Mapfre

The role of the administrative, management and supervisory bodies

Governance structure

The Annual General Meeting is the most senior governing body, while the Board of Directors is responsible for steering, administering and representing the Company, holding full powers of representation, disposition and management. Its actions are binding on the company, with no further limitation than the express powers of the Annual General Meeting in accordance with the law and the corporate bylaws.

The Board of Directors is the Company's primary decision-making body, and it performs oversight of the Company and its subsidiaries. Day-to-day management, on the other hand, is performed by the Company's executives and senior managers and by the competent bodies of the subsidiaries.

The Chairman of the Board of Directors is the Company's most senior management representative, although he/she does not have permanent delegation of powers. Said delegation falls to the Steering Committee, which acts as a delegate body of the Board of Directors, with all its powers except those that cannot be delegated due to legal imperative or, where applicable, express provision in the Bylaws or the Board of Directors Regulations.

Board Committees

The Board of Directors also has three other Committees:

Steering Committee: This committee's functions include high-level direction and ongoing oversight of the Company's day-to-day operations and strategies, as well as those of the subsidiaries. It has a maximum of 10 members, who are all of members of the Board of Directors.

Audit and Compliance Committee: The functions of this committee include reporting to the Annual General Meeting on matters within its remit, overseeing the effectiveness of internal control, internal audit, and risk management systems, as well as the process of preparing and presenting financial and non-financial information. The committee is also responsible for submitting a proposal for the appointment of an external auditor to the Board of Directors, establishing appropriate relations with the auditor, and ensuring the independence and effectiveness of the Internal Audit function. It is also the body responsible for oversight to ensure that the Company and the Group are duly applying good governance practices and complying with all applicable legislation, regulations, and internal rules. It has a minimum of three and a maximum of five members, with all of them being non-executive Directors, and a majority being Independent Directors.

Appointments and Remuneration Committee: This committee coordinates the appointment and remuneration policy that applies to the Group's directors and senior managers. It has a minimum of three and a maximum of five members, with all of them being non-executive Directors, and at least two of them being Independent Directors.

Risk and Sustainability Committee: This committee provides support and advising for the Board of Directors, in relation to defining and assessing the Group's risk management policies, determining the risk appetite, and establishing the risk strategy. It also defines and oversees the corporate sustainability policy and sustainability strategy. It has a minimum of three and a maximum of five members, with all of them being non-executive Directors, and at least two of them being Independent Directors.

Composition of governing bodies

At December 31, 2024, the Board of Directors consists of 15 members. Should the proposals for appointments, reelection, or ratification of board directors submitted to the Annual General Meeting held on March 14, 2025 (on the first call) be approved, the governing bodies would have the following composition:

(1) Executive Directors (2) Non-executive Nominee Directors (3) Non-executive Independent Directors (4) Lead Independent Director

5 members of the Board of Directors form part of the Executive Committee, while the remaining 10 directors do not belong to said committee. The non-director secretary of the Board of Directors is secretary and member of the Executive Committee.

Employee representation

Except for the cases indicated below, MAPFRE Group companies do not currently have employee representatives in the administrative, management, and supervisory bodies:

• MAPFRE ECUADOR COMPAÑÍA DE SEGUROS S.A. (Ecuadorian subsidiary of MAPFRE INTERNACIONAL): has an employee representative who is part of the Ethics Committee. Their participation in the Ethics Committee corresponds to a legal obligation under Ecuadorian jurisdiction (Article 6, Section II, Chapter III Principles of Good Corporate Governance, of the Code of Monetary, Financial, Securities and Insurance Resolutions).

• VERTI VERSICHERUNG AG (German subsidiary of MAPFRE INTERNACIONAL): 1/3 of Supervisory Board members must be employee representatives under German law. The Supervisory Board of VERTI GERMANY has six members and two of them are employee representatives.

Oversight of sustainability matters

The MAPFRE Board of Directors is the body responsible for approving the Group's Corporate Sustainability Policy and sustainability strategy, in addition to monitoring the development and fulfillment of the Sustainability Plan. To this end, it is regularly informed of the progress and level of fulfillment of the Group's commitments included in that plan. The Board of Directors is ultimately responsible for the results of the Double Materiality exercise, as well as for establishing the general guidelines for their proper management and globally overseeing their performance. It also delegates these responsibilities to different committees based on the specific area of management for each one. The Board of Directors addressed relevant sustainability matters on 9 occasions in 2024. Likewise, at the meetings of the Board of Directors, the chairman of the Risk and Sustainability Committee reports on the matters addressed and decisions made regarding sustainability.

Responsibilities for material impacts, risks and opportunities

The Risk and Sustainability Committee supervises the Group's sustainability strategy and policy, ensures their implementation and compliance, and monitors the environmental, social, and governance impacts, risks, and opportunities that have been assessed as material. This committee met 6 times in 2024.

The following governing bodies report to the Risk and Sustainability Committee, and are responsible for the operational management of impacts, risks, and opportunities:

• The Sustainability Operating Committee is a top-level executive body whose members are appointed by the Executive Committee. Its functions include proposing the sustainability strategy to the Risk and Sustainability Committee, driving the progress of the sustainability plan, and addressing issues relevant to the Group in this area, such as monitoring risks and opportunities associated with sustainability. This committee met 4 times to supervise each of the projects in the 2024-2026 Plan, identify trends, opportunities, and regulatory requirements related to sustainability, and establish action plans to address them.

• The Corporate Sustainability Division is responsible for designing, supervising, and supporting the implementation of the sustainability plan and for monitoring new regulations and their impact on the company. It also participates in internal committees and external forums to develop issues related to sustainability.

The Audit and Compliance Committee reviews the Sustainability Report prepared by the Company, which includes information on sustainability, on an annual basis. Starting this fiscal year, this review will be conducted on this Sustainability Statement, which reflects both the methodology of the Double Materiality exercise and the associated material impacts, risks, opportunities, and their corresponding management.

Additionally, the Annual General Meeting approves the compensation policy for board directors, based on a proposal from the Board of Directors, following a report from the Appointments and Remuneration Committee. Compensations are determined not only by financial performance but also by the achievement of specific objectives related to environmental and social responsibility. These objectives are aligned with the identified material impacts, risks, and opportunities, fostering a comprehensive and long-term approach to creating value for the company and its stakeholders.

Sustainability governance model

MAPFRE has established a comprehensive sustainability governance model:

Strategy level:

• Sustainability Policy
• Sustainability Plan
• Documents detailed in section "1.4.3. (MDR-P): Policies adopted to manage material sustainability matters"

Governance level:

• Executive Committee
• Board of Directors
• Risk and Sustainability Committee
• Sustainability Operating Committee

Execution level:

• Corporate Sustainability Office
• Sustainability Supervisors in the countries
• The Corporate Areas (CA) and countries are responsible for implementing the projects outlined in the plan

Monitoring level:

• Board of MAPFRE SA and subsidiaries
• Executive Committee
• Risk and Sustainability Committee
• Sustainability Operating Committee
• Corporate Sustainability Office

Role in risk management

The Board of Directors and other governing bodies address these topics as part of their incorporation into the agenda of their periodic sessions. This inclusion may occur on an ad hoc basis at the request of the corporate areas responsible for managing impacts, risks, and opportunities, or because it is already planned in the session schedule due to a topic's recurring relevance, or because it is associated with regulatory requirements.

The Board of Directors of MAPFRE has approved the following Solvency II policies regarding risks: Internal Control Policy, Risk Management Policy, Risk Appetite Policy, Own Risk and Solvency Assessment Policy, Solvency Capital Calculation and Internal Models Policy, Policy for the Constitution of Technical Provisions, Investment Policy, Asset and Liability Management Policy, Valuation Process Policy for Assets and Liabilities other than Technical Provisions, Credit Risk Management Policy, Reinsurance and Other Risk Mitigation Techniques Policy, Liquidity Risk Management Policy, and Operational Risk Management Policy. The Corporate Risk Division proposes their update to the Board of Directors, subject to a favorable report from the Risk and Sustainability Committee.

In addition to the quantitative treatment of Solvency II risks, and as part of the annual risk identification process, at the beginning of each fiscal year the Corporate Risk Division encourages the main areas or departments of the MAPFRE Group to identify material risks that may affect the Group over the period covered by its business plan, as well as emerging risks that both the insurance industry and MAPFRE may face in the longer term (5-10 years). With the information obtained, a risk map is generated, which is analyzed by the Risk and Sustainability Committee in the first quarter of the year. The aim is to examine the Group's exposure to risks that could significantly impact its operations, cause it to fail to meet its regulatory capital or rating objectives, or prevent it from maintaining an adequate level of capitalization on a continuous basis. Subsequently, in the third quarter of the year, an update of this risk map is presented in order to update the identified material risks, including, if necessary, any other risk that has increased in recent months.

This process also takes into account the results of the double materiality assessment, in order to identify environmental, social, and governance issues that are relevant for MAPFRE and for the stakeholders.

Impacts, risks, and opportunities are monitored through the procedures, protocols, rules, and policies developed by each of the organizational functions.

As mentioned in the section on Double Materiality, the role of the governing bodies is essential for its correct implementation and monitoring. Both the Sustainability Operating Committee and the Risk and Sustainability Committee play a crucial role in the annual review and supervision of this process.

In 2024, both committees validated the new methodology for the Double Materiality Assessment, including the consultation with stakeholders and the results obtained. Once approved, these results are integrated into the prioritization of material issues in the company's management and decision-making processes, through objectives, action plans, and metrics defined by the relevant corporate areas, ensuring that the corporate strategy is aligned with the identified impacts, risks, and opportunities.

Additionally, they oversee the evolution of these key issues within the sustainability framework, ensuring that the strategy responsibly adjusts to the identified challenges.

The objectives are subsequently approved and managed through the various internal committees established by the areas, eventually converging with the objectives set in both MAPFRE's strategic plan and our sustainability plan. These plans and their corresponding monitoring are presented to the Executive Committee and the Board of Directors.

The administrative, management, and executive Senior Management bodies play a crucial role in overseeing the establishment of goals related to the most relevant risks, opportunities, and incidents.

To effectively manage risks, MAPFRE has developed policies that assign responsibilities, establish guidelines and principles, and define the framework for action for each type of risk, including sustainability. The Board of Directors of MAPFRE S.A. is responsible for ensuring the efficacy of the Risk Management System, by establishing the risk profile and risk tolerance limits. It is also responsible for approving the strategies and policies. This system covers underwriting, market, credit, operational, liquidity, noncompliance, corporate governance, security, and sustainability risks, considering both potential and emerging risks.

In carrying out its functions, the Board of Directors relies on the committees outlined below, which are assigned the following responsibilities related to the monitoring of the risks to which the entity is exposed: (i) the Risk and Sustainability Committee, which advises the Board of Directors on the definition and evaluation of risk management policies, determining risk appetite and risk strategy, as well as defining and overseeing the corporate sustainability policy and sustainability strategy; and (ii) the Audit and Compliance Committee, which supervises the effectiveness of the Group's internal control, internal audit, and risk management systems.

In addition, the Group's Security, Crisis, and Resilience Committee ensures proper management of security risks.

Each of the main risks identified in the Risk Management System (including corporate governance, underwriting, market, credit, operational, liquidity, compliance, and security risks) has a specific written policy for its control and management.

The Board of Directors also approved the MAPFRE Group Strategic Plan, which includes a series of sustainability indicators. Contributions from the various Business Units, Countries, Corporate Areas are considered in the development of the Strategic Plan. The Board of Directors receives quarterly updates on the progress of the Strategic Plan, with a particular focus on the level of compliance with each indicator and the actions taken to achieve these objectives.

Expertise in sustainability

The Board of Directors, as a whole, possesses sufficient expertise in sustainability, with 80% of its members having significant knowledge in this area. At least 75% of Steering Committee and the Audit and Compliance, Appointments and Remuneration, and Risk and Sustainability Committees have significant knowledge of sustainability.

The expertise of the Board of Directors and its committees in the field of sustainability is closely aligned with the material issue identified, including climate change, own personnel, workers in the value chain, consumers, end users, and business conduct. This relevant knowledge of sustainability is aimed at ensuring the proper management of identified material impacts, risks, and opportunities, thereby strengthening the company's ability to address these strategic challenges effectively.

With regard to business conduct, the Board of Directors of MAPFRE, as the administrative, management, and supervisory body, sets the guidelines to foster an ethical and responsible culture, ensuring regulatory compliance and the integration of sustainability criteria into decision-making. Its role includes overseeing, through its committees, risks associated with inappropriate conduct, such as fraud, corruption, greenwashing, non-compliance with regulations, or any behavior that could harm the integrity and reputation of the company. The Board also ensures transparency in communication with stakeholders, aiming to maintain trust in the company and safeguard its long-term image and value.

Drawing on its experience in responsible management and governance through its delegate governing bodies, the Board of Directors promotes ethical values throughout the company, fostering the continuous implementation of best practices and a positive impact on its environment.

Diversity and experience

The Board of Directors of MAPFRE S.A. approved the Director Selection Policy on July 23, 2015, with the last amendment made on December 21, 2020. That policy states that during selection of candidates, special consideration will be given to diversity in terms of knowledge, experience, age, and gender, and it also states that at least 40% of the Board's members will be women.

As of the date of this Report, 46.67% of the Board's members are women. The majority participate in the Steering Committee and/or the Committees of the Board of Directors and/or have an important role:

• Catalina Miñarro Brugarolas: Second Vice Chairwoman of the Board of Directors and of the Steering Committee, Chairwoman of the Appointments and Remuneration Committee, and Lead Independent Director.
• Ana Isabel Fernández Álvarez: Member of the Steering Committee, Audit and Compliance Committee, Appointments and Remuneration Committee, and Risk and Sustainability Committee.
• Rosa María García García: Member of the Appointments and Remuneration Committee.
• María Amparo Jiménez Urgal: Member of the Appointments and Remuneration Committee.
• María del Pilar Perales Viscasillas: Member of the Appointments and Remuneration Committee, Audit and Compliance Committee, and Risk and Sustainability Committee.

Distribution by sex of the members of the Steering Committee and other Board committees, as of December 31, 2024:

M: Men; W: Women

The Board members also reflect geographic and cultural diversity, with members of three nationalities: Spanish, Brazilian, and Italian.

The MAPFRE Group's Institutional, Business and Organizational Principles include equality in relations with board directors, which requires objectivity in their selection and promotion, remuneration and nondiscrimination on the basis of race, political ideology, religious beliefs, gender or social status. Additionally, these standards explicitly state that the Board of Directors of MAPFRE shall develop a vacancy-filling plan to ensure the suitability of applicants based on their skills, professional and geographic backgrounds, as well as a sufficient presence of both genders. It also establishes that the competent bodies shall ensure vacancies will be filled in favor of diversity of knowledge, experience, age and gender.

Furthermore, MAPFRE has a Director Selection Policy, under which the candidate selection process prioritizes diversity of knowledge, experience, age, and gender, with the goal of ensuring that female directors represent at least 40% of the Board's total members. Ms. María Elena Sanz Isla was appointed as executive board director on March 10, 2023, which increased the percentage of female board members from 42.86% in 2022 to 46.67% in 2023, a figure that has been maintained in 2024.

As of December 31, 2024, the Board consists of 15 members who collectively possess knowledge, qualifications, and experience in the following areas: insurance and financial markets, business strategy and company models, governance systems, financial and actuarial analysis, regulatory frameworks, audit/accounting, sustainability, strategic consulting, legal/tax consulting, technology and digital transformation, industry, health, human resources, and teaching and research. The company has a Competency Matrix for the Board of Directors that defines the skills and knowledge required of all Board members. This document is also updated each time an appointment or resignation occurs, with the most recent update taking place in 2024.

Integration of sustainability-related performance in incentive schemes

Overview of remuneration governance

Remuneration for the Directors is determined in accordance with the legislation that applies to corporations, the Company's bylaws, the Regulations of its Board of Directors, and resolutions passed by the Annual General Meeting.

The Regulations of the Board of Directors govern the functions performed in relation to remuneration by the Board and by the Appointments and Remuneration Committee.

On March 10, 2023, the Annual General Meeting approved the Compensation Policy for Board Directors for the period 2023-2025, effective as of January 1, 2023. At the Annual General Meeting scheduled to be held on March 14, 2025 (on the first call), a new Compensation Policy for Directors will be submitted for approval, which will be in force from the date of its approval, if applicable, by the Annual General Meeting for the remaining period of 2025 and fiscal years 2026, 2027 and 2028.

Total remuneration of Directors (2024)

In thousands of euros

Average remuneration and evolution

In thousands of euros

Remuneration policy principles

The policy approved in 2023 includes the various components of the remuneration package for directors, which have been established based on the following general principles and foundations:

• Prioritizing medium-term and long-term value creation and profitability over short-term results
• Reasonable proportionality between the Company's economic situation and the market standards for comparable companies
• Alignment with the sales strategy and the Company's risk management, risk profile, objectives, and risk management practices
• Appropriate and efficient risk management, within the established risk tolerance limits
• Attraction and retention of talent
• Compensation adjusted to the levels of dedication, qualification, and responsibility
• Appropriate proportions for the fixed and variable components, avoiding excessive reliance on the variable components
• Deferred payment of a substantial portion of the variable remuneration
• Possibility of ex-post adjustments to the variable remuneration
• Avoidance of conflicts of interest
• Alignment of the remuneration system for the Executive Directors with the system that applies to Especially relevant personnel

Integration of sustainability metrics into incentive schemes

Especially relevant personnel, and all those who perform key functions, or whose professional activities have a material impact on the Company's risk profile, are subject to a variable remuneration system linked to achievement of financial and non-financial objectives directly connected to the strategic plans, and also subject to deferral rules.

Sustainability-related performance metrics are considered as benchmark indexes and are integrated into an incentive system.

Long-term incentive plans linked to sustainability KPIs

The long-term incentive plans in effect for 2024, applicable to the executive board directors of MAPFRE, S.A., operate on different overlapping cycles. These plans include various objectives, one of which is specifically related to GHG emissions. This objective focuses on achieving emissions neutrality in the operational footprint by 2026 across 15 countries where MAPFRE operates.

ESG objectives by cycle

Note: The Board of Directors of MAPFRE, S.A., in its meeting held on February 11, 2025, decided, following a favorable report from the Appointments and Remuneration Committee, to modify part of the objectives linked to the remuneration of the second cycle (2023-2025) and the third cycle (2024-2026) of the Medium and Long-Term Incentive Plan 2022-2026. The new objectives will be reported in the Sustainability Report corresponding to fiscal year 2025. These are described in the proposed Compensation Policy for Board Directors 2025-2028, which will be submitted for approval by the next Ordinary Annual General Meeting.

Medium and Long-Term Incentive Plan

On February 9, 2022, the Board of Directors, at the proposal of the Appointments and Remuneration Committee, approved an extraordinary Medium and Long-Term Incentive Plan. This plan, which is non-cumulative and multi-year, includes key MAPFRE Group executives and professionals, including the executive directors of the Company.

Strategy, business model and value chain

Description of products/services and key markets

Core business activities:

MAPFRE is a multinational group with a presence in 38 countries and activity in more than 100, operating through a network of 4,625 direct and delegate offices, 8,042 bancassurance offices, and 86,928 intermediaries. The company is primarily engaged in insurance, reinsurance, and financial activities.

Products and services:

MAPFRE offers a catalog of products and services adapted to the needs of clients, including:

• For individuals: Life, Health, Accident, Property and Casualty protection (Auto insurance, Homeowners, Family and Third-Party Liability insurance, etc.), Savings and Investment, Retirement, Burial, Travel and Leisure
• For professionals and SMEs: Solutions for vehicles, third-party liability, property, agriculture and livestock, accidents, health, life, retirement, savings and investment
• For companies of all sizes: From small family businesses to large multinational corporations, both at local and national level, and globally
• Specialist units: MAPFRE GLOBAL RISKS (large risks including aviation, energy, industry, construction), MAPFRE RE (reinsurance services in more than 100 countries through 18 offices), MAPFRE AM (asset management applying socially responsible investment principles)
• Assistance services: MAWDY brand offering travel, health, homeowners, vehicles, protection of purchases and goods, and roadside assistance
• Burial services: Through Enalta, including rental of mortuary rooms, cremations, and cemetery management

Significant groups of products/services

In 2024, the business activities were organized into:

• Three Business Units: Insurance, Reinsurance, and Assistance (MAWDY)
• Three Regional Areas: Iberia (Spain and Portugal), International (Brazil, Mexico, Other LATAM, EMEA, Global Risks), and North America (USA and Puerto Rico)

No revenue breakdown by product/service group was disclosed in the excerpts.

Significant markets/geographies

MAPFRE operates in:

• 38 countries with active presence
• More than 100 countries where it has activity

Regional structure (2024):

• Iberia (Spain and Portugal)
• International: Brazil, Mexico, Other LATAM, EMEA (including Germany, Italy, Malta, Portugal), Global Risks
• North America (USA and Puerto Rico)

Number of employees by geography

Total salaried employees at December 31, 2024: 30,585

By geographic area:

Total revenue by significant ESRS sustainability matter

Not disclosed in the excerpts provided.

Sustainability-related goals embedded in the business model

Strategic Plan 2024-2026 Goals:

Financial targets:

• Average growth: above 6%
• Average ROE (Return on capital): between 10% and 11%
• Average combined ratio: between 95% and 96%
• Solvency: 200% +/- 25 p.p.
• Leverage ratio: approximately 24%
• Payout: more than 50%, with commitment to maintaining stable or growing dividend

Sustainability Plan 2024-2026 - Three key goals:

1. Carbon neutrality in 15 countries
2. Sustainable investments: more than 95% aligned with ESG criteria
3. Women in management positions: 36% of management positions to be held by women by 2026

Business model sustainability pillars:

The MAPFRE business model focuses on delivering economic results in a sustainable manner to contribute to the development of societies. It is based on:

• Transformation and innovation
• Geographic diversification
• Customer orientation (private and business sectors)
• Multi-channel customer service
• Wide variety of products and services
• Deep commitment to caring for people

The model relies on good governance practices, environmental and investment responsibility, and contribution to society.

Strategic Plan 2024-2026 four pillars:

1. Growth and profitability
2. Efficiency and productivity
3. Transformation and culture
4. Sustainability

Sustainability strategy focus areas:

Environmental Commitment:

• Managing environmental footprint (energy consumption, renewable energy adoption, fleet transition)
• Carbon neutrality in 15 countries by 2026 and all Group countries by 2030
• Reduce carbon footprint by 30% by 2030 (compared to 2022 baseline)
• Purchasing energy with guarantees of origin, installing photovoltaic panels, reducing business trips, promoting mobile work
• Creating sustainable investment portfolio

Social Commitment:

• For own personnel: Integration of people with disabilities, promotion of senior talent, gender equality programs
• For value chain workers: Evaluating providers according to sustainability criteria; 95% of premiums by 2026 in countries where preferred home, motors, health network and procurement providers are evaluated
• For consumers: Promoting financial education and facilitating access to insurance

Business Conduct:

• Improving governance and transparency
• Incorporating sustainability objectives into executive remuneration
• Encouraging corporate volunteering
• Establishing system to measure social impact of activities

Description of upstream and downstream value chain

Upstream phases: Providers

MAPFRE works with close to 135,000 providers across regions, divided into:

Business providers: Directly related to products and services MAPFRE offers, collaborating to fulfill contractual obligations related to services or benefits.

General providers: Supply goods and support services but do not perform benefits derived from insurance or service contracts. Grouped into 5 main families:

• Technology and Telecommunications
• Infrastructures and Equipment
• Advertising and Marketing
• General Expenses
• External Services

Own operations: MAPFRE Group

Includes salaried and non-salaried employees (30,585 salaried employees at year-end 2024). Main business lines:

• Insurance: Life, automobile, health, home, and others
• Reinsurance: MAPFRE RE offering treaty and facultative reinsurance solutions
• Global Risks: Solutions for large companies, multinationals
• Assistance (MAWDY): Digital distribution models with partners
• MAPFRE AM (Asset Management): Managing group and client investments, pension funds, applying socially responsible investment principles
• Enalta: Burial services

Downstream phases: Customers and distributors

Distribution network:

• 4,625 own offices
• 8,042 bancassurance offices (including partnerships with Banco Santander, Bankinter, Banco do Brasil, Bhd Leon, Bank of Valleta)
• 86,928 intermediaries (agents, delegates, brokers)

Distributors types:

• Agents: Natural or legal persons with agency contract, including exclusive and tied agents
• Brokers: Independent intermediaries without contractual links implying connection with insurance companies
• Collaborators: Agreements with organizations whose main activity is not insurance sales, divided into banks/financial institutions and non-financial entities

Customer categories:

1. Individual customers: Natural persons with active contractual commitments, including:

• With direct relationship
• With relationship through commercial lines client
• With direct relationship but conditions set by affinity groups

2. Company customers: Legal entities with active contractual commitments, including:

• With direct relationship
• With direct relationship but conditions set by other companies

Relationship types with customers:

• Policyholder/contracting party
• Payer
• Insured Party
• Beneficiary

Key inputs and outputs

Business model inputs:

• Economic, political, social, and legal analysis of markets
• Understanding current and potential customer needs
• Analysis of risks to be insured (people, properties)
• Analysis of economic, social, environmental, and governance trends
• Analysis of physical and transition risk scenarios

Mechanisms to collect, develop and guarantee inputs:

• Process for reviewing and defining Group and country strategy
• Market Trend Observatory of corporate business area
• Country business model exercise led by corporate business area
• Risk Management System
• Studies by MAPFRE Economics
• Innovation model

Business model outputs:

• Wide range of insurance offerings (life, health, accident, property protection, savings, investment, retirement, burial, travel, leisure)
• Offerings adapted to each country according to customer needs
• Solutions for companies of all sizes (small, medium, large corporations) at local, national, and global levels
• Services beyond insurance through MAWDY
• Asset management services through MAPFRE AM
• Burial services through Enalta

Sustainable products (2024):

Objective: Achieve growth rate higher than Group's premiums to increase relative weight of sustainable products.

Network of ESG-approved service providers:

Since 2019, MAPFRE has implemented an ESG approval process for providers evaluating sustainability practices in environmental, social, labor, and corporate governance areas. As a result, MAPFRE has a network of over 11,000 approved service providers based on ESG criteria.

Interests and views of stakeholders

Overview

Profitable growth cannot be understood from a financial point of view alone. We are a dedicated company that also aspires to create and distribute value to all stakeholders.

MAPFRE's strategy with different stakeholders focuses on building long-term trust-based relationships grounded in commitment, dialog, integrity, responsibility, and transparency. This strategy contributes to the sustainable value creation model pursued by the Group and is guided by the MAPFRE Code of Ethics and Conduct, as well as the MAPFRE Sustainability Policy.

Key stakeholder groups, engagement channels and key concerns

Below are the main stakeholder groups for MAPFRE and the key aspects of the strategy and management related to them:

Integration into strategy and business model

MAPFRE incorporates the interests and perspectives of its key stakeholders by addressing them within each of the relevant operational areas through the due diligence process (refer to section "1.2.4 (GOV-4): Statement on due diligence"), as well as through the Double Materiality Assessment (please refer to section "1.4.1 (IRO-1): Description of processes to identify and assess material incidents, risks, and opportunities," which evaluates both the impact of MAPFRE's activities on stakeholders and the influence of external factors, such as sustainability issues and regulations, on the company. This approach enables us to integrate stakeholder needs and expectations into decision-making, ensuring that the company is well-prepared to address impacts and risks while seizing opportunities, all with a firm commitment to transparency and responsibility.

Value chain workers

Regarding value chain workers, although they may not directly collaborate with MAPFRE in shaping the company's strategy and business model, there are established processes and mechanisms to listen to their feedback, which can serve as a basis for evaluating the strategy and business model.

MAPFRE actively encourages listening to this group by integrating social criteria in the evaluation of providers and customers. For providers, social footprint criteria are included in the company's ESG approval process, and MAPFRE conducts site visits to monitor working conditions. If any issues are detected, corrective actions are taken. Additionally, contractual clauses are established to ensure responsible labor practices. For customers, social aspects are incorporated into investment and underwriting processes. In both cases, MAPFRE provides reporting channels to manage and resolve any labor-related incidents. These processes are described in greater detail in sections "3.2.2.2. S2–2: Processes for engaging with value chain workers about impacts" and "3.2.2.3. S2– 3: Processes to remedy negative impacts and channels for value chain workers to raise concerns"

Double Materiality Assessment integration

The Double Materiality Assessment considers the key factors that influence MAPFRE's strategy and business model. Among these factors are the interests, opinions, and concerns of the main stakeholders. For this, the results of the surveys and evaluations conducted are analyzed, with a subsequent focus on prioritizing the key concerns identified in the analysis, particularly those directly related to sustainability impacts.

Next, actions are identified to address these impacts, ultimately leading to adjustments in the aspects considered during the development and review of the strategy and business model. This approach ensures that stakeholders remain at the core of decision-making, giving them significant influence over the company's strategic direction.

Currently, MAPFRE does not foresee implementing measures that would require modifications to its strategy or business model.

Governance and reporting

To understand how the Board of Directors is informed of the stakeholders' opinions and interests related to the sustainability impacts of the company, please refer to section "1.2.2 (GOV-2): Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies."

For further details on the management of commitments with key stakeholders, please refer to the following sections:

• Own personnel: 3.1. Own workforce

• Customers: 3.3. Consumers and end users

• Providers: 4.1.3. (G1-2): Management of relationships with providers

Stakeholder participation in double materiality assessment

Stakeholder opinions collected through questionnaires, interviews and focus groups were used to assess impact materiality. The results from the responses gathered via the questionnaires, the main quantitative listening channel, are as follows:

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

Overview

After conducting the Double Materiality Assessment, the standards deemed material for MAPFRE in 2024 were identified:

• E1 - Climate change • S1 - Own personnel • S2 - Workers in the value chain • S4 - Consumers and end users • G1 - Business conduct

For each of these standards, the material impacts, risks, and opportunities were identified, which are essential for understanding how these factors influence MAPFRE's strategy and business model. In summary, a total of 51 material impacts, risks, and opportunities were identified.

In 2024, no significant financial effects arose from the identified risks, except for significant catastrophic events. Regarding the current financial effects of the identified opportunities, no significant financial impacts were recorded during the fiscal year.

Climate Change

Material Impacts, Risks and Opportunities

Positive impacts:

• Mitigation of climate change by reducing the carbon footprint of internal operations
• Promotion of a low-emissions economy due to underwriting and investment in activities that contribute to climate change mitigation
• Contribution to adapting society to climate change through product creation, inclusion of coverage, or adaptation of underwriting rules related to climate change risks

Negative impacts:

• Contribution to the greenhouse effect through collaboration with providers that do not implement practices aligned with climate change mitigation
• Contribution to the greenhouse effect through underwriting and investment in activities that are intensive in greenhouse gas emissions

Risks:

• Occurrence of events with acute physical risks of climate change that could disrupt the company's value chain
• Occurrence of chronic and acute physical risks of climate change that lead to an increase in the loss ratio
• Occurrence of climate change transition risks that result in a decrease in revenue from current products and services
• Occurrence of market climate change transition risks that result in a fall in the valuation of the company's financial assets

Opportunities:

• Promoting the offering of advisory services related to climate change
• Expanding the offering of insurance products related to climate change
• Developing new sources of revenue from new markets and investment products in climate change

Interaction with Strategy and Business Model

The MAPFRE Group business model and strategy are an example of how the company faces global challenges in terms of sustainability, how it manages environmental, social, and good governance risks, and how it innovates in the development of insurance products and solutions for the benefit of its customers and the community. Climate change risk management helps it to make important decisions affecting underwriting, acquisitions, investments, innovation in products and services, and reputation management, essential to earn the trust of stakeholders and adapt the Group's financial planning process to climate change.

Time Horizons

• Short-term: Up to 3 years
• Medium-term: Between 3 and 10 years
• Long-term: Over 10 years

The short-term horizon is used to identify material risks, a process aligned with strategic planning. The medium-term horizon is used to identify emerging risks, whose time horizon goes beyond the strategic planning period. It is also used to assess the transition risk. Long-term horizons are used in climate change scenarios for physical risk assessment, with time horizons until 2080.

Resilience

MAPFRE's strategy and business model are designed to be resilient in a dynamic environment, integrating financial stability, proactive risk management, and a strong commitment to sustainability. The company's high solvency ratio and strategic use of reinsurance are key indicators of financial strength. Stress tests demonstrate MAPFRE's ability to handle extreme scenarios and manage financial and operational risks.

MAPFRE seeks to identify, assess, and manage material impacts, risks, and opportunities in line with its commitment to sustainability and the integration of ESG criteria into its strategy and business model. The company evaluates both physical risks, derived from acute and chronic events that impact the underwriting and real estate portfolio, as well as transition risks, which influence the valuation of financial assets due to the transition toward a low-carbon economy.

Own Personnel

Material Impacts, Risks and Opportunities

Positive impacts:

• Contribution to the defense of human rights among own personnel
• Improved quality of life for employees, protecting their health, safety, and well-being
• Promotion of birth rate by supporting work-life balance in maternity or paternity situations
• Contribution to quality remuneration in the regions where the company operates
• Contribution to developing own talent capabilities
• Protection of employee data privacy

Risks:

• Deficiencies in the performance of the activity resulting from deficient personnel management and organization, as well as a shortage of talent for the required job positions

Opportunities:

• Attracting diverse and multidisciplinary talent by promoting diversity in the workforce
• Reduction in employee turnover due to satisfaction with working conditions
• Increased attraction of talent due to the quality of job offers
• Improved productivity due to the training of own talent

Interaction with Strategy and Business Model

No material negative impacts related to own personnel have been identified in the analysis of Double Materiality 2024.

The six positive material impacts identified are directly linked to the Company's efforts in relation to salaried personnel:

• Generation of the Company's occupational well-being programs
• Establishment of clear policies of respect for human rights, as well as mechanisms to report any conduct that endangers them
• Execution of periodic training activities and construction processes for performance evaluation
• Definition and periodic review of quality remuneration plans

These efforts are made to generate more positive impacts that promote a healthy and motivating work environment, seeking to strengthen the sense of belonging and increase team satisfaction.

The strengthening and evolution of the activities that generate the positive impacts are essential to take full advantage of the identified material opportunities, contributing to the sustainable growth and competitiveness of the company, through the capture of diverse and multidisciplinary talent, the reduction of turnover, and improved productivity.

No operations have been identified in MAPFRE activities that present a significant risk of forced labor or child labor. All workers of the company are under an employment contract meeting the requirements of local regulations, have the minimum age required, and are qualified to perform their tasks.

Workers in the Value Chain

Material Impacts, Risks and Opportunities

Positive impacts:

• Contribution to protecting the health and safety of employees in the supply chain and among distributors
• Protection of human rights in the supply and distribution chain
• Protection of human rights in underwriting criteria
• Contribution to social inclusion in investments

Negative impacts:

• Instances of discrimination in the supply chain or distribution network involving MAPFRE or its personnel
• Occupational harassment cases involving MAPFRE or its personnel
• Impact of human rights violations resulting from underwriting or investment in companies that do not align with international standards and principles

Opportunities:

• Improved quality of services and customer satisfaction through the proper management of provider workers

Interaction with Strategy and Business Model

MAPFRE understands that workers in its value chain may be negatively affected by their material impacts in the following way:

• Discrimination cases: workers linked to MAPFRE providers and distributors may be negatively affected if discrimination due to gender, ethnicity, religion, sexual orientation or other personal characteristics occurs in their work environments, connected to their relationship with MAPFRE
• Workplace harassment cases: providers' and distributors' workers, as well as those who operate in MAPFRE client companies, could be exposed to workplace harassment, linked to their relationship with the company
• Impact on human rights violations: Workers of companies in which MAPFRE invests or those providing underwriting services may be at greater risk of human rights violations if these companies do not comply with international principles

MAPFRE establishes a strong contractual relationship with providers, who assume direct responsibility for managing their workers. MAPFRE includes a "Brand Protection" clause in its contracts with providers, by means of which they must declare that they have read and understood the company's Code of Ethics and Conduct.

The impacts identified for workers in the value chain are directly aligned with the material opportunity identified for this group: improving the quality of services and customer satisfaction with the correct management of provider workers.

In the Double Materiality Assessment carried out in 2024, no specific geographical areas or products have been identified that present a significant risk of child, forced or compulsory labor among workers in the value chain.

Consumers and End Users

Material Impacts, Risks and Opportunities

Positive impacts:

• Development of accessible and inclusive products
• Promotion of accessible communication
• Contribution to information transparency
• Protection and responsible use of customer data
• Improved customer experience

Negative impacts:

• Deficiencies in customer advice due to poor commercial practices
• Loss of customer personal data due to cyberattacks

Risks:

• Decline in portfolio due to customer dissatisfaction from lack of information and shortcomings in product guidance
• Service interruptions due to failures in technology systems
• Loss of customer data resulting in mass fraud or service interruptions caused by cyberattacks
• Incorrect use of artificial intelligence that results in ethical conflicts (biases) or regulatory noncompliance

Opportunities:

• Increase in the customer portfolio due to commitment to diversity and inclusion
• Increase in the customer portfolio due to higher customer satisfaction
• Increase in the customer portfolio due to customer protection
• Promoting the development of new products covering cyber risk and new technologies (AI)

Interaction with Strategy and Business Model

These impacts, risks, and opportunities are linked to the subsequent phases of the value chain. The main emerging issues include the social inclusion of consumers or end users, incidents related to the information provided to them, and the personal security of consumers or end users.

MAPFRE seeks to develop comprehensive processes to identify, assess, and manage the impacts, risks, and opportunities related to protecting customer data, ensuring transparency, and developing accessible and inclusive products.

Business Conduct

Material Impacts, Risks and Opportunities

Positive impacts:

• Promotion of sustainable public policies
• Contribution to improving society by disseminating our business conduct and corporate culture

Negative impacts:

• Limited attention to the needs of stakeholders due to their low accessibility to MAPFRE whistleblower channels

Opportunities:

• Improved talent attraction and satisfaction of own personnel through the promotion of a corporate culture
• Improved business resilience by applying best practices in business conduct

Interaction with Strategy and Business Model

The Board of Directors of MAPFRE, as the administrative, management, and supervisory body, sets the guidelines to foster an ethical and responsible culture, ensuring regulatory compliance and the integration of sustainability criteria into decision-making. Its role includes overseeing, through its committees, risks associated with inappropriate conduct, such as fraud, corruption, greenwashing, non-compliance with regulations, or any behavior that could harm the integrity and reputation of the company.

Value Chain Location and Time Horizons

These material impacts are generally linked to a short-term time horizon, with the exception of those related to climate change and specific business conduct cases ("Limited attention to the needs of stakeholders due to low accessibility of MAPFRE's reporting channels"), which are mapped with a medium-term outlook.

The material impacts related to climate change could have positive or negative effects on the environment. The material impacts linked to own personnel, value chain workers, and consumers and end users may also have positive or negative effects on these groups.

Connection with Sustainable Development Goals

MAPFRE connects its environmental, social, and governance (ESG) impacts with the Sustainable Development Goals (SDGs) outlined in the 2030 Agenda, alongside its own strategy and business model. For environmental impacts, the Paris Agreement is also considered.

Changes from Previous Period

The material sustainability issues identified in 2024, in compliance with the CSRD, remain fully consistent with those recognized in the previous period. Climate change, own personnel, customer relations, and good governance (business conduct) continue to be considered material issues in the current fiscal year.

As part of the ongoing improvement process and the adoption of the Double Materiality methodology in accordance with the CSRD, workers in the value chain have now been incorporated as stakeholders.

Environmental issues other than climate change have not emerged as material according to the methodology applied in 2024. However, these topics are continuously analyzed and monitored.

It is worth highlighting that the Integrated Report 2023 did not specifically detail the material impacts, risks, and opportunities identified through the Double Materiality assessment.

In the 2024 Double Materiality exercise, no specific material impacts, risks, or opportunities related to Company issues were identified. All topics were covered by the disclosure requirements set forth by the ESRS.

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

Materiality analysis is essential for advancing our Strategic Plan 2024-2026 and reinforcing our commitment to sustainability. The results identify our key impacts, risks, and opportunities, which, when integrated into the company's decision-making and management processes, help adapt and steer the Group's strategy toward responsible progress in the right direction. This exercise is reviewed annually, and stakeholders are consulted every two years.

In 2024, we updated our methodology to align it with the EFRAG guidelines. While the financial and impact materiality requirements set by EFRAG were addressed in 2023, the methodology was refined in 2024 to ensure full compliance with both the EFRAG guidelines and the CSRD requirements. In doing so, we establish priorities for both stakeholders (outward) and MAPFRE (inward).

Governance and strategic integration

The Group Sustainability Office is responsible for preparing the Double Materiality Assessment, with support from the sustainability supervisors across various MAPFRE units to collect the necessary information from countries, businesses, and activities within scope.

The results of the Double Materiality Assessment are shared with key areas of the organization to ensure integration into the overall strategy and processes. The exercise is also delivered to the Corporate Risk Division to contribute to the company's risk identification process, which, in turn, serves as input for the Double Materiality Assessment.

Once the Double Materiality assessment is completed, the Sustainability Operating Committee and the Risk and Sustainability Committee annually validate the process and results. They also oversee the progress of material sustainability issues along with their impacts, risks, and opportunities.

In 2024, both committees validated the new methodology developed for conducting the Double Materiality assessment. After completing stakeholder consultations and obtaining the results from the study, they approved the process and its findings. Since its approval, the prioritization of material issues has been integrated into the company's management and decision-making processes, and, consequently, its overall strategy.

This methodology and its results will be reviewed again in the first half of 2025.

Approach, process, and methodology

This double materiality approach evaluates material issues across two main areas:

Financial materiality: This area includes the financial impact of sustainability risks and opportunities associated with the company's activities on the company itself. Financial materiality is assessed by estimating the probability and impact of these factors on the company's financial stability in the short, medium, and long term.

Impact materiality: This area covers the impact of the company's activities and its value chain on the environment, understood to encompass both the natural environment and society. Impact materiality is determined by evaluating the severity and probability that stakeholders attribute to various impacts.

This analysis allows us to:

1. Pinpoint stakeholders' concerns regarding identified material impacts, risks, and opportunities (IROs), identify initiatives and establish priorities.
2. Measure the potential financial impact for the business and define both risk control and mitigation measures and initiatives to leverage the opportunities that arise.
3. Help prioritize sustainability initiatives and align them with the Group's strategic initiatives.
4. Identify how each material issue of the materiality analysis impacts the Sustainable Development Goals (SDGs).
5. Identify sustainability issues that are material to the company and must therefore be reported in compliance with the requirements of the European Corporate Sustainability Reporting Directive (CSRD).
6. Use its results in the Group's risk identification processes.

Phases and results: Double Materiality Assessment

The Double Materiality Assessment is conducted across all of the Group's businesses and operations, and its methodological development consists of four key phases:

Phase 1. Definition of the scope of analysis

This phase establishes the scope for evaluating double materiality through the following sub-phases:

a. identification of the most relevant sustainability topics for the company. To assess the materiality of sustainability issues within this framework, the topics are explored in the phases of impact and financial materiality through the identification of impacts, risks, and opportunities related to the company's activities and its value chain.

b. the identification of the stakeholders involved in the exercise and their prioritization,

c. the definition of listening channels used to engage with stakeholders.

Identification of sustainability topics:

Taking the sustainability topics analyzed in MAPFRE's 2023 materiality exercise as a starting point, they were complemented by a study of topics from external sources, mainly the European Sustainability Reporting Standards (ESRS) that complement the Corporate Sustainability Reporting Directive (CSRD), the proposal for an EU Directive on Corporate Sustainability Due Diligence, the GRI and SASB standards, the TCFD and CDP recommendations and guidelines, the ISO 50001 and ISO 14001 certifications, The Global Risk Report 2023 published by the World Economic Forum, the CRO Forum's Mind the Sustainability Gap report, the Financial Stability Report December 2022 by EIOPA, and a benchmark for market pairs; as well as internal sources such as the MAPFRE risk matrix.

As a result of the above, a list of topics was defined for the 2024 study, grouped into three categories: environment, social, and governance.

Stakeholder identification and prioritization:

Stakeholders were identified taking into account those already defined by MAPFRE in its stakeholder-relations strategy, together with an analysis of those identified in external sources.

The identification process began with an as-is analysis of the materiality exercise from the previous year, complemented by an industry peer benchmark. Finally, a gap analysis was conducted to identify the stakeholders who would be involved in the exercise. These stakeholders were then prioritized according to two concepts: "influence" and "interest":

• Influence refers to the ability of a stakeholder to impact or alter the company's decision-making. The evaluation was based on the following five criteria: i) ability to influence decision-making; ii) capacity to influence the company's financing; iii) ability to influence other stakeholders; iv) the extent to which its own decisions condition MAPFRE's activity; v) substitutability of the stakeholder. The total result obtained for the influence accounted for 60% of the final prioritization score.

• Interest refers to the level of benefit or usefulness that the stakeholder derives from the company's activities. Scores were assigned based on the following criteria: i) the involvement of the Group's activities and decisions with each stakeholder; ii) the financial or social benefits that the stakeholder may obtain from MAPFRE. The total result obtained for interest accounted for 40% of the final prioritization score.

Taking these factors into account, each stakeholder was assigned a weight or importance.

Stakeholder consultation:

In 2024, a total of 20,158 people were consulted, representing the following stakeholder groups:

Phase 2. Evaluation of impact materiality and financial materiality

Impact materiality:

The assessment of impact materiality was based on the guidelines provided by the ESRS and EFRAG. In line with the indications of the ESRS and EFRAG on the Double Materiality process, impact materiality was measured based on two main factors: severity and probability.

Severity was further divided into three subcategories: scale, scope, and remediable nature.

Impacts have different characteristics:

• Positive/Negative: Impacts are categorized as positive or negative depending on whether their effect on the environment is beneficial or harmful, respectively.
• Real/Potential: Impacts are classified as real if they have already occurred or are ongoing during the reference period, while potential impacts are those that are likely to occur in the short, medium, or long term.
• With/without impact on human rights: This classification applies to negative and potential impacts and refers to whether or not the impact involves a human rights violation.

These concepts influenced the calculation of impact materiality in the following ways:

• The severity of positive impacts is determined by scale (rated from 1 to 5 based on stakeholder surveys, according to the perceived relevance of each issue) and scope (rated from 1 to 5 based on geographical and population segments, according to the extent of the impacts). However, the severity of the negative impacts is formed by scale, scope, and remediable nature. The remediable nature variable is rated from 1 to 5 based on how effective the actions and measures the company could take to mitigate the impact are perceived to be.

• The materiality of current impacts is measured solely in terms of severity, while the materiality of potential impacts is measured using both severity and probability.

• Furthermore, in the case of a negative and potential impact that is classified as having an impact on human rights, severity takes precedence over probability.

Finally, once all impact materiality results were calculated, the arithmetic mean was determined, and all impacts with a materiality result above the average value were classified as material.

Financial materiality:

Financial materiality was calculated at a consolidated level, meaning that risks and opportunities were assessed from the perspective of MAPFRE as a Group, considering the following sources of information:

• public information about the company (e.g., TCFD report 2023)
• Internal information (e.g., risk map, sustainability plan, strategic plan)
• Risks and opportunities associated with the impacts identified in the impact materiality exercise
• Environmental and social dependencies

To calculate the financial effect and probability aligned with the ESRS, an additional parameter was considered: time horizons.

The time horizons used to assess financial materiality were defined by the CSRD ESRS:

• Short-term: up to 1 year
• Medium-term: 1 to 5 years
• Long-term: more than 5 years

Once the time horizons were defined, the financial effect and probability of the risks and opportunities for the short, medium, and long term were analyzed.

This analysis focused on evaluating the following aspects for each time horizon:

i) Financial effect, the impact on future cash flows. To quantify the financial effect of risks, a scale of 1 to 5 was applied, aligned with the corporate risk assessment process, based on the effect on equity from the previous fiscal year. For opportunities, a scale of 1 to 5 was also used, but based on their effect at the income or cost level from the last fiscal year.

ii) Probability, the degree of certainty that a potential impact will occur or that a current impact will be maintained.

Once the time horizons were defined, the arithmetic mean was calculated for each of the results obtained and those with a materiality result above the average value were classified as material.

Phase 3. Reporting of results

As a result of the methodology described above and analyzing both impact and financial materiality, MAPFRE identified the following material topics for 2024:

1. Climate change
2. Own personnel
3. Workers in the value chain
4. Consumers and end users
5. Business conduct

Phase 4. Integration and linking of results

The table below shows the link between material issues and the Group's strategy, as well as their connection to the Strategic Plan:

Comprehensive risk management

Sustainability in the insurance industry is based on the proper management of risks faced by the organization. At MAPFRE, this is implemented through responsible risk assumption and management. The identification of impacts, risks, and opportunities carried out through the Double Materiality Assessment is integrated into the company's comprehensive risk management process.

At MAPFRE, the primary objectives of the Risk Management System are to establish a reliable and effective risk management culture and system, ensure that all potential risks are analyzed when decisions are being made, and maintain the Group's financial solvency and solidity, all with the aim of strengthening the Group's position as a trusted insurance company. To this end, it considers the integrated management of each and every business process and on the adaptation of risk levels in the established strategic objectives.

To ensure the effective management of the risks faced by the Group, including potential, emerging, and sustainability-related risks, MAPFRE has developed a set of management policies. These policies establish the general guidelines, basic principles, and framework for action for each type of risk, ensuring consistent application across the Group's companies. They also assign responsibilities, define strategies, and outline information processes and procedures for the identification, measurement, monitoring, management, and reporting of risks, as well as establish reporting lines.

Governance Framework for the Risk Management System:

The responsibilities of the risk management systems are integrated into the Group's organizational structure according to the three-lines-of-defense model, so that all the staff of the organization have responsibilities for compliance with the control objectives.

The Board of Directors of MAPFRE S.A. is the most senior body responsible for ensuring the efficacy of the Risk Management System, by establishing the risk profile and risk tolerance limits. It is also responsible for approving the main risk management strategies and policies. The Board has a Risk and Sustainability Committee and an Audit and Compliance Committee to provide assistance with the Board's functions related to the Risk Management System.

In addition, the Group has other committees with responsibilities related to risk management, including the Group's Security, Crisis, and Resilience Committee, the Security Committee, the Investment Risk Committee, and the Sustainability Operating Committee.

The Group Risk Office coordinates the set of strategies, processes, and procedures necessary for comprehensive risk management, and its actions are supervised by the Third Vice Chairman and Chief Financial Officer (CFO), by delegation of the MAPFRE S.A. Board of Directors and its delegate committees.

On a quarterly basis, MAPFRE's governing bodies receive information regarding quantification of the main risks that the Group is exposed to, along with the capital resources available for addressing those risks. They also receive information related to compliance with the limits established in the risk appetite and other specific risk policies.

Stakeholder participation in risk identification:

The Group promotes the development of various procedures focused on ensuring that the main risks that could affect it are taken into consideration, along with any stakeholder concerns related to environmental, social, and governance matters.

The prioritization of sustainability issues relevant to both stakeholders and MAPFRE is conducted regularly through the Double Materiality Assessment.

The employees participate in a proactive manner to identify, control, and report risks, and they provide feedback regarding the Internal Control System and Risk Management System. In addition, this is complemented by the following procedures:

• The control environment survey, which is given at least biannually, with the objective of gathering opinions from all of the organization's employees regarding the existing control environment. This helps raise awareness regarding the risk culture within the organization, while identifying weaknesses and opportunities for improvement in the Internal Control System and Risk Management System.

• The procedure for reporting and recording operational risk events, which allows employees from the first line of defense to notify the Risk Division about any operational risk events or incidents occurring at their company. The Risk Divisions at the companies maintain records regarding all such events that have occurred, and they coordinate with the areas responsible to produce the action plans needed to manage them. On a quarterly basis, they also report any events with an economic impact of more than €100,000 to the Corporate Risk Division. In turn, the Corporate Risk Division reports to the Risk and Sustainability Committee on a quarterly basis, to ensure that the Group's governing bodies are receiving all relevant information regarding operational risks. Operational events and incidents are classified into the following categories, in accordance with international event recording standards: Internal Fraud (includes acts involving corruption or violations of the Code of Ethics and Conduct); External Fraud (includes system security and cyberattacks); Employment Practices and Occupational Safety; Customers, Products, and Market Practices; Damage to Tangible Assets; ICT System Failures; and Process Execution, Delivery, and Management.

• The risk control procedures, which are used to perform a dynamic qualitative analysis for each process. This makes it possible for the managers from each area or department to identify the potential risks affecting the business processes and support processes. The supervisors from the areas and departments prepare internal control manuals and other descriptive documents. These contain descriptions of the procedures and activities, and identify the persons who will participate in them. They also identify the associated risks and the controls used to mitigate them. By understanding and documenting these controls, the supervisors from the various areas and departments at the MAPFRE companies are able to assess the effectiveness of the established controls. They can determine whether the relevant risks identified are sufficiently controlled, and can implement any necessary corrective measures.

Risk identification:

At the beginning of each year, the Corporate Risk Division performs management to ensure identification of all material risks that could affect the Group's ongoing compliance with the business plan, as well as other risks that could emerge over a longer time period.

This information was also subject to updating throughout the year, to add any other risks that had become more significant during recent months. This was done by analyzing a variety of external risk reports, and by taking into account the supervisory body's perspectives. In January 2024, the identification of material risks involved 338 key employees from companies across 24 countries where the Group operates.

This process also takes into account the results of the double materiality assessment, in order to identify environmental, social, and governance issues that are relevant for MAPFRE and for the stakeholders.

ESG risks and opportunities:

MAPFRE performs ongoing analysis of factors that have, or could have, an impact on our business if they materialize, in relation to our investment and underwriting activities. This analysis considers environmental, social and governance (ESG) factors, as these enable additional information to be gathered on social movements and transformations, and the expectations of stakeholders and the market that affect the organization.

Likewise, as a global insurance company, MAPFRE has an important role to play in helping society by identifying sustainable development opportunities for the insurance business and offering its customers products and services that further the transition to a low-carbon economy.

A proper analysis of ESG factors, and how they might affect the business in the short, medium and long term, will show their relationship to the company and possible inclusion in the list of risks drawn up by the company and in the adoption of prevention and mitigation measures.

To carry out this analysis, MAPFRE has developed an internal ESG evaluation model that assesses and quantifies the environmental, social, and governance impact of the activities carried out by a business group, considering the sector and the countries where it operates. This methodology has been implemented in the global risks business, in the business of Spain and Brazil, and in the facultative reinsurance business.

The model assigns a reputational risk level to the business group, which is linked to the level of authorization required to underwrite the operation. The approval of the Management Committee of each country or business unit may be required and, where appropriate, the additional authorization of the CEO. In this case, if the operation is authorized, with the corresponding mitigation measures, the Group Sustainability Office is informed and a plan of mitigation measures for said risk may be required.

The integration of ESG risks into other general and traditional risk categories occurs naturally within the management and control processes, utilizing the Risk Management System and a taxonomy that incorporates ESG-related risks. The Corporate Risk Division at MAPFRE prepares the Group's risk map annually to identify the material risks that may impact the different companies, based on responses to evaluation questionnaires. These questionnaires provide an overview of the probability of occurrence and the impact of risks, classified according to general risk categories, including climate change risks and other risks related to the environment, society, and governance.

Use of value chain mapping

MAPFRE evaluates the material impacts, risks, and opportunities associated with its value chain. This includes both the upstream and downstream phases of its value chain, encompassing the company's direct and indirect business relationships.

Information on the value chain is based on the results of the Double Materiality Assessment, focusing only on parts of the value chain where sustainability issues are relevant.

Inputs to the assessment

The assessment used the following inputs:

• Sector benchmarks (industry peer benchmark, CRO Forum's Mind the Sustainability Gap report, Financial Stability Report December 2022 by EIOPA)
• ESRS guidance (European Sustainability Reporting Standards complementing CSRD)
• Internal experts (sustainability supervisors across various MAPFRE units, 338 key employees from companies across 24 countries)
• External consultants (stakeholder consultation with 20,158 respondents)
• Stakeholder consultation (93.01% own personnel, 4.90% providers and distributors, 2.06% customers, 0.08% financial community, 0.01% bodies and institutions)
• Other frameworks (GRI and SASB standards, TCFD and CDP recommendations, ISO 50001 and ISO 14001, World Economic Forum Global Risk Report 2023, UN Directive on Corporate Sustainability Due Diligence proposal)
• Internal sources (MAPFRE risk matrix, sustainability plan, strategic plan, TCFD report 2023)

Scoring criteria

For impact materiality:

• Scale: rated from 1 to 5 based on stakeholder surveys, according to the perceived relevance of each issue
• Scope: rated from 1 to 5 based on geographical and population segments, according to the extent of the impacts
• Irremediable character (remediable nature): rated from 1 to 5 based on how effective the actions and measures the company could take to mitigate the impact are perceived to be
• Likelihood: The materiality of current impacts is measured solely in terms of severity, while the materiality of potential impacts is measured using both severity and probability. In the case of a negative and potential impact that is classified as having an impact on human rights, severity takes precedence over probability.

For financial materiality:

• Size of effect (financial effect): For risks, a scale of 1 to 5 was applied, aligned with the corporate risk assessment process, based on the effect on equity from the previous fiscal year. For opportunities, a scale of 1 to 5 was also used, but based on their effect at the income or cost level from the last fiscal year.
• Likelihood (probability): the degree of certainty that a potential impact will occur or that a current impact will be maintained

Threshold for materiality

For impact materiality: Once all impact materiality results were calculated, the arithmetic mean was determined, and all impacts with a materiality result above the average value were classified as material.

For financial materiality: Once the time horizons were defined, the arithmetic mean was calculated for each of the results obtained and those with a materiality result above the average value were classified as material.

Frequency and last review

The Double Materiality Assessment exercise is reviewed annually, and stakeholders are consulted every two years.

The methodology was refined in 2024 to ensure full compliance with both the EFRAG guidelines and the CSRD requirements.

The Sustainability Operating Committee and the Risk and Sustainability Committee annually validate the process and results. In 2024, both committees validated the new methodology.

This methodology and its results will be reviewed again in the first half of 2025.

MAPFRE Group maintains environmental commitments in its insurance and reinsurance underwriting business to contribute to the transition toward a low-carbon economy, reinforcing the commitment to be a net zero company by 2050.

MAPFRE faces significant risks due to climate change, especially in relation to natural disasters that may increase in frequency and severity, impacting claims and the resources needed for their management. To address these risks, specialized reports and control systems are used to manage exposure to catastrophic risks, determining maximum underwriting capacities per risk and event. In 2021, MAPFRE implemented the ExpoCat tool for georeferencing and controlling catastrophic exposures, improving information management and decision-making.

Additionally, the Group's reinsurer, MAPFRE RE, is responsible for placing reinsurance protections to mitigate catastrophic risks, ensuring that the Group can withstand losses without compromising its solvency.

These commitments are defined in the Underwriting Policy, approved by MAPFRE SA's Board of Directors, and are applicable to all insurance and reinsurance companies and in line with the corporate business strategy. MAPFRE has a Global Business Committee which meets monthly, and an Underwriting Policy Committee which meets each semester and is responsible for, among other things, the correct application of this policy, as well as to analyze and propose operating standards of exclusion for ESG matters.

MAPFRE implements its Sustainable Investment Policy from a dual approach: "a posteriori" to evaluate and adjust existing portfolios according to their ESG score, and "a priori" to integrate these criteria into the research of future investments.

MAPFRE has developed a Responsible Investment Framework that establishes rating thresholds, defines exclusion policies, and promotes shareholder participation, aligning its sustainable investment strategy with its long-term sustainability vision.

MAPFRE's Sustainability Plan (2024-2026) includes actions such as specific training for professionals, collaboration with universities, dissemination of content, and creation of products that incorporate ESG criteria.

In 2021, MAPFRE implemented the ExpoCat tool for georeferencing and controlling catastrophic exposures, improving information management and decision-making.

MAPFRE Group maintains environmental commitments in its insurance and reinsurance underwriting business to contribute to the transition toward a low-carbon economy, reinforcing the commitment to be a net zero company by 2050.

Energy consumption and mix (E1-7, formerly E1-5)

Total energy consumption and breakdown by source – 2024 and 2023

Mapfre reports energy consumption under the operational control approach. Data for the fourth quarter may be extrapolated in certain countries due to data gaps at the time of publication.

Fossil consumption breakdown: Mapfre does not break down fossil consumption by coal, crude oil/petroleum, natural gas, or other fossil sources, as it is not considered a high-impact climate sector under ESRS.

Nuclear sources: Energy consumption from fossil and nuclear sources is calculated based on generation technology, applying each technology's share in the national energy mix to Mapfre's electricity consumption.

Self-generated renewable energy: In 2024, Mapfre generated 3.10 GWh (3,146 MWh reported in table) of renewable energy through photovoltaic installations at buildings in Spain, Mexico, Italy, Peru, the Dominican Republic, and Malta. This self-consumption reduced GHG emissions by 651 tCO₂eq.

Energy intensity

Not disclosed for 2024. Mapfre is not classified as a high climate impact sector under ESRS, and energy intensity per revenue is not reported for operations.

Scope and methodology

• Scope: Operational control perimeter aligned with consolidated financial reporting. In 2024, Mapfre adjusted the operational control perimeter to include all parent companies, subsidiaries, and joint ventures with ≥51% ownership, adding entities such as Mapfre RE do Brasil, Reinsurance MGMT (US), Ireland Assist, Panama operations, and La Financière Responsable (FR), representing 1% of Group employees.
• Data quality: Energy consumption data for the fourth quarter may be extrapolated in certain countries due to data gaps at publication.
• Emission factors: Scope 1 and 2 emission factors sourced from DEFRA and International Energy Agency (IEA). GWP based on IPCC AR6 over a 100-year period.
• Renewable electricity certification: For EU power contracts (Spain, Portugal, Italy, Germany), Guarantees of Origin (GdOs) are used. For other countries, iRECs certify renewable sourcing. In 2024, 53% of purchased electricity was under GdOs, 29% under iRECs, and 19% without certification. At year-end, iREC certificates were purchased for Brazil, the USA, Mexico, Peru, Puerto Rico, and Turkey to cover total electricity consumption.

MAPFRE faces significant risks due to climate change, especially in relation to natural disasters that may increase in frequency and severity, impacting claims and the resources needed for their management.

Furthermore, the increase in climate risk could potentially introduce material uncertainty in the assumptions and lead to an inaccurate assessment of insurance risk.

Policies related to own workforce

As described in section "1.4.3.1. (MDR-P): Policies adopted to manage material sustainability issues" of this Sustainability Statement, MAPFRE has the following documents (related policies, frameworks, and standards) relating to own personnel to manage the material impacts, risks, and opportunities identified:

Code of Ethics and Conduct

• Scope: Applicable to all MAPFRE employees, executives, and members of the governing bodies, as well as those who work closely with the company (including temporary agency staff, providers, and contractors, among others)
• Governance: The Ethics Committee is responsible for investigating any potential noncompliance with the Code and determining the appropriate penalties
• Key content: Addresses respect and protection of human rights (section 4.2), including rejection of forced labor, compulsory labor, and child labor; rejection of discrimination; freedom of association and collective bargaining
• Public availability: Available for all stakeholders on the corporate website
• International standards: Aligned with UN International Bill of Human Rights, Global Compact Principles, OECD Guidelines, UN Women's Empowerment Principles, and ILO standards on labor rights
• Monitoring: The Ethics Committee recorded a total of 102 complaints/grievances in 2024, with established investigation and resolution procedures

Human Rights Policy

• Scope: Applicable to all MAPFRE employees, executives, and members of the governing bodies, as well as those who work closely with the company (including temporary agency staff, providers, and contractors, among others)
• Governance: Updated by the Board of Directors of MAPFRE S.A. on December 18, 2024; the Deputy General Management of Labor Relations oversees its development and implementation
• Key content: Establishes MAPFRE's commitment to respect fundamental rights; guides actions regarding rejection of discrimination, child and forced labor; respect for freedom to join a union and collective bargaining; includes procedures to identify and mitigate risks of human rights violations; guarantees right to freedom of opinion, information and expression; promotes safe and healthy working environment rejecting harassment and violent or offensive behavior
• Public availability: Available for all stakeholders on the corporate website; providers are informed at the time of approval and contracting
• International standards: Inspired by UN International Bill of Human Rights, UN Global Compact Principles, UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Companies, UN Women's Empowerment Principles, global standard of conduct for LGBTI people, ILO conventions and Declaration on Fundamental Principles and Rights at Work, Principles for Sustainable Insurance (PSI), UN Principles for Responsible Investment (PRI)
• Monitoring: In 2024, 14,457 Group employees participated in training courses on procedures related to the MAPFRE Human Rights Policy and the ten Principles of the Global Compact (59,991.25 hours); 47.25% of workforce completed training by year-end; external whistleblower channels available

Health, Well-being, and Occupational Risk Prevention Policy

• Scope: Applicable to all levels of the organization, from management to employees; covers 100% of workers (salaried and non-salaried) and all persons related to MAPFRE including providers, collaborators, customers, and visitors to facilities
• Governance: While no individual governing body is specified, the company's collective commitment is emphasized; the policy is approved by the Board of Directors
• Key content: Establishes organizational commitment to ensuring health and safety of workers; aims to create healthy and well-being-oriented work environment; seeks to enable employees to perform duties under best physical, psychological, and social conditions; goes beyond mere compliance with occupational risk prevention regulations; includes Global Healthy Company Management Model based on ISO 45001 standard
• Public availability: Available to all stakeholders on the corporate website
• International standards: References World Health Organization (WHO) principles on healthy workplaces and organizations
• Monitoring: Absenteeism ratio monitored (target: less than 3.2%; actual 2024: 3.26%); workplace accidents tracked (236 cases in 2024); severity index 0.18; frequency index 4.11; Healthy Company report prepared annually and presented to MAPFRE Risk and Sustainability Committee

Policy on Diversity and Equal Opportunities

• Scope: Applicable to all MAPFRE employees and collaborators; covers recruitment, promotions, professional development, training, and relationships with employees, clients, providers, and other stakeholders
• Governance: Approved by the Board of Directors of MAPFRE on July 23, 2015; management and team leaders are obliged to ensure compliance
• Key content: Promotes respect for individuality and elimination of discriminatory conduct; guarantees equal opportunities and fosters inclusive workplace culture; rejection of discrimination based on age, gender, marital status, nationality, culture, race or ethnicity, sexual orientation, gender identity and/or gender expression, beliefs, or any other physical or social condition; linked to Diversity, Inclusion, and Equity Strategy called "Inclusion for sustainable growth"
• Public availability: Policy publicly available; MAPFRE urges management and team leaders to apply these principles
• International standards: Equal Treatment in Employment Directive (2000/78/EC) - European Union; General Law on the Rights of Persons with Disabilities and their Social Inclusion; Law on the Effective Equality between Women and Men; Royal Decree 1026/2024
• Monitoring: Gender diversity in management positions tracked (target 34% women in 2024, 35% in 2025, 36% in 2026; actual 2023: 33.1%); awareness-raising actions including International Women's Days participation; health campaigns with gender perspective

Promotion, Selection, and Mobility Policy

• Scope: Applicable to all activities related to selection, promotion, and mobility of employees, at all levels of the organization and in all geographical areas where the Group operates
• Governance: Management and those responsible for managing teams within MAPFRE are responsible for implementation; prioritizes employees and team supervisors as target stakeholders
• Key content: Seeks to develop global talent within MAPFRE; offers internal growth opportunities to employees; ensures satisfaction and commitment; promotes employability through professional development, training, and mobility programs; key principles include equal opportunities, nondiscrimination, and transparency in selection, promotion, and mobility processes
• Monitoring: Functional mobility target for Core and Strategic countries: 15% increase in 2024 (reference: 16.06% in 2023); measured quarterly

Digital Disconnection Policy

• Scope: Not explicitly detailed in excerpts but mentioned as applicable to own personnel
• Key content: Implements policies for disconnection from work
• International standards: Not specified in excerpts

Corporate Security and Privacy Policy

• Scope: Covers entire MAPFRE Group
• Key content: Ensures adequate protection of information owned by MAPFRE and information belonging to customers, collaborators, employees, and other stakeholders; guarantees confidentiality, authenticity, privacy, availability and integrity of information and systems that store, transmit, or process it; supports data protection for employees
• Monitoring: Annual evaluation of Security Plans compliance; effectiveness of training and dissemination actions measured; number of potential incidents reported and their scope minimized; reported to Corporate Security, Crisis, and Resilience Committee

Remuneration Policy

• Scope: Applies globally to all employees
• Key content: Establishes appropriate and competitive remuneration in accordance with applicable benchmark indexes, according to function/job position, merit, and performance; based on applicable regulations while guaranteeing equality and nondiscrimination
• Monitoring: Gender pay gap monitored (CSRD methodology: 29.45%; adjusted gap in fixed remuneration: 1.3% average, 0.75% median)

Corporate Protocol for the Prevention and Treatment of Harassment at MAPFRE

• Scope: Applicable to employees and related parties
• Key content: Provides procedures for prevention and treatment of harassment; includes specific whistleblower channel for workplace or sexual harassment
• International standards: Law 2/2023 of February 20 regulating protection of persons reporting regulatory infractions; Directive 2019/1937 (Whistleblowing Directive); ILO Convention on harassment protocols
• Monitoring: In 2024, 28 complaints for harassment and 4 complaints regarding discrimination recorded; 20 dismissed, 10 disciplined, 2 under investigation

Institutional, Organizational and Business Principles

• Key content: Human rights protection expressly provided for in these principles
• Governance: Approved at highest level of organization

Taking action on material impacts on own workforce

Material impacts, risks and opportunities addressed

MAPFRE has defined actions to manage material impacts, risks and opportunities identified in relation to own personnel:

Positive Impacts (IP):

• S1-IP1: Improved quality of life for employees, protecting their health, safety, and well-being
• S1-IP2: Promotion of birth rate by supporting work-life balance in maternity or paternity situations
• S1-IP3: Contribution to quality remuneration in the regions where the company operates
• S1-IP4: Contribution to developing own talent capabilities
• S1-IP5: Contribution to the defense of human rights among own personnel
• S1-IP6: Protection of employee data privacy

Risks (R):

• S1-R1: Deficiencies in the company's performance due to inadequate personnel and organizational management, along with a shortage of talent for the required positions

Opportunities (O):

• S1-O1: Attracting diverse and multidisciplinary talent by promoting diversity in the workforce
• S1-O2: Reduction in employee turnover due to satisfaction with working conditions
• S1-O3: Increased attraction of talent due to the quality of job offers
• S1-O4: Improved productivity through the training of internal talent

Actions and linkage to IROs

The following table shows how actions link to the material impacts, risks and opportunities:

Scope

All actions address own workforce (own operations).

Key action details

Training and knowledge management

• Coverage: 100% of workforce trained in 2024
• Resources delivered: 1,059,282.85 hours of training
• Average hours: 34.62 hours per employee
• Investment: €323.71 average per employee
• Number of training actions: 7,613 training actions (in-person and/or online)
• Breakdown by gender:
  • Men: 487,161 hours (46%), 37.74 hours average
  • Women: 572,122 hours (54%), 33.82 hours average
• Technical and sales training: 74.75% of total training
• Specific programs:
  • 76 courses on prevention and anti-harassment procedures: 10,157 completed enrollments by 7,095 employees
  • 283 anti-corruption programs: 53,953 enrollments by 17,674 employees
  • Cybersecurity training "The Firewall Mindset": 21,535 employees completed by end 2024
  • Global Cybersecurity Program: 1,598 people (common module), 2,749 people (specific module)

Performance evaluation

• Participation: 25,223 employees (92% of workforce) in 2024
• Breakdown by job level and gender: See detailed table in source (Senior management through Associates)

Work-life balance initiatives

• Social benefits coverage (% of entitled employees):
  • Health Insurance: 94.9%
  • Pension plan and savings insurance: 64.9%
  • Life Insurance: 96.3%
  • Insurance bonuses: 69.7%
  • Long service bonus: 19.5%
  • School aid for children: 39.0%

Job integration and promotion of diversity

• Metrics tracked:
  • Senior talent satisfaction index
  • % of people with disabilities on the workforce
  • % Women in Management Positions

Remuneration analysis

• Approach: Appropriate and competitive remuneration based on applicable benchmark indexes, function/job position, merit and performance
• Principles: Guaranteeing equality and nondiscrimination
• Annual total compensation ratio: 53.39 (ratio between highest-paid person and median compensation)

Human Rights

• Complaints mechanism: Protocol for prevention and treatment of harassment
• 2024 incidents: 32 complaints (28 harassment, 4 discrimination)
  • 20 dismissed
  • 10 disciplined
  • 2 under investigation
• Serious incidents: No cases of forced labor, human trafficking or child labor recorded in 2024

Data protection

• Addressed through specific measures (detail not provided in excerpts)

Effectiveness monitoring

Quantification of progress on the actions is detailed in the "Targets and Metrics" section (S1-5), where metrics are defined for achieving the targets linked to these actions.

Link to policies

Actions are linked to MAPFRE's Code of Ethics and Conduct and related policies as described in section 4.1.2.1 Ethical Behavior, which provides guidance for everyone's behavior at MAPFRE.

Targets related to own workforce

Mapfre discloses the following targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities for own workforce:

Gender Equality Target

Target metric: Representation of women at management level

Target value: 36%

Target year: 2026

Baseline year: Not disclosed

Baseline value: Not disclosed

Scope: Own operations (management level)

Type: Absolute percentage target

Validation: Internal (referenced in Strategic Plan 2024-2026)

Progress: Not disclosed

Disability Inclusion Target

Target metric: Percentage of people with disabilities in the workforce

Target value: 3.5%

Target year: Not disclosed

Baseline year: Not disclosed

Baseline value: Not disclosed

Scope: Own workforce

Type: Absolute percentage target

Validation: Internal

Progress: Not disclosed

Related Qualitative Objectives

The document lists multiple qualitative objectives linked to material impacts, risks, and opportunities (IROs S1-IP1 through S1-O4), including:

• Avoid any type of occupational discrimination against people with disabilities
• Have leaders who commit to the development and well-being of their teams
• Promote an inclusive and sustainable workplace for people with disabilities
• Consolidate a safe, healthy, and well-being-oriented work environment
• Promote a favorable environment for childbirth
• Offer employees a Corporate Volunteering Program
• Offer Senior employees appropriate work environment

However, these qualitative objectives do not include specific quantified targets, baseline years, or target years.

*Executive board directors of Spanish companies

Collective bargaining coverage and social dialogue

Overview

Collective bargaining is an instrument for regulating the economic conditions, social benefits, and other working conditions of MAPFRE employees.

Since collective bargaining is not structured in the same way in all countries, MAPFRE does not have a global collective bargaining agreement applicable in several countries because the legal, social, or business type or sector conditions that allow it to be implemented do not exist.

Total employees covered: 18,712 employees covered by collective agreements in 10 countries.

Coverage by country

Coverage rate breakdown

*Turkey: 0% coverage
**Peru: 8% coverage

Collective bargaining agreements signed in 2024

Total agreements signed: 39 agreements with workers' legal representatives during 2024.

Main agreements:

• Spain: 4th Equality Plan, Trade Union Rights Agreement, and MAPFRE Insurance Group Telework Agreement
• Uruguay: Addendum to the Collective Bargaining Agreement
• Peru and Brazil: Respective Collective Bargaining Agreements
• Argentina: Salary agreements in the sector and updates to compensation for remote working expenses

European Works Council

MAPFRE has no representation of its salaried workers through a European Works Council.

Global workforce representation

MAPFRE's global workforce is represented by employees' legal representatives.

Diversity metrics

Gender split at top management

Leadership positions (management and expert management, and middle and expert managerial positions):

Board of Directors of MAPFRE S.A.:

• 7 women among its members, representing 46.7% at 31/12/2024

Distribution by job position level and gender:

Additional leadership metrics:

• 107 women hold senior management positions or positions on boards of directors
• 30.23% of employees in senior management positions are women
• 44.53% of those in junior management positions are women
• 43.57% of leadership positions in business areas are held by women
• 30.43% of STEM (Science, Technology, Engineering, Mathematics) positions are held by women

Age band distribution of total workforce

Total salaried workers by gender

*This information is not reported due to the fact that the company's records include the information relating to the gender that appears in the official personal identification of each employee.

People with disabilities

**Workforce data for BRASILSEG, Enalta, LFR and Insignia Life is excluded.

**The number of employees with disabilities in Germany and the United States is subject to legal restrictions. In the case of Germany, during the recruitment interview, the employer can only ask about a serious disability if it is impossible to do the job. In the United States, information on disability is provided by an external provider.

Additional diversity data (2024)

• 55.4% of new hires were women
• At close of 2024: 4% of people with disabilities in the company

Adequate wages

S1-10: Appropriate salaries

Remuneration, benefits and recognition

MAPFRE establishes appropriate and competitive remuneration in accordance with the applicable benchmark indexes, according to function/job position, merit, and performance. This remuneration is based on applicable regulations while guaranteeing equality and nondiscrimination.

Benchmark disclosed: The company references "applicable benchmark indexes" and "applicable regulations" but does not specify:

• Whether a living wage benchmark is used
• The name or source of any living wage assessment methodology
• What specific benchmark indexes are applied
• Coverage percentage of workforce assessed against living wage criteria
• Geographic scope of any living wage assessment

Benefits

MAPFRE offers employees social benefits as part of the "emotional salary" - products and services the company pays to ensure employee well-being. Benefits are offered to all employees regardless of contract type (permanent/temporary) or workday (full-time/part-time).

Social benefits and uptake rates:

• Health Insurance: 94.9% uptake
• Pension plan and savings insurance: 64.9% uptake
• Life Insurance: 96.3% uptake
• Insurance bonuses: 69.7% uptake
• Long service bonus: 19.5% uptake
• School aid for children: 39.0% uptake
• Newborn child allowance: 2.0% uptake
• Meal allowance: 95.3% uptake
• Loans: 14.3% uptake

Additional benefits include disability/incapacity coverage, employee education grants, aid for spouses and children with disabilities, Christmas gifts, awards, advances, and shareholding.

Objective-based model

MAPFRE has a global management by objectives model that aligns employees with strategic objectives, with 100% of workforce directed to objective-based management.

Living wage assessment: Not disclosed. The disclosure references compliance with "applicable regulations" and "benchmark indexes" but does not specify whether these constitute a living wage methodology or merely minimum wage/collective bargaining compliance.

Social protection

Coverage of social protection benefits

MAPFRE provides various social protection benefits to employees, covering major life events including sickness, disability, unemployment, parental leave, and retirement.

Employee benefits coverage (2024)

Additional social protection measures

Beyond the benefits listed above, MAPFRE provides:

• Life insurance: Coverage established in case of death, with an insured capital sum of 400,000
• Occupational illness insurance
• Disability/incapacity coverage
• Employee education grants
• Aid for spouses and children with disabilities
• Financial assistance: In 2024, financial assistance to employees for special situations (usually resulting from health problems) amounted to 483 thousand euros
• Retiree support: Financial assistance to retired employees totaled 1.3 million euros, of which 1,297,689 euros correspond to bonuses for retiree health insurance

Scheme type

MAPFRE operates both company-provided insurance schemes and promotes long-term savings plans to guarantee a supplement to retirement through various plans. The company encourages financial education for all employees and social protection systems.

Health and safety management coverage

100% of own workers are covered by an occupational health and safety management system based on the ISO 45001 standard.

The Health, Well-being, and Occupational Risk Prevention policy covers 100% of workers (salaried and non-salaried) and all persons related to MAPFRE including providers, collaborators, customers, and visitors to facilities.

Parental leave provisions

MAPFRE offers:

• Primary caregiver: Average of 115 days of paid parental leave by law + average of 14 days beyond the law
• Non-primary caregiver: Average of 28 days of paid parental leave by law + average of 5 days beyond the law
• Entitlement: 99.7% of employees entitled to maternity/paternity leave (99.4% men, 100% women)

Parental leave metrics (2024)

Additional family support measures

• Nursing support: 42.7% of women use nursing rooms in the workplace, and 88.5% avail of other special measures during the nursing period (special flexitime leave or reduced working hours)
• Paid leave for family care: 98.6% of employees have paid leave for family care in addition to parental leave. In 2024, 5.3% of men and 9.4% of women enjoyed these permits

Executive director provisions

Executive directors receive life and disability insurance, with contributions to defined benefit plans (including employee pension plans) amounting to 3.7 million euros in 2024 (2.9 million in 2023).

Persons with disabilities

Target

MAPFRE has committed to achieving 3.5% of employees being individuals with disabilities by 2024 and 2025.

2024 Performance

At the close of 2024, MAPFRE has 4.2% of people with disabilities in the company globally.

Breakdown by gender and legal restrictions:

*Workforce data for BRASILSEG, Enalta, LFR and Insignia Life is excluded.

**Countries with legal restrictions: The number of employees with disabilities in Germany and the United States is subject to legal restrictions. In the case of Germany, during the recruitment interview, the employer can only ask about a serious disability if it is impossible to do the job. In the United States, information on disability is provided by an external provider.

Methodology

The measurement formula used is the number of employees with disabilities divided by the total workforce. The information has been collected in accordance with the legal definitions of "people with disabilities" in force in the different countries in which MAPFRE operates. This indicator is not validated by an external body other than the verifier of this document.

2024 Integration activities

• 103 people with disabilities joined the workforce in 2024
• 3 people with disabilities completed internships at MAPFRE
• 11,970 employees from around the world have completed MAPFRE's Global Disability Program course, "Perspectives without labels" (cumulative since launch)
• 281 volunteering activities were carried out to improve the quality of life of people with disabilities
• Donations totaling 161,636 euros were made to centers that support the inclusion of people with disabilities in the workplace
• 144,920 euros allocated to special employment centers or companies with similar characteristics

Training and skills development metrics

Performance and career development review coverage

In 2024, a total of 25,223 employees participated in the performance evaluation process, representing 92% of the workforce.

Breakdown by gender and job position level (2024):

Training hours

Training was provided to 100% of the workforce in 2024, with a total of 1,059,282.85 training hours delivered, representing an average of 34.62 hours of training per employee.

Average training hours by gender and job position level (2024):

Overall average training hours per employee: 34.62 hours (2024)

Training investment

The company invested an average of 323.71 euros per employee (2024).

Total investment in training: 9,905,581€ (2024)

Multi-year training indicators

Training scope and delivery

• A total of 7,613 training actions (in-person and/or online) were carried out
• Technical and sales training represents 74.75% of total training provided
• 76 courses on prevention and anti-harassment procedures were implemented, with 10,157 completed enrollments by 7,095 employees
• 283 anti-corruption programs with 53,953 enrollments by 17,674 employees
• 271 employee training courses on occupational health and safety with 25,014 enrollments by 14,449 employees
• 14,457 Group employees participated in training courses on procedures related to the MAPFRE Human Rights Policy and the ten Principles of the Global Compact (59,991.25 hours), representing 47.25% of the workforce

Training attendance by position level and gender (Human Rights training)

Knowledge transfer evaluation

In 2024, 5,334 questionnaires were completed by employee supervisors, with 68% of responses indicating a rating of at least 4 out of 6 (high or very high level of transfer).

Health and safety metrics

Coverage of health and safety management system

100% of workers (salaried and non-salaried) are covered by the company's health and safety management system based on ISO 45001. This includes all persons related to MAPFRE and other groups such as providers, collaborators, customers, and visitors to facilities.

Fatalities

There have been no fatalities due to work-related injuries or health problems in 2024. (In 2023, 1 male employee fatality was recorded due to workplace accident.)

Work-related injuries and absenteeism

Note: Recordable occupational injuries are reported, not differentiating those cases with major consequences. Hours worked are theoretical hours. Commuting accidents are included. Days calculated on an average basis of 7.5 hours per day.

Injury and absenteeism rates

In 2024, 238,753 days lost due to absenteeism arising from non-occupational accidents and common illnesses, equivalent to 1,790,648 hours. The absenteeism ratio formula is the total number of days lost due to occupational accident, non-occupational accident, common illness, and occupational illness divided by the total number of theoretical days worked.

27,591 employees (91% of the workforce) are represented on Health and Safety Committees.

Work-life balance metrics

Work-life balance measures

Number of employees benefiting from work-life balance measures (2024):

Maternity and paternity leave entitlement and usage

MAPFRE offers an average of 115 days of paid parental leave (maternity/paternity) for the primary caregiver by law and an average of 14 days beyond the law. For non-primary caregivers, it offers an average of 28 days of paid parental leave (maternity/paternity) by law and an average of 5 days beyond the law.

2024 metrics:

Family care leave

98.6% of employees have paid leave for family care, in addition to parental leave, to offer more support to families with dependents who have physical or mental health problems that require additional care.

Usage rates (2024):

• Men: 5.3%
• Women: 9.4%

Nursing support measures

Worldwide:

• 42.7% of women use nursing rooms in the workplace
• 88.5% of women avail of other special measures during the nursing period, such as special flexitime leave or reduced working hours

Compensation metrics

Pay gap

MAPFRE discloses both an unadjusted and an adjusted gender pay gap for 2024.

Unadjusted gender pay gap (CSRD methodology):

The unadjusted gender pay gap, calculated according to the CSRD-required formula, amounts to 29.45%. This figure is based on total annual compensation (fixed salary plus target variable compensation) of all employees within the MAPFRE Group globally, taking into account reference annual working hours.

The formula used is:

Gender Pay Gap = ((Average gross remuneration per hour for male salaried workers – Average gross remuneration per hour for female salaried workers) / Average gross remuneration per hour for male salaried workers) × 100

MAPFRE notes that this unadjusted figure does not reflect the reality of the MAPFRE Group, as it does not account for factors such as different social and economic realities across countries, and the functions and responsibilities assigned by each position.

Adjusted gender pay gap (Equal Pay Gap methodology):

MAPFRE continues to apply the methodology for calculating the adjusted pay gap, verified by Ernst & Young (EY). This methodology considers various factors for creating comparison groups or clusters to provide more accurate compensation comparisons based on functions, responsibilities, business unit, and country.

The formula for the Equal Pay Gap is:

Equal Pay Gap = Σ (Gender Pay Gap in each cluster × Number of employees in the cluster) / Total number of employees analyzed

The group's overall adjusted gap for 2024 is:

MAPFRE is committed to maintaining its gender pay gap within +/-1%, applying the adjusted pay gap calculation methodology (equal pay gap), which was verified in 2018 by EY.

Remuneration ratio

The annual total compensation ratio is 53.39.

This ratio is calculated based on all MAPFRE employees globally, representing the relationship between the annual total compensation (fixed salary plus target short-term variable remuneration) of the highest-paid person and the median annual total compensation (fixed salary plus target variable remuneration) of all employees, using the annualized full-time equivalent salary, excluding the highest-paid person.

Methodology and scope

Scope exclusions: The compensation data for employees of BRASILSEG, Enalta, LFR, and Insignia Life is not considered for the calculation of the gender pay gap or the compensation ratio. This is either because MAPFRE does not have operational control over these companies or because the number of employees is too small relative to the total.

Validation: The adjusted pay gap methodology has been verified by the consulting firm Ernst & Young (EY).

Incidents, complaints and severe human rights impacts

In 2024, 32 complaints, grievances, or claims concerning harassment and discrimination were received. Of these, 28 complaints for harassment were recorded within the Group, and 4 complaints regarding discrimination have been processed through this procedure. All complaints have been evaluated, 20 have been dismissed, 10 have been disciplined and 2 are still under investigation.

Breakdown of complaints

Status of complaints

In the cases described, the procedures established in the Protocol for the prevention and treatment of harassment in MAPFRE have been followed as described in section "4.2.1. Ethical Behavior".

Severe human rights impacts

MAPFRE has not recorded any cases of serious incidents related to human rights, such as forced labor, human trafficking or child labor, among its personnel during this fiscal year. This absence of cases confirms our commitment to compliance with the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Business.

Fines, penalties and compensation

No penalties, fines or compensation for damages were recorded in 2024.

Consequently, no fines, penalties or compensation have been generated for damages and losses related to this type of incident, so there is no reconciliation to report between these amounts and the financial statements.

OECD National Contact Points

There is no record of claims presented through the OECD National Points of Contact for Multinational Companies.

In 2012, we adopted the Principles for Sustainable Insurance (PSI) promoted by the United Nations Environment Programme Finance Initiative (UNEPFI), committing to integrate environmental, social, and governance (ESG) issues into our decision-making for the underwriting processes of the Group's insurance operations.

MAPFRE has consistently and decidedly striven from the start to adopt the best corporate governance practices. MAPFRE's good governance practices are oriented toward creating sustained financial and social value over the long-term. The company's objective is to ensure financial stability and safeguard the interests of shareholders, maximizing the positive impact on society as a whole.

MAPFRE is governed by the Recast Text of the Spanish Companies Act and has a series of Institutional, Business and Organizational Principles in place that have been approved by the Board of Directors of MAPFRE S.A., which, together with its Bylaws, the Annual General Meeting's Regulations, and the Board of Directors' Regulations, define the structure, composition and functions of each of its governing bodies and make up the minimum mandatory compliance framework for all of the companies in the MAPFRE Group and their respective governing bodies. In addition, MAPFRE has a group of corporate policies and standards that complement its governance system.

Regarding the Spanish National Securities and Exchange Commission (CNMV) Good Governance Code of Listed Companies as of December 31, 2024, MAPFRE complies fully with 90.62% and fully or partially with 96.87% of the recommendations.

Incidents of corruption or bribery

Confirmed incidents, convictions and fines

During 2024, no convictions were recorded in relation to cases of corruption and bribery, and no fines were paid for violations of the anti-corruption and anti-bribery laws.

Since no convictions have been recorded or fines paid for violation of anti-corruption or anti-bribery laws, no activities have been required to address such violations in the anti-corruption and anti-bribery procedures and rules.

Investigation and speak-up mechanisms

MAPFRE has established multiple whistleblower channels to facilitate reporting of irregularities:

Internal Whistleblower System: Until December 18, 2024, MAPFRE operated an Internal Complaints System established under Directive (EU) 2019/1937, which guaranteed protection of whistleblowers and absence of retaliation. During fiscal year 2024, 96 communications were received through this system, of which 94 were not accepted for processing due to dealing with matters outside the scope of the channel, one was processed with corrective measures adopted, and one was in the processing phase.

Code of Ethics and Conduct Reporting Channel: In 2024, 102 complaints/grievances were recorded, of which 97 were not accepted for processing because they dealt with matters outside the remit of the Code of Ethics and Conduct (transferred to appropriate channels), one was processed with no violation found after investigation, and four required further information from whistleblowers.

Financial and Accounting Reporting Channel: During fiscal year 2024, 69 complaints/grievances were received, of which 68 were not accepted for processing by the Audit and Compliance Committee because they dealt with matters outside the financial and accounting scope (transferred to competent areas), and one required further information.

Workplace or Sexual Harassment Channel: A specific channel existed until December 2024 for reporting harassment incidents, governed by MAPFRE's Protocol on Harassment Prevention and Response.

Internal Reporting System: On December 18, 2024, the Board of Directors approved a new Internal Reporting System Policy and Reporting Management Procedure, which merged all previously existing channels into a single system. Since establishment, 6 communications were registered, of which 4 were not accepted for processing (transferred to appropriate bodies) and 2 were admitted and currently under investigation.

All channels guarantee confidentiality of whistleblowers and protection against retaliation. The Corporate Compliance Division, designated as head of the system, provides necessary resources and training for proper functioning.

Anti-corruption framework

MAPFRE maintains a zero-tolerance policy for corruption and bribery through:

• Anti-Corruption Policy (approved by Board of Directors, updated December 18, 2024)
• Criminal Risk Prevention Model (revised July 2023)
• Code of Ethics and Conduct
• Anti-money laundering and financing of terrorism regulations
• Fraud prevention measures

The Group Compliance Division analyzed 75 processes potentially associated with criminal risks and identified and reviewed 275 controls to prevent materialization of these risks.

Training

In 2024, 101,296.48 hours of anti-corruption and bribery training were completed, including prevention of money laundering and financing of terrorism, with 17,674 participants representing 57.76% of all MAPFRE employees. Training is provided at the time of hiring, available annually in the learning catalog, and adapted to regulatory changes.

In 2024, 100% of external directors had received training on anti-corruption and bribery by completing the specific program launched in 2022.

The Corporate Compliance Division acts as chair of the Criminal Risk Committee. No significant incidents or cases of legal non-compliance occurred during the 2024 fiscal year, nor were any sanctions imposed or fines paid in relation to criminal risk prevention.

Political influence and lobbying activities

Political engagement approach

In relation to governments and public-sector authorities, MAPFRE conducts its business activities in full compliance with the legislation in force in the countries where it operates, while also acting in accordance with the Group's Code of Ethics and Conduct, Anti-Corruption Policy, and Sustainability Policy.

Since 2019, MAPFRE has been enrolled in the European Union's Transparency Register (registration no. 97070533624840). The purpose of this system is to promote transparency, openness, and institutional trust during interactions with European institutions, while also offering the possibility of participating in the decision-making process for public policies. There is also an associated code of conduct, which means that MAPFRE's participation also reflects a commitment to specific ethical principles and forms of behavior during all of its work with EU institutions that is intended to represent the company's interests.

MAPFRE's priorities and actions related to public affairs are presented and discussed each year at meetings of the Group's Executive Committee, which is the body responsible for those activities in terms of reporting to its administration, management, and supervisory bodies. Development of the strategy applied to those matters requires the MAPFRE Group's International Affairs department to closely and continuously collaborate with many of the Group's other corporate departments, to ensure that the information presented to the Executive Committee is appropriate, robust, and in line with the established positioning.

In addition, each year the Executive Committee receives and improves a Global Institutional Presence Map. This is prepared by the Group Institutional Relations Division, and it contains information related to the associations, foundations, chambers of commerce, and other types of national and international institutions to which the MAPFRE Group belongs in the countries where it has a presence.

Ethical standards and guidelines

MAPFRE conducts its business activities in accordance with the Group's Code of Ethics and Conduct, Anti-Corruption Policy, and Sustainability Policy. In compliance with the Anti-Corruption Policy, no direct or indirect contributions were made in 2024 to any political parties.

All MAPFRE Group collaborations (including contributions made in the public interest, donations and/or those supporting events of exceptional public importance) took place in accordance with the Group's policy framework, with special attention to the rules and guidelines from the Code of Ethics and Conduct and MAPFRE's Institutional, Business, and Organizational Principles.

Political contributions

In compliance with the Anti-Corruption Policy, no direct or indirect contributions were made in 2024 to any political parties.

Financial contributions and lobbying expenditure

All contributions made by MAPFRE are financial, with no contributions made in kind.

Trade association memberships

In most cases, MAPFRE provides support for promotional activities, lobbying, representation of industry interests, and similar activities through the Group's membership in local and international commercial and industry associations, which also allows it to obtain a global, comprehensive view of the existing industry trends and regulatory frameworks. This approach also provides guidance on issues that affect the insurance industry and their associated impact, risks, and opportunities.

The expenditure associated with contributions from the mentioned industry and institutional organizations amounted to approximately €2.7 million in 2024, with the following standing out based on the amount of the contributions:

• The Geneva Association (contribution: €81,400)
• European CFO Forum (€36,364)
• Institute of International Finance –IIF (€40,500)

The total contributions made to chambers of commerce in different countries total €250,095.

Primary business and industry associations by country

SPAIN:

• Spanish Chamber of Commerce
• Spanish Confederation of Business Organizations (CEOE)
• Spanish Association of Insurers and Reinsurers (UNESPA)
• Foundation for Applied Economics Studies (FEDEA)
• Research Cooperative for Insurance and Pension Fund Companies (ICEA)
• Spanish Association of Collective Investment Vehicles and Pension Funds (INVERCO)
• Institute for Healthcare Development and Integration Foundation (IDIS)
• Association of Independent Workers (ATA)
• ClosingGap
• SERES Foundation
• Forética Sustainable Business Organization
• Spanish Confederation of Young Businessperson Associations (CEAJE)
• Ibero-American Business Council Alliance (CEAPI)
• Ibero-American Business Foundation (FIE)
• Brazil-Spain Chamber of Commerce
• American Chamber of Commerce in Spain
• Hispano-Turkish Chamber of Commerce

BRAZIL:

• National Federation of General Insurance (FENSEG)
• National Federation of Capitalization Companies (FENACAP)
• Official Spanish Chamber of Commerce in Brazil
• National Federation of Reinsurers (FENABER)
• National Federation of Private Pension Fund and Life Insurance Companies (FENAPREVI)

USA:

• American Property Casualty Insurance Association
• Massachusetts Insurance Federation, Inc.
• Spain-U.S. Chamber of Commerce

MEXICO:

• Mexican Association of Insurance Institutions (AMIS)
• Spanish Chamber of Commerce, A.C.

PERU:

• Official Chamber of Commerce of Peru

PUERTO RICO:

• Puerto Rico Association of Insurance Companies
• Spanish Chamber of Commerce in Puerto Rico

GERMANY:

• German Insurance Association (GDV)
• German Chamber of Commerce and Industry

MAPFRE RE:

• International Underwriters Association
• National Federation of Reinsurers (FENABER)

MAPFRE GLOBAL RISKS:

• International Union of Aerospace Insurers (IUAI)
• Latin American Association of Maritime Underwriters (ALSUM)
• International Engineering Insurers Association (IMIA)
• International Union of Marine Insurance (IUMI)

Focus areas and advocacy topics

In 2024, the main topics of interest that these industry organizations focused their work on, listed here in order of importance, were:

1. Competitiveness and CMU – €658,318
2. Digital and cyber – €394,991
3. Prudential – €263,327

MAPFRE's institutional activities are connected to material impacts, risks, and opportunities including:

• Contribution to adapting society to climate change through product creation, inclusion of coverage or adaptation of underwriting rules associated with climate change risks
• Occurrence of events with acute physical risks of climate change that could interrupt the company's value chain
• Occurrence of chronic and acute physical risks of climate change that lead to an increase in the loss ratio
• Occurrence of climate change transition risks that result in a decrease in revenue from current operations

Key objectives include:

1. Promote a competitive and unobstructed natural disaster insurance market
2. Promote the value of insurance solutions in relation to ESG matters
3. Support and advocate for greater climate protection through public policies

Details of the payments made by the Group's fully consolidated Spanish companies to providers in the financial years 2024 and 2023 are provided in the following tables.

Information regarding invoices paid in a period of time less than the maximum established in the late payment regulation is shown in the accompanying table.