Mapfre

Reference: pages 207-213.

The Board of Directors of MAPFRE, S.A. is the Company's primary decision-making and oversight body; day-to-day management sits with the Steering Committee, a delegate body holding all Board powers except those reserved by law or the bylaws. The Board is supported by three consultative, non-executive committees: the Audit Committee, the Appointments and Remuneration Committee, and the Risk, Sustainability and Compliance Committee, which reviews sustainability matters and reports to the Board ahead of report approval. As of 31 December 2025 the Board had 15 members, spanning Spanish, Brazilian and Italian nationalities, with knowledge across senior management, international business and other fields. If proposals to the Annual General Meeting on 13 March 2026 are approved, the governing bodies' composition would change further; the Board also resolved changes to Steering Committee membership effective 1 January 2026, including the appointment of Raul Costilla Prieto.

Reference: pages 214-216.

The Corporate Sustainability Office informs the administrative, management and supervisory bodies of material impacts, risks and opportunities on a quarterly basis, including updates on due diligence and the effectiveness of policies, actions, parameters and goals. In 2025 the Risk, Sustainability and Compliance Committee and other relevant committees approved a new Double Materiality methodology, and the Board approves the Group's Strategic Plan (which includes sustainability indicators) and is informed quarterly on its monitoring. The report sets out, per material topic, the actual and potential impacts, risks and opportunities managed by governing bodies: for Climate Change these include two positive impacts, two negative impacts, two risks (transition and physical) and two opportunities; Own Workforce records four positive impacts and one opportunity with no material negative impacts or risks identified; Workers in the Value Chain, Consumers and End Users, and Business Conduct are set out similarly (page 214-216).

Reference: pages 216-218.

Executive directors' medium- and long-term variable remuneration is delivered through overlapping multi-year incentive plans (the 2022-2026 and 2025-2029 plans), which include ESG objectives weighted at 15% of variable remuneration across each cycle. The 2025-2027 cycle's ESG objectives cover carbon neutrality of the operational footprint, the percentage of employees with disabilities (3.5% in 2025), the adjusted gender pay gap in fixed remuneration, ESG-approved preferred network providers, the share of the global investment portfolio rated using ESG criteria, and Mapfre's score in sustainability indexes; the 2024-2026 cycle separately targeted a 25% reduction in operational carbon footprint by 2027 against a 2022 baseline. Total 2025 director remuneration was 18,405 thousand euros (17 directors: 8 women, 9 men), and the average total remuneration by gender is also disclosed.

Reference: pages 219-221.

Mapfre's due diligence approach, based on the OECD Guidelines for Multinational Enterprises, addresses negative impacts on workers, consumers, the environment, human rights and business conduct through four stages: establishing commitments and designing preventive actions; defining and implementing action plans; verification and evaluation; and adoption of corrective measures. Remediation follows three levels of participation - causal, contribution and link relationships - depending on Mapfre's proximity to the adverse impact. Internal systems supporting due diligence include an impact self-assessment guide developed with the Global Compact Spanish Network, the materiality survey, an ESG analysis report in underwriting and investment, RepRisk monitoring, and ESG-based provider approval. A table maps each of the five key due-diligence elements (governance integration, stakeholder collaboration, impact identification, adverse-incident response, and effectiveness monitoring) to the specific sustainability statement sections where it is addressed.

Reference: page 222.

Mapfre has begun implementing an internal control system over sustainability information (ICSSI), aimed at reasonable assurance on the reliability of sustainability data, covering existence and occurrence, completeness, regulatory compliance, presentation and disclosure, and comparability. The ICSSI operates under the three-lines-of-defense model and defines preventive controls (segregation of duties, authorisations, training, access controls), detective controls (reviews, reconciliations, data analysis, audits) and corrective controls, with a risk-and-control assessment methodology and an ICSSI assessment questionnaire. Implementation is progressive: in 2025 the system was communicated to all reporting entities, and evaluation of controls begins in 2026, starting with the main markets. The Audit Committee periodically oversees ICSSI effectiveness and the report preparation process, reporting to the Risk, Sustainability and Compliance Committee, which in turn informs the Board before approval.

Reference: pages 223-231.

Mapfre is a multinational insurance, reinsurance and financial services group present in 37 countries, doing business in more than 100, through 4,488 direct and delegate offices, 6,234 bancassurance offices and 84,794 intermediaries, organised into four business units (Insurance, Reinsurance, Global Risks, Assistance-MAWDY) and three regional areas (Iberia, International, North America). Its own workforce comprised 30,846 employees at year-end 2025. The value chain runs from roughly 12,396 upstream support providers, through Mapfre's own operations, to distributors (agents, brokers, collaborators) and approximately 131,992 downstream business providers; Mapfre applies the ESRS 1 paragraph 10.2 phase-in for value-chain data. The Strategic Plan 2024-2026 rests on four pillars - Growth and Profitability, Efficiency and Productivity, Transformation and Culture, and Sustainability - targeting average growth above 6%, ROE of 11-12%, and a combined ratio of 94-95%.

Reference: pages 235-237.

Mapfre's main stakeholder groups are individual and collective customers, service and support providers, distributors (agents, brokers, delegates), the financial community (investors, shareholders, analysts), its own workforce, bodies and institutions (regulators, industry peers), and society. For each group the report sets out how Mapfre commits, the purpose of engagement, and how it responds - for example NPS and satisfaction surveys and social-media monitoring for customers, listening and participation groups and eNPS questionnaires for employees, quarterly results presentations for investors, and site visits and query channels for providers. Stakeholder interests feed into strategy through the due diligence process and the Double Materiality Assessment described under IRO-1, which evaluates both Mapfre's impact on stakeholders and external sustainability factors affecting the company; value chain workers' feedback is captured indirectly through provider and customer engagement mechanisms rather than direct participation in strategy-setting.

Reference: pages 237-240.

Following the 2025 Double Materiality Assessment, the standards deemed material for Mapfre are E1 (Climate Change), S1 (Own Workforce), S2 (Workers in the Value Chain), S4 (Consumers and End Users) and G1 (Business Conduct); environmental issues other than climate change did not emerge as material. In total, 31 material impacts, risks and opportunities were identified, down from 53 in 2024, reflecting a more focused review process. Material impacts are generally linked to a short-term horizon, except climate change and specific Human Rights, discrimination/harassment and social-inclusion impacts mapped to a medium-term horizon. No significant financial effects from the identified risks materialised in 2025 beyond catastrophic events, and no significant financial impacts from opportunities were recorded during the year. The Double Materiality Assessment found no company-specific (entity-specific) material impacts, risks or opportunities outside the ESRS-defined topics.

Reference: pages 240-247.

Mapfre's Double Materiality exercise is led by Corporate Sustainability, validated by the Sustainability Operating Committee and relayed to the Risk, Sustainability and Compliance Committee, and follows ESRS 1, EFRAG IG 1 guidance and sector benchmarking. It comprises four phases: defining stakeholders and listening channels; impact materiality assessment (severity - scale, scope, remediability - and probability, scored 1-5 and 0.1-0.9, against a threshold set at the average score); financial materiality assessment of risks and opportunities (financial effect and probability, scored 1-5 and 0-5); and derivation, integration and linkage of results to the corporate risk map and Strategic Plan. In 2025, 430 key employees from companies in 25 countries participated in risk identification. Climate-related IRO identification is detailed further under E1's IRO-1 subsection (2.2.2.2), using the GHG Protocol, PCAF and IPCC/NGFS scenarios; see also E1-2 (2025 ESRS numbering) for climate-specific risk identification and scenario analysis.

Reference: pages 247-256.

The ESRS content index lists, by chapter and standard, which disclosure requirements Mapfre has implemented and their home page in the 2025 Sustainability Statement: ESRS 2 general disclosures (BP-1/BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1/IRO-2/MDR) from pages 202-247; E1 Climate Change (SBM-3, E1-1 through E1-8) from page 277; S1 Own Workforce (SBM-3, S1-1 to S1-6 and S1-8 to S1-17) from page 321; S2 Workers in the Value Chain (SBM-3, S2-1 to S2-5) from page 377; S4 Consumers and End Users (SBM-3, S4-1 to S4-5) from page 388; and G1 Business Conduct (IRO-1, G1-1 to G1-6, MDR) from page 407. Appendix I (page 433) cross-references the data points derived from other EU legislation included in Appendix B of ESRS 2, and Appendix II links Law 11/2018 requirements to the CSRD/ESRS structure.

Reference: pages 273-274.

Mapfre's Climate Transition Plan (CTP) is structured around four pillars - own operations, investment, underwriting and the value chain - developed through decarbonisation targets aligned with the 2030 Agenda and the Paris Agreement, with an aspirational goal of net-zero emissions by 2050. The Board of Directors approves the CTP annually, following review by the Risk, Sustainability and Compliance Committee and the Sustainability Operating Committee; the 2025 edition is scheduled for Board approval together with this report in February 2026. The Board addressed sustainability and climate matters on 16 occasions in 2025, and the Risk, Sustainability and Compliance Committee met seven times to review regulatory developments and Sustainability Plan progress. Mapfre states that the CapEx-plan requirement under Delegated Regulation (EU) 2021/2178 does not apply to it as a financial institution.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (climate) and E1 SBM-3, where this content is disclosed in the FY2025 report (pages 277-284). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Mapfre classifies material climate risks as physical (increased natural catastrophes) or transition (lack of adaptation to a low-GHG economy), identified through the Double Materiality Assessment (page 277). For physical risk, methodology draws on IPCC/NGFS scenarios, RCP 2.6/4.5/8.5 combined with SSP pathways, the STORM project (wind, RCP8.5, 2050) and AQUEDUCT (flooding, RCP8.5, 1-in-250-year return period), plus INFORM Climate Change (RCP45-SSP2, RCP85-SSP5, 2050 and 2080) (pages 279, 281-282). For transition risk, Mapfre applies a "late transition" NGFS scenario via the EIOPA 2022 stress test and the "Fit for 55" framework (EBA, EIOPA, ESMA, ECB), simulating abrupt 2030 policy implementation (pages 279, 283). Analysis covers insurance, real estate and investment portfolios plus operational resilience, with physical-risk horizons to 2080; explicit temperature projections per scenario are not given, and results draw on the 2024 ORSA rather than a refreshed 2025 exercise (page 280).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (climate), where this content is disclosed in the FY2025 report (pages 277-280). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Applying the 2024 ORSA climate scenarios, Mapfre's own funds remain within its risk appetite over the three-year planning horizon. Physical-risk results vary by portfolio: drought in Brazil and tropical storms in the US, Mexico, Puerto Rico and the Dominican Republic are the most material perils for the non-life liabilities portfolio; less than 3% of the European real estate portfolio's market value is exposed; and the life and burial insurance portfolio's exposure to extreme-temperature mortality is assessed as immaterial. Transition-risk scenarios (EIOPA, based on NGFS) point to a negative impact on eligible own funds from asset revaluation. Mapfre states plainly that available climate scenarios are "difficult to translate into short-term...implications" and that uncertainty increases with the time horizon (page 280). Capacity to adapt includes maintaining access to competitively priced financing, reallocating or divesting assets, adjusting products and services, and workforce reskilling (page 280).

Reference: pages 284-285.

Mapfre's climate policies span adaptation and mitigation of climate change, energy efficiency and deployment of renewable energy, implemented through the Sustainability Policy, Environmental Policy, Investment Policy, Sustainability Risk Integration Policy, Responsible Investment Framework, Underwriting Policy and Sustainable Underwriting Framework. The Responsible Investment Framework directs capital toward sustainable sectors and clean energy while limiting exposure to carbon-intensive industries, and the Sustainable Underwriting Framework integrates sustainability criteria into product design to encourage customers toward energy-efficient and sustainable practices. Energy efficiency and renewable-energy deployment specifically are governed by the Environmental Policy. These policies apply across both Mapfre's own operations and its underwriting and investment activities, and are cross-referenced to the MDR-P table of policies adopted to manage material sustainability matters (page 284).

Reference: pages 292-299.

Mapfre's 2025 climate actions span four levers: underwriting (sustainable-product development, customer engagement, compliance with underwriting commitments, and expanding the geographies assessed under the ESG methodology); investment (new sustainable investment products, ESG methodology reviews, engagement and voting activities); value chain (a provider qualification model rolled out across 11 countries including Germany, Brazil, Spain and Mexico); and direct emissions reduction through named Scope 1 (fuels/fleets), Scope 2 (electricity) and Scope 3 (mobility, investment, underwriting) decarbonisation levers. Actions are explicitly mapped against the eight climate IRO codes (E1-IP1, E1-IP2, E1-IN1, E1-IN2, E1-R1, E1-R2, E1-O1, E1-O4), though the two climate risks currently lack a specific mitigation goal. Sustainable-product development is implemented "using existing resources within day-to-day operations, with no specific financing allocation" (page 294).

Reference: pages 285-292.

Mapfre's internal-operations targets, set against a 2022 baseline, are a 62% reduction in Scope 1+2 (market-based) by 2030 (53% by 2026), a 12.5% Scope 3 (operational) reduction by 2030 (6% by 2026), and a 30% total carbon footprint reduction by 2030 (23% by 2026); 2025 short-term targets were raised in-year to a 21% reduction after 2024 outperformed its 10% target by 15 points. Investment-portfolio targets cut Scope 1+2 GHG intensity by 43% by 2030 (20% by 2026) against a 2022 baseline, aligned with the Net-Zero Asset Owner Alliance's Target Setting Protocol. Underwriting targets cut motor-portfolio emissions 14% and global-risks-portfolio emissions 20% by 2030 (2022 baseline). Methodology follows the SBTi framework using the IEA Net Zero 2050 scenario for operations, and NZAOA/IPCC 1.5C pathways for investments; targets are not externally validated (pages 285-292).

Reference: pages 305-306.

Mapfre's total energy consumption was 111,743 MWh in 2025 (up from 106,908 MWh in 2024), of which 65,088 MWh (59%) came from renewable sources, 44,698 MWh (41%) from fossil sources, and 212.7 MWh (0.19%) from non-fuel nuclear sources. Fossil-source consumption is not broken down by the AR 34 categories, as Mapfre determined its activities fall outside the high-climate-impact sectors to which that requirement applies. Self-generated renewable energy (mainly rooftop photovoltaic installations across headquarters buildings in Spain, Mexico, the Dominican Republic, Italy, Peru, Malta, Portugal and Panama) totalled 3,472 MWh, avoiding 791 tCO2eq of emissions. Mapfre targets 100% renewable electricity across all countries by 2030, with electricity from renewable sources already secured in 19 countries and a country-by-country roadmap for the remainder through 2030.

Reference: pages 306-316.

Gross Scope 1 emissions were 10,725 tCO2eq in 2025 (up 5.23% year-on-year, against a 12,003 tCO2eq 2022 baseline); gross Scope 3 emissions totalled 3,223,163 tCO2eq (down 3.73%). Total GHG emissions were 3,289,672 tCO2eq location-based (down 3.74%) and 3,277,202 tCO2eq market-based (down 3.77%). The Group adjusted its operational control perimeter in 2025 to match the consolidated financial reporting boundary (51%-plus ownership), adding Hospital General M.D.S. (Panama, 92 employees, 0.3% of workforce) to the carbon inventory. Scope 3 category 15 (investments) is included, and Mapfre has begun quantifying underwriting-portfolio emissions for the Auto and Global Risks lines. The GHG gases covered are CO2, CH4, N2O, HFC, PFC, SF6 and NF3; biogenic emissions are not material to Mapfre's activities and are not included in any scope.

Reference: pages 316-319.

In 2025 Mapfre approved a Corporate Natural Capital Framework aligned with the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy and TNFD recommendations, complementing the 2021 Corporate GHG Emissions Offsetting Strategy that targets carbon neutrality by 2030 for own operations. Non-reduced emissions across Scope 1, 2 and Scope 3 categories 1, 5, 6 and 7 have been offset since 2021 in Spain and Portugal, expanded from 2024 to Germany, Brazil, the US, Italy, Mexico, Peru, Puerto Rico and Turkey, with Colombia, Malta and Panama added in 2025. Compensation projects prioritise nature-based solutions - reforestation, avoided deforestation, regenerative agriculture, ecological restoration and renewable energy - including the Agreena Carbon Project (Germany, 73.5 tCO2eq in 2025, up 226.67% year-on-year) and the Envira Amazonia Project (Brazil, 676 tCO2eq), aligned with the Oxford Principles 2024. The strategy is reviewed at least every three years.

Reference: pages 319-320.

Mapfre introduced an internal carbon pricing system in 2019, set at 9 euros per tonne of CO2eq for 2025 (including a 10% reversal buffer for non-registered projects), applied uniformly across the Group to internalise the social and environmental cost of emissions and support the 2021, 2024 and 2030 neutrality commitments. In 2025 the price covered 9,347 tCO2eq of Scope 1 emissions (87.15% of Group Scope 1), 21.27 tCO2eq of Scope 2 (1.23%), and 32,407 tCO2eq of Scope 3 categories 1, 5, 6 and 7 (77.92% of those quantified categories); investment- and underwriting-portfolio emissions are not yet covered. A revised internal-carbon-price calculation methodology, incorporating scientific guidance on the future evolution of carbon pricing, was approved in 2025 and becomes effective in 2026.

Reference: pages 322-324.

Mapfre's own-workforce policies comprise the Code of Ethics and Conduct, the Protection and Safeguarding of Human Rights Policy, the Promotion, Selection and Mobility Policy, the Diversity and Equal Opportunity Policy, the Health, Well-being and Occupational Risk Prevention Policy, the Corporate Security and Privacy Policy, the Digital Disconnection Policy, the Workforce Remuneration Policy and the Institutional and Business Principles. In 2025, 20,768 employees participated in human-rights training (69,852.8 hours), with 67.3% of the workforce having completed a training action by year-end. The Global Healthy Company Management Model (ISO 45001-based, approved 2022) covers 100% of salaried and non-salaried workers. Mapfre's Diversity, Inclusion and Equity Strategy 2025-2027 targets 40% women in positions of responsibility (36% in management) and 3.5% employees with disabilities, alongside a Digital Disconnection Policy regulating out-of-hours communications.

Reference: pages 325-327.

Mapfre operates a continuous employee-journey listening model combining listening and participation groups (young employees, senior profiles, expatriates, new hires), transactional eNPS questionnaires, and an annual recommendation, satisfaction and commitment survey (99.6% employee coverage) that in 2025 also incorporated a culture diagnosis. Key indicators include a Relational eNPS with 84% of employees in countries scoring "very good or excellent," a 69% Employee Satisfaction Index, a 64% Leader Index, and a 7.8/10 Culture Index. Beyond these channels, 52% of the workforce is represented by legal worker representatives (ranging 50-100% in Argentina, Germany, Brazil, Spain, Italy, Malta, Tunisia, Uruguay and Venezuela), engaged through parity committees, periodic meetings and dedicated communication channels; Mapfre has no European Works Council.

Reference: pages 327-328.

Employees can raise concerns through the channels described under G1-1 Ethical Conduct, plus the Corporate Protocol for the Prevention and Treatment of Harassment, a global mechanism accessible via the corporate intranet (and to third parties via the website) that requires initial whistleblower contact within five working days and allows resolution by mediation where appropriate. Where harassment is confirmed, Human Resources may implement psychological, medical and social support, working-condition adjustments, retraining, or other measures. Human Resources inboxes handle other labour-related grievances. The Policy on the Protection and Safeguarding of Human Rights, the Code of Ethics and Conduct, and the Harassment Protocol explicitly extend protection to legal workers' representatives, and employee satisfaction with these channels is tracked through the surveys described under S1-2.

Reference: pages 328-340.

Mapfre maps its own-workforce IROs (human rights promotion, quality of life/health/safety, quality remuneration, talent development, data privacy, labour inclusion, and a talent-attraction opportunity) to actions spanning occupational well-being programmes, human-rights policies extended to non-salaried staff, performance-evaluation and training processes, and remuneration reviews. Fifteen sub-actions are detailed across the chapter, including the Healthy Company strategy (ISO 45001-based) targeting mental and cardiovascular health, the Diversity, Inclusion and Equity Strategy 2025-2027, gender-pay-gap monitoring, and individual development plans. No material negative impacts or risks on own workforce were identified in the 2025 Double Materiality Assessment; four positive impacts and one opportunity (talent attraction and retention) were identified instead, and no operations were found to present a significant risk of forced or child labour.

Reference: pages 340-349.

Mapfre's own-workforce objectives, linked to seven IRO codes, include: 40% women in positions of responsibility and 36% women in management by 2026 (35.4% and 43.1% achieved in 2025, up from 34.5% and 42.7% in 2024); a 3.5% workforce disability rate; gender pay equity; individual development plans; identified successors for management-adjacent roles; reduced vacancy-fill times; and increased intern numbers. Progress is monitored quarterly. The report also references a workplace strategy consolidating a safe, healthy and well-being-oriented environment, and targets to promote an inclusive workplace for people with disabilities and to make Senior employees (over 50) highly satisfied, each tracked through the ESI, disability-representation and gender-diversity metrics described in the corresponding parameter sections.

Reference: pages 349-358.

Mapfre's own workforce totalled 30,846 salaried employees at 31 December 2025 (30,585 in 2024): 13,837 men and 17,009 women, with gender for a residual number of employees not reported because company records capture only the gender shown on official identification documents by country. The largest country populations are Spain (11,632), Brazil (4,375), Mexico (2,237), the United States (1,894) and Peru (1,444), with a further breakdown across 15-plus countries including the Dominican Republic, Colombia, Argentina, Italy, Germany, Turkey, Puerto Rico, Panama, Portugal, Chile and Malta. Workforce data is also broken down by contract type and full-time/part-time status elsewhere in the section, consistent with the ESRS requirement to disaggregate by gender, country and employment characteristics.

Reference: page 359.

Mapfre has no single global collective bargaining agreement, given differing legal and sectoral conditions across countries, but 18,802 employees are covered by collective agreements across 10 countries, with coverage ranging from 79% (Argentina) to 100% (Brazil, Portugal, Italy, Uruguay, Venezuela, Tunisia) and 88% in Malta and 99% in Spain. In the European Economic Area, workplace representation reaches 80-100% in Germany, Spain and Malta, while non-EEA coverage is concentrated in Brazil, Tunisia, Uruguay and Venezuela (80-100%) and Argentina and Italy (60-79%); most non-EEA countries show 0% collective bargaining coverage under the ESRS methodology. During 2025, 456 agreements were signed with workers' representatives, including union-election agreements in Spain and wage agreements in Argentina and Brazil; Mapfre has no European Works Council.

Reference: page 360.

By job-position level and gender in 2025, senior management and expert managers comprised 1,174 men and 632 women, middle management and experts 3,320 men and 2,772 women, advisors 6,598 men and 8,041 women, and associates 2,745 men and 5,564 women. By age, 15.5% of the 30,846-strong workforce is under 30, 53.4% is between 30 and 50, and 31.0% is over 50 (up from 29.7% in 2024). Diversity metrics are complemented by the Senior talent satisfaction index (based on annual surveys of employees over 50), the percentage of employees with disabilities, and the percentage of women in management positions, none of which are validated by an external body beyond the assurance provider.

Reference: pages 360-362.

Mapfre monitors wage adequacy primarily through the gender pay gap described under S1-16, alongside a broad benefits package ("emotional salary") available regardless of contract type or working hours: 95.3% of eligible employees use health insurance, 97.8% life insurance, 68.7% insurance bonuses, and 65.5% pension/savings insurance, with further benefits for disability, education, family support and loans. A global management-by-objectives model directs 100% of the workforce to objective-based performance management. In Spain, a voluntary flexible share-purchase plan attracted 2,321 applicants (22.0% of the Spanish workforce) for 2026, and the 4th Equality Plan (affecting 10,991 workers since 2023) sets out measures on access to employment, training, remuneration and work-life balance.

Reference: pages 369-371.

Mapfre's Global Healthy Company Management Model (ISO 45001-based) prioritises mental health and cardiovascular health for 2025-2027, supported by psychosocial risk assessments, psychological assistance, stress-management training and Health and Safety Committees covering 28,423 employees (92.0% of the workforce); 28 countries have procedures to investigate work-related injuries, illnesses and incidents. Financial-protection measures include employee savings/pension plans and ad hoc financial assistance, which totalled 423,472 euros for active employees facing health-related hardship and 1.5 million euros for retirees, mainly for health-insurance subsidies. Work-life balance benefits recorded include flexible schedules (19,689 employees), teleworking (20,717), paid leave (14,300) and reduced workdays (1,637), each tracked with 2024 comparatives.

Reference: page 371.

The percentage of employees with disabilities remained stable at 4.2% at year-end 2025, unchanged from 2024, calculated as the ratio of employees with disabilities to total workforce using each country's legal definition of disability. The indicator, intended to measure the impact of the Diversity Policy and disability-integration measures, is not validated by an external body other than the report's assurance provider. A gender breakdown of the disability metric is provided in the S1-5 targets section rather than repeated here.

Reference: pages 372-373.

In 2025, 24,961 employees (91% of the workforce) participated in periodic performance and professional-development evaluations, up sharply from 2024 in both absolute and percentage terms across job levels: senior management and expert managers saw participation of 1,105 men (9.8%) and 586 women (4.3%), versus 1,098 men (4.4%) and 561 women (2.2%) in 2024, with middle management and experts, advisors and associates broken down similarly. The metrics track the proportion of the workforce receiving structured feedback on objectives and development needs by gender and hierarchical level, supporting the talent-development actions described under S1-4.

Reference: pages 373-374.

All employees are covered by Mapfre's health and safety management system. In 2025 there were 245 recordable workplace accidents (111 men, 134 women), mainly commuting accidents, falls and blows, one occupational illness, and no work-related fatalities. Non-occupational-accident and common-illness absenteeism totalled 235,211 lost workdays (1,764,083 hours), with a severity index of 0.18 (0.16 men, 0.19 women) and a frequency index of 3.97 (4.04 men, 3.91 women). The 2025 health-related absenteeism ratio was 3.0, beating the 3.2 target set for the year (2026 target: not to exceed 3.2). Three-year comparatives (2023-2025) are provided for accidents, illnesses and lost workdays.

Reference: pages 374-376.

Worldwide, 62.3% of women use nursing rooms and 84.6% use other nursing-period measures; 97.1% of employees have access to paid family-care leave, taken by 12.2% of men and 16.5% of women in 2025. Of 831 employees who took maternity/paternity leave, 97.1% of men and 89.2% of women returned to work (92.4% overall), and 90.4% of men and 88.0% of women remained employed 12 months later (88.9% retention overall); 99.7% of the 30,846-strong workforce is entitled to maternity/paternity leave. Mapfre offers an average of 119 days of paid leave for primary caregivers (10 days beyond legal minimums) and 29 days for non-primary caregivers (3 days beyond legal minimums).

Reference: pages 375-376.

Applying the CSRD methodology (a weighted average across countries and business units by headcount), Mapfre's unadjusted gender pay gap was 25.7% in 2025 (29.45% in 2024, on a non-comparable prior methodology). Mapfre also discloses an adjusted pay gap, verified by Ernst & Young, that controls for role, function, business unit and country: 1.27% average and 0.79% median in fixed remuneration, and -0.03% average and 1.89% median in variable remuneration. Remuneration data for BRASILSEG is excluded from both calculations due to lack of operational control. The annual total compensation ratio - the highest-paid individual's total compensation relative to the median employee's - was 53.58% (53.39% in 2024), excluding BRASILSEG, Enalta, LFR and Insignia Life.

Reference: page 376.

In 2025, 67 discrimination and harassment complaints were received through the Internal Information System (32 in 2024); 9 were deemed inadmissible and 58 admitted for processing, of which 28 were dismissed after investigation, 20 confirmed with corrective measures adopted, and 10 remain under investigation. No complaints were submitted through OECD National Contact Points. Mapfre recorded no serious human-rights incidents - forced labour, human trafficking or child labour - among its staff in 2025, and consequently no related fines, penalties or damages requiring reconciliation with the financial statements.

Reference: pages 378-379.

Mapfre's value-chain-worker policies include the Code of Ethics and Conduct, the Policy on the Protection and Safeguarding of Human Rights, the Responsible Investment Framework, the Sustainable Underwriting Framework, the Corporate Protocol for the Prevention and Treatment of Harassment, the Underwriting Policy and the Procurement Standard, each mapped to the specific value-chain agents affected (providers, distributors, customers). These policies, developed in line with the UN Guiding Principles on Business and Human Rights, are supplemented by external whistleblower channels detailed under G1-1, made available to value-chain workers. Mapfre recorded no 2025 cases of non-compliance with these principles, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises, involving value chain workers.

Reference: pages 379-381.

Mapfre engages value-chain workers indirectly through the agents to which they are linked: facility visits assess working conditions, infrastructure and health-and-safety compliance for providers with fixed premises; a new towing-services and repair-shop NPS, launched in 2025 with three surveys (Puerto Rico, MAWDY Colombia, Mexico), captures business-provider worker perceptions; and a Global relational NPS for distributor clients, refreshed in 2025 across 14 countries, gauges broker experience. For investment-related workers, Mapfre's annual Major Sustainability Adverse Events monitoring tracks portfolio companies for Global Compact/OECD Guidelines violations and pay-gap/board-diversity performance. The Global Healthy Company Management Model extends to value-chain workers located in Mapfre offices.

Reference: pages 381-382.

Value-chain workers can access the same Internal Reporting System available to Mapfre's own workforce, without provider or customer intermediation, alongside the Corporate Protocol for the Prevention and Treatment of Harassment. In investment, an Engagement Policy promotes dialogue with investee companies on responsible practices and integrates remediation mechanisms and ethical considerations into investment decisions. Mapfre states these remedies are currently addressed indirectly through general processes rather than value-chain-worker-specific ones, and that work will continue in coming years to assess whether value-chain workers are aware of, and trust, these structures. The Corporate Policy on the Internal Reporting System explicitly prohibits retaliation against whistleblowers and those assisting them.

Reference: pages 382-385.

Mapfre's four value-chain-worker IROs (harassment/discrimination risk, human-rights-violation risk from underwriting/investment, human-rights protection, and social inclusion through investment) map to actions including provider facility visits and activity monitoring (minimum annual frequency, resulting in action plans and provider ratings), compliance verification with local Occupational Risk Prevention regulations during approval, public Internal Reporting Systems, and the ESG-methodology reviews described under E1-3. A risk-segmentation provider-approval process integrates labour-dispute and social data with support from specialised third parties, directing tailored improvement plans to higher-risk providers. In 2025, no widespread or systemic patterns of forced or child labour were identified across the value chain, and no serious human-rights problems were reported upstream or downstream.

Reference: pages 385-387.

Mapfre's stated value-chain-worker objectives include ensuring adequate coordination in occupational risk prevention and are linked to the same four IRO codes covered under S2-4 (protection of human rights, social inclusion, harassment risk, and human-rights-violation risk from underwriting/investment). The report states these objectives are managed through overall, indirect processes shared with other topics rather than through value-chain-worker-specific numeric targets, and that specific processes to track mitigation will continue to be developed in coming years. Progress monitoring draws on the provider ESG-approval metrics, the towing/repair-shop and distributor NPS measurements described under S2-2, and the ESG investment and underwriting coverage targets set out under E1-4.

Reference: page 389.

Mapfre's consumer-facing policies comprise the Policy on the Protection and Safeguarding of Human Rights, the Anti-Corruption Policy, the Business Continuity Policy, the Corporate Claims Policy, the Security and Privacy Policy, the Sustainability Policy, the Underwriting Policy, the Global Customer Experience Plan, the AI Solutions User Guide and the Customer Relationship Governance Model. Human-rights protections for customers are anchored in the Institutional and Business Principles and the Code of Ethics and Conduct, and customers can access the Internal Reporting Systems described under G1-1 to identify and remedy human-rights-related impacts. No customer groups with heightened vulnerability characteristics were identified in the 2025 Double Materiality Assessment.

Reference: pages 390-393.

Mapfre engages consumers proactively through market-research-driven product design (informed by Mapfre Economics and the Business Trends Observatory), and through NPS and satisfaction surveys run by the Mapfre Quality Observatory: a 2025 relational NPS wave covered 40,032 Mapfre customers and 41,247 competitor customers across 21 countries and 113 companies, complemented by a transactional NPS live in 16 insurance companies and 19 MAWDY companies. More than 399 people globally are dedicated to quality monitoring, supporting 269 certified processes and ISO 9001 certification in 10 countries. Reactively, Mapfre monitors social media and manages whistleblower channels; a 2025 "Manifesto for Humanistic, Ethical, and Responsible AI" governs AI-driven personalisation of customer offers.

Reference: pages 393-394.

Mapfre provides internal channels for the extrajudicial defence of policyholder rights in every direct-insurance country; in Spain, an Insured Party Defense Counsel (established 1984) and a Complaints department (operating since 2003) process grievances under the Customer Defense Regulations, with complaint data captured in a 360-degree customer data repository. In 2025 Mapfre Peru Compania de Seguros y Reaseguros received a financial penalty for non-compliance with Peru's personal-data-protection regulation (RLPDP), arising from an individual customer complaint about data processing rather than a broader data-security failure. Customers can also raise concerns through the Internal Reporting System, which the Corporate Policy protects from retaliation.

Reference: pages 394-401.

Mapfre's seven consumer IROs (accessibility/inclusion, transparent information, data protection as positive impacts; service-related dissatisfaction and cyberattack data-loss as negative impacts; macroeconomic deterioration and social/geopolitical erosion as risks) map to actions including a Welcome Pack project, improved customer experience initiatives, and cybersecurity solutions to prevent, detect, respond to and recover from attacks. Further actions detailed in the chapter cover product accessibility, complaint-handling improvements and vulnerable-group support - specialised Life-insurance advice, financial-planning tools and simplified access for elderly and at-risk customers - implemented in line with Mapfre's commitment to equal treatment and regulatory compliance for these groups.

Reference: pages 401-404.

Mapfre's consumer targets include reaching 70% of retail-customer revenue with an NPS above the competitive average by 2026 (measured since 2015 via relational and transactional NPS); protecting customer information under the Corporate Security and Privacy Policy, tracked through Security Plan compliance and incident minimisation (ISO 27001, NIST); increasing senior (55+) customers taking tailored products by 5.5% and users of senior-focused benefits by more than 20,000 against a 2023 baseline; reaching 250,000 insured parties by 2026 through new distribution channels in Brazil and Colombia; and expanding healthcare access, including two new hospitals with Sanitas (2027-2029) and continued growth of the Savia digital-health platform.

Reference: pages 407-413.

Mapfre's business-conduct framework rests on the Institutional and Business Principles, the Code of Ethics and Conduct (revised by the Board on 22 December 2025), the Anti-Corruption Policy, the Criminal Prevention Model, the Corporate Policy on the Internal Reporting System, the Framework for Responsible Institutional Relationships, and the Purchasing Standard, distributed via the online learning campus and a Culture module being updated for January 2026. The unified Internal Reporting System, approved December 2024 and amended December 2025, received 649 communications in 2025: 364 deemed inadmissible and 285 accepted for processing (55% from employees), resolving 145 as unfounded and 109 as confirmed with corrective action, with 31 still under investigation. Anti-corruption and compliance training totalled 49,298 hours across 17,170 participants (56.01% of the workforce).

Reference: pages 413-417.

Mapfre manages provider relationships through an Operational Provider Management Model live in 21 countries for both the Insurance and MAWDY business units, underpinned by centrally defined Procurement Rules executed by decentralised country purchasing groups. The Code of Ethics and Conduct includes a dedicated provider section, and the ESG approval and qualification process now covers more than 17,513 approved service providers assessed on environmental, social, labour and governance criteria, supported by on-site visits, contractual sustainability clauses and technological self-service tools. Sustainable provider management is aligned with Mapfre's broader due-diligence approach described under GOV-4, extending equally to general procurement and to business providers serving customers directly.

Reference: pages 417-419.

Mapfre applies a zero-tolerance anti-corruption framework - the Anti-Corruption Policy (approved 2020, revised December 2025), Criminal Risk Prevention Models, anti-money-laundering rules and the Corporate Anti-Fraud Policy - under which the Corporate Compliance Department reviews 98 identified criminal-risk processes and 280 associated controls. No significant incidents, sanctions or convictions related to corruption, bribery or criminal-risk prevention were recorded in 2025. The Compliance Function, resourced with more than 50 full-time-equivalent staff, holds AENOR ISO 37301 certification and was subject to an external review by Baker McKenzie of criminal-risk-prevention models. In 2025, 39% of people in the highest-risk management functions completed anti-corruption training, and 85.83% of external directors received specific anti-corruption training.

Reference: page 419.

During 2025, no convictions related to corruption or bribery were recorded, and no payments were made for fines relating to violations of anti-corruption and anti-bribery laws. Because no convictions or fines were recorded, Mapfre states it was not necessary to take any action to address breaches of its anti-corruption and anti-bribery procedures and standards during the year.

Reference: pages 419-421.

Mapfre has been enrolled in the EU Transparency Register since 2019 (registration no. 970705336248-40) and reports its public-affairs priorities annually to the Executive Committee, supported by a Global Institutional Presence Map of associations, foundations and chambers of commerce across its countries of operation. Total 2025 contributions and lobbying-related expenses were 2,917 thousand euros (2,700 thousand in 2024), comprising 2,180 thousand euros to lobbying/interest-representation groups and 737 thousand euros to associations, chambers of commerce and tax-exempt groups; no contributions were made to political campaigns, organisations or candidates. In accordance with the Anti-Corruption Policy, no direct or indirect political-party contributions were made, and all contributions were financial rather than in-kind.

Reference: pages 423-424.

Mapfre's average provider payment period was 10.65 days in 2025 (10.23 days in 2024), with a ratio of transactions paid within terms of 10.1 days (9.76 in 2024); total payments made were 3,043,863 thousand euros against 69,019 thousand euros of pending payments. The general payment-term criterion is a maximum of 30 days from invoice receipt, and the general practice favours immediate digital payment. No significant legal proceedings for payment delays were pending at year-end. Mapfre has not yet adopted a single global standard internal payment term across its geographies but states it will disclose the outcomes of action plans to expand payment-practice detail, including for SME-classified providers, in future reporting periods.

Targets related to business conduct

Back-filled from the business conduct chapter's MDR-T table and the G1-3/G1-4 sections, where this content is disclosed in the FY2025 report (pages 417-419, 424). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Mapfre states explicitly that its two positive business-conduct impacts - promoting sustainable public policies and disseminating responsible corporate culture - "currently do not have a specific goal assigned" (page 424); the MDR-T table instead links stated targets (business continuity plans, information-security protection, the 12%-of-premiums sustainable-product target) to G1's macroeconomic, geopolitical and cyber risks rather than to corruption prevention specifically. Consistent with MDR-T's other limb, effectiveness of anti-corruption efforts is tracked through structured monitoring: the Criminal Prevention Model's 98 identified processes and 280 controls are periodically reviewed (page 417), and training coverage of at-risk management functions (39% in 2025, expected to rise) and external directors (85.83%) is tracked as a proxy for programme effectiveness (page 419).