Svenska Handelsbanken

Reference: page 59.

The Board is Handelsbanken's highest administrative body, responsible for adopting overall goals, strategy and steering documents. In 2025 it comprised nine elected members plus two employee representatives and two deputies, all non-executive; women made up 44 per cent of elected members and 78 per cent of independent members (page 59).

Sustainability expertise reaches the Board through specialists in the organisation rather than a dedicated Board seat. Sustainability matters are addressed primarily through the Audit committee, for example when discussing interim reports, annual accounts and the double materiality assessment (page 61). Operationally, the Head of Handelsbanken Savings and Financing chairs the Sustainability committee (established 2010, meets at least three times a year) and the Green Finance committee, both with day-to-day work led by the operating sustainability manager; the CFO is responsible for sustainability reporting. A table lists 17 steering documents by owner (Board or CEO) and whether each is public (page 60). Further detail on Board composition sits in the Corporate Governance Report, pages 42-55.

Reference: page 61.

Reporting on the Bank's overall sustainability work goes quarterly to the Audit committee and the Board as part of preparing interim reports, presented by the CFO. The Board considers impacts, risks and opportunities primarily through the steering documents it issues on strategy and risk management, complemented by internal instructions and guidelines.

During 2025 the Board and relevant committees revised several policies, including the policy for sustainability, and addressed changes to the Bank's sustainability organisation and internal reporting. The Audit committee and the Board also addressed the transition to ESRS reporting and the updated double materiality assessment, including the material impacts, risks and opportunities set out in SBM-3 (pages 66-70) - work described as both an alignment with ESRS and part of implementing the Board's 2024 decision to further integrate sustainability into core business.

Reference: page 61.

Handelsbanken applies fixed remuneration as its main principle; executive officers receive fixed pay plus potential participation in the Oktogonen collective profit-sharing scheme, from which the Board itself is excluded. Oktogonen rewards the Bank's overall performance - long-term value creation, a responsible risk level and customer benefit - rather than individual sales incentives or specific sustainability targets, and provisions depend on the corporate goal of higher profitability than peer competitors being met.

Customer-facing co-workers and managers receive no variable remuneration and have no centrally set sales or volume targets, which the Bank frames as removing the risk that personal financial incentives distort customer advice. The Remuneration committee prepares guideline proposals for executive remuneration, which go to the AGM for approval at least every four years, and evaluates compliance and remuneration levels on an ongoing basis (pages 61-62).

Reference: page 62.

Handelsbanken presents its due diligence process through a table mapping the UNGP/OECD-aligned core elements to specific disclosure requirements and pages: (a) embedding due diligence in governance, strategy and business model references GOV-2, GOV-3 and SBM-3 (pages 61, 66); (b) engaging with affected stakeholders references GOV-1, SBM-2 and IRO-1 (pages 59-61, 65, 71-72) plus the Environmental, Social and Governance sections (pages 81-83, 95-96, 107-108); (c) identifying and assessing adverse impacts references IRO-1, ESRS 2 IRO-1 E1 and SBM-3 (pages 71-72); (d) taking action references pages 60, 83-84, 97-98, 102-104 and 108-113; and (e) tracking effectiveness references pages 66, 72-75, 84-85, 98, 102-103, 105 and 108-113 (page 62-63).

Reference: page 63.

Handelsbanken Finance has overall responsibility for sustainability reporting, including ensuring effective processes to manage risks related to reporting quality. The Bank states it strengthened its sustainability reporting processes alongside the transition to ESRS, including by more clearly dividing responsibilities, increasing traceability requirements and enhancing internal controls of reported information; Taxonomy reporting in particular has additional control procedures, including duality requirements for reconciling system data with control functions.

Internal control over sustainability reporting is based on the process the Bank already applies to financial reporting under the COSO framework, which is being gradually expanded to cover the sustainability statement. The stated aim of risk assessments and control activities is to reduce the risk of significant errors, particularly operational errors in data preparation; outcomes are reported by the CFO to the Board's Audit committee alongside the annual accounts.

Reference: page 62.

Handelsbanken organises sustainability activity across five areas: business conduct, advisory services, financing, asset management, and creating and sharing knowledge locally. The stated corporate goal - higher profitability than peer competitors in its home markets - is pursued through more satisfied customers and lower costs, both of which the Bank frames as linked to sustainability performance.

Sustainability-linked lending volumes at year-end totalled SEK 225.1 billion (189.6), comprising SEK 157.0 billion (123.4) of green loans and SEK 68.1 billion (66.2) of sustainability-linked loans (page 62). The Bank excludes new coal mine, oil or gas extraction financing and business relationships involving internationally prohibited weapons, and lending to the fossil-fuel sector has declined 68 per cent since 2021 (page 64). The value chain spans upstream funding and suppliers, own operations (co-workers, branches, systems), and downstream lending, deposits, asset management and transaction management, mapped against the twelve material sustainability matters in a dedicated table (page 64).

Reference: page 65.

Handelsbanken names its principal stakeholder groups as customers, co-workers, owners and investors, trade unions, authorities and legislators, and the rest of society including suppliers, identified by the significance of their impact on, or from, the Bank's activities. A stakeholder dialogue table sets out engagement channels and purpose for each group: for example, co-workers through PLUS performance reviews, the Group-wide work environment survey and Board employee representatives; customers through daily branch, phone and digital contact plus regular surveys; owners and investors through the AGM and quarterly investor calls; and suppliers through continuous dialogue and Code of Conduct monitoring (pages 65-66).

Viewpoints from affected stakeholders are routed through standard governance, with the operating sustainability manager reporting to the Head of Handelsbanken Savings and Financing, who reports to the CEO and, when necessary, the Board.

Reference: page 66.

Twelve sustainability matters were identified as material through the double materiality assessment, addressed under E1 Climate change, S1 Own workforce, S4 Consumers and end-users, G1 Business conduct, and the entity-specific matters Contribute to society, Counteract financial crime and Financial stability. Handelsbanken states it "currently sees no significant changes in the business model, value chain, strategy or decision-making as a result of identified positive or negative impacts" (page 66).

Tables for each topical standard and entity-specific matter (pages 67-70) set out where each matter sits in the value chain, its impact/risk/opportunity classification and time horizon. The Bank's strategy and business model - long-term relationships, low risk tolerance and cost-consciousness - are presented as the basis for managing these matters; quantitative detail on climate resilience is cross-referenced to the ESRS 2 SBM-3 E1 discussion on page 82.

Reference: page 71.

The 2025 double materiality assessment updated the 2024 assessment's methodology and structure, aligning with the final EFRAG Materiality Assessment Implementation Guidance and clarifying assessment scales; it remained mainly qualitative given "limited access to complete and reliable data" (page 71). Impact materiality used scale, scope, likelihood and (for negative impacts) irremediable character; financial materiality used likelihood and a five-point financial-effect scale tied to monetary thresholds against the income statement (pages 71-72). The process was led by Handelsbanken Sustainability with Group Risk Control input, and the outcome was adopted by the CEO with the Audit committee informed.

Feedback from 2024 stakeholder dialogues indicated ESRS E4 Biodiversity and ESRS S2 Workers in the value chain "have the lowest information value," so a new external dialogue on those topics was not repeated in 2025; internal stakeholders substituted instead (page 71). The Bank states that its own operating sites and customers' sites "were not considered for the disclosure requirements of ESRS E2, E3 and E5, since the availability of relevant and complete information was not deemed sufficient" (page 71).

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

Reference: page 75.

Rather than a single consolidated concordance table, Handelsbanken states that "a list of the disclosure requirements included in the sustainability statement, based on the results of Handelsbanken's double materiality assessment and the materiality assessment at datapoint level, is presented at the beginning of each topic area" - pointing readers to page 58 for ESRS 2, page 80 for E1, page 94 for S1 and S4 plus the entity-specific matter Contribute to society, and page 106 for G1 plus Counteract financial crime and Financial stability (page 75).

"Other sustainability matters covered by the other topical reporting standards have not been assessed as material since Handelsbanken has no material direct impact on them through its own operations or in the value chain" (page 75). The datapoint-level materiality assessment, covering EU legislation cross-references (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law), is tabulated on pages 76-79.

Reference: page 81.

Handelsbanken published its first Group-wide climate transition plan in 2023, updated regularly with new regulatory requirements. It is structured on Glasgow Financial Alliance for Net Zero (GFANZ) guidance for the financial sector and "has been adopted by the Head of Handelsbanken Savings and Financing, who also has Group-wide responsibility for sustainability" (page 82). The plan covers financed emissions from lending and asset management - over 99 per cent of the Bank's reported emissions - with the Bank's own operations to be brought in "over the next few years."

The Group-wide target is to cut absolute Scope 1 and 2 emissions; there is no Group-wide lending target, since financed emissions are instead monitored against sector pathways aligned with 1.5°C (page 82, detailed under E1-4/E1-6). Implementation runs through home-market Steering committees and a Group-wide Task force on Climate chaired by the Operational Head of Sustainability, with progress reviewed via stress tests carried out as of 31 December 2025 (pages 82-83).

Reference: page 82.

The steering documents addressing climate and energy are the Policy for sustainability, the Credit policy and the Guidelines regarding the environment and climate change (page 82). The sustainability policy sets the Bank's direction to support customers' transition and minimise its own environmental and climate impact; the climate guideline translates this into integration of physical and transition risk into credit assessments and stress tests, and into KPI and reporting compliance.

Handelsbanken "has established specific criteria for business relationships with fossil fuel companies, based on the IEA's Net Zero by 2050 scenario," under which it avoids new relationships with coal-mining companies and avoids financing new oil and gas exploration (page 82). The credit policy is not written specifically as a climate policy but forms the basis of the credit process, incorporating sustainability risk into credit assessment. Asset management subsidiaries operate under separate steering documents referencing UN PRI and the UN Global Compact (pages 82-83).

Reference: page 83.

Own-operations actions in 2025 included converting roughly 1,600 light fittings to LED in Sweden (about 40 per cent complete, target 2026), continuing Eco-Lighthouse certification in Norway (seven more premises certified), and installing smart electricity meters across about 40 per cent of UK premises; Sweden's energy-per-square-metre target was exceeded, with an 11 per cent reduction against a 2.5 per cent annual goal (page 83).

Lending actions included launching a green loan for forests in Sweden, publishing an updated Green Bond Framework across four home markets in August 2025, the UK's "Sustainable Home Reward" (up to GBP 1,000 for energy label A/B homes), and a Netherlands target of 80 per cent of real estate portfolios at energy label A by 2030 (pages 83-84). In asset management, Handelsbanken Fonder identified companies representing 70 per cent of financed emissions and began climate dialogues with 17 (13) not yet aligned with net-zero (page 84). No individual action's impact is separately quantified; effect is tracked at an aggregate emissions level.

Reference: page 84.

Own operations: reduce absolute Scope 1 and 2 emissions 50 per cent by 2030 versus a 2021 base year across all home markets, plus 100 per cent renewable electricity procurement by 2030 and a 2.5 per cent annual energy-intensity reduction at the Swedish headquarters (2023-2030). Handelsbanken states this target "is not science-based and stakeholders were not involved in setting it" (page 84).

No Group-wide lending target exists: financed emissions are instead benchmarked against sector pathways, and the Bank "has decided not to apply for validation of its climate targets with the SBTi for the time being," citing limited correlation between financed-emissions estimates and its governance mechanisms (page 85). Handelsbanken Fonder (about 90 per cent of assets under management) targets net-zero portfolio emissions by 2040 under the Net Zero Investment Framework 2.0, with an interim target of 50 per cent of portfolio companies aligned to net-zero by 2030 and a supplementary reference target of a 50 per cent carbon-footprint reduction by 2030 versus 2020 (pages 84, 86).

Reference: page 85.

Total energy consumption fell from 66,512 MWh (2024) to 61,536 MWh (2025). Fossil energy consumption dropped from 39,539 MWh (59 per cent of the total) to 30,892 MWh (50 per cent), while total renewable energy consumption rose from 26,973 MWh (41 per cent) to 30,644 MWh (50 per cent), including 30,239 MWh of purchased renewable electricity/heat/steam/cooling and 61 MWh of self-generated solar power (page 85).

Handelsbanken has not signed nuclear-energy purchase agreements in any home market, though nuclear may form part of the local grid mix consumed and is folded into the total reported volume rather than separately calculated. A supplementary district-heating agreement signed during the year reclassified some previously fossil-labelled energy as renewable from 2025; the Bank's default rule is that energy not explicitly labelled renewable is classified as fossil.

Reference: page 85.

Own-operations emissions: gross Scope 1 fell to 128 tCO2e (2025) from 143 (2024) and 339 (2021); gross market-based Scope 2 fell to 1,829 tCO2e from 2,205 and 2,718. Total market-based GHG emissions across the Group, including financed emissions, rose 10 per cent to 54,378,315 tCO2e (page 87-88), driven by financed-emissions growth as loan-portfolio coverage expanded from 88 to 94 per cent of loans to the public and the lending emissions base year was updated from 2021 to 2024 - a change the Bank states makes prior-year figures non-comparable (page 86).

Asset management financed emissions rose to approximately 49 million tCO2e (from approximately 45 million), attributed mainly to volume growth and improved data coverage, calculated under the PCAF methodology with average Data Quality Scores of 1.3 (Scope 1+2) and 3.0 (Scope 3) (page 91). Emissions from companies active in fossil-fuel value chains rose but remained 0.3 per cent of total financed emissions (page 89). Calculations are not third-party verified (page 85).

Reference: page 90.

Handelsbanken has invested in carbon dioxide removal through Milkywire's Climate Transformation Fund, which in 2025 supported 18 CDR projects estimated to capture approximately 80 tonnes of CO2, following standards including Puro.earth, Isometric, Rainbow and CSI C-Sink; about 10 per cent of contracted tonnes relate to European projects. Named projects include Kairos Carbon (wet organic residues to geologically stored CO2), Planeteers (biogenic flue-gas capture converted to ocean-stable hydrogen carbonate), Arbon (humidity-swing Direct Air Capture) and Releaf Earth (palm kernel waste converted to biochar).

The Bank made no other carbon-removal credit purchases during the year, and states the credits generated "do not count as a corresponding adjustment under Article 6 of the Paris Agreement." Handelsbanken "does not to date have a developed strategy for negative carbon emissions," nor existing plans, holdings or agreements for carbon credits to be cancelled (page 90).

Reference: page 90.

Handelsbanken states plainly: "Handelsbanken does not apply internal carbon pricing in any of its operating areas" (page 90). The one-line disclosure sits in the Metrics and targets section directly after E1-7 GHG removals and GHG mitigation projects financed through carbon credits, within the wider E1 Climate change section (pages 81-91). No shadow price, internal fee-and-dividend mechanism, planned introduction date or rationale for the absence of a carbon price is given anywhere else in the sustainability statement.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and ESRS 2 IRO-1 E1 (pages 71-76). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk is framed as flood exposure; transition risk as EPBD-driven energy-efficiency requirements (pages 72-74).

Scenarios used:

• Physical (lending) - data approximating RCP 8.5 (3.2-5.4°C by 2100, IPCC AR5), sourced per market from Sweden's MSB/SMHI, Norway's NVE, the UK's JBA and the Netherlands' Climate Impact Atlas, to 2050-2100 (pages 73-74).
• Transition (lending) - NGFS Net Zero 2050, plus expected/stressed macro-scenarios for EPBD property costs over five years (pages 74-75).
• Physical and transition (asset management) - an ISS ESG model using RCP 4.5/8.5 (Physical Value at Risk 0.1-0.7%) and IEA NZE2050 (Transition Value at Risk 1.1%, concentrated in Industrials/Materials) (pages 75-76).

Analyses ran in 2024, updated 2025 with new volumes, unchanged in outcome (page 72). Scope covers lending in the four home markets plus Handelsbanken Fonder, HWAM, Optimix, Handelsbanken Liv and discretionary management. Assumptions include energy-declaration building classes and investment cost passed to collateral value (page 75); the Bank flags "significant" uncertainty from input-data differences (page 72).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and ESRS 2 IRO-1 (pages 66-67, 71-76, 82-83). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

SBM-3 states that "the Bank believes that the fundamental principles of its business model are highly resilient to the risks and opportunities arising from climate change," with products, processes and staff competence able to adapt "in stages" within the Bank's established methods and low risk tolerance (page 82). The report does not use the phrase "resilience analysis as defined under the ESRS," so it cannot be confirmed from the text whether a formally scoped ESRS resilience analysis, distinct from the scenario-based risk work, was performed.

Supporting evidence comes from the scenario analyses under IRO-1: stress tests of lending and asset-management portfolios "as of 31 December 2025" (pages 82-83), low additional-credit-loss outcomes under both expected and stressed EPBD transition scenarios (pages 74-75), and asset management's finding of "limited exposure and high resilience to transition risks" (page 83). SBM-3 cross-references page 82 for "quantitative resilience in the context of climate change work" (pages 66-67).

Reference: page 95.

The main steering documents are the Policy for remuneration, Guidelines for work environment, Policy for ethical standards, Policy for sustainability and the Guidelines regarding human rights and working conditions, all applying to every co-worker in the Group (page 95). The remuneration policy requires pay to be "market-based, equal and gender-neutral"; the work-environment guidelines require systematic activities ensuring co-workers "feel good, develop and function optimally... and enjoy a good work-life balance," with the CEO holding overall responsibility (page 96).

The human rights and working conditions guidelines commit the Bank to the UN Guiding Principles on Business and Human Rights, the ILO Core Conventions, the OECD Guidelines for Multinational Enterprises and the UN Global Compact, and state that Handelsbanken "does not accept child labour, forced labour or human trafficking in its own operations or in its business relationships" (page 96-97). A gender equality, diversity and inclusion framework, established by the Head of Handelsbanken HR, complements these documents.

Reference: page 96.

Handelsbanken's decentralised model puts responsibility on all managers for regular dialogue with co-workers and trade union or worker representatives as part of daily operations, supplemented by an annual planning and performance review (PLUS) for every co-worker resulting in an individual action plan. The Bank states it "has not conducted any in-depth analysis of groups at particular risk of vulnerability during the year" (page 96).

A Group-wide work environment survey runs annually; for the communication health factor, 95 per cent of co-workers reported having had regular follow-ups during the year (page 96). Trade union cooperation is long-standing, with country-specific forums meeting at least quarterly in every home market plus a European Works Council that meets around four times a year, covering organisational change, employee and rehabilitation issues and new managerial appointments (page 96).

Reference: page 96.

The annual Group-wide work environment survey covers all co-workers and includes questions on their understanding of how to respond to victimisation, discrimination, sexual harassment and threatening or violent situations; 98 per cent reported a good understanding this year (page 96-97). All work environment incidents - injuries, accidents, illnesses, near-misses, victimisation, harassment and intimidation - must be logged in the Bank's internal system, WEIN, investigated by the responsible manager (in consultation with a worker representative where appropriate), with mandatory annual safety training covering incident reporting (page 97).

Beyond WEIN, co-workers can report misconduct first to their manager or, where that is not appropriate, through the Bank's externally managed whistleblower system, which protects reporter identity and is available to co-workers, consultants and external stakeholders (page 97).

Reference: page 97.

Permanent employment covered 95 per cent (94) of the workforce. Beyond statutory and collective-bargaining terms, the Bank offers supplementary parental-leave remuneration, localised pension solutions, and the Oktogonen profit-sharing scheme. Systematic work environment management runs an annual cycle of surveys, risk assessments, actions and follow-up; a new survey tool introduced in 2025 means results are "not fully comparable with last year" (page 98).

Skills development includes the Handelsbanken Leadership programme (142 leaders completed it in 2025, down from 183) and the mandatory "Sustainability in the financial industry" course, completed by 96.5 per cent of co-workers since launch, with targeted refresher training on companies/human rights and AI/sustainability delivered to 3,800 Swedish advisors (page 98). Gender-equality work is coordinated through a Group-level Diversity Council and local committees in Sweden, the UK and Norway; women held 49 per cent of all roles and 44 per cent of management positions (page 99).

Reference: page 98.

Handelsbanken tracks three own-workforce targets, none externally validated and none set with worker involvement: equal pay ("aims to achieve equal pay across all areas of the Bank" - unadjusted average pay gap 20 per cent Group-wide in both 2025 and 2024, ranging from 9 per cent in Norway to 25 per cent in the UK); a good and inclusive work environment (Trust and Respect Index score of at least 80, achieved 87 in 2025, no 2024 comparison due to a new survey tool); and gender balance (women or men to hold at least 40 per cent of all employee and manager roles by 2026 - already met at 49/51 for all employees and 44/56 for managers) (page 98).

Equal pay itself is explicitly "not set as a measurable target," since the Bank views gender pay gaps as "partly structural in nature and requir[ing] long-term commitments" alongside collective-bargaining constraints (page 98).

Reference: page 99.

Total headcount fell to 12,437 (2025) from 13,291 (2024), split 6,323 male and 6,114 female in 2025 (6,713 male, 6,578 female in 2024); no employees were recorded under "other" or "not reported" gender categories in either year. Headcount is calculated as the average full-time-equivalent-basis figure for the year, with gender based on legal gender (page 99). This own-workforce total sits alongside the separate non-employee (consultant) count reported under S1-7, and country-level employee counts by home market reported under S1-8.

Reference: page 99.

Handelsbanken's non-employee workforce consists of external consultants, the majority working on IT-related activities, numbering 555 in 2025 compared with 960 in 2024. The Bank attributes the reduction to "the Bank's increased focus on efficiency and cost adjustments" (page 99). Consultants are reported as full-time equivalents, compiled monthly by country based on contract scope as of the last day of the preceding month, coordinated by the Bank's consultancy procurement unit in Sweden and averaged over the year.

Reference: page 99.

70 per cent (70) of the Bank's employees are covered by collective bargaining agreements, pertaining to employees in Sweden, Norway, Finland and Luxembourg; employees outside union membership are still covered by agreement terms though not individually represented. A table breaks down collective bargaining coverage and social dialogue by home market and coverage band (page 100).

Beyond national-level union dialogue, Handelsbanken has operated a European Works Council since the 1990s, meeting around four times a year with representatives from the Executive Team and workers from Sweden, Norway, the UK, the Netherlands and Luxembourg, covering cross-border matters such as the work environment and future performance (page 99). Staff turnover was 9.7 per cent (7.5) in 2025, with 1,206 employees (993) leaving the Bank (page 100).

Reference: page 99.

Gender balance on the Executive Team stood at 3 women to 5 men in 2025 (4/5 in 2024), or 38/62 per cent (44/56). Age-breakdown tables cover all employees, managers and the Executive Team: across all employees, 15.0 per cent were under 30, 45.7 per cent were 30-50 and 39.3 per cent were over 50; the Executive Team skewed older, with 75 per cent over 50 in 2025 versus 77.8 per cent in 2024 (page 99-100).

Reference: page 100.

Handelsbanken applies individual salary-setting, determined at recruitment, on role change and through annual salary reviews between manager and employee, with terms and benefits varying by country according to local market conditions, collective bargaining agreements and legislation. The Bank states that "all employees receive a salary that is deemed adequate and, at a minimum, equivalent to the reference salaries applicable under collective bargaining agreements and/or national legislation" (page 100).

Reference: page 100.

Handelsbanken states that "all Handelsbanken employees are covered by social protection against loss of income in the event of illness, unemployment, work-related injury, parental leave and pension," regulated through collective bargaining agreements or local legislation depending on the market (page 100). The disclosure is a single confirming statement rather than a country-by-country breakdown; no separate quantification of coverage levels, benefit amounts or gaps between statutory and collectively agreed protection is given in the statement.

Reference: page 100.

97 per cent of women (97 in 2024) and 96 per cent of men (96) reported having regular PLUS performance reviews with their manager. Average registered training hours per employee were 20.5 for women and 18.6 for men in 2025, down from 22.8 and 21.7 respectively in 2024 - training completed via the Bank's training platforms (page 100).

Reference: page 100.

Health and safety management runs through the Group-wide work environment survey covering all co-workers, described in detail under S1-4 (page 97), with additional metrics presented under S1-5 (Trust and Respect Index, page 98). No separate work-related injury/fatality rate table is disclosed at S1-14 itself; the section instead cross-references the survey-based management system and target already reported elsewhere (page 100).

Reference: page 100.

100 per cent (100) of the Bank's employees are entitled to family-related leave under local legislation and/or collective bargaining agreements. In 2025, 22 per cent (19) of employees took such leave, of whom 56 per cent (56) were women and 44 per cent (44) were men (page 100). The metric sits alongside the systematic work environment management described under S1-4, which the Bank states aims to help co-workers "enjoy a good work-life balance" as part of its annual survey and follow-up cycle.

Reference: page 100.

The unadjusted gender pay gap (women's pay relative to men's, objective factors like role complexity and experience not controlled for) was 17 per cent in Sweden, 25 per cent in the UK, 9 per cent in Norway (revised from 11 per cent after an improved internal-control process) and 18 per cent in the Netherlands, for a Group total of 20 per cent in both 2025 and 2024 (page 100-101). The total remuneration ratio - highest-paid individual to median total remuneration across all other employees - was 22 in both years (page 100).

Reference: page 100.

72 cases (73) related to discrimination, including harassment, were reported through the Bank's Group-wide and local channels in 2025; total complaints relating to working conditions and equal treatment - including work-related injuries, accidents, illnesses, near-misses and intimidation - numbered 208 (233). No complaints were received by National Contact Points under the OECD Guidelines for Multinational Enterprises. The Bank notes that the majority of reported discrimination and working-condition cases "involve persons outside the Bank" who exposed co-workers to situations creating insecurity or a lack of respect (page 101).

Handelsbanken paid SEK 0 in compensation, fines or penalties related to these incidents and complaints in 2025, down from SEK 81,043 in 2024 (page 101).

Reference: page 101.

The steering documents addressing consumers and end-users are the Policy for operational risk (adopted by the Board, covering IT and information security risk under "a low risk tolerance for operational risks"), the Guidelines for security and data protection, and the Policy for complaints management (page 101). The security guidelines cover administrative and technical measures and are built on the ISO/IEC 27001 international standard; they were updated in 2025 "to clarify methods and processes for risk management" under the Digital Operational Resilience Act (DORA) and to strengthen requirements for external suppliers (page 101).

The complaints policy requires prompt handling "in accordance with applicable regulations," treating every complaint as "an opportunity to correct errors and address shortcomings or misunderstandings" so the complainant "should feel acknowledged and treated with respect" (page 101).

Reference: page 101.

Handelsbanken combines local branch presence with digital channels; in Sweden customers can reach Personal service by phone around the clock using secure identification. Communication must be "accurate, factual and easy to understand," per the Bank's communication policy, applying equally in normal circumstances and crisis situations such as IT outages, for which shared business-continuity instructions and templates are updated at least annually (page 101-102).

Where a personal data breach is judged to have significantly affected one or more individuals, those individuals are informed under applicable regulation, with the responsible branch contacting the customer on guidance from the Privacy Officer where necessary; the Bank states it "applies the same procedures for all customers," including vulnerable groups such as children (page 102). Complaints are first directed to the branch, with designated complaints officers in each home market for escalation.

Reference: page 102.

Complaints can be submitted by e-mail, phone or letter and are "handled carefully and promptly in accordance with regulations and internal guidelines"; each is formally reviewed, with written reasons provided on request if a complaint cannot be fully or partially rectified. Customers dissatisfied with a decision can appeal to the National Board for Consumer Disputes (ARN) in Sweden or the equivalent body elsewhere (page 102).

Co-workers undergo regular training in complaints management, and received complaints "are compiled and analysed on a quarterly basis" with process adjustments made where necessary; the Bank states it "continuously reviews its relevant policies to clarify how customers are protected against negative consequences when complaints are made" (page 102).

Reference: page 102.

Handelsbanken maintains dedicated incident, continuity and crisis management processes, with resource planning built into annual business planning so functions can be mobilised for major incidents. It participates in sector-wide cybersecurity forums including Trusted Introducer, FIRST, Finance Sweden's Banks Security Committee and the Swedish National Cybersecurity Centre's Finance Sector Forum, alongside a collaboration with other major Swedish banks (page 102-103).

Information security follows ISO/IEC 27001; the Bank underwent recertification in 2025 and expanded certification scope to cover identity and access management for internal users. DORA-related work "transitioned to the maintenance phase during 2025." A governance-risk-compliance (GRC) system continues rolling out to strengthen documentation and monitoring of personal-data processing risk, described as "a long-term improvement effort" expected to complete over several years (page 103). Complaints officers regularly present analyses, including identified improvement areas, to the Board, CEO and product owners.

Reference: page 103.

Two internally set, non-externally-validated targets: at least 96 per cent of Group co-workers completing mandatory annual cybersecurity training (97.7 per cent achieved in 2025, versus 96.6 per cent in 2024), and self-service systems maintaining at least 99.30 per cent availability (99.43 per cent achieved, versus 99.41 per cent in 2024) (page 103-104).

613 personal data breaches were reported internally in 2025 (640 in 2024); of these, 12 (17) required notification to the Swedish Authority for Privacy Protection (IMY) or an equivalent local authority, and 1 (0) was reported to the UK's Information Commissioner's Office. The Bank sets no numeric target for breach counts, stating that "each incident is analysed individually and measures are taken to prevent similar events from occurring" rather than through a quantitative target (page 104). A previously reported metric on "customer privacy and poor management of customer data" was dropped in 2025 as not materially useful to impact follow-up.

Reference: page 107.

The steering documents addressing corporate culture, and corruption and bribery, are the Policy for ethical standards, the Policy for management of conflicts of interest, the Policy for sustainability, the Policy against corruption and the Guidelines for supplier arrangements (page 107). The anti-corruption policy "stipulates the Bank's zero-tolerance of corruption"; the conflicts-of-interest policy requires higher-risk units to report identified conflicts and actions taken annually, with every unit head responsible for identifying and managing potential conflicts in their own area.

Corporate culture itself is tracked as a long-term target through the annual work environment survey, which evaluates factors including transparent communication and perceptions of respect, trust and pride (page 107). An "Employee conduct" box sets out code-of-conduct extracts covering market-abuse avoidance, private securities/currency trading rules, conflict-of-interest transaction bans and mandatory disclosure of outside assignments (page 107).

Reference: page 108.

Handelsbanken's purchasing covers property, external IT, communication, travel, marketing and other overhead costs, coordinated internationally where possible. Procurement guidance references the UN Global Compact, OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights and ILO Guiding Principles; UK subsidiaries additionally comply with the Modern Slavery Act and the Norwegian business with the Transparency Act (page 108).

A Supplier Code of Conduct, primarily applied to larger suppliers in Sweden and increasingly elsewhere, is checked through pre-contract due diligence, supported by external sustainability data and risk-classification tools; high-risk contracts are followed up at least annually. Since 2024 the Bank has targeted at least 90 per cent of suppliers (by purchase volume, for those with annual spend above SEK 5 million) having signed the Code of Conduct or an approved equivalent; the 2025 outcome was 90.3 per cent, up from 83.3 per cent in 2024 (page 108).

Reference: page 108.

Anti-corruption work is risk-based, with particular attention on operations, industries and geographies "where the risk of corruption is considered to be higher," and co-workers with customer contact, lending or procurement decision authority, or sensitive-information access treated as particularly exposed. Training on anti-corruption and other financial crime is mandatory for all co-workers and consultants with assignments over six months, and the Board and subsidiary boards undergo annual training covering the link between corruption, money laundering and terrorist financing (page 108-109).

An external whistleblower system allows anonymous reporting by co-workers, consultants and external stakeholders, with all cases investigated promptly by a function independent of operations. "No incidents of corruption or bribery were reported during the year" (page 109).

Targets related to business conduct

Back-filled from the business conduct chapter (G1-2, G1-3, G1-4), where targets and effectiveness-tracking are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Handelsbanken discloses two quantified targets adjacent to business conduct. Under supplier management (G1-2), it targets at least 90 per cent of relevant suppliers (by purchase volume, spend above SEK 5 million) having signed the Code of Conduct or an approved equivalent - achieved at 90.3 per cent in 2025, up from 83.3 per cent in 2024 (page 108). Under anti-corruption training (G1-4), the target is at least 90 per cent of employees and 100 per cent of the Board completing annual anti-corruption/AML/CFT training each year; outcomes ranged from 90-94 per cent for employees and were 100 per cent for the Board across 2021-2025 (page 109-110).

Effectiveness is also tracked in the absence of a standalone incidents target: the Bank "continuously evaluates existing metrics and reviews the potential to develop additional relevant and appropriate indicators," with confirmed corruption/bribery cases collected annually across the Group (page 109).

Reference: page 109.

There were 0 (0) confirmed incidents of corruption or bribery in 2025, and no related legal cases, disciplinary measures, dismissals or terminated business relationships; data covers confirmed cases of giving/receiving bribes, breach of trust or improper use of position, and was "not verified by an external party" (page 109-110).

Board member training completion in anti-corruption, AML and counter-terrorist-financing stood at 100 per cent every year from 2021 to 2025 (9-10 members); subsidiary board completion ranged from 89 per cent (2023) to 100 per cent (other years). Employee completion was 94 per cent (2025), 92 per cent (2024), 91 per cent (2023), 92 per cent (2022) and 90 per cent (2021), against targets of at least 90 per cent for employees and 100 per cent for the Board (page 109-110).