, total consumption was 17,165 m³ (2024: 20,016 m³). Water intensity was 19.9 m³ per FTE in 2025 (2024: 21.5). Stored water is used only "in insignificant quantities" for the sprinkler system in Hamburg (page 184). The report gives no separate consumption figure for the five premises in water-stressed areas (page 183).

Transition plan on biodiversity and ecosystems

Reference: page 185.

Portfolio only. The report prints this section as "E4-1 Transition plan and consideration of biodiversity and ecosystems in strategy and business model" and describes no biodiversity transition plan. It states that "HCOB does not currently consider its business model to be exposed to any material risks in connection with biodiversity and ecosystems", a view confirmed by the double materiality analysis, where biodiversity risks were analyzed in the risk inventory (page 185). The Bank "does not operate in sectors that are typically exposed to increased biodiversity risks, such as agriculture, forestry or mining". It still takes account of its impact through ship financing, the one material E4 impact (page 185).

Policies related to biodiversity and ecosystems

Reference: pages 185-186.

Portfolio only. Ship financing affects marine ecosystems through invasive species, GHG emissions, harmful paints and noise, and HCOB has policies for managing and measuring this (page 185). For each financing the "Credit Manual" ESG scoring checks for a negative impact on biodiversity, with questions on ballast water treatment systems (BWTS), hull painting and waste disposal (page 186). The policies build on IMO guidelines, including the Ballast Water Management Convention and, from June 2025, the Hong Kong Convention on ship recycling, plus the Responsible Ship Recycling Standard joined in 2020 (page 186). Compliance monitoring is "largely carried out as part of the inspections initiated by the respective flag states" (page 186).

Actions and resources related to biodiversity and ecosystems

Reference: page 186.

Portfolio only. ESG scoring was fully applied in the lending and investment process; each loan answers biodiversity questions, only transactions with an overall score of at least 4 were concluded, and loans scored 5 and 6 were excluded, which "will also be the case in 2026" (page 186). The ship portfolio was also analyzed for installed BWTS using the Clarksons database "in order to gain a better understanding of the negative impacts on biodiversity and ecosystems", and the analysis is planned again for 2026 (page 186). "No compensation measures in connection with biodiversity are planned at present" (page 186). No budget or other resources are quantified.

Targets related to biodiversity and ecosystems

Reference: page 186.

Portfolio only. HCOB "currently has no specific target for measuring the effectiveness of its measures related to conservation of biodiversity and ecosystems, as banks can only influence the topic indirectly through their financing activities" (page 186). It adds that policies and measures were implemented as far as possible to address the material negative impact. The E4 impact table also records "no targets defined" for the impact "Pressure on marine ecosystems, particularly from invasive species" (page 185).

Impact metrics related to biodiversity and ecosystems change

Reference: page 187.

Portfolio only. For the first time the ship portfolio was analyzed for ballast water treatment systems (BWTS), using public data on the financed ships (page 187). Share of ships with a BWTS installed: 96.3 % in 2025 (2024: 94.6 %); installation pending 0.0 % (0.2 %); no BWTS or no information 3.7 % (5.2 %). By technology: UV irradiation 27.8 % (22.1 %), electrochemical 51.8 % (60.6 %), chemical 2.8 % (3.2 %), thermal 0.3 % (0.2 %), unknown 17.4 % (14.0 %). The Bank notes that UV irradiation "is particularly environmentally friendly, as it does not use any harmful chemicals and leaves no toxic residues" (page 187).

Policies related to resource use and circular economy

Reference: page 188.

Corporate only. The internal environmental policy "regulates the consumption of resources in business operations, including the handling of waste". Employees are encouraged to separate waste at the workplace so it can be recycled in full, and non-recyclable waste goes to energy recovery. The head of Facility Management is responsible for operational implementation, and the policy's scope and responsibility are set out in the E1 chapter (page 188). The single material E5 impact is "Waste generation by banking operations" (page 188).

Actions and resources related to resource use and circular economy

Reference: pages 188-189.

Corporate only. Three actions are listed (page 188): a waste separation system collecting residual waste, organic waste, recyclables and glass, with paper collected separately for data protection reasons and "almost 60 waste separation systems" at Hamburg and Kiel; digitalization, which has steadily reduced paper use, with printing paper that is wood-free and made of at least 50 % recycled or sustainable material; and re-use of decommissioned office furniture and equipment, offered to non-profit organizations again in 2025 (page 189). With the Hamburg move in 2026, continued use of the existing furniture, by the Bank or third parties, is planned (page 189). No budget is stated.

Targets related to resource use and circular economy

Reference: page 189.

Corporate only. The report states: "Although HCOB strives to further reduce waste volumes, no quantitative reduction targets have been defined as the possibilities at the existing locations have largely been exhausted" (page 189). The E5 impact table also records "no targets defined" for waste generation by banking operations (page 188). No qualitative target, milestone or deadline is given.

Resource outflows

Reference: pages 189-190.

Corporate only. Total waste at Hamburg and Kiel was 63.5 t in 2025 (2024: 59.3 t); with the other locations the total is 71.0 t (2024: 66.7 t) (page 189). Waste data come quarterly from regional waste service providers and are broken down by type; other locations are extrapolated per FTE (page 189). Waste intensity is 82.3 kg per FTE (2024: 71.4). Total paper consumption was 3.4 t, 3.9 kg per FTE (2024: 4.5 t, 4.8 kg) (page 190). The section covers waste and paper only and gives no figures for products or materials leaving the operations; the Bank says "As HCOB is not a manufacturing company" its direct resource use is mainly energy, water and waste (page 138).

Waste

Reference: pages 189-190.

Corporate only. Waste by type and disposal route, in tonnes, 2025 (2024) (pages 189-190):

• Total waste: 71.0 (66.7), of which Hamburg and Kiel 63.5 (59.3) and other locations 7.5 (7.4).
• Non-recycled waste: 24.7 t, 35 % of the total (2024: 24.8 t, 37 %).
• Non-hazardous waste recycled: 46.3 (42.0).
• Hazardous waste and radioactive waste: both rows show no quantities (dashes).

The disposal table lists combustion under disposal at 24.7 t (24.8), which equals the non-recycled waste. Waste is disposed of by type and "where possible, recycled or used for energy recovery" (page 188). Figures for locations other than Hamburg and Kiel are extrapolated using the number of full-time employees (page 189).

Policies related to own workforce

Reference: pages 193-196.

Employer/works council agreements regulate working time, mobile working, phased-in early retirement, occupational health and safety, equal opportunities for women and men, inclusion of severely disabled persons, performance management and talent management (pages 193-196). Other policies: the Code of Conduct, the Code of Diversity, a gender-neutral remuneration strategy and a Whistleblowing-Policy (pages 194-196). Policies apply to all employees in Germany except executives, who are covered through the executives' committee (page 193).

Context: the 2025 "Franchise Focus" strategy brought "a socially responsible reduction in staff" decided in the first half of 2025 and "implemented gradually until 2028" under a reconciliation of interests agreement and social plan (page 193). The report says "Negative impacts related to human trafficking, forced or compulsory labour and child labour are completely ruled out" (page 193). HR is generally responsible for implementation (pages 193-195).

Taking action on material impacts on own workforce

Reference: pages 199-202.

Actions address the three material impacts: high workload, insufficient equal opportunities and violations of employee rights (page 199). They include flexible working time and family support, occupational health management with company doctors, social counselling and stress seminars, annual pay reviews, gender pay gap calculations, a mandatory Code of Diversity training course, and training and talent programs (pages 200-202). The 2025 employee survey showed the commitment index rising from 7 (2023) to 7.2 (2025) (page 200).

Resources "come from the current budget and no additional funds were provided" (page 199). Effectiveness is monitored through HR Controlling KPIs (sick days, share of women, gender pay gap), monthly dialogue with the works councils and employee surveys (page 202).

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

Reference: page 203.

Two targets address "Equal treatment and opportunities for all: insufficient consideration of equal opportunities", both due by the end of 2027 (page 203):

• A 33 % share of the underrepresented gender (currently women) in management functions and at senior expert level: 31.6 % at 31 December 2025 (31.4 % a year earlier).
• A 33 % share of the underrepresented gender at business unit head level: 31.3 % at 31 December 2025 (22.2 % a year earlier, a gap the report attributes to the reorganization).

Both cover all Group locations, are managed by HR and are measured in absolute numbers. "No milestones or intermediate targets are defined." (page 203). No targets are set for the high workload and employee rights impacts, which are recorded as "no targets defined" (page 192).

Characteristics of the undertaking's employees

Reference: pages 204-205.

Headcount at 31 December 2025 was 970 (2024: 1,036): 378 women, 592 men, none non-binary or unspecified. Permanent employees 923, fixed-term 47, temporary workers 0; full-time 771, part-time 159. By region, 896 in Germany and 74 abroad; Germany is the only country shown (pages 204-205). The data cover HCOB and all Group companies and equal 862.4 FTEs.

Turnover: 127 employees left in 2025 (2024: 97), a rate of 12.5 % at Group level (2024: 9.5 %, recalculated). The 2024 rate was restated because it had omitted fixed-term departures (page 205). Resignations account for 4.2 % and the end of fixed-term contracts for 2.7 % (page 205). Temporary workers are excluded under the phase-in (page 204).

Collective bargaining coverage and social dialogue

Reference: page 205 (see also pages 196, 207).

The table shows Germany, the only EEA country with more than 50 employees making up over 10 % of the workforce, in the 20 to 39 % band for collective bargaining agreement coverage and in the 80 to 100 % band for representation in the workplace (social dialogue). No non-EEA country is listed. The note says: "There is no European works council for the 2025 reporting year" (page 205).

Context: works councils at the German locations act under the BetrVG and "the collective bargaining agreement for the private banking industry" (page 196), and the S1-10 section refers to "extensive collective bargaining coverage and regulations" (page 207).

Diversity metrics

Reference: page 206.

Employees at 31 December 2025: 970 in total, 39 % women (378) and 61 % men (592); non-binary and unspecified none. By age: under 30, 104; 30 to 50, 440; over 50, 426 (page 206).

Top management level, defined as all business unit heads: 16 people, 5 women (31 %) and 11 men (69 %); by age, 8 aged 30 to 50 (50 % women) and 8 over 50 (13 % women) (page 206). In 2024 there were 18 top managers, 4 of them women (22 %). The report defines top management as "all BU heads" (page 206 footnote). The 2024 comparatives are shown beside the 2025 table.

Adequate wages

Reference: page 207.

The remuneration system has fixed and variable components "aligned with the relevant market". The report gives its adequate-wage result directly: "As in the previous year, no employees (0%) are paid below the applicable benchmark (minimum wage) for fair compensation" (page 207). It points to S1-8 for collective bargaining coverage, and to measures on adequate wages described under S1-4 (pages 201, 207). Pay is reviewed at least once a year and benchmarked internally and externally (page 201). No per-country breakdown is given.

Social protection

Reference: page 207.

The report states that "employees at all Group locations are 100% insured against loss of earnings due to illness, unemployment, workplace accidents, parental leave and retirement", as in the previous year (page 207). The cover is either required by law or arranged by the company, for example an additional company pension scheme and the assumption or subsidy of private health insurance at selected locations. "The range and amount of company insurance cover can vary depending on the location" (page 207). No country-level breakdown is given.

Persons with disabilities

Reference: page 207.

Employees with disabilities were 5.7 % of the workforce in 2025 (2024: 5.0 %): women 3.1 % (2.8 %) and men 2.5 % (2.2 %); non-binary and unspecified none (page 207). The data cover all HCOB Group companies and include active employees, those on parental leave or long-term sick leave or on leave of absence, and early retirees. The Bank has an employer/works council inclusion agreement for severely disabled persons and those with equivalent status, and a representative body for them (SBV) (pages 195, 197).

Training and skills development metrics

Reference: pages 207-208.

All employees were covered by Bank-wide performance management in 2025, with at least two performance and career development reviews a year. The Group company Klarphos is not subject to formal performance management (page 207). Participation in regular reviews was 99 % (2024: 99 %): women 98 %, men 99 % (page 208). Average training hours per employee were 20 in 2025 (2024: 25): women 18 (26), men 22 (24) (page 208). The note says the figure "includes mandatory training hours" (page 208). Further detail is in S1-1 and S1-4.

Health and safety metrics

Reference: page 208.

"As in the previous year, 100 % of employees are covered by a health and safety management system", and HCOB was certified in 2022 as a "company with exemplary occupational safety" by the Hamburg state authority, valid for six years (page 208). In 2025 there were five reportable accidents at work (2024: three), causing 153 sick days, and no work-related illnesses. The accident rate was 3.3 cases per 1 million hours worked (2024: 2). There were no fatalities from work-related injuries or illnesses (page 208). Safety measures are described under S1-1 and S1-4.

Work-life balance metrics

Reference: page 208.

"100% of the HCOB employees are entitled to leave for family reasons within the framework of the social policy and/or collective bargaining agreements" (previous year: 100%) (page 208). Share of employees who took leave for family reasons: 9.4 % in 2025 (2024: 10.7 %), of which women 6.3 % (6.6 %) and men 3.1 % (4.1 %); non-binary and unspecified none (page 208). Related measures are flexible working time, mobile working and family support described under S1-4 (page 200).

Compensation metrics (pay gap and total compensation)

Reference: page 209.

The unadjusted gender pay gap for 2025 is 21.4 % (previous year: 24.6 %). It covers employees at all levels below the Management Board, including all international locations (page 209). The annual ratio of total remuneration, comparing the highest-paid individual (including Management Board members) with the median of all employees, is 65.2 (previous year: 74.6) (page 209). The gap is "the percentage difference between the average gross hourly earnings of women and men", regardless of career level, experience, qualifications or job function (page 209). Equal pay measures are listed under S1-4 (page 201).

Incidents, complaints and severe human rights impacts

Reference: page 209.

The table shows no incidents of discrimination in 2025 or 2024, two complaints through the channels for employees to raise concerns (2024: four), no complaints to the OECD national contact points, no material fines, penalties or damages (shown as nil), and no serious human rights issues or incidents related to own workforce (page 209). The note says the complaints "were duly examined by those responsible" and "did not reveal any substantiated cases of discrimination, which is why no fines, penalties or compensation payments were imposed" (page 209).

Policies related to value chain workers

Reference: pages 211-213.

Corporate (suppliers): a strategic approach based on the UN Guiding Principles on Business and Human Rights and the OECD guidelines. "HCOB is not aware of any cases that violate these guiding principles" (page 211). The Supplier Code bans forced labor, child labor and human trafficking; suppliers must agree to it in writing before contracting, and contracts usually carry audit rights. Critical product groups are buildings and land, office and business equipment, and IT hardware. Procurement & Vendor Management is responsible (page 211). "No workers in the value chain are currently involved" in creating the policies (page 211).

Portfolio (ships): the Bank relies mainly on IMO conventions and flag-state inspections (page 212). The ESG scoring S score checks whether the flag state has ratified MLC 2006, using the Paris MoU White, Grey and Black list (page 213).

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions

Reference: pages 214-215.

Corporate: sustainability is part of the supplier review: credit checks, comparison with sanctions and embargo lists and negative reports, and signing the Supplier Code. Suppliers who refuse may be excluded, and violations may end the relationship (page 214). "The effectiveness of these approaches is not verified."

Portfolio: each loan undergoes the Compliance Assessment and Sector Restrictions check and ESG scoring; only transactions scoring at least 4 were concluded and 5 and 6 were excluded (pages 214-215). "The effectiveness of these measures and initiatives in terms of achieving the desired results for the value chain workers is not tracked." No serious human rights problems or incidents were reported in 2025, and "No additional means were allocated" (page 215).

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

Reference: page 215.

The report states: "HCOB has not currently set a target for assessing the effectiveness of measures to protect value chain workers, as Banks can only manage the topic indirectly via financing activities, among other things." It adds that policies and measures were implemented as far as possible (page 215). The S2 impact table records "no targets defined" for both material impacts, the supplier-related working conditions impact and the impact of critical working conditions on ships (page 210).

Business conduct policies and corporate culture

Reference: pages 217-220.

Under G1-1 the chapter treats three of the five material impacts (page 217): violation of the Code of Conduct, endangering whistleblowers and influence on political decisions. Supplier treatment is covered under G1-2 and corruption under G1-3. Policies: the Code of Conduct (for employees, service providers, suppliers, clients and third parties), the Code of Diversity and a training policy owned by Compliance (pages 217-218). The Whistleblowing-Policy "guarantees anonymity, confidentiality and protection against reprisals" and applies to employees and external third parties including value chain workers (page 218). A donation and sponsorship policy bars donations to political parties (page 218), and benefits and anti-fraud policies apply Group-wide (page 219).

Culture is supported by compliance training every three years, weekly legal monitoring, annual compliance risk analyses, and quarterly compliance reporting to the CRO and the Management Board (page 219). An investigation committee handles suspected fraud and corruption (page 220).

Targets related to business conduct

Reference: pages 217-223.

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

HCOB sets no business conduct targets. The G1 impact table records "no targets defined" for all five material impacts (page 217).

Effectiveness is tracked instead (pages 219, 223):

• "The Compliance business unit reports directly to the CRO and the Overall Management Board at least quarterly", and the Risk Committee of the Supervisory Board receives the quarterly compliance report (page 219).
• An overall compliance risk assessment is made at least once a year, and compliance management is reviewed at least every three years (page 219).
• Donations are monitored through regular reporting and evaluation (page 219).
• Training completion rates are measured and compared with the prior year (page 223).

Incidents of corruption or bribery

Reference: page 224.

"HCOB did not record any incidents of corruption or bribery during the reporting year." The table of incidents shows no entries for 2025 or 2024 on convictions for anti-corruption and anti-bribery laws, fines, measures taken against violations, confirmed incidents, legal proceedings against the company or its employees, and employees dismissed or disciplined for corruption or bribery (page 224). The ombudsperson received no reports in 2025 (2024: two) (page 214).

Political influence and lobbying activities

Reference: page 224.

Corporate only. "HCOB does not exert any direct political influence and does not make donations of money or in-kind donations to political parties or party-affiliated political associations." It represents its interests through the Federal Association of German Banks (BdB), the Auditing Association of German Banks, the Association of German Pfandbrief Banks and chambers of commerce, including the ICC Germany. Contributions to associations were around 459 T€ (previous year: 447 T€). Two Management Board members sit on BdB committees and the board of a regional association. No Management Board or Supervisory Board member held a comparable public administration position in the two years before appointment. HCOB is registered in the German Transparency Register (page 224).

Payment practices

Reference: pages 224-225.

Corporate only. HCOB "does not have fixed standard terms of payment, but offers its service providers and suppliers various payment options" (page 224). The metrics cover invoices of the German locations only, excluding expense reports, reimbursements and transaction-related commissions; payment days are weighted by invoice amount from the date of invoice receipt (page 224).

Results for 2025 (2024): the share of payments within the agreed terms rose from 53 % to 69 %; the average payment period fell from 24 to 22 days; and for overdue invoices it fell from 31 to 17 days (page 225). The report credits the insourcing of financial accounting. As at 31 December 2025 there were no pending court proceedings for late payment (previous year: none) (page 225).