Banco Sabadell

The governance system and the organisation of the different decision-making levels are both being continuously improved and adapted to the needs that are emerging from the new sustainability environment. Board of Directors With the exception of matters reserved to the Annual General Meeting, Banco Sabadell's Board of Directors is the most senior decision-making body of the company and its consolidated Group as it is responsible, by law and pursuant to the Articles of Association, for the management and representation of the Bank. The Board of Directors acts mainly as an instrument of supervision and control, delegating the management of the Institution's ordinary business matters to the Chief Executive Officer. The Board of Directors is subject to well-defined and transparent rules of governance, in particular to the Articles of Association and the Regulation of the Board of Directors, and it conforms to best practice in the area of corporate governance. To ensure better and more diligent performance of its general supervisory duties, the Board is directly responsible for approving the Institution's general strategies. It also approves its policies and is therefore responsible for establishing principles, commitments and objectives in the area of sustainability, and for including them in the Institution's strategy. As at 31 December 2024, the Board of Directors is made up of fifteen members. Of these, two are Executive Directors (13.33% of the total Board) and thirteen are Non-Executive Directors, while ten are Independent Directors (66.67% of the total Board), two are Other External Directors (13.33% of the total Board) and one is a Proprietary Director (6.67% of the total Board). There is no trade union representation on the Board. As at 2024 year-end, there were six female directors, including five female Independent Directors out of a total of ten Independent Directors and one female Other External Director. Women represent 40% of the full Board of Directors, thus bringing forward the fulfilment of the Bank's commitment stated in Sabadell's Commitment to Sustainability and achieving early compliance with the provisions of Organic Law 2/2024 of 1 August on equal representation and balanced presence of women and men. [Matrix of competences and diversity shown] When defining the general strategy, the business objectives and the risk management framework of the Institution, the Board of Directors considers aspects related to sustainability, including climate-related, environmental, social and governance risks, and it also effectively oversees them. In April 2024, the Board of Directors revised its Sustainability Policy, which incorporates ESG parameters into the activities and organisation of Banco Sabadell Group. This policy establishes the core principles that guide Banco Sabadell Group in its task of addressing the challenges of sustainability, defining the management parameters, as well as the organisation and governance structure needed for its correct implementation. In relation to the management and control of environmental risk, the Board is ultimately responsible for embedding it into the general strategy and for establishing the necessary mechanisms for its review. Its duties range from monitoring environmental risk to approving and reviewing the organisational and functional framework for managing, controlling and reporting on this risk, approving the associated policies and reviewing them on an annual basis. Lastly, it is worth noting that the Board of Directors has received specific training on climate risk management, the impact deriving from those risks, policies and regulations in that regard, as well as measurement metrics such as the carbon footprint and decarbonisation pathways. Board Committees The Board Strategy and Sustainability Committee was set up in 2021 and is chaired by the Chairman of the Board of Directors, in the capacity of Other External Director. It is formed of five Directors: three Independent, one Other External and its Chair. This Board Committee met 15 times in 2024. This Board Committee is responsible for analysing and reporting to the Board of Directors on environmental risk policies and for reporting to the Board of Directors on any amendments or periodic updates of the environmental risk strategy. It is also responsible for supervising the model for identifying, controlling and managing risks and opportunities in relation to sustainability including, where applicable, environmental risks. Banco Sabadell continues to move forward with its activities and organisation to support and accelerate the important economic and social transformations that contribute to sustainable development and the fight against climate change. Firm in its resolve, the Bank maintains its Commitment to Sustainability, approved in 2022, which sets out an action framework that integrates a forward-looking vision, for the period 2025-2050, of Environmental, Social and Governance (ESG) commitments in the Bank's strategy, aligns the Bank's business objectives with the Sustainable Development Goals (SDGs), and establishes levers to activate the transformation and promotion of initiatives in this area. [Details about other Board Committees and Internal Committees follow] Organisation The Sustainability and Efficiency division was created in 2021 and is the unit responsible for defining and managing Banco Sabadell Group's responsible banking strategy, including the cross-cutting implementation of ESG criteria across all of the Bank's business units, affiliates and subsidiaries. The Sustainability and Efficiency Director is a General Manager who forms part of the Institution's Management Committee and reports directly to the Chief Executive Officer. At the end of 2024, certain internal organisational changes were approved, applicable as from 1 January 2025, as a result of which the Sustainability division is to be integrated within the People division. The Director of the People and Sustainability division is a General Manager who forms part of the Institution's Management Committee and reports directly to the Chief Executive Officer. The Sustainability division is a cross-cutting structure that has an overview of all new initiatives to be implemented in the Bank, collaborating in their definition, promoting them and taking charge of their monitoring. [Details about three lines of defence organization continue]

The material Impacts, Risks and Opportunities (hereinafter, IROs) have been identified using the double materiality analysis and are set out in detail in section 3.3 SBM-3: Material impacts, risks and opportunities and their interaction with strategy and business model. In this respect, the material IROs have been grouped into a total of six topics: Climate change mitigation and adaptation, Energy, Own workforce, Access to products and services and non-discrimination, Cybersecurity and data protection, and Business conduct. In this vein, the Management Committee is the highest level executive committee and is regularly informed of material impacts, risks and opportunities at top-level committee meetings. The governance process for each of the above-mentioned topics is described below: Climate change mitigation and adaptation All matters related to climate change (mitigation and adaptation) are regularly reviewed by the Sustainability Committee. The Management Committee, for its part, engages in regular monitoring of the Sustainable Finance Plan and updates to the regulatory framework. In addition, those that concern business lending are submitted to the relevant Business Committees of the Institution, while those that relate to the measurement of borrowers' climate-related and environmental risks are relayed to the Technical Risk Committee. As for the Board Committees, in relation to that to which each topic refers: • Board Strategy and Sustainability Committee: Carries out regular monitoring of the Institution's progress in ESG matters through the review of the Corporate Sustainability Report, which contains information about the overall ESG environment in the context of the macroeconomic and regulatory environment, and about the Institution's ESG outlook, the integration of ESG risks into management arrangements and the priority indicators of Sabadell's Commitment to Sustainability. • Board Risk Committee: One of the main responsibilities of the Board Risk Committee is that of putting forward the proposed Risk Appetite Statement (RAS) to the Board of Directors for its approval. It should be noted that the RAS has been strengthened over the past year through the inclusion of new environmental risk metrics linked to credit risk. • Delegated Credit Committee: Approves or reports favourably to the Board of Directors, as applicable, on decisions concerning credit risk acceptance, credit risk refinancing and restructuring, and sales of foreclosed assets, according to the assumptions and limits established by the Board of Directors, following analysis by the Board Committee to ensure that the companies that are the subject of such decisions take sustainability indicators into account. • Board Audit and Control Committee: During the year, in accordance with the duties incumbent upon it, the Board Committee has monitored and analysed the sufficiency, clarity and integrity of all financial and related non-financial disclosures published by the Bank. • Board of Directors: Responsible for approving the Institution's policies, for establishing principles, commitments and objectives in the area of sustainability, and for including them in the Institution's strategy. [Detailed governance processes for Energy, Own workforce, Access to products and services, Cybersecurity and data protection, and Business conduct topics follow]

Banco Sabadell Group's Remuneration Policy is consistent with the goals of the risk and business strategy, the corporate culture, the protection of shareholders, investors and customers, the values and long-term interests of the Group, as well as with customer satisfaction and the measures taken to prevent conflicts of interest without providing incentives for excessive risk-taking. To that end, Banco Sabadell Group's Remuneration Policy is based on the following principles: 1. Promote business and social sustainability in the medium-long term and ensure alignment with Banco Sabadell Group's values. This involves: • Aligning remuneration with shareholders' interests and with the creation of long-term value. • Implementing rigorous risk management, considering measures to prevent conflicts of interest. • Aligning with Banco Sabadell Group's long-term business strategy, objectives, values and interests. 2. Ensure a competitive and fair remuneration system (external competitiveness and internal fairness) that: • Is able to attract and retain the best talent. • Rewards professional experience and responsibility, irrespective of the employee's gender. In this respect, Banco Sabadell Group's Remuneration Policy is based on equal pay for male and female employees for equal work or for work of equal value. • Is aligned with market standards and is flexible, so that it can be adapted to changes in the environment and sector requirements. 3. Reward performance, thereby aligning remuneration with individual results and the level of risk taken: • Finding an adequate balance between the various remuneration components. • Considering current and future risks and results, without providing incentives for excessive risk-taking beyond Banco Sabadell Group's tolerated threshold. • Implementing a simple, transparent and clear-cut remuneration scheme. The Group's Remuneration Policy should be easy to understand and easy to communicate to the entire workforce. The Banco Sabadell Group Remuneration Policy, in its entirety, includes information about the integration of sustainability risks. In particular, in terms of sustainability, the following aspects are taken into consideration: • The remuneration policy and practices integrate sustainability risks and information in that regard is published on the Group's website. The remuneration policy and practices shall encourage behaviour consistent with the Group's risk-based approaches related to climate and the environment, as well as with the commitments voluntarily undertaken by the Group. In addition, they shall promote a long-term approach to the management of climate-related and environmental risks. • Remuneration components must contribute to the promotion of environmental, social and governance actions in order to make the business strategy sustainable and socially responsible. The specific operation of variable remuneration will be described in the Banco Sabadell Group companies' regulations. In any case, variable remuneration will be linked to results, in such a way that its total amount will be based on an assessment that: • Combines the results of the Group, entity, business unit or division in which activities are carried out and/or those of the employee. • Takes into account both financial and non-financial criteria, aligned with the strategic planning, budget and risks taken or indicators in the fields of environment, society, diversity and gender equality. • In terms of long-term remuneration, multi-year targets will also be considered, based on quantitative criteria linked to a period long enough to properly reflect the risk taken. Within the Group's objectives, the Synthetic Sustainability Indicator (SSI) has a weight of 10% in employees' variable remuneration and includes ESG metrics and indicators. In the case of the Executive Directors, this indicator has a weight of 14% for the CEO and 13% for the CRO. In terms of its composition, it is structured in four blocks: Green loans or sustainability-linked loans (40% weight); gender diversity indicators (percentage of female representation in management, 20% weight); indicators linked to the attainment of the Sustainable Finance Plan (20% weight); and score given by ESG rating agencies (20% weight). [Table showing parameter definitions and weights] Furthermore, to reinforce the alignment of remuneration with the Group's sustainability commitment, in 2023 a synthetic sustainability indicator was included in the multi-year targets set by the Group, directly linked to long-term remuneration, weighted at 20%. Its composition is structured around the synthetic indicator related to Sustainable Business (green & social loans, sustainability-linked loans, and other mobilised funds) and to Diversity (percentage of women in the management team). In long-term remuneration, in addition to the annual targets established for short-term variable remuneration, the multi-year targets must be met. For the period 2024-2026 the multi-year target indicators are: shareholder value creation (relative Total Shareholder Return or TSR), weighted at 40%; profitability (Return On Tangible Equity or ROTE), weighted at 40%; and Sustainability (the above-mentioned synthetic sustainability indicator), weighted at 20%. Additionally, some job functions have been assigned sustainability targets as part of their individual targets. Targets will be set in such a way that the assignment of variable remuneration includes all current and future types of risk, with either annual and multi-year targets or with ex-ante adjustments to variable remuneration. Banco Sabadell Group annual and multi-year targets, their weighting and their scale of achievement will be approved by the Board of Directors, based on a proposal by the Board Remuneration Committee. Guidelines on target setting and their weights for all staff members are approved by the Board Remuneration Committee. The individual targets of each staff group will be detailed in the corresponding remuneration policies.

The Group takes into account sustainability risks in its assessment, management and control processes through the activities carried out. In this respect, Banco Sabadell Group has a Sustainability Policy, which aims to provide a framework for all of the Institution's activity and organisation within ESG parameters. The Policy incorporates environmental, social and governance factors in decision-making and, at the same time, based on those factors, it responds to the needs and concerns of all of its stakeholders. The Sustainability Policy sets out the core principles on which the Group bases its approach to tackling the challenges of sustainability, and defines the corresponding management parameters, as well as the organisation and governance structure required for their optimal implementation. Effective integration of environmental, social and governance risks into management arrangements requires a strategy and set of regulations that establish the guidelines, targets and limits required at different points of the credit approval workflow. The Bank therefore attaches great importance to the assessment of the climate-related and/or environmental, social and/or governance risks of its counterparties. Specifically, climate-related and/or environmental risks are set out in detail in section 5.1.4.1 ESRS 2 IRO-1: Description of the processes to identify and assess material climate-related impacts, risks and opportunities. In terms of social risks, various social factors are considered, such as those related to rights, well-being, and the interests of people and communities. The risk of loss arising from any negative financial impact on counterparties stemming from the current or prospective impacts of social factors is also included. To that end, a series of actions linked to the process for identifying, measuring and managing social risk for both retail and business customers have been implemented. Although it is true that many of these actions apply to both types of customers, the Due Diligence Policy as regards the granting of credit is geared towards retail customers, while the Defence Sector Policy, the Eligibility Guide and the IRCA are actions mostly aimed at corporates. The Group therefore has an Environmental and Social Risk Framework that consolidates the set of applicable criteria (sectoral standards) that are intended to limit the financing of customers or projects that the Institution considers to be contrary to the transition to a sustainable economy or that lack alignment with international regulations or best practices in the industry. The above-mentioned Framework also integrates compliance with the rules and standards at the level of social risk, some sector-specific (e.g. in the energy and agricultural sectors, special consideration is given to the negative impact they may have on society and local communities), and others of general application, such as the International Labour Organisation (ILO) Conventions and the UN Guiding Principles on Business and Human Rights. In this regard, the Framework has the same thresholds and scopes of application and the same mechanisms for effective implementation as those described in section 5.1.4.1 ESRS 2 IRO-1: Description of the processes to identify and assess material climate-related impacts, risks and opportunities, including the dispute screening tool provided by a reputable third-party supplier. Specifically, the general exclusions limiting the financing of companies with a high level of social risk, regardless of the sector to which the borrower belongs, are: a. Companies for which Banco Sabadell has sufficient reason to believe that they employ child labour or forced labour, as defined in the ILO conventions, or that have participated in human rights violations and/or that do not follow the principles of the Institution's human rights policy. b. Companies involved in the resettlement of indigenous or vulnerable groups without their free, prior and informed consent, or that otherwise infringe the rights of those groups. c. Companies for which Banco Sabadell has sufficient reasons to believe that they are in material breach of applicable laws and regulations in relation to human rights and the environment, even if the circumstances in question do not constitute a breach of the local legislation of each country. d. Companies that do not have health and safety policies in place to protect their workers, such as OHSAS 18001 or ISO 45001. On the other hand, the Group has a Human Rights Policy and a related Due Diligence Procedure, both approved in 2021, which are reviewed annually and are applicable to all Group companies. They establish basic principles of action, as well as the mechanisms required to identify, prevent, mitigate and/or remedy any potential negative impacts on human rights that the Bank's activities and processes may entail, in particular with regard to granting finance to companies, or in relation to its human resources management model or supplier engagement processes. They also establish the need for employees to receive training in all of these areas. The principles governing the Human Rights Policy take into consideration the impact and relationship with four main stakeholder groups: Group employees, customers, suppliers and commercial partners, and the communities or environment in which the Group conducts its business and operates. The Group also has a new version of the Group Code of Conduct, first approved in 2021 by the Board of Directors, which underwent an in-depth review to adapt it to regulatory requirements, supervisory guidelines and specifications, and to market standards. Every member of the Group's workforce was required to read and expressly accept the new version of the Group's Code of Conduct.

The main function of the Internal Controls over Sustainability Reporting (hereinafter, ICSR) unit is the design and implementation of the general control framework corresponding to Banco Sabadell Group's Sustainability Report. This includes the identification of significant quantitative data generation processes involved in generating the quantitative information contained in the Sustainability Report. A data generation process is considered to be one which generates quantitative indicators associated with the Impacts, Risks and Opportunities (IROs) stemming from the double materiality analysis and one which comprises common elements, such as a data origination source and the processing and analysis of those elements prior to final disclosure. The ICSR unit analyses those data generation processes, through a thorough analysis with the expert areas involved, and identifies the risks associated with those processes, which are related to the content of the Comisión Nacional del Mercado de Valores (CNMV) guidance that serves as the frame of reference, and controls are designed and incorporated, jointly with those responsible for the data, to mitigate the previously identified risks. The resulting matrix of risks and controls provides a holistic view of the processes and systems involved in producing the Sustainability Report. The matrix can be consulted to identify the executor and the reviewer of the control, the data that it covers and the process to which it belongs, among other fields. Furthermore, with the entry into force of the new European Corporate Sustainability Reporting Directive (CSRD), the ICSR unit has identified risks and designed controls over the new double materiality exercise in order to ensure the correct execution of this exercise and its completeness. Based on the above-mentioned Directive, content controls have been established over the qualitative information disclosed throughout the Sustainability Report in relation to policies, actions, metrics and targets, as these are considered to constitute sensitive information and there are risks involved in their disclosure to the markets. With regard to the assessment of the established controls, which mitigate the associated risks through their prevention or detection, this is carried out using the Bank's Governance, Risk and Compliance (GRC) tool, which is managed by the ICSR unit, where the areas responsible complete assessment forms accompanied by evidence supporting each of the controls. Having completed the assessment, the GRC tool managed by the ICSR unit has a certification module that can be accessed by members of Senior Management. The certification process is based on the hierarchical and organisational ratification, at three levels, of the result achieved in the assessment of the controls. The Board of Directors delegates the supervisory function regarding the internal control systems to the Board Audit and Control Committee. Every six months, the current situation of the ICSR as a result of new applicable regulatory requirements is reported to the Board Audit and Control Committee and to the Technical Committee on Accounting and Financial Disclosures. In addition, every year after the end of the tax year, the result of the assessment of the controls and the conclusions derived from it are escalated to the Board Audit and Control Committee.

The Institution's business model is geared towards profitable growth that generates value for shareholders. This is achieved through a strategy of business diversification based on criteria related to profitability, sustainability, efficiency and quality of service, together with a conservative risk profile, while maintaining high standards of ethics and professional conduct combined with sensitivity to the interests of all stakeholders. [Business model diagram and key figures shown] The Group's strategy promotes sustainable financing and investment to drive forward the transition towards a more sustainable model and a low-carbon economy, offering customers and investors the best possible solutions. Thus, the Bank committed to mobilise €65bn in sustainable finance between 2021 and 2025. Up to December 2024, more than €57.9bn had been mobilised, €19bn of them during this year. To honour this commitment, the Bank is taking further action to raise awareness and offer advice across all sectors of the business fabric, offering solutions to finance the investments required for this transition. • Sustainable financing solutions: • Financing solutions in the different business lines: To bring processes for loan approval, portfolio management and reporting tasks in line with international standards on sustainable financing (the Green Loan Principles and Sustainability-Linked Loan Principles issued by the Loan Market Association and the Green Bond Principles and Sustainability-Linked Bond Principles issued by the International Capital Market Association, ICMA), in 2020 the following types of financing were defined, according to the intended use of the funds: • Green and Social Loans (GSLs), in which the use of the funds is the main criterion for determining the green, social or sustainable nature. This type of financing is closely related to Banco Sabadell's Sustainable Financing Framework, whose main references are the EU Taxonomy and the best practices in the market such as the Green Loan Principles, and to the green bonds issued by the Bank in recent years under the SDG Bond Framework. To promote GSL transactions, the Bank has approved discounts that allow it to offer better prices to customers. The rollout of the Next Generation EU Recovery Funds is expected to significantly boost this type of financing (the section "Next Generation EU" provides more details about the actions that the Bank is taking in relation to the aforesaid funds). • Sustainability-Linked Loans (SLLs), which relate to the type of financing that incentivises the achievement of sustainability targets, linking the transaction price to the evolution of one or more KPIs. This category does not require the funds to be used for any specific purpose. It is considered essential that the selected indicators be relevant for customers, as this enables their sustainability strategy to gain more traction. [Detailed sections follow for Corporate & Investment Banking, Business Banking, Retail Banking, and additional business lines including sustainable savings and investment solutions, Sinia Renovables, and Mexico operations]

Banco Sabadell Group is firmly committed to ensuring sustainability across all its dimensions and, as a financial institution, it is aware of the important role that it plays in its economic, social and environmental surroundings, fostering care for the environment, supporting social progress and upholding a model of good governance, aligned with international best practice. The Group, in keeping with its commitment, has been conducting materiality assessments of topics related to sustainability, aligning with best practice in relation to sustainability and transparency. Specifically, in 2022, the double materiality approach was included for the first time and the concept of impact included in the 2021 review of GRI standards was introduced. In line with this development and with the entry into force of the new European Corporate Sustainability Reporting Directive (CSRD), a new double materiality exercise has been carried out in order to identify the material impacts, risks and opportunities related to sustainability. To that end, the guidelines set out in the European Sustainability Reporting Standards (ESRS) created by the European Financial Reporting Advisory Group (EFRAG) and adopted by the European Commission have been taken into account. This analysis, as established in the aforesaid standards, serves as a basis for determining the Institution's material topics and, consequently, those that should be included in the Group's Sustainability Report. Under the double materiality approach, this exercise includes assessing the effect of different sustainability topics from two points of view: 1. Impact materiality: referring to the Bank's effects on the environment and society through its activities, both directly and indirectly. 2. Financial materiality: referring to the effects of the environment and society on the Bank's financial position. Methodological phases: The methodological performance of the double materiality analysis carried out comprises four key phases: 1. Definition of the perimeter under analysis 2. Impact materiality assessment 3. Financial materiality assessment 4. Definition of materiality thresholds The first phase of the process is described below, as the following three phases are described in section 4.1 Double materiality, which meets the requirements of "IRO-1: Description of the processes to identify and assess material impacts, risks and opportunities". Definition of the perimeter under analysis: The aim of this first phase is to outline the Double Materiality analytical framework. This phase involved determining: a. The key sustainability topics for the Institution: To identify the possible material topics to be evaluated in the double materiality exercise, an analysis was carried out to identify those topics that are, in principle, more important for the Institution from an ESG perspective. In this respect, the topics referred to in the ESRS were comprehensively analysed, in addition to the topics deemed to be material in previous materiality exercises and the Principles for Responsible Banking, among others. Based on these priority topics, a process then took place to rule out or discard the less material topics, applying expert criteria, merging those with synergies between them and keeping those that were thought to have priority. To perform this discarding process, the following analyses were taken into consideration: (i) other regulatory references and questionnaires from ESG rating agencies, (ii) analyses of other stakeholder groups (internal information about the opinions of investors, customers and NGOs), and (iii) comparative analyses of the sector's ESG disclosures. b. Stakeholder groups to be involved in the exercise and definition of channels to listen to what they have to say: The Bank's main stakeholder groups were identified by reviewing previous exercises, analysing recommendations included in the CSRD, and analysing peer group entities. The groups identified for the double materiality exercise were the following: • Financial Community: investors, shareholders and rating agencies • Employees: Banco Sabadell Group workforce • Suppliers: main suppliers that might be more affected by ESG topics • Customers: retail and business customers • Bodies and Institutions: regulators of the domestic and European framework • Society: citizens, communities and organised civil society • Peers: comparable institutions in the sector [Detailed description of stakeholder engagement methods follows]

As a result of the double materiality exercise, the following material impacts, risks and opportunities have been identified: [Comprehensive table showing sustainability topics, material impacts, and value chain positioning] [Double materiality analysis results table showing impact materiality, financial materiality (risk and opportunity), and double materiality results for all ESRS topics] Following the analysis, Banco Sabadell concluded that the current risks identified in the double materiality analysis (which include the risk of digital fraud, higher costs to adapt solutions to vulnerable groups and credit risk caused by the physical climate risks to which customers are exposed and which reduce their creditworthiness) currently product no significant effects. This conclusion was reached after evaluating the impact that they currently have on the Bank's financial statements, such as the income statement and the balance sheet, having verified that they have no material significance. Assuming that these impacts may be following a growing trend, risks are being managed in order to minimise the potential extent of those impacts in the future. In relation to current opportunities, including those related to a wider offer of sustainable finance solutions and improved advice for the climate transition, as well as those related to the opportunity to attract new customers through digital channels and increased cross-selling, it was concluded that they have material significance and the Institution is working to benefit from them and to continue developing the sustainable solutions that it offers to its customers. Thus, the Bank committed to mobilise €65bn in sustainable finance between 2021 and 2025. Up to December 2024, more than €57.9bn had been mobilised, €19bn of them during this year. As a result of the digitalisation strategy pursued by the Institution, over 150,000 customers were onboarded digitally in 2024 and this figure is expected to continue rising in the coming years, making it an increasingly significant source of income. [Specific qualitative analysis of the financial materiality of environmental risks follows with detailed assessment tables and results] Double materiality analysis evolution During 2024, the double materiality analysis that was conducted in 2022 was updated. That update mainly consisted of bringing the framework of ESG topics and the methodology in line with the requirements and indications of the ESRS. As a result, the matrix published in the previous year underwent some changes in terms of the prioritisation of certain topics, considering the ESRS in the methodology, as well as the increasing importance of ESG topics for the Bank's stakeholder groups.

Identification and assessment of impact materiality The double materiality analysis identified the main positive and negative impacts related to each sustainability-related topic that the Bank has or could have on society and the environment. Each of them are assessed according to their characteristics through the scale, scope, irremediable character and likelihood, the scale being the severity or benefit of the impacts on the environment and society, as well as the time horizon of potential negative impacts. In the case of a potential negative impact assessed as impacting human rights, severity prevails over likelihood. During the assessment exercise carried out, 1,612 participants, broken down according to the chart below, were actively involved through ad hoc questionnaires and interviews with General Management: [Stakeholder involvement chart shown] The Bank's General Management has been involved in both the assessment of impact materiality (scale, irremediable character and likelihood, since the scope of the impact is set by means of an internal analysis) and of financial materiality (financial effects, likelihood and trend over time). On the other hand, retail customers, business customers, employees and suppliers took part in the impact materiality assessment through an analysis of the scale. In that regard, 56 impacts were identified, which were assessed under the impact materiality perspective. Identification and assessment of financial materiality First, the main risks and opportunities of each sustainability-related topic that affects or could affect the Bank's financial statements were identified. These risks and opportunities were assessed in the short, medium and long term through their financial effects and likelihood of occurrence. This assessment identified 42 risks and 21 ESG opportunities, which were assessed under the financial materiality perspective. Definition of materiality thresholds and results Based on the chart analysis of the normal distribution of the results obtained in the assessments of impact materiality and financial materiality, the Impacts, Risks and Opportunities (IROs) that stand out from the entire sample have been identified. The IROs belonging to the group of scores that are above the rest are classified as "material impacts, risks and opportunities". Internal control processes for the double materiality analysis As described in section "2.5 GOV-5. Risk management and internal controls over sustainability reporting", the Internal Controls over Sustainability Reporting (ICSR) unit identified risks and designed controls over the new double materiality exercise in order to ensure the correct execution of this exercise and its completeness. The Board of Directors delegates the supervisory function regarding the internal control systems to the Board Audit and Control Committee. Every six months, the current situation of the ICSR as a result of new applicable regulatory requirements is reported to the Board Audit and Control Committee and to the Technical Committee on Accounting and Financial Disclosures. In addition, every year at the end of the tax year, the result of the assessment of the controls and the conclusions derived from it are escalated to the Board Audit and Control Committee. [Detailed assessment of environmental degradation, social and governance risks follows, including biodiversity risk, Environmental and Social Risk Framework, and additional risk assessments]

Disclosure requirements addressed in the Sustainability Report Once the material topics for the Bank have been identified, the sustainability information that is to be disclosed in the annual Sustainability Report is structured. Based on these material topics and the structure of the European Sustainability Reporting Standards (ESRS), this report covers environmental information first, followed by information on social aspects to finally conclude with information related to governance. Thus, the structure of the Sustainability Report follows the table of contents set out below: [Comprehensive table showing all topical standards, disclosure requirements, and page numbers covered in the report]

E1-1: Transition plan for climate change mitigation [Note: The text indicates this section exists on page 56 but the provided content appears to be cut off at the double materiality analysis section. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

E1-2: Policies related to climate change mitigation and adaptation [Note: The text indicates this section exists on page 70 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

E1-3: Actions and resources in relation to climate change policies [Note: The text indicates this section exists on page 73 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

E1-4: Targets related to climate change mitigation and adaptation [Note: The text indicates this section exists on page 80 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

E1-5: Energy consumption and mix [Note: The text indicates this section exists on page 85 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

E1-6: Gross Scopes 1, 2, 3 and Total GHG emissions [Note: The text indicates this section exists on page 87 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

E1-7: GHG removals and GHG mitigation projects financed through carbon credits [Note: The text indicates this section exists on page 91 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

E1-8: Internal carbon pricing scheme [Note: The text indicates this section exists on page 92 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-1: Policies related to own workforce [Note: The text indicates this section exists on page 95 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-2: Processes for engaging with own workers and workers' representatives about impacts [Note: The text indicates this section exists on page 98 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-3: Processes to remediate negative impacts and channels for own workers to raise concerns [Note: The text indicates this section exists on page 99 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-4: Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions [Note: The text indicates this section exists on page 104 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-5: Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities [Note: The text indicates this section exists on page 110 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-6: Characteristics of the undertaking's employees [Note: The text indicates this section exists on page 112 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-8: Collective bargaining coverage and social dialogue [Note: The text indicates this section exists on page 115 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-10: Adequate wages [Note: The text indicates this section exists on page 116 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-13: Training and skills development [Note: The text indicates this section exists on page 116 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-14: Health and safety metrics [Note: The text indicates this section exists on page 117 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-15: Work-life balance metrics [Note: The text indicates this section exists on page 119 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-16: Compensation metrics (pay gap and total compensation) [Note: The text indicates this section exists on page 119 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S1-17: Incidents, complaints and severe human rights impacts [Note: The text indicates this section exists on page 124 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S4-1: Policies related to consumers and end-users [Note: The text indicates this section exists on page 133 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S4-2: Processes for engaging with consumers and end-users about impacts [Note: The text indicates this section exists on page 136 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S4-3: Processes to remediate negative impacts and channels for consumers and end-users to raise concerns [Note: The text indicates this section exists on page 137 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S4-4: Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions [Note: The text indicates this section exists on page 140 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

S4-5: Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities [Note: The text indicates this section exists on page 145 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

G1-1: Corporate culture and business conduct policies and corporate culture [Note: The text indicates this section exists on page 147 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

G1-2: Management of relationships with suppliers [Note: The text indicates this section exists on page 154 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

G1-3: Prevention and detection of corruption and bribery [Note: The text indicates this section exists on page 157 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]

G1-4: Confirmed incidents of corruption or bribery [Note: The text indicates this section exists on page 157 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]