Storebrand

Sustainability governance and board composition (pp.33, 35)

The Group Board of Storebrand ASA has overarching responsibility for monitoring sustainability impacts, risks and opportunities and for ensuring compliant reporting. Sustainability guidelines are approved annually by the Group Board and by the boards of all subsidiaries, which define roles: the Group Board's Audit Committee monitors sustainability-reporting quality; Group Executive Management and managing directors set targets/actions and embed sustainability into risk management; the Chief Sustainability Officer (CSO) supports the Group CEO and EVPs.

Board composition (year-end 2025): 10 members – 6 women, 4 men (60%/40%); 7 elected by the General Meeting (Nomination Committee-recommended), 3 elected by employees. Average female-to-male ratio for the year: 1.4. All 7 General Meeting-elected members are independent, with no employment or contractual relationships with Storebrand beyond board membership; none sit on Group Executive Management. No conflicts of interest arose in 2025; no board member has served more than 12 years. Members bring experience across finance, insurance, asset management, sustainability, technology and international business. 14 Board meetings were held in 2025. Chair: Jarle Roth; Deputy Chair: Martin Skancke.

Information flow to governing bodies (p.33)

The Chief Sustainability Officer informs the Group Board, subsidiary boards and the Audit Committee at least annually on material impacts, risks and opportunities as part of the double materiality assessment; sustainability reporting is a standing Audit Committee agenda item. The Group Board is informed of due-diligence assessments through the annual statement under the Norwegian Transparency Act, signed by the Group Board and the boards of all in-scope group companies. The annual report under the Norwegian "Duty of Activity and Reporting" (Aktivitets- og redegjørelsesplikten) is likewise signed by the Group Board and subsidiary boards, and subsidiary boards conduct an annual review of the climate transition plan's status.

All business areas have sustainability targets; EVPs report progress regularly to Group Executive Management. All material sustainability matters were reviewed by Group Executive Management and the Group Board during 2025.

Remuneration structure and sustainability accountability (p.39)

Storebrand deliberately emphasises fixed salary as the primary remuneration component for Executive Management and makes limited use of variable pay: Executive Management receives no commission-based or variable remuneration. Instead, a significant share of gross fixed salary is allocated to purchasing Storebrand shares with a three-year lock-in period, aligning executives with long-term shareholder interests. The Compensation Committee reviews the Group Executive Management remuneration model annually to confirm alignment with strategy and long-term objectives, including sustainability targets. Board members receive fixed fees only – no incentive-based, option-linked, or performance-linked remuneration.

Sustainability accountability operates through governance oversight rather than a bonus formula: throughout 2025 the Board oversaw the CEO's progress on implementing the 2024 climate transition plan, and Group Executive Management is held accountable for sustainability targets monitored in regular business reviews (e.g., EVP Corporate Market on labour-market participation/disability-related products; EVP Retail Market on motor-claims spare-parts share and mortgage-portfolio emissions; all business areas on air-travel carbon footprint).

Due diligence process cross-reference (pp.115-116)

Storebrand's statement on due diligence is presented as a table mapping the six core elements of the due diligence process to where they are addressed across the report, rather than as freestanding narrative:

• Embedding in governance, strategy and business model – Corporate governance and SBM-3 (pp.32-33, 66)
• Engaging with affected stakeholders – SBM-2 stakeholder table and topical "Our approach" sections (pp.52-53, 91, 93, 95)
• Identifying and assessing adverse impacts – IRO-1 process and topical IRO sections (pp.53-55, 100-101, 104, 107)
• Taking action on adverse impacts – topical Actions sections (pp.67-79, 94, 97, 108, 110-112)
• Tracking effectiveness and communicating – topical Targets/Metrics sections (pp.67-77, 93-98, 101-104, 109-113)

Storebrand's separate report under the Norwegian Transparency Act is referenced as available on the company website.

Risk management and internal controls for sustainability reporting (p.51)

Storebrand structures risk management and internal control for sustainability reporting on the COSO-ICSR framework, jointly owned by the Sustainability Department and the Accounting Department, covering three risk areas: Climate (investments, banking, P&C insurance, own operations); Social sustainability (own employees, consumers and end-users); Business conduct (financial-crime prevention and information-security incidents).

Controls include: internal data providers assessing potential errors and prioritising risk mitigation; an internally developed IT system requiring documentation, quality control before approval, and change logging; approval by the responsible data owner followed by an independent sample-based review from the Sustainability and/or Accounting Departments. The Board's Audit Committee oversees sustainability reporting as a standing agenda item at every meeting, with risk-assessment and control results reported periodically to governing bodies. Main risks relate to supplier data quality, mitigated via supplier expectations, automated processes, traceability logs and data reviews.

Business model and value chain (pp.9, 51)

Storebrand is a Nordic savings and insurance group headquartered at Lysaker, Norway, offering pension, savings, insurance and banking products to private individuals, companies and public-sector entities over more than 250 years of operation. At year-end 2025, Storebrand was one of the largest private asset managers in the Nordic region, with NOK 1,609 billion invested in around 3,450 companies worldwide, approximately 61,000 corporate customers, and savings from more than 2 million people in Norway and Sweden.

Storebrand's corporate strategy is directly linked to material sustainability matters (climate, social factors, business conduct), embedded in product development, risk assessment and daily operations. Examples: active ownership and exclusion of coal-related companies in the investment portfolio; no P&C insurance underwriting for fossil-based activities (narrow carve-outs for administration/office/employee-related insurance); loss-prevention and circular claims-settlement products in insurance; the bank engaging mortgage customers on reducing home GHG emissions and on ESG-aware investment choices.

Key stakeholders and engagement (pp.52-53)

Governing bodies are informed of stakeholder perspectives through Group Board meetings, strategy processes and investor dialogue; the Board approves the double materiality assessment, which itself channels stakeholder input.

Material impacts, risks and opportunities (pp.56-58)

Storebrand's 2025 DMA confirms E1 (Climate change), S1 (Equal treatment and opportunities for all), S4 (Consumers and end-users) and G1 (Corruption and bribery) as material topics, plus entity-specific Financial crime and Information security (both reported within G1). E2, E3, E4, E5, S2 and S3 have no dedicated chapter in 2025.

Representative material IROs: climate risk of reduced returns/demand in savings and investment products; financed-emissions and transition/physical risk in investments and residential mortgages; opportunities in green insurance, circular claims settlement and green mortgages; gender-imbalance and pay-gap negative impacts alongside competence-development and diversity opportunities; customer information/privacy risks; corruption, financial-crime and information-security risks.

Sub-topics material in 2024 but reassessed non-material for 2025 (more consistent threshold application, review of positive impacts vs. mitigation actions): work-life balance, working environment, violence/harassment measures, responsible marketing practices, corporate culture, political engagement/lobbying, and supplier-relationship management. Storebrand concluded no matters identified at the reporting date are expected to significantly affect its financial position, performance or cash flows in the next financial period.

Double materiality assessment process (pp.53-55)

Storebrand updates its DMA annually, applying EFRAG's four-phase guidance, building substantially on the 2024 assessment (no structural changes to outcomes). Activities, relationships and stakeholders were mapped across life insurance, P&C insurance, investments, banking and own operations; internal stakeholders (operations, banking, P&C, life insurance, asset management, HR, risk/compliance, sustainability) were involved in identification, weighting and validation via workshops – external stakeholder workshops were judged unnecessary since internal staff have continuous external contact.

Weighting: impacts scored on scale, scope and (for negative impacts) irremediable character using EFRAG's 1-5 scales, with human-rights severity weighted above likelihood; risks/opportunities assessed on financial magnitude and likelihood. Business-area results were consolidated at Group level, weighted by capital volume and financial results, using existing ORSA operational-risk thresholds (adjusted for DMA-specific factors). Environmental screening covered pollution, water/marine resources and biodiversity (using ENCORE and other nature-risk data sources) and resource use/circular economy (P&C supplier materials, asset-management exposure to linear/circular business models) – none became a dedicated material topic in 2025. The Group Board reviewed the DMA results on 26 August 2025; no material changes have arisen since.

ESRS disclosure index and EU-legislation cross-references (pp.58-61, 117-121)

Storebrand's ESRS Index confirms disclosure requirements reported under ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1 (E1-1 to E1-4, E1-6 to E1-8; E1-5 and E1-9 not included), S1 (S1-1 to S1-7, S1-9, S1-13, S1-14, S1-16, S1-17; S1-8, S1-10 to S1-12 and S1-15 not included), S4 (S4-1 to S4-5) and G1 (G1-1, G1-3, G1-4; G1-2, G1-5, G1-6 not included), plus entity-specific disclosures on anti-money laundering/terrorist financing, international-sanctions monitoring, financial misconduct and information security.

A separate appendix (pp.117-121) maps ESRS 2 datapoints to other EU legislation (SFDR Principal Adverse Impact indicators, Pillar 3 ESG disclosure tables, the EU Climate Benchmark Regulation and the EU Taxonomy Climate Delegated Act) – covering board gender diversity, board independence, the due-diligence statement, and fossil-fuel/controversial-weapons/tobacco involvement flags – several of which are marked "Not Material" for Storebrand's own operations.

Group transition plan to net zero by 2050 (pp.65-66)

The Board adopted Storebrand's transition plan in 2024, targeting net zero emissions by 2050, structured by business area (investments, P&C insurance, banking, own operations), with subsidiary boards adopting aligned plans; targets are monitored by Group Executive Management regularly and by the Board annually. Storebrand is candid about limits: "meeting the ESRS requirements is challenging, as they are not tailored to the financial sector" – for the investment portfolio it uses intensity-based rather than absolute Scope 3 targets, so it has no Group-wide absolute Scope 3 target and cannot meet all ESRS transition-plan requirements as currently specified.

Embedding examples: active ownership and coal-company exclusions in investments; no P&C insurance for fossil-based activities (narrow office/admin/employee-insurance exceptions); bank engagement with mortgage customers on home-energy emissions. Fossil-sector investment exposure: oil NOK 12,582m (1% of AUM), gas NOK 11,792m (1%), coal NOK 0 (0%). Locked-in emissions risk: low for real estate/infrastructure/private equity, low-to-medium for equity/bonds, managed via active ownership and net-zero-aligned capital allocation; Storebrand is not excluded from EU Paris-aligned benchmarks. Costs are budgeted within each business area (chiefly headcount and ESG-data infrastructure) and not currently considered materially higher.

Climate policies for investments (p.66)

Governance sits with the Board of Storebrand Asset Management AS (SAM), which annually adopts: ambitions for all investments on human rights, nature, deforestation and climate; requirements for managing climate risk and the net-zero-by-2050 goal (emission reductions, transition financing, climate commitment); and criteria for avoiding investments in companies violating Storebrand's sustainability principles. Supporting guidelines include the Guideline for Sustainable Investments and the Exclusion Policy. The Group's overarching Sustainability Policy (see Corporate governance, "Sustainability governance and control") covers all sub-topics and IROs.

SAM manages both external capital and internal capital on behalf of asset owners Storebrand Livsforsikring and SPP (approximately 46% of SAM's assets); the life insurance companies set investment-mandate frameworks for SAM to implement. Swedish pension regulation and the Norwegian self-selected individual pension account (EPKS) mean some customers can choose funds outside Storebrand's policies.

Climate actions by business area (pp.67, 71, 73-74, 76, 78-79)

Investments: active ownership (dialogue, voting, investor coalitions – 367 stewardship dialogues on climate in 2025, 38% of total dialogue); reallocation to solution companies and green bonds; exclusions (162 companies excluded at start of 2025, rising to 188 by year-end); real-estate energy-efficiency projects (Norway refurbishment completed 2025; rooftop-solar framework agreement).

P&C insurance (Storebrand Forsikring): loss-prevention advice and products (e.g., increased water-sensor reimbursement, SMS storm alerts, Båtvakten leak sensors); circular claims settlement (sustainability declarations in all supplier agreements, raised vehicle write-off thresholds, extended new-car guarantees to favour repair over replacement); climate-risk pricing using external terrain/flood data alongside site-specific assessments.

Banking: customer engagement on portfolio sustainability characteristics (e.g., Kron's sustainability-preferences module); mortgage actions include measuring CO2e/m2 against CRREM's Norwegian decarbonisation pathway, embedding energy efficiency/climate risk in credit decisions, and customer energy-efficiency advice.

Own operations: energy/water management, waste sorting, a 2024-updated travel policy with per-department carbon budgets and an internal CO2 fee, and a 2025-updated green bond framework; supplier engagement toward net-zero-by-2050 commitments.

Quantified targets by business area (pp.67-70, 72-73, 75, 77)

Investments: net zero by 2050; equities/bonds emissions intensity target -60% by 2030 vs. a 2018 baseline of 14.4 tCO2e/MNOK (2025 reduction ~56%, ahead of the 2025 interim target); AUM share in SBTi-validated companies already past its 2027 target; allocation to sustainable solutions already past its 2030 target (15%/20% by 2025/2030); real-estate location-based intensity down ~58% vs. 2018 (Norway/Sweden); infrastructure net-zero-pathway alignment at 90% (2025), meeting the 2030 target early; private-equity carbon intensity at 41% of the listed index (2024), within the <60% target. Several equities and real-estate targets are SBTi-validated and/or set as NZAOA 1.5°C-pathway sub-targets.

P&C insurance: motor-claims component-reuse targets (glass, plastic, steel/aluminium, used spare parts) – all four 2025 targets achieved.

Banking: mortgage-portfolio emissions intensity (kgCO2e/m2) trending down toward the 2030 target, aided by a 21% drop in Norway's electricity emission factor (2024-2025).

Own operations: 100% renewable electricity (met); air-travel Scope 3 target reached in 2025 (368 tCO2e reduction); waste-recycling rate trending toward 80% by 2030; supplier science-based-target/circularity commitments running ahead of a linear pathway toward 80% by 2030.

Group GHG inventory 2025 (pp.79-82)

Storebrand's Scope 1 emissions are limited to gas fireplaces at its offices (immaterial); Scope 2 covers electricity, district heating and cooling at 14 office locations. Scope 3 is dominated by financed emissions (Category 15: equities, corporate bonds, infrastructure, real estate and Storebrand Bank's mortgage lending), alongside business travel, office waste, claims-settlement materials/waste, and cloud/data-centre services.

Total gross Scope 3: 35,653,248 tCO2e (2025) vs. 33,076,890 tCO2e (2024), +8%. Total GHG emissions (location-based): 35,653,360 tCO2e (2025) vs. 33,077,041 (2024); (market-based): 35,894,540 tCO2e (2025) vs. 33,282,443 (2024) – both +8%. Category 15 Investments alone: 35,634,101 tCO2e location-based (2025) vs. 33,069,982 (2024) – effectively all of Scope 3. GHG intensity per net turnover improved despite the absolute rise: 2,444 tCO2e/MNOK location-based (2025) vs. 2,603 (2024); turnover grew to NOK 14,588m (2025) from NOK 12,714m (2024).

Methodology follows the GHG Protocol and, for financed emissions, PCAF and SFDR definitions; coverage is approximately 100% for equities, ~69% for corporate bonds and ~99% for real estate (Scope 1-2).

Carbon credits for air-travel offsetting only (p.84)

Storebrand purchases carbon credits solely to compensate for business air-travel emissions, prioritising emission reduction first. Credits are sourced through Klimate (which conducts project due diligence; the credits themselves are not independently third-party verified) and are exclusively removal credits – biogenic (afforestation, soil enhancement) or technological (direct air capture, geological storage) – aligned with the Oxford Offsetting Principles.

In 2025, Storebrand supported projects corresponding to 922 tCO2e (100% biogenic removals), planned for cancellation in 2026. Credits actually cancelled in 2025 totalled 2,016 tCO2e (100% removal projects, 100% recognised quality standards: Plan Vivo 77%, Carbon Standards International EBC 21%, Gold Standard 2%), versus 0 in 2024. Additional forward-dated credits have been purchased from Inherit Carbon Solutions (biomethane-facility carbon capture from organic waste) and Climeworks, with delivery timing undisclosed due to uncertainty.

Internal carbon fee on air travel (p.79)

Storebrand applies an internal carbon fee to all employees' business air travel, charged to each department and followed up by leaders through the Group's business-management reporting. The fee was NOK 1,500 per tCO2e in 2025 (up from NOK 1,000/tCO2e in 2024), adjusted in line with the carbon-price pathway recommended by Rosendahl and Wangsness (2023) as referenced by the Climate Committee 2050. It covers Scope 3 Category 6 air-travel emissions, equivalent to about 0.003% of Storebrand's total Scope 3 emissions.

The mechanism has not been externally validated; proceeds fund carbon-reduction projects/credits equivalent to air-travel emissions and, potentially, own-operations emission-reduction measures. Storebrand states it regularly evaluates the fee's effect against its emission-reduction trajectory.

Own-workforce policies (p.91)

Three named policies govern the workforce: the Employee handbook / HSE handbook (Executive Vice President People, Brand & Communications; ongoing), covering working environment, inclusion, learning, development dialogues and whistleblowing channels; the Activity Duty and Duty to Issue a Statement framework (Board of Directors, annually) for systematic gender-equality/diversity improvement work (map challenges, analyse causes, set measures, evaluate results); and Storebrand's Code of Conduct (CEO, annually), setting a framework for inclusive and equitable behaviour and non-discriminatory recruitment/remuneration.

Guidelines apply to all employees (permanent, temporary, interns) and are expected of external consultants, partners and board members, aligned with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises.

Engaging the workforce (pp.93, 95)

People-department partners hold cooperation-committee meetings with all Group and business areas 4-6 times a year on competence/development; an annual People Review (Q4) identifies development areas. On working environment and inclusion, Storebrand applies a four-step model from the activity/reporting duty (identify challenges, analyse root causes, set targeted measures, evaluate results), monitored through the employee survey and reviewed by the Working Environment Committee (AMU) and the Diversity Committee (an AMU advisory body meeting quarterly, chaired by the EVP for People, Brand & Communications).

At-risk groups are identified through anonymised pulse-survey data plus insights from safety representatives and dialogue meetings.

Grievance and remediation channels (p.95)

Employees can raise concerns through AMU, the Diversity Committee and safety representatives, or via an external whistleblowing channel with anonymous reporting. All employees are trained on how to handle concerns; issues are handled at the lowest appropriate organisational level. Reports (internal and external) are processed by the Whistleblowing Council, chaired by the EVP for People, Brand & Communication with participation from Governance, Risk & Compliance (GRC) and Group Legal; serious concerns are escalated to the CEO.

People, Brand & Communications and line leaders handle cases confidentially, safeguard both parties, and apply an explicit anti-retaliation prohibition. Effectiveness is evaluated annually by report volume and follow-up actions; Storebrand's own score is 8.6/10, 0.7 points above the industry average.

Key actions in 2025 (pp.94, 97)

Learning/AI: AI competence built via 90 AI Champions; ~1,200 employees applied for a Copilot licence with >96% adoption; internal Q1 2025 survey found 86% reporting increased efficiency/quality (vs. 70% in May 2024). Practical Leadership engaged 48 leaders in 2024 and another 48 from autumn 2025; 26 future leaders started at Storebrand Academy. Mandatory annual training covers sustainability, financial crime, privacy, information security and ethics.

Gender/diversity: a salary review addressed gender-related pay gaps; participation in She Index, Women in Finance Charter and the FiftyFifty programme (10 women completed in 2025, new cohort of 10 started); Sandbox internship 7M/8W, corporate trainee programme 5M/6W. Storebrand ranked 4th on the SHE Index in 2025 (having won in 2023 and 2024) and was recognised by Equileap as a global gender-equality leader. Since 2023, 449 employees completed an e-learning course on diversity/inclusion/belonging (with IMDI and Catalysts). Inclusive Working Life programme (since 2002) and the new Storebrand VEL service support employees at risk of sick-leave-driven exclusion.

Learning and gender-balance targets (pp.93, 96)

Learning: score on learning/development (Peakon, 1-10) rose to 8.3 in 2025 (2018 baseline 7.4), against an ongoing target of >8; learning hours per employee were 10 in 2025 (10.8 in 2024), target >8; manager-support score 8.6, target >8; 94% completed mandatory annual courses, target 95% (deemed unrealistic at 100% given turnover/hiring).

Gender balance and pay: gender balance across all management levels reached 40% women in 2025 (37% in 2024, 38% in 2023), against a 50% by 2030 target. Women's unadjusted average earnings as a share of men's rose to 87% in 2025 (85% in 2024, 83% baseline). Across all employees (Hay Grade 12-26), the ratio is 95%, target: maximum 5% gap. Whistleblowing-reported harassment cases target: zero (achieved each year). Diversity & Inclusion score (Peakon): 8.4, target >8.

Workforce composition (pp.91-92)

Total employees: 2,541 (2025) vs. 2,368 (2024) – 1,429 male, 1,109 female, 3 not-reported (2025). By country: Norway 2,036, Sweden 462 (2025). By contract: 2,490 permanent, 51 temporary (2025); no non-guaranteed-hours employees.

Turnover: 7.0% (2025) vs. 8.2% (2024, restated from a previously reported 6.1% due to a system error in the 2024 reporting). Turnover is calculated as permanent employees leaving divided by average permanent headcount; temporary staff, consultants and apprentices are excluded. Data is HR-system-sourced and not externally validated.

Non-employee workforce (pp.91-92)

Storebrand's external labour totalled 1,297 individuals in 2025 (1,307 in 2024), comprising 586 consultants and 711 partners/distributors (2025); interns were separately reported (9 in 2024, none in 2025). Figures are reported as headcount of individuals (not FTEs), reflecting external labour with their own employer responsibility as well as agency-hired personnel, as of 31 December.

Age and gender diversity (pp.97-98)

Age distribution (2025): under 30: 15%; 30-50: 59%; over 50: 26%. Gender in management (2025 vs. 2024): Board of Directors 60%/50% women; Group Executive Management 50%/50%; management level 1-4 women 41%/37%; female managers overall 40%/37%. Senior management (levels 2-3): 41% women both years (26 of 64 in 2025; 23 of 56 in 2024).

External recruitment: 363 hires in 2025 (339 in 2024), 39% women both years.

Engagement and development metrics (p.94)

Employee engagement (Peakon): 8.6 in 2025 vs. 8.5 in 2024, both above the industry average (7.9 in 2025, 8.0 in 2024). Development-dialogue participation: 82% in 2025 (81% in 2024 – restated from a previously reported 54% women / 57% men due to missing data in the 2024 reporting). Average learning hours per employee: 10 in 2025 vs. 10.8 in 2024, tracked via Workday (campus/e-learning, Storebrand Day, certifications).

Sick leave and workplace injuries (p.98)

Sick leave: Norway 3.2% (2025) vs. 3.3% (2024), against a target of <3.5%; Sweden 1.6% (2025) vs. 2.0% (2024), same <3.5% target. Measured as a share of total annual absence; from 2025 onward, child-sickness days are excluded from the calculation (2024 figures still include them, limiting comparability), and work-related vs. non-work-related sick leave is not distinguished for data-protection reasons. Reviewed quarterly by AMU.

Injuries: two work-related incidents with minor personal injury in 2025 (none in 2024); accident frequency rate 0.44 per million working hours (based on 2,542 employees at standard annual hours).

Pay gap and CEO pay ratio (pp.96, 98)

Gender pay gap (unadjusted, women's earnings as % of men's): 87% in 2025 (85% in 2024, 83% baseline/2023). Across all employees on a job-category-adjusted basis (Hay Grade 12-26): 95% (2025); excluding extended senior management (Hay Grade 12-20): 95% (2025); expanded top management (Hay Grade 21-26): 90% (2025, vs. 86% in 2024). Target: keep the gap below 5% across all pay categories, aligned with the EU Pay Transparency Directive; the Korn Ferry Hay methodology benchmarks roles.

CEO pay ratio: 11.12:1 in 2025 (11.05:1 in 2024). Group CEO base salary NOK 10,294,443 (2025) vs. NOK 9,805,000 (2024); median employee total remuneration (excluding CEO) NOK 925,906 (2025) vs. NOK 887,568 (2024).

Whistleblowing cases and human-rights incidents (p.98)

The Whistleblowing Council reviewed 41 cases in 2025, up from 10 in 2024 – an increase Storebrand attributes to strengthened reporting awareness and greater visibility of whistleblowing channels rather than worsening conduct. No cases involving severe human-rights impacts were reported in 2025. Reported discrimination incidents: 0 (both 2025 and 2024). Total fines, penalties and compensation for damages related to these incidents: NOK 0 (both years).

Customer-facing policies (p.100)

Three named policies: Information, sales and advice guidelines (CEO, annually) – defines roles, responsibilities and competence requirements for staff providing customer information and advice; Storebrand is a FinAut member, following Norway's authorised-advisor norms for informed, needs-based advice. Privacy Policy ("Policy for Storebrand ASA processing personal data") (CEO, annually) – roles/responsibilities for personal-data processing. Storebrand's Code of Conduct – advice tailored to customer knowledge/needs/preferences, privacy and digital security, conflict-of-interest management, and equal/fair customer treatment.

Aligned with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. "Responsible marketing practices" – material in 2024 – was assessed non-material for 2025 and does not appear in this policy set.

Customer engagement and privacy processes (pp.101, 104)

Access to quality information and to products/services is managed through digital solutions, personal advisory, and customer-satisfaction surveys (Norsk Kundebarometer, EPSI – described as "an external auditor of the customer base"), plus feedback from online/mobile banking, the corporate portal and customer service. Kron conducts user testing at all product-development stages; since 2022, Storebrand has developed services that reduce disability-related and labour-market exclusion, adapting products via pilot testing. Paper, telephone and advisory channels remain available for non-digital customers.

On privacy, each legal entity's managing director is responsible for personal-data processing; an internal control system verifies processing in customer solutions and partner cooperation, supported by data-processing agreements and a privacy notice updated at least annually. All employees complete annual privacy training, and customers can manage privacy settings via a self-service portal or contact the Data Protection Officer directly.

Complaints handling and breach notification (pp.102, 104)

"Effective complaints handling" is supported by accessible digital and postal complaint channels, with a designated complaints officer in each business unit. Complaints processed by the Norwegian Financial Services Complaints Board rose to 363 in 2025 from 169 in 2024 – Storebrand attributes this mainly to improved, more precise data collection (correcting prior under-reporting from system limitations) alongside customer-base growth (figures exclude SPP).

For privacy, medium- and high-risk security breaches trigger customer notification covering the incident, measures taken and recommendations; a network of privacy advisors supports the business, and the Data Protection Officer is a direct contact point for complaints, which are also handled by individual group companies.

Key actions in 2025 (pp.102-104)

Good advice and simplification: loss-prevention campaigns including the "Bedbug Campaign" (travel) and "Turn and Win" (home fire safety); an AI-supported project simplified and standardised insurance terms, with positive customer and employee feedback.

Access and digitalisation: Kron's digital investment platform averages 50% weekly active use across its 130,000 customers and had Norway's most satisfied investment customers in 2023-2025. Storebrand Bank's robotic-process-automation programme (launched 2023) now runs over 50 robots, automating more than 35% of Bank Operations and cutting credit-card/banking service processing from up to a week to 4 hours; 84% of insurance customers submitted claims digitally in 2025.

Privacy: privacy protection is embedded in internal control and risk management, with a dedicated framework for monitoring operational incidents with privacy implications and assessing regulatory reportability; the Data Protection Officer reports regularly to the Board and Group Executive Management, and frameworks are reviewed annually.

Customer-satisfaction and privacy targets (pp.101-104)

Nine customer-satisfaction targets (base year 2023, mostly NPS/EPSI scores) span retail and corporate insurance, banking, savings/investments and pensions in Norway and Sweden. Highlights for 2025: EPSI insurance retail Norway 67.9 (vs. 67.1 in 2024, +0.8, target +1pt); EPSI banking retail Norway 68.4 (vs. 64.7, +3.7); EPSI savings & investments retail 67.4 (vs. 66.9, +0.5); EPSI pension corporate Norway fell to 56.4 (vs. 60.8 in 2024), which Storebrand attributes to an industry-wide trend reflecting "uncertainty rather than dissatisfaction." The same target set covers "Access to products and services."

For privacy, Storebrand sets no quantitative target, stating it is "not considered appropriate to establish quantitative targets for this area"; ambition is framed qualitatively around a technology-neutral privacy framework and GDPR/Personal Data Act compliance. Privacy incidents: 161 (2025, flat vs. 2024, down from 241 in 2023); non-conformity reports to the Norwegian Data Protection Authority: 14 (2025) vs. 18 (2024) vs. 42 (2023). No fines, warnings or improvement orders from Norwegian or Swedish data-protection authorities in 2025.

Business conduct policy framework (p.107)

Five named policies, all CEO-approved annually: Storebrand's Code of Conduct (framework for conduct across corruption/bribery, financial crime and information security); Financial Remuneration Guidelines (incentive model supporting sound risk management); Guidelines for anti-money laundering, terrorist financing and sanctions; Guidelines for digital security, operations and development (covering internal and external ICT suppliers); and Risk Management Guidelines (Board-set risk-management requirements). Internal rules and training materials are available to all employees via the intranet.

Note: "corporate culture" as a distinct sub-topic was assessed non-material in the 2025 double materiality assessment (SBM-3, p.58); the policy descriptions above focus on conduct rules and controls rather than a standalone culture narrative.

Anti-corruption controls (p.108)

Storebrand's Board-approved risk objective is "to maintain a low risk that the Storebrand Group is unable to protect itself against serious crime, including corruption." Heightened-risk areas identified: award of large public contracts such as public occupational pensions, establishing/renewing business partnerships, loan approvals, and employees misusing their position. Suppliers must adhere to the UN Global Compact's ten principles (including anti-corruption) under Storebrand's supplier sustainability declaration.

Anti-corruption training is mandatory annually for all employees, managers and non-employees (and available to the Board), built around 13 guiding questions on offered events, invitations and gifts; the procedure was updated in 2025 with clearer guidance on conflicts of interest and a prohibition on political engagement. Detection runs through the whistleblowing channel (see S1-3), assessed under Storebrand's sanctions matrix and the Working Environment Act; the Whistleblowing Council informs the CEO and relevant subsidiary boards of confirmed breaches.

Corruption incidents and training coverage (p.109)

Confirmed incidents of corruption or bribery, convictions, and fines: all zero for 2023, 2024 and 2025. A footnote flags an important caveat: "A charge issued towards the end of the year is currently under review by the authorities, and the outcome is still uncertain. We are cooperating fully with the authorities" – appearing to relate to a matter arising near year-end 2025, still unresolved at reporting date. Storebrand states it maintains zero tolerance for corruption but does not set quantitative, time-bound targets in this area, noting "there will always be a small inherent risk" despite robust systems.

Training coverage: percentage of functions-at-risk covered by the anti-corruption training programme was 94% in 2024 and 2025, against a 2026 target of 95% (100% deemed unrealistic given leave and long-term absence).