Hannover Rück SE

Reference: pages 57-61.

Hannover Rück SE has a two-tier board system. At 31 December 2025 the Executive Board had eight members, all executive, and 37.5% were women (three of eight). The Supervisory Board had nine non-executive members, three of them elected employee representatives, and roughly 44% were women (four women, five men) (p.57). Four of the six shareholder-side members are independent under the German Corporate Governance Code, about 66%, and the company reports independence for shareholder representatives only (p.57).

Who is responsible for sustainability:

• The CEO, Clemens Jungsthöfel, "bears responsibility, in particular, for the areas of strategy, sustainability, organisation, information technology, human resources management, corporate communications, risk management, legal, compliance and internal audit" (p.57).
• "Overall responsibility for adequate handling of the impacts of business activity, risks and opportunities rests with the Executive Board" (p.59).
• The ESG governance structure has a "Sustainability Function", an "ESG Management Team" (ESGMT) and an "ESG Expert Network" (p.59). Harald Kayser was designated ESG expert on the Supervisory Board in 2024 (p.58).
• The Supervisory Board "is entrusted with an advisory and monitoring role and examines the sustainability statement" (p.59). Its Finance and Audit Committee monitors the accounting process, the internal control system and risk management (p.59).

Reference: pages 60-61.

The Executive Board receives half-yearly information from Group Strategy & Sustainability on progress against the Group Strategy 2024-2026, "Staying Focused. Thinking Ahead.", and decision papers on sustainability topics through the year. "In the year under review, it validated the materiality assessment" (p.61).

The Supervisory Board, its Finance and Audit Committee and the ESG expert on the Supervisory Board dealt with sustainability matters in 2025, including the findings of the materiality assessment and regulatory developments. The Chief Risk Officer reported to the Supervisory Board and the Finance and Audit Committee on risk topics including natural catastrophe risks (p.61). Through its annual review of the sustainability statement the Supervisory Board also engages with the material impacts, risks and opportunities. A numbered overview of the material impacts, risks and opportunities is in the table "Identified material impacts, risks and opportunities" (pp.74-75).

Reference: pages 61-62 (variable remuneration components incorporated by reference to the remuneration report, p.57).

Executive Board target direct remuneration is made up of "40 % fixed remuneration and 60 % variable remuneration components" (p.61). The Supervisory Board sets criteria for an individual premium or deduction of -25 to +25 percentage points on the variable part, and these criteria "also include sustainability goals" (p.61).

Two sustainability targets are named: the Carbon Disclosure Project (CDP) rating, with a target set at "Management level", and the Engagement Index from the annual employee survey (p.61). The company is explicit about the limits: "specific quantitative sustainability-related performance criteria are not defined as targets for the remuneration of the Executive Board" (p.61), and "it is not possible to make a mathematically precise determination of the proportion of variable remuneration dependent on sustainability- or climate-related targets or impacts" (p.61). Supervisory Board pay is fixed and not linked to target attainment (p.61).

Reference: page 61.

Hannover Re gives a mapping table of the core elements of due diligence to the paragraphs of its sustainability statement (p.61). The table lists: embedding due diligence in governance, strategy and business model (ESRS 2 GOV-2, GOV-3, SBM-3); engaging with affected stakeholders (GOV-2, SBM-2, IRO-1, MDR-P and the topical standards); identifying and assessing adverse impacts (IRO-1, SBM-3); taking actions to address them (MDR-A and the topic-level actions and transition plans); and tracking effectiveness and communicating (MDR-M, MDR-T and the topical metrics and targets) (p.61).

The statement introduces the table as "an overview of the information contained in its sustainability statement on the procedure for fulfilment of due diligence" (p.61).

Reference: pages 61-62.

All risk-related processes run through the risk management process and an internal control system (ICS) applied Group-wide, communicated through the Risk and Capital Management Policy (p.61). For sustainability reporting the company names its main risks as "incorrect or delayed data deliveries, misinterpretations of metrics or processes, as well as incomplete data from the upstream or downstream value chain" (p.62). Reporting is classed as an operational risk (business process and data quality risk) and "Sustainability management, including sustainability reporting, is listed as an explicit element of the internal control system" (p.62).

Controls named are plausibility checks, multiple pairs of eyes, deadline management, an authoring system that documents workflows and approvals, and "quality controlling by two members of staff in the Group Risk Management division prior to publication" (p.62). Quantitative data follow a Group-internal reporting manual of the parent company Talanx. The Executive Board and Supervisory Board are informed at least annually of material developments and outcomes in sustainability reporting (p.62).

Reference: pages 62-63.

Hannover Rück SE is a European Company based in Hannover, Germany, and "one of the largest reinsurers in the world" (p.62), with reinsurance revenue of around EUR 26.8 billion. Its main activities are property and casualty reinsurance and life and health reinsurance (NACE K65.2.0). It employs "more than 4,000 staff" (p.62) and is present on all continents (p.62).

The Group Strategy 2024-2026, "Staying Focused. Thinking Ahead.", targets profitability, earnings growth, economic value creation, dividends and capital strength, plus strategic goals on employee engagement and environmental stewardship. The Environmental Strategy and the People & Culture Strategy carry the main sustainability work (p.62).

Value chain (pp.62-63): inputs are risk data and capital; outputs are reinsurance protection and financial security. Upstream are primary insurers, capital providers, brokers, retrocessionaires and suppliers; downstream are claims settlement and investing activities.

Reference: page 63.

The company names its key stakeholders as customers and brokers, investors, employees, regulators and financial supervisory authorities, and civil society. Dialogue runs through direct client discussions, annual employee surveys, employee representative bodies, industry associations and direct investor engagement on ESG matters (p.63). Views are also fed in through the materiality assessments (see IRO-1).

The Group Strategy 2024-2026 picks up stakeholder expectations: employee expectations shape the People & Culture Strategy and societal and legislative expectations on decarbonization shape the Environmental Strategy (p.63). "The Executive Board also validates the results of the materiality assessment" (p.63), and the Supervisory Board and the Finance and Audit Committee are informed of the findings. The company states that "relationship to stakeholders is not expected to change significantly" (p.63) as a result of the Group Strategy.

Reference: pages 63-64; table of 32 IROs pages 74-75.

The Group's material impacts, risks and opportunities (IROs) concern climate change, its own workforce and business conduct. "The IROs (Impacts, Risks, Opportunities) identified in connection with climate change are concentrated primarily on global core business in the downstream value chain" (p.63), while workforce and business conduct IROs relate to own operations (p.63). "No major changes were identified in relation to previous reporting periods" (p.63); individual IROs were further specified and consolidated, and "anti-competitive behaviour was categorised as a non-material matter" (p.63).

Financial effects (p.64): the risks are potentially material but "caused no material financial impacts on the undertaking's assets, financial position and net income in the reporting period", and the company says "It is currently impossible to put a more precise number on the financial impacts" (p.64).

Resilience (p.64): climate change is "the most significant sustainability risk for Hannover Re". Business planning covers the next year plus an outlook for four more years, with none beyond five years.

Reference: pages 64-67.

Hannover Re runs a two-stage double materiality process. It performs an annual trigger analysis and, if no triggers occurred, validates the last assessment; "Irrespective of the outcome of the trigger analysis, Hannover Re conducts a complete materiality assessment at the latest every three years" (p.64). For 2025 it validated the 2024 assessment (p.64).

Impacts (p.65): scale, scope and irremediability are each scored 0 to 5; for positive impacts scale and scope are multiplied by 1.5. Potential impacts are multiplied by a probability from 0.65 to 1. "Positive and negative impacts are categorised as material if the materiality score reaches 8 or more" (p.65).

Risks and opportunities (p.66): likelihood is scored 0.65 to 1 and magnitude 1 to 5; "A risk or opportunity is categorised as financially material if the total score exceeds a threshold of 3" (p.66). Sustainability risks are assessed with tools in line with the Solvency II delegated regulation (p.66).

Inputs include internal workshops (external stakeholders are represented by internal ones per ESRS 1 AR 8), risk management data, WWF risk filters and UNEP-FI impact maps for the investment portfolio (pp.65-67). Topic-level IRO-1 statements for E2, E3, E4 and E5 each conclude that no material impacts, risks or opportunities were found (pp.66-67).

Reference: pages 68-75.

Form of the index: the report does not print a disclosure-requirement-by-disclosure-requirement concordance. IRO-2 instead has (a) a table of ESRS sub-topics with the pages that cover them (pp.68-70), (b) a datapoint list from other EU legislation marked "Material", "Not material" or "Phase-in" (pp.71-73), and (c) a numbered table of 32 material IROs (pp.74-75).

The sub-topic table gives page ranges only for climate change (E1: 83-96), own workforce (S1: 96-104) and business conduct (G1: 104-107). Every E2, E3, E4, E5, S2, S3 and S4 sub-topic, and G1 animal welfare, political engagement and lobbying, and supplier relationships including payment practices, shows a dash instead of a page range (pp.68-70). The company states that "the following standards are material for Hannover Re and thus form the basis for the reporting" (p.55): E1, S1 and G1, plus "Data privacy and cyber security" as an undertaking-specific topic reported in G1 (p.55).

"The key information provided in the sustainability statement in connection with the impacts, risks and opportunities assessed as material is determined primarily on the basis of internal policies, actions, targets and data" (p.75).

Reference: page 83.

Hannover Re states plainly that it has no transition plan: "[E1_17] Hannover Re is not planning to adopt a transition plan as defined by the ESRS at the present point in time." (p.83)

No transition plan content is given in E1-1. The climate material elsewhere in the E1 chapter is policy and target based: the Environmental Strategy 2024-2026 with decarbonization of underwriting and investment portfolios and own operations as an action field (p.83), and targets in E1-4 (pp.88-91). On the investment target the company says it "has not to date identified or quantified any concrete levers or actions as defined by the CSRD for achievement of its investment target" (p.90), and that "Assurance has not been obtained for the 1.5°C-compatibility of the target and it is not based on climate scenarios" (p.90).

Reference: pages 84-86 (E1 chapter, climate part of IRO-1).

Back-filled from ESRS 2 IRO-1 as presented in the E1 chapter of the FY2025 report (pages 84-86). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk: the company uses an internally developed climate-related approach and "looks at two main scenarios with a temperature increase of 2 °C by 2050 (~RCP 4.5) and 4 °C by 2050 (significantly more extreme than RCP 8.5)" (p.85). These feed natural catastrophe, mortality and morbidity risk. The stress test is run every two years at Group level on the year-end portfolio, as an instant shock (p.85). Life and health modeling uses the pathways RCP 4.5 and RCP 8.5 for 2100 (p.84). Time horizons are short-term up to 1 year, medium-term up to 5 years and long-term longer than 5 years (p.84). "Hannover Re has not identified any material climate change-related risks to its own operations" (p.84).

Transition risk: the investment stress test uses carbon intensity and external ESG data across corporate bonds, covered bonds and equities, and the company says "no explicit scenario within the meaning of the ESRS is used that restricts global warming to 1.5°C with or without a limited overshoot" (p.86). Litigation risk in underwriting is assessed with a scenario aligned with RCP 8.5 (p.86).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Reference: pages 64 and 83-85 (ESRS 2 SBM-3 and the E1 chapter).

Back-filled from ESRS 2 SBM-3 and the E1 SBM-3 section, where this content is disclosed in the FY2025 report (pages 64, 83-85). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company calls climate change "the most significant sustainability risk for Hannover Re" (p.64). Its resilience statement is qualitative: "Regular evaluation of the exposure and the actions taken to manage the business have to date ensured that Hannover Re's business model can demonstrate its resilience even in times of rising loss expenditures due to the consequences of climate change" (p.83).

Capacity to adapt: annual renewals in property and casualty reinsurance give short response times and room to steer risks (p.84). A strategic risk exists if insurability changes over the long term, for example if cover can no longer be provided for buildings in some regions (p.64). Findings of the scenario analyses can lead to adjustments to reinsurance products (p.83).

Uncertainty: "All assumptions made are subject to considerable uncertainty" (p.85), and the 4°C scenario is described as physically highly unrealistic and an extreme case (p.85).

Climate resilience is also presented under E1-3 (2025 ESRS numbering).

Reference: pages 83 and 86-91.

The central policy is the Group-wide Environmental Strategy 2024-2026. It has three action fields: decarbonization of the underwriting and investment portfolios and of own operations, more engagement with cedants, brokers, issuers and employees, and targeted support for societal resilience. The Executive Board holds ultimate responsibility (p.83).

Underwriting: a 2022 ESRS position paper for property and casualty business commits Hannover Re to decline portfolios used exclusively for thermal coal and cover exclusively for new greenfield upstream or midstream oil and gas (p.87). The Facultative Division's ESG manual excludes new thermal coal plants and mines (since April 2019) and sets a phased exit with "the complete exclusion of all thermal coal risks in 2038" (p.87). A Climate and Disaster Resilience Position on the protection gap and the Risk and Capital Management Policy complete the set (p.88).

Investments: the Responsible Investment Standards, in written form since 2012, exclude issuers with 25% or more of revenue from shale oil or gas or oil sands, 10% or more from thermal coal mining or power, and 5% or more from Arctic offshore drilling (p.89). A medium- to long-term climate strategy for investing activities was approved in 2021 (p.89).

Own operations: Hannover has bought only renewable electricity since 2012, extended to all office locations in 2024 (p.91).

Reference: pages 88, 90 and 91.

Hannover Re reports no climate actions beyond its policies, in each of its three areas. For reinsurance: "Aside from implementation of the climate change-related policies described under E1-2, Hannover Re does not engage in any other actions in reinsurance business that can be subsumed under the requirements of the ESRS" (p.88). For investing: "Hannover Re does not engage in any actions in investing activities that could be subsumed under the requirements of the ESRS" (p.90).

The stated reason is that "possible actions with the potential for carbon reduction are quantifiable to only a limited extent for methodological reasons" (p.88). For own operations the company says the action fields on renewable energy supply and fleet electrification "were defined and reported as targets (see E1-4)" (p.91).

No actions, resources, CapEx or OpEx are quantified under E1-3. This is a nil return given in the company's own words.

Reference: pages 88-91.

The company says its targets rest on strategic assumptions, not on specific scientific insights (pp.88, 90, 91).

Underwriting: cut the number of facultative treaties for thermal coal risks by 20% over 2024 to 2026 (a 19 percentage point reduction against the 2023 reference year was reached by end-2025); initiate ESG contact with the 100 largest property and casualty clients over 2024 to 2026 (70% reached); underwrite five additional natural catastrophe programs in emerging and developing countries (achieved by end-2025) (p.88).

Investments: a 70% cut in the EVIC-based GHG intensity of corporate bonds, covered bonds, equities and quasi-sovereign issuers between 2019 and end-2029, from a base intensity of 147.8 tCO2e/EUR million; the reduction at year-end 2025 was 65%. "The target thus covers roughly 7.3 % (5.5 %) of Hannover Re's Scope 3.15 emissions" (p.90). Also dialogue with at least 20 issuers over 2024 to 2026 (20 held in 2025) and a 30% cut by end-2029 in oil and gas exposure within liquid corporate bonds from a 7.4% base (9.1% achieved by end-2025) (p.90).

Own operations: 100% green electricity globally (achieved; 67% in the 2023 base year) and full electrification of the Hannover company car fleet by 2030 (33% in 2025 against 9% in 2023) (p.91).

No absolute Scope 1, 2 and 3 reduction target is set.

Reference: pages 91-92.

Total energy consumption was 113,920.5 MWh in 2025 against 105,379.5 MWh in 2024 (p.92). Fossil sources accounted for 62,804.1 MWh, 55.1% of the total, up from 37.5% in 2024. Renewable sources were 51,116.4 MWh, 44.9%, down from 62.5% (p.92). Purchased or acquired electricity, heat, steam and cooling from fossil sources rose to 45,488.9 MWh from 23,519.8 MWh. There is no nuclear consumption (p.92).

The company notes that the E1 metrics include energy data from fully consolidated investments such as investment property, "based primarily on averages and estimates and hence limited in their informational value and reliability" (p.91), and that significant year-on-year deviations were "mainly due to improved data coverage and other factors such as inventory movements" (p.91). Data were collected to 31 October 2025 and the last two months extrapolated (p.91).

On energy intensity, Hannover Re is in the high climate impact sector "Real estate activities" through renting out real estate, but says "It is not possible to report the energy intensity for activities in high climate impact sectors" (p.92).

Reference: pages 93-95.

Scope 1: 3,551.9 tCO2e in 2025 against 3,270.3 in 2024 (+8.6%); 341.5 tCO2e of that is own operations (434.7 in 2024). Scope 2 location-based: 23,987.1 tCO2e (-15.2%). Scope 2 market-based: 23,137.5 tCO2e against 6,273.5 in 2024 (+268.8%), of which 497.3 is own operations (p.93). The 2024 figures were restated for a changed significance assessment of coolant losses and new Defra factors for district heating (p.56).

Scope 3: totals of 7,580,109.9 tCO2e without and 18,843,266.8 tCO2e with the financial investments line (2024: 9,480,229.0 and 25,186,327.1) (p.93). Material categories are 3.1, 3.3, 3.6 and 3.15; categories 3.2, 3.4, 3.5 and 3.7 to 3.14 are assessed non-material, each with a reason (pp.94-95). The text puts financed emissions at "18.84 (25.18) million tonnes CO2e with a degree of coverage of 88.6 % (88.3 %)" (p.95).

Intensity: "284 tCO2e (705 tCO2e including Scope 3 emissions from financial investments) per EUR million of reinsurance revenue" (p.94).

Limits the company states: estimates and sector averages dominate Scope 3.15, and "The share of greenhouse gases in Scope-3-emissions determined from primary data is around 0.02%" (p.95). Of the total, 10.7 (14.7) million tCO2e relate to corporate financing debt and 5.8 (7.5) million to sovereign debt (p.95), yet the basis-for-preparation section says government bonds "account for by far the largest share of the total financed emissions" (p.56).

Reference: pages 95-96.

Hannover Re "purchased carbon certificates outside its value chain in an amount of 13,000 tCO2e in the year under review" (p.95). The certificates meet Verified Carbon Standard or Gold Standard and are used "separately from the emissions and the emission reduction target" (p.95). They serve as voluntary offsets for 100% of the emissions of own operations (Scope 1, Scope 2, Scope 3.1, 3.3 and 3.6 attributable to own operations) (p.95).

Of the 13,000 tCO2e cancelled for 2025, 6,000 tCO2e cancelled in February 2025 had already been allocated to 2024 (p.95). The table on page 96 splits the 13,000 tCO2e into 9.2% removal projects and 90.8% reduction projects; removal credits are 100% Verified Carbon Standard, reduction credits are 77.1% Verified Carbon Standard and 22.9% Gold Standard; no share is reported as qualifying as corresponding adjustments (p.96). No further certificates were planned for retirement (p.95).

The company reports no removals of its own: it "did not bring about any withdrawal and/or storage of greenhouse gases in connection with projects developed within its own activities" (p.95).

Reference: page 96.

Nil return, stated in one sentence: "Hannover Re does not use an internal carbon pricing scheme and is not currently planning to implement one" (p.96). No shadow price, fee or other pricing mechanism is described, and no related financial figures are given.

Reference: pages 96-99.

Policies cover all employees, "with the sole exception of employees working for the subsidiaries Argenta, Integra and underwriting agencies belonging to the South African group" (p.97). The main instruments:

• Code of Conduct (worldwide, adopted by the Executive Board and Supervisory Board): covers well-being, equality, fair treatment and diversity; new employees receive it with their contract and all employees are trained on it in a rotating three-year cycle (p.97).
• People & Culture Strategy 2024-2026 with three action fields: employer attractiveness, performance culture and talent development, and diversity, equal opportunities and inclusion. A target of more than 25% women at management levels M1 to M3 stands against 29.1% at 31 December 2025 (p.97).
• Global Rewards Framework Policy, Global Assignment Policy and the "Ways of working somewhat different" concept (pp.97-98).
• A human rights Policy Statement published in 2021 and validated again by the Executive Board in 2025 (pp.98-99).

One gap is stated: "Hannover Re does not have a uniform worldwide policy for the avoidance of occupational accidents" (p.99), because employee activities "do not entail any particular risk of work-related accidents" (p.99). The company sees no risk of serious human rights violations through trafficking, forced labor or child labor in its workforce (p.99).

Reference: pages 100-101.

Hannover Re identifies negative impacts mainly through the annual Employee Engagement Survey and says actions are reviewed and implemented where impacts are found. Budgets for the actions sit in the relevant functional budgets, and the actions cover all employees except those at Argenta, Integra and the South African underwriting agencies (p.100).

Actions described:

• "MyLearning" learning platform (rolled out 2024): mandatory and optional training; usage is monitored through reports on participants and training duration (pp.100-101).
• Mobile and flexible working under a company agreement with a lump sum for mobile working costs; effectiveness is tracked through the Engagement Survey (p.101).
• Hannover Re Career Guide (launched 2023), the global job architecture. For this one "The effectiveness of the action is not tracked" (p.101).
• Leadership Development Portfolio (2024) for all managers (p.101).
• Data Exchange Platform Global Rewards, with local Compensation Committees meeting twice a year; "The effectiveness of the action is not explicitly tracked" (p.101).

Reference: pages 97 and 102.

Hannover Re sets no outcome-oriented workforce targets and says so: "It was not considered necessary to set more extensive specific, measurable and outcome-oriented targets within the meaning of ESRS S1-5 in conjunction with ESRS 2 MDR-T and they were therefore not defined" (p.102).

Effectiveness is instead monitored through the policies and actions in S1-1 and S1-4, using "analyses of workshop results, sickness rates, employee turnover and employee surveys" (p.102), with progress analyzed semi-annually (p.102).

One quantified aim exists under the People & Culture Strategy: more than 25% women on management levels M1 to M3, against 29.1% at 31 December 2025. The company adds that this "does not constitute a measurable and outcome-oriented target as defined by ESRS S1-5 in conjunction with ESRS 2 MDR-T" (p.97).

Reference: pages 102-103.

At 31 December 2025 Hannover Re had 4,245 employees by headcount (4,139 in 2024): 2,180 women and 2,065 men, with none reported as other or undisclosed (p.102). By contract: 3,877 permanent and 368 temporary; by working time: 3,732 full-time and 513 part-time (p.102). The headcount table by country shows Germany 1,972, South Africa 551, the United Kingdom 466 and the United States 375 (p.102).

Employee turnover in 2025 was 10.2%: "423 employees left the company for a range of different reasons" (p.103), counting all work-related exits (p.103).

Definition: all figures are headcount under a broad ESRS definition. "The eight members of the Executive Board of the Hannover Re Group do not fall under the definition of employees" (p.103), and ESRS headcounts run higher than IFRS ones because IFRS excludes for example trainees and employees in dormant employment relationships (p.103).

Reference: page 103.

"The total percentage of employees covered by collective bargaining agreements in the 2025 reporting year is 46.7%" (p.103). In Germany, France and Sweden all non-executive staff are covered by local collective bargaining agreements (p.103). The report also gives a coverage-rate table by country group, split into employees in the EEA and outside it (p.103).

Employment relations at European locations are governed by the Act on the Participation of Employees in a European Company (SEBG), the Statute of Hannover Rück SE and the "Agreement on the Participation of Employees in Hannover Rück SE". All employees under that agreement are represented by the SE Employee Council (p.103).

Reference: page 103.

Top management (levels M1 to M3 below the Executive Board): 179 people in 2025 (176 in 2024), of whom 52 were women (29.1%, up from 25.0%) and 127 men (70.9%). The "Various" and "Gender not reported" rows are both zero (p.103).

Age (all employees): under 30: 707 (16.7%, 679 in 2024); 30 to 50: 2,500 (58.9%, 2,369); over 50: 1,038 (24.5%, 1,091) (p.103).

Board diversity (female share of the Executive and Supervisory Boards) is reported under GOV-1 (p.57). The People & Culture Strategy's third action field covers diversity, equal opportunities and inclusion (p.97).

Reference: page 104.

The company reports that no employee is paid below an adequate wage. The row "Total number of employees paid below an adequate wage in HC" is 0 in both 2024 and 2025, and the "All employees are paid an adequate wage" row reads "Yes" for both years (p.104).

Method: "By considering country-specific reference values or relevant collective bargaining agreements, it is ensured that the remuneration meets the requirements of the complex and specialised work environment" (p.104). The statement does not name the adequate wage benchmarks used for each country.

Reference: page 104.

Method: "The remuneration-related metrics are based on the gross hourly wages determined for all employees" (p.104). Fixed and variable pay and fringe benefits are included, and employees in dormant employment relationships are included in the pay gap calculation. The ratio also includes Executive Board remuneration. The company warns that "Significant fluctuations may arise from year to year" (p.104) in this ratio, because the highest-paid individual's pay includes variable components (p.104).

Reference: page 104.

"Number of cases of discrimination within the meaning of the legal definition pursuant to § 3 General Act on Equal Treatment (AGG) including harassment reported in the reporting period: four" (p.104). Three were incidents of one employee harassing another, with actions taken in all instances; in one the accused person left the company. The fourth case was closed without confirmation of the accusation (p.104).

Other complaints through employee channels: zero. Fines, sanctions and compensation for these cases: EUR 0. Severe human rights incidents connected with the workforce: zero, with EUR 0 in fines, penalties and compensation (p.104).

Reference: pages 104-107.

Culture: the purpose is "Beyond risk-sharing - we team up to create opportunities" (p.104), and the values are Responsibility, We Spirit and Drive. The Group-wide Code of Conduct "is a central element of the corporate culture" (p.104). Culture has been surveyed annually since 2019, and since 2024 the survey focuses on employee engagement (p.105). The compliance culture is supported by a "Raise Awareness Campaign", training and the Speak Up system.

Policies: the governance and compliance management system follows the "three lines of defence" model. Policies named are the Code of Conduct (adopted by the Executive and Supervisory Boards, owned by the Compliance unit), the Compliance Group Policy, the Conflict of Interest Group Policy and a Third Party Code of Conduct for suppliers (p.105). For data privacy and cyber security it names an Information Security Policy and a Group Data Protection Guideline (pp.105-106).

Whistleblowing (p.106): the Speak Up system takes reports by person, phone, e-mail or online system, anonymously if wanted, and implements the German Whistleblower Protection Act. The company "has adopted compliance standards consistent with the United Nations Convention against Corruption" (p.106).

Training (p.106): every employee receives compliance training at least every three years, and "The Hannover Re Group has identified all units, including all local offices, as at-risk functions" (p.106).

Reference: pages 100, 106-107.

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

Hannover Re's G1 chapter has no separate targets section and sets no outcome target on corruption or bribery. It does state one coverage aim for training: "The training cycle, in which a 100 % training rate is targeted, considers a period of three calendar years" (p.107).

Effectiveness is tracked in other ways:

• Risk-mitigating measures such as controls, work instructions and training are "regularly reviewed in respect to their adequacy and effectiveness" (p.106) by the Compliance unit.
• Tips and actions are summarized each year in a compliance report to the Executive Board, the Supervisory Board and its Finance and Audit Committee (p.106).
• "The effectiveness of the reporting procedure is evaluated by the Compliance unit" (p.100), as stated under S1-3.
• In the absence of reported incidents the company saw no need for further action plans (p.107).

Reference: page 107.

"The number of convictions for violation of anti-corruption and anti-bribery laws in the 2025 financial year is zero" (p.107), so the amount of fines is EUR 0. The count of reported incidents is drawn from the reporting channels, from Internal Audit findings and from Compliance monitoring; Compliance verifies each report, and every incident is documented, categorized and assessed (p.107).

Because there were no reported incidents, the company "did not see any need to approve incident-related actions or action plans" (p.107) beyond existing prevention mechanisms.

"None of the metrics listed in ESRS G1 have been validated by any external body other than the one responsible for quality assurance" (p.107).