LHV Group

Reference: page 85.

LHV is governed by a Supervisory Board and a Management Board. As of end-2025 the Supervisory Board has 6 members (down from 7 in 2024), of whom one (17%) is classified as independent. The Management Board, led by CEO Mihkel Torim, comprises 4 executive members responsible for finance, risk, IT and general management, with no non-executive members or worker representatives.

The LHV Group ESG governance structure assigns the Supervisory Board approval of the ESG Policy and oversight of the sustainability strategy; the Management Board defines ESG strategy and everyday implementation. Within it, the Group CEO holds "ultimate supervisory of ESG", the Group CRO owns "ESG and climate risk identification, assessment, and mitigation", and the Group CFO owns "ESG management and ESG integration into financial decision-making and reporting functions".

Gender diversity: the combined Supervisory and Management Boards were 70% male / 30% female in 2025 (73%/27% in 2024).

Reference: page 86.

Sustainability-related information reaches LHV's governing bodies through the ESG governance structure: "responsibility owners... report regularly and as needed to the board on key ESG topics." In 2025, climate risk management was a stated primary focus, with "regular updates on climate risk management progress... provided to the Risk and Capital Committee", which led to "practical solutions tailored for LHV" that were approved by the Management Board.

LHV states that in the 2025 ESG Materiality Assessment, "material ESG risk drivers under stressed scenarios resulted in knowledge that the risk to LHV's portfolio can currently be considered over materiality level, but do not pose significant challenges to LHV's strategy or business model within the assessed time horizons" - information that fed into board-level discussion of trade-offs against ESG commitments and strategic objectives.

Reference: page 86.

Sustainability goals are embedded in LHV's remuneration framework. For Management Board members, "sustainability objectives, carry equal weight (16-20%) compared to other 4-5 performance considerations." Management Board members engaged in climate-related areas have "specific climate-related objectives and targets... incorporated into their remuneration with equal weight."

The remuneration package combines a base salary with an annual performance bonus (floor of EUR 0) and a long-term, option-based compensation programme approved by the shareholders' general meeting; the maximum ratio between variable and fixed components is 200%, also shareholder-approved. Full remuneration principles are detailed in the Corporate Governance report and Remuneration report sections of the management report.

Reference: page 86.

LHV maps its due-diligence approach against the ESRS core elements directly in the sustainability statement. "Embedding due diligence in governance, strategy and business model" is addressed in the sustainability strategy, value-chain and governance sections; "engaging with affected stakeholders" through the stakeholder engagement and social information chapters; "identifying and assessing adverse impacts" through the double materiality assessment process; "taking actions to address those adverse impacts" through the climate, workforce and consumer chapters; and "tracking the effectiveness of these efforts and communicating" through the climate mitigation targets, remuneration and financial-literacy KPIs.

The table explicitly cross-references each due-diligence element to the specific sustainability-statement sections that satisfy it, rather than presenting due diligence as a standalone narrative.

Reference: page 87.

"At LHV, sustainability reporting follows the same process as financial and operational reporting, addressing mainly compliance risk." LHV states it has "established internal controls to ensure the accuracy, completeness, and reliability of all sustainability-related disclosures", with a data governance structure that captures, validates and reports sustainability data "with the same precision as financial data."

Oversight follows LHV's three-lines-of-defence model: business and supporting units collect and manage sustainability data; risk management and compliance teams ensure robustness of data collection; and internal audit "conducts independent reviews to confirm that ESG risk management and reporting processes are effective, and compliant with regulatory requirements."

Reference: page 79.

LHV is "the largest domestically owned finance group and capital provider in Estonia." Main subsidiaries are AS LHV Pank, LHV Bank Ltd (UK), AS LHV Varahaldus, AS LHV Kindlustus and AS LHV Paytech; Estonian offices are in Tallinn, Tartu and Pärnu, with UK offices in London, Leeds and Manchester. The Group has "over 1,200 employees and serves a customer base exceeding 694 thousand" (up from 612 thousand in 2024).

Business segments are retail banking, corporate banking, asset management, hire-purchase and consumer finance, financial intermediaries, and insurance. The value chain table describes upstream procurement (consulting, IT, facilities, furniture and catering, marketing), own operations (sales and marketing, personnel, financial and risk management, technology), and downstream use of financial products and services by customers.

Reference: page 81.

LHV maintains "regular dialogue with the stakeholders with whom we have the most direct relations." The stakeholder table names seven groups with their engagement channels and expectations: customers (ESG questionnaires, sustainable products - engagement and ESG integration); employees (annual surveys, seminars - feedback and development); shareholders (AGM, ESG reporting - profitability and engagement); policy makers/regulators (working-group membership - policy input); business networks (Estonian Banking Association, Finance Estonia, Green Tiger - ESG promotion); suppliers (direct communication - payment practices and value-chain sustainability); sustainability organisations (Green Tiger, KELL - financing the green transition); and the wider public (events, press - transparency and ethical conduct).

Stakeholder engagement is carried out via surveys, meetings and direct communication, with responsible units reporting to the Management Board; no strategy adjustment was required in 2025 as a result.

Reference: page 82.

LHV's 2025 double materiality assessment found material IROs "across the topics of climate change (ESRS E1), own workforce (ESRS S1), consumers and end-users (ESRS S4), and business conduct (ESRS G1)." This is "largely consistent" with 2024 "except for... Resource use and circular economy (ESRS E5), which was reassessed in greater detail... and the topic was reassessed as not material as no IROs above the materiality threshold (3.5 on a 5 point scale) were identified."

The material-IRO table (page 83) lists 16 individually described IROs across the four material topics, spanning negative and positive actual/potential impacts, financial risks and a financial opportunity, each mapped to value-chain location (upstream/own operations/downstream) and time horizon. LHV states its "most significant impacts, risks, and opportunities stem from its core banking activities", with climate and environmental effects linked mainly to downstream lending and social/governance topics to own operations.

Reference: page 87.

LHV's double materiality assessment (DMA) covers "own operations and core business lines - banking in Estonia and the UK, asset management, and insurance." LHV Pank represented 85.8% of total assets and 75.0% of net income in 2025 (90.9%/80.2% in 2024), so the analysis focuses primarily on LHV Pank's Estonian and UK activities.

The DMA followed three steps: (1) mapping business model, activities, value chain and stakeholders; (2) identifying IROs using the UNEP FI Portfolio Impact Analysis Tool for impact materiality (with subject-matter experts and external ESG consultants from KPMG scoring severity and likelihood) and a three-step Business Environment Scan/qualitative/quantitative process for financial materiality; and (3) determining material IROs. Time horizons follow short (<3 years), medium (3-10 years) and long (10-30 years, extended to >30 years for risks), consistent with EBA and ECB guidance.

Reference: page 90.

Section 8.1.5 sets out LHV's ESRS content index, mapping each covered disclosure requirement to its section in the report. General disclosures cover BP-1, BP-2 and all of GOV-1 to IRO-2. Under climate change (E1), the index lists E1-1 through E1-6 plus cross-references to ESRS 2 SBM-3 and IRO-1. Under own workforce (S1): S1-1 to S1-6, S1-9, S1-10 and S1-16. Under consumers and end-users (S4): S4-1 to S4-5. Under business conduct (G1): G1-1 to G1-3, with G1-1, G1-3 and ESRS 2 GOV-1 additionally incorporated by reference from the Corporate Governance report (sections 4 and 5).

Disclosure requirements not appearing in the index - including several S1 requirements phased in under ESRS 1 Appendix C and datapoints marked "N" (not subject to materiality) in the Annex 1 cross-cutting table - are absent from this year's statement for the reasons the index and Annex 1 record.

Reference: page 94.

LHV does not have a standalone written transition plan; instead "the key elements, such as setting climate change mitigation targets, of our transition strategy are already integrated into our broader corporate governance, risk and decision-making framework." LHV states it "is not active in a high climate impact sector."

The ESG Policy, "which outlines high-level principles for achieving sustainability objectives, including our support for the transition to a low-carbon economy, is reviewed and approved annually by the Supervisory Board", with the Management Board driving implementation. In 2025 LHV "started work on preparing the prudential transition plan as is expected from credit institutions", to be finalized in 2026. LHV states "it does not own any assets that would cause locked-in emissions currently nor is it expected for the foreseeable future," and that identified climate risks such as flooding "are not material in terms of potential credit loss to our overall operations."

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 89-90). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical and transition risk drivers were identified through a three-step financial-materiality process (Business Environment Scan, qualitative scoring, quantitative analysis), using a third-party consultancy's Physical Hazard Risk prototype for real estate collateral. "Forward-looking ESG scenarios - such as NGFS climate pathways... IPCC SSP-RCP climate scenarios (SSP1-1,9; SSP1-2,6; SSP2-4,5; SSP3-7,0 and SSP5-8,5), and IEA energy outlooks - were applied alongside internal and external data sources, including sectoral emissions, borrower-level exposures, and macroeconomic indicators to determine climate related physical and transition risks" (page 90). SSP5-8.5 is named as a high-emission physical-risk pathway; the report does not name a specific 1.5°C-aligned transition scenario (e.g. IEA NZE) beyond the general reference to "IEA energy outlooks", nor does it state temperature-projection detail or the date the analysis was carried out - gaps worth flagging.

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (pages 86, 89). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

LHV states its "strategy and business model have demonstrated resilience in addressing both material sustainability impacts and financial risks", assessed "for both physical and transition risk in the form of stress tests" (page 86). The financial-materiality assessment concluded that "LHV's portfolios are currently relatively resilient to ESG risk. The main vulnerabilities identified relate to physical flood risk and its effect on collateral values, as well as transition risk linked to energy prices, energy intensity, and evolving energy performance regulations posing credit risk" - a conclusion the report says is "supported by previous resilience assessments of real estate collateral vulnerabilities and related stress tests" (page 89), which confirm the identified risks "do not pose material threats to LHV's financial stability." No ESRS-defined resilience analysis addressing capacity to adjust financial resources or redeploy assets over time horizons is presented.

Reference: page 95.

LHV's climate policy framework centres on the ESG Policy (approved annually by the Supervisory Board), the ESG Risk Management Policy (which "defines risk management framework, i.e. main principles, governance and risk appetite for the ESG risk LHV is facing"), and the Green Office Principles, which guide sustainable management of office operations across "employee engagement, resource efficiency, use of renewable energy, waste management, and sustainable transport."

The Credit Policy "defines sustainable and responsible business conduct in relation to financing" and underpins LHV's exclusion list, under which LHV "will refrain from knowingly offering credit products to customers whose activities bear clear evidence of human rights violations and serious environmental harm." Climate change mitigation, rather than adaptation, is the strategy's primary objective, since "the impacts of climate change are assessed as not currently significant enough to warrant prioritizing climate change adaptation measures" in Estonia.

Reference: page 95.

LHV directs actions through its lending activities and internal risk processes. Sustainable financing products include home loans for A/B energy-class homes, car leasing for zero/low-emission vehicles, and investment loans for corporate sustainable development. Climate-related risk is "addressed during loan reviews based on the size of the loan and the customer's field of activity", with a mandatory ESG risk assessment for business customers with credit exposure exceeding EUR 1 million.

LHV supports external awareness efforts, partnering with environmental organisations Green Tiger and Sustainable Business Estonia (KELL) through seminars and conferences, and continuing its collaboration with the Estonian Business School's ESG Management Program, under which LHV "offer[s] our business customers preferential terms to participate", promoting sustainability practices among business customers.

Reference: page 96.

LHV has set four climate change mitigation targets. On the loan portfolio: "by the year 2030, to increase the share of renewable energy projects under the energy sector within our loan portfolio to 90%", and "to have at least 50% of our annually signed mortgage contracts for A and B energy class housing" (29.3% in 2025, up from 24.3% in 2024). On own operations: to "maintain zero emissions in scope 1 operations" (already at zero) and to reach "100% use of electricity generated from renewable sources by 2030" for scope 2 - as of end-2025, five of LHV's six offices hold renewable energy certificates.

LHV has not established a GHG emissions base year, citing "ongoing technical improvements which are focused on enhancing our data collection and data quality", so these targets are not expressed as an absolute emissions-reduction trajectory.

Reference: page 100.

LHV refined its energy consumption methodology in 2025, using supplier-provided energy-production-mix data and introducing a new "Other" category for inputs such as peat and landfill gas that fall outside standard renewable/fossil definitions. Total energy consumption was 3,451 MWh in Estonia and 172 MWh in the UK (2024: 3,866 MWh and 562 MWh respectively).

The share of renewable sources in total energy consumption was 71% in Estonia and 2% in the UK; total renewable energy consumption was 2,447 MWh (Estonia) and 4 MWh (UK), all from purchased renewable electricity, heat, steam and cooling rather than self-generation. Fossil energy consumption was 639 MWh (Estonia, 19% share) and 137 MWh (UK, 80% share); the UK also drew 31 MWh from nuclear sources (18% share).

Reference: page 97.

LHV's Gross Scope 1 emissions were 0 tCO2e (unchanged from 2024). Gross location-based Scope 2 emissions were 856 tCO2e (2024: 1,343 tCO2e); market-based Scope 2 fell to 189 tCO2e (2024, restated: 698 tCO2e), which LHV attributes to obtaining direct emissions data from suppliers and an increased share of certified renewable energy. Gross Scope 3 emissions were 573,454 tCO2e, dominated by Category 15 (Investments/financed emissions), which LHV identifies as "the most material source of Scope 3 emissions" and no longer discloses other Scope 3 categories separately "in regard to information materiality principle."

Total GHG emissions (market-based) were 573,643 tCO2e (2024, restated: 546,414 tCO2e). A methodology update required restating LHV Bank Limited's (UK) 2024 emissions, revising the "previously reported 91,040 tCO2e to 3,752 tCO2e."

Reference: page 101.

LHV's workforce policy framework is group-wide and includes the Human Resources Policy ("defines the people management framework... for recruitment, development and employee motivation"), the Diversity Policy ("setting principles, governance and practices to ensure fair and unbiased hiring and promotion"), the Conflict of Interest Policy, and the Remuneration Policy. Occupational health and safety is governed by Occupational Safety and Working Environment Guidelines for Estonian offices and a separate Health and Safety Policy for UK offices.

LHV states it "follows national laws and requirements but has not specifically aligned its policies with UN Guiding Principles on Business and Human Rights." Policy owners are the Head of Human Resources or Head of Compliance, with approval by the Management Board or Supervisory Board respectively.

Reference: page 106.

LHV runs an anonymous "Q12 engagement survey" twice a year; in 2025 employees rated the statement "At work, my opinions seem to count" at 4.46 in May and 4.42 in October on a 5-point scale. Engagement also occurs through quarterly townhall meetings "led by the members of the board", regular 1:1 manager meetings, and organisational- and team-level consultation. HR reviews survey results with managers and feeds insights into policy, workload and performance-target decisions.

LHV states that engagement activities "primarily take place at the organizational level and involve participation and consultation" rather than formal negotiation with workers' representatives, and that it plans to "advance and enforce workforce engagement on an ongoing basis."

Reference: page 107.

Employees can report "accidents, incidents, and complaints" through the Incidents and Complaints form in Outlook Notifications, the Report a Violation form on the Intranet (both allow anonymous reporting), direct contact with Human Resources, or a member of the Working Environment Council. Reports "are handled delicately and individually through a thorough investigation", with anonymity and confidentiality guaranteed for good-faith reporters and protection against adverse treatment.

LHV states that "as no cases requiring remedies have occurred, there has been no need to establish an internal regulation" for providing remedies, though it "does not rule out the possibility of providing remedies... when deemed reasonable." Employees also retain the right to report directly to the Estonian Financial Supervision Authority or, in the UK, the FCA/PRA.

Reference: page 102.

In Q1 2025 LHV implemented redundancies "as part of a cost-saving and efficiency programme (automation, streamlined management layers and consolidated responsibilities)", a one-off increase in employer-initiated terminations, while improving labour-market conditions separately increased voluntary employee mobility. To advance gender balance in leadership, LHV's Diversity Policy targets, "by 30 June 2026, that either 40% of the supervisory board members or 33% of the management and supervisory board members combined are of the underrepresented gender."

On pay equity, LHV piloted a new job-family structure in 2025 ("to ensure that the pay ratio between different employee groups... moves towards a balanced level where no group is paid more than 5% above or below another group's pay level by 2029"), to be refined further in 2026.

Reference: page 105.

LHV has "set group-wide employee-related target of achieving pay equality of 95:105 by 2029." Progress is being pursued through the 2025 pilot of job families - internally defined groups of comparable roles that should be compensated similarly - to move the pay ratio between employee groups toward this balanced band; LHV states it "will continue this work in 2026 to further refine and align the job family structure and pay levels."

A related, non-quantified diversity target (40% of the supervisory board, or 33% of combined boards, of the underrepresented gender by 30 June 2026) is disclosed under S1-4/policies rather than as a separate own-workforce target metric.

Reference: page 103.

At end-2025, LHV Group had 1,253 total employees (-28 from 2024): 1,100 in Estonia and 153 in the UK. 97.4% worked full time and 2.6% part time. LHV recorded 288 new hires (including 50 interns) and 302 leaving employees during the year, giving a voluntary turnover rate of 11.7% and an overall turnover rate of 20.2% (2024: 8.1% and 12.8% respectively) - the increase driven in part by the Q1 2025 redundancy programme.

Of the workforce, 1,152 held permanent contracts and 30 temporary contracts. LHV states it "has no employees with particular characteristics working in specific contexts" in its workforce.

Reference: page 104.

LHV reports a breakdown of employees by age band and gender for both permanent and temporary contracts, and by contract type. Under permanent contracts, women made up 56.5% of headcount and men 43.5% in 2025 (56.2%/43.8% in 2024); age distribution for women was concentrated in the 30-50 bracket (70.2% of women, 2025). LHV states it "fosters a culture where everyone is treated with respect and dignity" and does not "attribute to any dimensions of diversity a predetermined value, either positive or negative."

The Diversity Policy's board-level gender target (40% of the supervisory board, or 33% of combined boards, of the underrepresented gender by 30 June 2026) is disclosed alongside these workforce-level metrics.

Reference: page 105.

LHV states its compensation practices comply with "the Employment Contracts Act and the Government's Minimum Wage Regulations in Estonia, and the National Minimum Wage Act 1998 and National Minimum Wage Regulations 2015 in the UK", and that it "aims to ensure that all employees receive compensation that meets or exceeds the legal requirements."

Pay is structured through a job-evaluation system built on 13 grades (developed by Fontes/Figure, based on ILO methodology) benchmarked against market median data, with HR overseeing adjustments for accuracy and fairness across both jurisdictions.

Reference: page 108.

LHV reports 100% workforce coverage (1,253 employees) under its health and safety management system, with zero work-related injuries, zero work-related fatalities, and zero incidents of discrimination recorded in 2025. A footnote confirms "no incidents or complaints have occurred; therefore, no fines, penalties, or compensation have been paid."

LHV's phase-in list (page 78) defers two specific S1-14 sub-datapoints for this period: "the data points on cases of work-related ill-health and on number of days lost to injuries, accidents, fatalities and work-related ill health", and health and safety metrics for non-employees - so the core injury/fatality metrics reported above are not yet supplemented by ill-health or non-employee data.

Reference: page 105.

The unadjusted gender pay gap was 29.01% in Estonia (2024: 28.27%) and 13.23% in the UK (2024: 17.42%). The adjusted gender pay gap, which "accounts for job roles, levels, and experience", was 5.02% in Estonia (2024: 4.49%) and 1.23% in the UK (2024: 1.46%).

The ratio of the highest-paid individual's total annual remuneration to the median employee's was 12.79 in Estonia (2024: 14.96) and 6.19 in the UK (2024: 6.06). LHV attributes the wider unadjusted gap partly to the concentration of men in senior, higher-paid roles, and is piloting a job-family structure targeting a 95:105 pay-equality ratio by 2029.

Reference: page 108.

LHV reports zero incidents of discrimination and zero complaints from its own workforce in 2025, with 100% health-and-safety-system coverage. A footnote states "no severe human rights incidents connected to the undertaking workforce have occurred; therefore, no fines, penalties, or compensations have been paid." Separately, LHV notes that "no employees have reported any violations or misconduct this year" through its whistleblowing and incident-reporting channels (page 107).

Employees retain the right to report directly to external supervisory authorities (the Estonian Financial Supervision Authority, or the FCA/PRA in the UK) without prior notification to LHV.

Reference: page 108.

LHV's consumer-facing conduct is governed by its Code of Ethics, Customers Complaints Handling guideline, Procedure for external communication, Personal Data Protection Guideline and related internal regulations. LHV states it is "always guided by the best interests of our customers" and, per its Customer Service guidelines, "always consider[s] the best possible solution for the customer" when weighing which services are most suitable.

LHV states that "all consumers and end-users are treated equally, while providing tailored support to those who may require additional assistance", and that its statements under general disclosure consider "the potential significant impacts of our operations, products, and services on our direct customers and end-users" - covering both retail and corporate customers, without extending to partners' own customers.

Reference: page 108.

Customer feedback is gathered through an automated survey "triggered after interactions via email, phone, chat or in-person meetings"; within 24 hours of an interaction, customers receive a feedback request to rate their experience and add open-ended comments, applying equally to private and business clients. This is supplemented by dedicated email addresses, customer support lines and direct conversations at client meetings.

In LHV's most recent Kantar Emor survey (2024), LHV's service recommendation index was 74; a new survey is planned for 2026. LHV states that keeping customer experience high "promotes loyalty, helps us retain customers, and encourages brand advocacy."

Reference: page 108.

Client complaints are governed by the Handling of Client Complaints guideline. Clients may submit complaints via direct communication (phone, meetings, chat), written channels (post, email, website) or indirectly through regulators (the Financial Supervisory Authority, Consumer Protection and Technical Regulatory Authority) or third-party forums. Written complaints receive acknowledgment within 1 business day; resolution timelines are "15 days for private individuals and payment transactions and 30 days for legal entities."

The Non-Financial Risk Department coordinates analysis of complaints requiring further review with relevant business units, while the Compliance Department "conducts monthly analyses of complaints against LHV Pank, focusing on compliance risks, root causes, and the resolution process", reporting justified complaints to product and service managers.

Reference: page 109.

LHV's digital channels are used by 63.2% of private customers whose native language is not Estonian (2024: 64.5%) and 46.1% of customers over 65 (2024: 46.1%); LHV is "working on testing and implementing visual and navigational changes" to improve accessibility, including for visually impaired users. On financial literacy, LHV runs free seminars through its Investment School, supports the Investor Toomas conference and Investment Festival, and has backed the availability of Estonian-language investment books with Äripäeva Kirjastus.

Share of investment-services contracts among clients under 26 was 47.2% in 2025 (2024: 47.7%); the general investment-services coverage rate among private customers was 41.7% (2024: 41.6%). LHV also runs annual market-wide campaigns to counter rising phishing and financial-crime attempts.

Reference: page 109.

LHV has "set a target to increase the coverage rate of investment services contracts among young clients to reach 60% by 2030", against a 2025 baseline of 47.2% (down slightly from 47.7% in 2024). LHV states that "while formal targets for these KPIs have not been established at this stage" for its other consumer KPIs (digital-channel usage among non-native-Estonian speakers and over-65s), it continues to track them "to guide the ongoing development of our services."

Reference: page 43.

LHV's corporate culture is anchored in its core values - "simple, supportive, and effective" - and built on the mandatory Code of Ethics, described as "the foundation of LHV's various internal regulations." Policies are reviewed yearly by the governing bodies. LHV group companies operate an internal whistleblowing channel, accessible via the intranet and "operat[ing] separately from the management chain", supporting anonymous submissions; reports are directed to the Compliance department for impartial review, with protection against discrimination or unfair treatment for good-faith reporters.

Corporate culture is evaluated through employee feedback, satisfaction surveys and compliance training. LHV states its policies "have not been formally assessed against the United Nations Convention against Corruption, as there is no practical necessity for such an evaluation within the finance sector's rigorous regulatory framework."

Reference: page 111.

LHV states it "highly values its relationships with suppliers and strives to foster fairness, responsibility, and strong partnerships", while acknowledging that "this area may not have been identified as material in terms of our impacts and risks." Supplier evaluation considers "not only conventional criteria like cost and quality but also ESG aspects", guided by the Rules for conclusion and management of service contracts, which "ensures that sustainability is integrated in the procurement process."

The Green Office Principles guide LHV's approach to "minimize environmental impacts throughout the lifecycle of purchased goods and services, including their production, usage, and disposal", and LHV states it "prioritize[s] locally produced goods whenever feasible to further support sustainability and local economies."

Reference: page 44.

LHV has established processes "to prevent, detect, investigate, and address potential incidents of corruption or bribery, governed by mandatory internal rules accessible on the intranet"; employees are contractually obligated to review and confirm understanding of these rules, including on joining. LHV states it "does not have a specific anti-corruption or anti-bribery training program", though relevant topics are addressed within mandatory internal policies, alongside detailed gift-acceptance rules.

LHV "has not identified areas or functions within the organization that present a risk of corruption or bribery", and its policies "have not been formally assessed against the United Nations Convention against Corruption... nor is there currently any plan to conduct such an assessment." The whistleblowing mechanism covers reporting of suspected corruption and bribery incidents.

Back-filled from the business conduct chapter, where business conduct effectiveness is addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement (pages 44-45). G1-3 became a standalone DR only in the 2025/2026 ESRS.

LHV discloses no measurable, outcome-oriented business conduct target (no quantified corruption-incident or compliance-training coverage goal is stated). Consistent with MDR-T's other limb, effectiveness is instead tracked through incident review: "in accordance with the content of the reported violation, investigations are also conducted in compliance with the Internal Fraud Prevention Procedure", investigations are "managed independently by the internal control function, a second-line compliance function that operates separately from the management chain", and "the outcomes of investigations, where applicable, are reported to the relevant governing bodies, ensuring transparency and accountability in the handling of such matters" (page 44). LHV reports it has had no confirmed corruption or bribery incidents to review in 2025 (G1-4).

Reference: page 45.

LHV states plainly: "LHV has no confirmed incidents related to corruption or bribery." No convictions, legal decisions or fines for anti-corruption or anti-bribery violations are reported for the period, and no employees were dismissed or disciplined, nor were any business-partner contracts terminated, for corruption or bribery.

This is corroborated by the whistleblowing mechanism described under G1-1/G1-3, which "enables the reporting of any suspected incidents (including corruption and bribery), ensuring a structured process for identifying such cases", and by the Annex 1 cross-cutting datapoints table, which marks the "Fines for violation of anti-corruption and anti-bribery laws" datapoint as "N" - not subject to materiality (page 116), consistent with there being no incidents to report.

Reference: page 44.

LHV states plainly: "LHV does not engage in lobbying activities and does not directly or indirectly support any political organization." LHV's credit institution subsidiary, LHV Pank, "is registered in the EU Transparency Register under the identification number 449511822591-64."

On public-administration connections, LHV confirms that "none of the members of LHV's administrative, management, or supervisory bodies appointed during the reporting period held comparable positions in public administration (including regulators) in the 2 years preceding their appointment", adding that "any such connections, if they arise, will be disclosed in future reports."