iso4217:EUR iso4217:EUR xbrli:shares 5493006QMFDDMYWIAM13 2025-12-31 5493006QMFDDMYWIAM13 2024-12-31 5493006QMFDDMYWIAM13 2023-12-31 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:DerivativesMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:DerivativesMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:DerivativesMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:EquityInvestmentsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:EquityInvestmentsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:EquityInvestmentsMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:DebtSecuritiesMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:DebtSecuritiesMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:DebtSecuritiesMember 5493006QMFDDMYWIAM13 2025-12-31 san:LoansAndAdvancesMember 5493006QMFDDMYWIAM13 2024-12-31 san:LoansAndAdvancesMember 5493006QMFDDMYWIAM13 2023-12-31 san:LoansAndAdvancesMember 5493006QMFDDMYWIAM13 2025-12-31 san:LoansAndAdvancesCentralBanksMember 5493006QMFDDMYWIAM13 2024-12-31 san:LoansAndAdvancesCentralBanksMember 5493006QMFDDMYWIAM13 2023-12-31 san:LoansAndAdvancesCentralBanksMember 5493006QMFDDMYWIAM13 2025-12-31 san:LoansAndAdvancesCreditInstitutionsMember 5493006QMFDDMYWIAM13 2024-12-31 san:LoansAndAdvancesCreditInstitutionsMember 5493006QMFDDMYWIAM13 2023-12-31 san:LoansAndAdvancesCreditInstitutionsMember 5493006QMFDDMYWIAM13 2025-12-31 san:LoansAndAdvancesCustomersMember 5493006QMFDDMYWIAM13 2024-12-31 san:LoansAndAdvancesCustomersMember 5493006QMFDDMYWIAM13 2023-12-31 san:LoansAndAdvancesCustomersMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:PropertyPlantAndEquipmentNotSubjectToOperatingLeasesMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:PropertyPlantAndEquipmentNotSubjectToOperatingLeasesMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:PropertyPlantAndEquipmentNotSubjectToOperatingLeasesMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:PropertyPlantAndEquipmentSubjectToOperatingLeasesMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:PropertyPlantAndEquipmentSubjectToOperatingLeasesMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:PropertyPlantAndEquipmentSubjectToOperatingLeasesMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:DerivativesMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:DerivativesMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:DerivativesMember 5493006QMFDDMYWIAM13 2025-12-31 san:ShortPositionsMember 5493006QMFDDMYWIAM13 2024-12-31 san:ShortPositionsMember 5493006QMFDDMYWIAM13 2023-12-31 san:ShortPositionsMember 5493006QMFDDMYWIAM13 2025-12-31 san:DepositsMember 5493006QMFDDMYWIAM13 2024-12-31 san:DepositsMember 5493006QMFDDMYWIAM13 2023-12-31 san:DepositsMember 5493006QMFDDMYWIAM13 2025-12-31 san:DepositsCentralBanksMember 5493006QMFDDMYWIAM13 2024-12-31 san:DepositsCentralBanksMember 5493006QMFDDMYWIAM13 2023-12-31 san:DepositsCentralBanksMember 5493006QMFDDMYWIAM13 2025-12-31 san:DepositsCreditInstitutionsMember 5493006QMFDDMYWIAM13 2024-12-31 san:DepositsCreditInstitutionsMember 5493006QMFDDMYWIAM13 2023-12-31 san:DepositsCreditInstitutionsMember 5493006QMFDDMYWIAM13 2025-12-31 san:DepositsCustomersMember 5493006QMFDDMYWIAM13 2024-12-31 san:DepositsCustomersMember 5493006QMFDDMYWIAM13 2023-12-31 san:DepositsCustomersMember 5493006QMFDDMYWIAM13 2025-12-31 san:DebtInstrumentsMember 5493006QMFDDMYWIAM13 2024-12-31 san:DebtInstrumentsMember 5493006QMFDDMYWIAM13 2023-12-31 san:DebtInstrumentsMember 5493006QMFDDMYWIAM13 2025-12-31 san:OtherFinancialLiabilitiesMember 5493006QMFDDMYWIAM13 2024-12-31 san:OtherFinancialLiabilitiesMember 5493006QMFDDMYWIAM13 2023-12-31 san:OtherFinancialLiabilitiesMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:FinancialLiabilitiesAtFairValueThroughProfitOrLossDesignatedUponInitialRecognitionCategoryMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:FinancialLiabilitiesAtFairValueThroughProfitOrLossDesignatedUponInitialRecognitionCategoryMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:FinancialLiabilitiesAtFairValueThroughProfitOrLossDesignatedUponInitialRecognitionCategoryMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMember 5493006QMFDDMYWIAM13 2025-12-31 san:PensionsAndOtherEmploymentDefinedBenefitObligationsProvisionMember 5493006QMFDDMYWIAM13 2024-12-31 san:PensionsAndOtherEmploymentDefinedBenefitObligationsProvisionMember 5493006QMFDDMYWIAM13 2023-12-31 san:PensionsAndOtherEmploymentDefinedBenefitObligationsProvisionMember 5493006QMFDDMYWIAM13 2025-12-31 san:OtherLongTermEmployeeBenefitsProvisionMember 5493006QMFDDMYWIAM13 2024-12-31 san:OtherLongTermEmployeeBenefitsProvisionMember 5493006QMFDDMYWIAM13 2023-12-31 san:OtherLongTermEmployeeBenefitsProvisionMember 5493006QMFDDMYWIAM13 2025-12-31 san:TaxesAndOtherLegalContingenciesProvisionMember 5493006QMFDDMYWIAM13 2024-12-31 san:TaxesAndOtherLegalContingenciesProvisionMember 5493006QMFDDMYWIAM13 2023-12-31 san:TaxesAndOtherLegalContingenciesProvisionMember 5493006QMFDDMYWIAM13 2025-12-31 san:CommitmentsAndGuaranteesGivenProvisionMember 5493006QMFDDMYWIAM13 2024-12-31 san:CommitmentsAndGuaranteesGivenProvisionMember 5493006QMFDDMYWIAM13 2023-12-31 san:CommitmentsAndGuaranteesGivenProvisionMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:MiscellaneousOtherProvisionsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:MiscellaneousOtherProvisionsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:MiscellaneousOtherProvisionsMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:LoanCommitmentsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:LoanCommitmentsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:LoanCommitmentsMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:FinancialGuaranteeContractsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:FinancialGuaranteeContractsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:FinancialGuaranteeContractsMember 5493006QMFDDMYWIAM13 2025-12-31 san:OtherCommitmentsMember 5493006QMFDDMYWIAM13 2024-12-31 san:OtherCommitmentsMember 5493006QMFDDMYWIAM13 2023-12-31 san:OtherCommitmentsMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:FinancialAssetsAtFairValueThroughOtherComprehensiveIncomeCategoryMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:FinancialAssetsAtFairValueThroughOtherComprehensiveIncomeCategoryMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:FinancialAssetsAtFairValueThroughOtherComprehensiveIncomeCategoryMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:FinancialAssetsAtAmortisedCostCategoryMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:FinancialAssetsAtAmortisedCostCategoryMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:FinancialAssetsAtAmortisedCostCategoryMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:InterestIncomeFromOtherFinancialAssetsMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:InterestIncomeFromOtherFinancialAssetsMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:InterestIncomeFromOtherFinancialAssetsMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:OtherFinancialAssetsAndLiabilitiesMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:OtherFinancialAssetsAndLiabilitiesMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:OtherFinancialAssetsAndLiabilitiesMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:FinancialAssetsReclassifiedFromFairValueWithChangesInOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:FinancialAssetsReclassifiedFromFairValueWithChangesInOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:FinancialAssetsReclassifiedFromFairValueWithChangesInOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:ReclassifiedFinancialAssetsFromAmortizedCostMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:ReclassifiedFinancialAssetsFromAmortizedCostMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:ReclassifiedFinancialAssetsFromAmortizedCostMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:OtherGainsOrLossesMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:OtherGainsOrLossesMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:OtherGainsOrLossesMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:ArgentinaHyperinflationaryEconomy 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:ArgentinaHyperinflationaryEconomy 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:ArgentinaHyperinflationaryEconomy 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:IssuedCapitalMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:SharePremiumMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 san:OtherEquityInstrumentsIssuedMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:OtherEquityInterestMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:IssuedCapitalMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:SharePremiumMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 san:OtherEquityInstrumentsIssuedMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:OtherEquityInterestMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:IssuedCapitalMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:SharePremiumMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 san:OtherEquityInstrumentsIssuedMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:OtherEquityInterestMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:IssuedCapitalMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:SharePremiumMember 5493006QMFDDMYWIAM13 2024-12-31 san:OtherEquityInstrumentsIssuedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:OtherEquityInterestMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:IssuedCapitalMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:SharePremiumMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:OtherEquityInstrumentsIssuedMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:OtherEquityInterestMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:IssuedCapitalMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:SharePremiumMember 5493006QMFDDMYWIAM13 2025-12-31 san:OtherEquityInstrumentsIssuedMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:OtherEquityInterestMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:RevaluationSurplusMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:OtherReservesMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:TreasurySharesMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 san:ProfitLossAttributableToShareholdersOfParentMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 san:InterimDividendsMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:RevaluationSurplusMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:OtherReservesMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:TreasurySharesMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 san:ProfitLossAttributableToShareholdersOfParentMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 san:InterimDividendsMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:RevaluationSurplusMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:OtherReservesMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:TreasurySharesMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 san:ProfitLossAttributableToShareholdersOfParentMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 san:InterimDividendsMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:RevaluationSurplusMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:OtherReservesMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:TreasurySharesMember 5493006QMFDDMYWIAM13 2024-12-31 san:ProfitLossAttributableToShareholdersOfParentMember 5493006QMFDDMYWIAM13 2024-12-31 san:InterimDividendsMember 5493006QMFDDMYWIAM13 2024-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2024-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember 5493006QMFDDMYWIAM13 2024-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:RevaluationSurplusMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:OtherReservesMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:TreasurySharesMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:ProfitLossAttributableToShareholdersOfParentMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:InterimDividendsMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember 5493006QMFDDMYWIAM13 2025-01-01 2025-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:RevaluationSurplusMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:OtherReservesMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:TreasurySharesMember 5493006QMFDDMYWIAM13 2025-12-31 san:ProfitLossAttributableToShareholdersOfParentMember 5493006QMFDDMYWIAM13 2025-12-31 san:InterimDividendsMember 5493006QMFDDMYWIAM13 2025-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2025-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember 5493006QMFDDMYWIAM13 2025-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:IssuedCapitalMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:SharePremiumMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 san:OtherEquityInstrumentsIssuedMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:OtherEquityInterestMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:IssuedCapitalMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:SharePremiumMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 san:OtherEquityInstrumentsIssuedMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:OtherEquityInterestMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:IssuedCapitalMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:SharePremiumMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 san:OtherEquityInstrumentsIssuedMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:OtherEquityInterestMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:IssuedCapitalMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:SharePremiumMember 5493006QMFDDMYWIAM13 2023-12-31 san:OtherEquityInstrumentsIssuedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:OtherEquityInterestMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:IssuedCapitalMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:SharePremiumMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:OtherEquityInstrumentsIssuedMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:OtherEquityInterestMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:RevaluationSurplusMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:OtherReservesMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:TreasurySharesMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 san:ProfitLossAttributableToShareholdersOfParentMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 san:InterimDividendsMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:RevaluationSurplusMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:OtherReservesMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:TreasurySharesMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 san:ProfitLossAttributableToShareholdersOfParentMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 san:InterimDividendsMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:RevaluationSurplusMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:OtherReservesMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:TreasurySharesMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 san:ProfitLossAttributableToShareholdersOfParentMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 san:InterimDividendsMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:RevaluationSurplusMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:OtherReservesMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:TreasurySharesMember 5493006QMFDDMYWIAM13 2023-12-31 san:ProfitLossAttributableToShareholdersOfParentMember 5493006QMFDDMYWIAM13 2023-12-31 san:InterimDividendsMember 5493006QMFDDMYWIAM13 2023-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2023-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember 5493006QMFDDMYWIAM13 2023-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:RevaluationSurplusMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:OtherReservesMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:TreasurySharesMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:ProfitLossAttributableToShareholdersOfParentMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:InterimDividendsMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember 5493006QMFDDMYWIAM13 2024-01-01 2024-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:IssuedCapitalMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:SharePremiumMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 san:OtherEquityInstrumentsIssuedMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:OtherEquityInterestMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:IssuedCapitalMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:SharePremiumMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 san:OtherEquityInstrumentsIssuedMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:OtherEquityInterestMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:IssuedCapitalMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:SharePremiumMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 san:OtherEquityInstrumentsIssuedMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:OtherEquityInterestMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:IssuedCapitalMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:SharePremiumMember 5493006QMFDDMYWIAM13 2022-12-31 san:OtherEquityInstrumentsIssuedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:OtherEquityInterestMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:IssuedCapitalMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:SharePremiumMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:OtherEquityInstrumentsIssuedMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:OtherEquityInterestMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:RetainedEarningsExcludingProfitLossForReportingPeriodMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:RevaluationSurplusMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:OtherReservesMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:TreasurySharesMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 san:ProfitLossAttributableToShareholdersOfParentMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 san:InterimDividendsMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:PreviouslyStatedMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:RevaluationSurplusMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:OtherReservesMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:TreasurySharesMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 san:ProfitLossAttributableToShareholdersOfParentMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 san:InterimDividendsMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:FinancialEffectOfCorrectionsOfAccountingErrorsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:RevaluationSurplusMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:OtherReservesMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:TreasurySharesMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 san:ProfitLossAttributableToShareholdersOfParentMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 san:InterimDividendsMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:FinancialEffectOfChangesInAccountingPolicyMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:RevaluationSurplusMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:OtherReservesMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:TreasurySharesMember 5493006QMFDDMYWIAM13 2022-12-31 san:ProfitLossAttributableToShareholdersOfParentMember 5493006QMFDDMYWIAM13 2022-12-31 san:InterimDividendsMember 5493006QMFDDMYWIAM13 2022-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2022-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember 5493006QMFDDMYWIAM13 2022-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2022-12-31 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:RevaluationSurplusMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:OtherReservesMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:TreasurySharesMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:ProfitLossAttributableToShareholdersOfParentMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:InterimDividendsMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 ifrs-full:AccumulatedOtherComprehensiveIncomeMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:AccumulatedOtherComprehensiveIncomeAttributableToNonControllingInterestsMember 5493006QMFDDMYWIAM13 2023-01-01 2023-12-31 san:NonControllingInterestExcludingAccumulatedOtherComprehensiveIncomeMember
BANCO SANTANDER, S.A.
ANNUAL REPORT
FOR THE YEAR ENDED 31 DECEMBER 2025
TABLE OF CONTENTS

Part 1.- Consolidated directors’ report, auditor's report and consolidated financial statements | 3
Part 2.- Supplemental information | 911

Part 1.
Consolidated directors´ report, auditor's report and
consolidated financial statements

2025 Annual report Unless otherwise specified, references in this annual report to other documents, including but not limited to other reports and websites, including our own, are for information purposes only. If the contents of such other documents and websites refer to this annual report, they are not nor should be considered part of it. Unless the context suggests otherwise, 'Banco Santander' means Banco Santander, S.A., and 'Santander', 'the Group' and 'Grupo Santander' mean Banco Santander, S.A. and subsidiaries. |  |

Annual report 2025 3
C onsolidated directors’ report

Business model and strategy | 7

The Santander Way | 8
Our business model | 9
2025 results | 10
Looking ahead | 16

Sustainability statement | 17

Consolidated non-financial information and sustainability
information statement

1. Sustainability at Santander (General information) | 21
2. Climate transition plan (Environmental information) | 31
3. Supporting employees, communities and customers (Social information) | 70
4. Business conduct (Governance information) | 93
Sustainability notes | 99
Independent verification report | 243
Other sustainability information | 249

Corporate governance | 251

1. 2025 overview | 253
2. Ownership structure | 260
3. Shareholders and general meeting | 266
4. Board of directors | 274
5. Senior management team | 324
6. Remuneration | 326
7. Group structure and internal governance | 358
8. Internal control over financial reporting (ICFR) | 361
9. Other corporate governance information | 369

Economic and financial review | 409

1. Economy, regulation and competition | 411
2. Significant events in 2025 | 417
3. Group selected data | 418
4. Group financial performance | 420
5. Financial information by segment | 464
6. Alternative performance measures (APMs) | 499
7. Technological innovation: artificial intelligence, cybersecurity and fintech ecosystem | 509
8. Significant events since year end | 512
9. New reporting structure from 1 January 2026 | 513
10. Trend information 2026 | 537

Risk management and compliance | 546

1. Risk management and control model | 548
2. Credit risk | 556
3. Market, structural and liquidity risk | 568
4. Capital risk | 580
5. Operational risk | 582
6. Compliance risk | 588
7. Model risk | 594
8. Strategic risk | 596

Glossary of terms, acronyms and abbreviations | 599

Auditor's report and consolidated financial statements

Auditor's report | 609
Consolidated financial statements | 619

Notes to the consolidated financial statements | 635
Appendix | 864

General information | 908

Annual report 2025 4

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2025 consolidated
directors’ report
This report was approved unanimously by our board
of directors on 24 February 2026
Our approach to this document
We changed the layout of our consolidated directors’ report in
2018 to include the contents previously provided in these
documents, which we no longer prepare separately:
• Annual report
• Consolidated directors’ report
• Annual corporate governance report
• Board committee reports
• Sustainability report
• Annual report on our directors’ remuneration
The consolidated directors’ report also includes all information
required by Spanish Act 11/2018 on non-financial information and
diversity and the information on sustainability prepared by the
Group in accordance with the European Standards of Sustainability
Reporting (ESRS). It can be found in the 'Sustainability statement'
chapter, which constitutes the consolidated non-financial
information statement and sustainability information.
The consolidated directors' report is originally issued in Spanish. In
the event of a discrepancy with this translation, the Spanish-
version prevails.
Auditors’ reviews
As required by law, our 2025 consolidated directors’ report was
subject to three reviews by our independent statutory auditors,
PricewaterhouseCoopers Auditores, S.L. They can be summarized
as follows:
• PricewaterhouseCoopers Auditores, S.L. verified that the
information in this report is consistent with our consolidated
financial statements and that its contents comply with applicable
regulation. For more details, see 'Other information:
Consolidated management report section of the 'Auditor’s report'
within 'Auditor's report and consolidated annual accounts'.
• PricewaterhouseCoopers Auditores, S.L., issued a verification
report, with limited assurance, on the Consolidated Non-
Financial Information statement and the information on
sustainability required under Act 11/2018 and under the
European Standards of Sustainability Reporting (ESRS) included
in this consolidated directors' report. To read the verification
report, see the 'Independent verification report' in the
'Sustainability statement' chapter.
• PricewaterhouseCoopers Auditores, S.L. issued an independent
reasonable assurance report on the design and effectiveness of
Banco Santander's internal control system over financial
reporting, which can be found in section 8.6 'External auditor
report' of the 'Corporate governance' chapter.
Non-IFRS and alternative performance measures
This report contains financial information prepared according to
International Financial Reporting Standards (IFRS) and taken from
our consolidated financial statements, as well as alternative
performance measures (APMs) as defined in the Guidelines on
Alternative Performance Measures issued by the European
Securities and Markets Authority (ESMA) on 5 October 2015, and
other non-IFRS measures. The APMs and non-IFRS measures were
calculated with information from Grupo Santander; however, they
are neither defined or detailed in the applicable financial reporting
framework nor audited or reviewed by our auditors.
We use the APMs and non-IFRS measures when planning,
monitoring and evaluating our performance. We consider them to
be useful metrics for our management and investors to compare
operating performance between accounting periods.
Nonetheless, the APMs and non-IFRS measures are supplemental
information; their purpose is not to substitute the IFRS measures.
Furthermore, companies in our industry and others may calculate
or use APMs and non-IFRS measures differently, thus making them
less useful for comparison purposes. APMs using environmental,
social and governance labels have not been calculated in
accordance with the Taxonomy Regulation or with the indicators
for principal adverse impact in SFDR.
For more details on APMs and non-IFRS measures, see sections 6.
'Alternative performance measures (APMs)' and 9.2 'Alternative
performance measures (APMs) of the new reporting structure' of
the 'Economic and financial review' chapter and section SN 9
'Alternative performance measures (APMs)' of the 'Sustainability
statement' chapter.
Annual report 2025 5

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Sustainability information
This report contains, in addition to financial information,
sustainability-related information, including environmental, social
and governance-related metrics, statements, goals, targets,
commitments and opinions. The sustainability information can be
found throughout the report but mostly in the 'Sustainability
statement' chapter.
The sustainability information is provided in accordance with
Directive 2022/2464 on corporate sustainability reporting (CSRD)
and Law 11/2018 on non-financial and diversity reporting.
Sustainability information is not audited nor, save as expressly
indicated under ‘Auditors’ reviews’, reviewed by an external
auditor. Sustainability information is prepared following various
external and internal frameworks, reporting guidelines and
measurement, collection and verification methods and practices,
which may materially differ from those applicable to financial
information and are in many cases emerging and evolving.
Sustainability information is based on various materiality
thresholds, estimates, assumptions, judgments and underlying
data derived internally and from third parties. Sustainability
information is thus subject to significant measurement
uncertainties, may not be comparable to sustainability information
of other companies or over time or across periods and its inclusion
is not meant to imply that the information is fit for any particular
purpose or that it is material to us under mandatory reporting
standards. The sustainability information is for informational
purposes only, without any liability being accepted in connection
with it except where such liability cannot be limited under
overriding provisions of applicable law.
Forward-looking statements
Banco Santander hereby warns that this annual report contains
'forward-looking statements', as defined by the US Private
Securities Litigation Reform Act of 1995. Such statements can be
understood through words and expressions like 'expect', 'project',
'anticipate', 'should', 'intend', 'probability', 'risk', 'VaR', 'RoRAC',
'RoRWA', 'TNAV', 'target', 'goal', 'objective', 'estimate', 'future',
'ambition', 'aspiration', 'commitment', 'commit', 'focus', 'pledge'
and similar expressions. They include (but are not limited to)
statements on future business development, shareholder
remuneration policy and non-financial information. However, risks,
uncertainties and other important factors may lead to
developments and results that differ materially from those
anticipated, expected, projected or assumed in forward-looking
statements.
The important factors below (and others described elsewhere in
this report), as well as other unknown or unpredictable factors,
could affect our future development and results and could lead to
outcomes materially different from what our forward-looking
statements anticipate, expect, project or assume:
• general economic or industry conditions (e.g., an economic
downturn; higher volatility in the capital markets; inflation;
deflation; changes in demographics, consumer spending,
investment or saving habits; and the effects of the war in
Ukraine, the uncertainties following the ceasefire agreement in
the Middle East or the outbreak of public health emergencies in
the global economy) in areas where we have significant
operations or investments;
• exposure to operational risks, including cyberattacks, data
breaches, data losses and other security incidents;
• exposure to market risks (e.g., risks from interest rates, foreign
exchange rates, equity prices and new benchmark indices);
• potential losses from early loan repayment, collateral
depreciation or counterparty risk;
• political instability in Spain, the US, the UK, other European
countries and Latin America;
• changes in monetary, fiscal and immigration policies and trade
tensions, including the imposition of tariffs and retaliatory
responses;
• legislative, regulatory or tax changes (including regulatory
capital and liquidity requirements) and greater regulation
prompted by financial crises;
• acquisitions, dispositions, integrations and challenges arising
from deviating management’s resources and attention from
other strategic opportunities and operational matters;
• reputational risk and potential adverse reactions of stakeholders,
including adverse effects on the market price of our securities;
• climate-related conditions, regulations, targets and weather
events;
• uncertainty over the scope of actions that may be required by us,
governments and other to achieve goals relating to climate,
environmental and social matters, as well as the evolving nature
of underlying science and industry and governmental standards
and regulations;
• our own decisions and actions, including those affecting or
changing our practices, operations, priorities, strategies, policies
or procedures; and
• changes affecting our access to liquidity and funding on
acceptable terms, especially due to credit spread shifts or credit
rating downgrade for the entire group or core subsidiaries.
Forward looking statements are based on current expectations and
future estimates about Santander’s and third-parties’ operations
and businesses and address matters that are uncertain to varying
degrees, including, but not limited to developing standards that
may change in the future; plans, projections, expectations, targets,
objectives, strategies and goals relating to environmental, social,
safety and governance performance, including expectations
regarding future execution of Santander’s and third parties’ energy
and climate strategies, and the underlying assumptions and
estimated impacts on Santander’s and third-parties’ businesses
related thereto; Santander’s and third-parties’ approach, plans and
expectations in relation to carbon use and targeted reductions of
emissions; changes in operations or investments under existing or
future environmental laws and regulations; and changes in
government regulations and regulatory requirements, including
those related to climate-related initiatives.
Forward-looking statements are aspirational, should be regarded
as indicative, preliminary and for illustrative purposes only, speak
only as of the date of approval of this annual report and are
informed by the knowledge, information and views available on
such date and are subject to change without notice. Banco
Santander is not required to update or revise any forward-looking
statements, regardless of new information, future events or
otherwise, except as required by applicable law.
Annual report 2025 6

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Past performance does not indicate future outcomes
Statements about historical performance or growth rates must not
be construed as suggesting that future performance, share price or
earnings (including earnings per share) will necessarily be the
same or higher than in a previous period. Nothing in this annual
report should be taken as a profit and loss forecast.
XHTML electronic format and XBRL tags
This annual report was prepared in eXtensible HyperText Markup
Language (XHTML) format. The consolidated financial statements
and the notes to the consolidated financial statements that it
includes, have been tagged with eXtensible Business Reporting
Language (XBRL), in accordance with Directive 2004/109/EC and
Commission Delegated Regulation (EU) 2019/815.
To view the XBRL tags, you must open this document with an
appropriate viewer. You can find this document with an XBRL
viewer on Banco Santander's corporate website.
Not a securities offer
This annual report and the information it contains does not
constitute an offer to sell, nor a solicitation of an offer to buy any
securities.
Glossary of terms, acronyms and abbreviations
To facilitate a better understanding of this anual report, a glossary
of terms, acronyms and abbreviations has been included at the end
of the consolidated directors' report.
Annual report 2025 7

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Business model and strategy
Annual report 2025 8

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

The Santander Way

| Our purpose |  |  |  | Our aim |  |  |  | Our how |
| To help people and businesses prosper |  |  |  | To be the best open financial services platform by acting responsibly and earning the lasting loyalty of our people, customers, shareholders and communities |  |  |  | Everything we do should be Simple, Personal and Fair |

Annual report 2025 9

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Our business model
Generating value for our stakeholders

CUSTOMER FOCUS |  | Building a digital bank with branches

→ Customer focus is the essence of our strategy. Our multichannel
offering enables us to fulfil all our customers' financial needs,
making us their global, trusted and responsive partner.
→ Our customer growth investments are centred around three basic
things: providing great products at competitive prices, a frictionless
digital experience and being a trusted financial partner.
→ We are building a digital bank with branches to make our
customers' lives easier. By merging technology with human touch,
we offer fully-digital products while ensuring our branches provide
support and advice. This blend of innovation and personalization
ensures our customers get the best of both worlds.

| 2024 | 2025
Total customers (mn) | 173 | 180
Active customers (mn) | 103 | 106

SCALE |  | Global & in-market scale

→ Santander has a unique combination of global scale and local
leadership.
→ Our activities are organized under five global businesses: Retail &
Commercial Banking, Digital Consumer Bank, Corporate &
Investment Banking, Wealth Management & Insurance and
Payments.
→ These five global businesses support value creation based on the
profitable growth and operational leverage that ONE Santander
and network benefits provide.
→ Our global approach to technology and development of global
platforms is helping us to provide our customers with cost
competitive products and the best digital experience.

|  |  |  |  |  |  |  |  |  |  |  | ONE Santander
Global businesses |  |  | Retail | Retail & Commercial Banking | }
| Consumer | Digital Consumer Bank | }
| CIB | Corporate & Investment Banking | }
| Wealth | Wealth Management & Insurance | }
| Payments | Payments | }
From 2026 onwards, Digital Consumer Bank and Payments will be renamed Openbank and Payment Solutions, respectively.

DIVERSIFICATION |  | Business, geographical and balance sheet

→ Our simple and well-targeted range of products and services
meets the needs of a wide spectrum of customers: individuals,
SMEs, mid-market companies, large corporates, Wealth
Management customers, first-time banking customers, auto
customers and dealers.
→ Santander has a strong, simple and diversified balance sheet in
terms of products, businesses and markets, with a very low
exposure to market risk and is highly collateralized and made up
mainly of loans.
→ Diversification and a medium-low risk profile deliver recurrent pre-
provision profit, with among the lowest volatility across peers.

Group net operating income (pre-provision profit)
EUR billion

Our unique business model and consistent execution of our strategy provide higher returns and value creation for our shareholders and, at the same time, lower volatility

Annual report 2025 10

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2025 results
Record results for the fourth consecutive year with a strong growth of 8 million new
customers

→ Record profit , underpinned by higher customer activity → Strong operating performance and profitability on the back of ONE Transformation → Solid balance sheet with robust credit quality and very strong organic capital generation → Capital productivity and disciplined capital allocation are driving double-digit value creation

FY'25 Attributable Profit |  | Fees
€14.1bn +12% |  | €13.7bn +5%
Efficiency ratio |  | RoTE
41.2% –0.6pp |  | post-AT1 | pre-AT1
| 16.3% +0.8pp | 17.1% +0.8pp
CoR |  | CET1
1.15% -0pb |  | 13.5% +0.7pp
TNAVps + DPS |  | EPS
+14% YoY |  | +17% YoY

Note: YoY changes. In constant euros: FY'25 attributable profit +16% and fees +9%. CET1 ratio on a phased-in basis, i.e. in accordance with the transitory treatment of the CRR. YoY
comparison based on published Dec-24 ratio, which was calculated on a fully-loaded basis. TNAVps + Cash DPS includes the €11.00 cent cash dividend per share paid in May 2025
and the €11.50 cent cash dividend per share paid in November 2025, both forming part of our shareholder remuneration policy.
Delivering on all our 2025 and key Investor Day targets

|  |  |  | 2025 |  | 2023-25 |
|  |  |  | 2025 | Targets | 2023-25 | ID targets |
Revenue |  | u |  | €62.4bn | c.€62bn | ü | +8% CAGR 22-25 | c.7-8% CAGR 22-25 | ü
Fees |  | u |  | +9% | Mid-high single digit growth | ü | +7% CAGR 22-25 | c.8-9% CAGR 22-25 |
Cost base |  | u |  | -1% in euros | Down vs. 2024 in euros | ü | +4% CAGR 22-25 | c.4-5% CAGR 22-25 | ü
Efficiency ratio |  | u |  |  |  |  | 41.2% in 2025 | c.42% in 2025 | ü
CoR |  | u |  | 1.15% | c.1.15% | ü | 1.15% in 2025 | c.1.0-1.1% |
CET1 A |  | u |  | 13.5% | 13% operating range 12-13% | ü | 13.5% in 2025 | >12% post-Basel III | ü
RoTE |  | u |  | 16.3 post-AT1 | c.16.5% post-AT1 | ü | 17.1% pre-AT1 | in 2025 | 15-17% pre-AT1 | ü
TNAVps + Cash DPS |  | u |  | +14% | Double-digit growth through-the-cycle | ü | +14% CAGR 22-25 | Double-digit growth through-the-cycle | ü

Note: data and YoY changes in constant euros, unless otherwise indicated. TNAVps + Cash DPS includes the €11.00 cent cash dividend per share paid in May 2025 and the €11.50
cent cash dividend per share paid in November 2025, both forming part of our shareholder remuneration policy.
A. CET1 ratio is phased-in, calculated in accordance with the transitory treatment of the CRR.
Annual report 2025 11

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Our unique business model and execution of our strategy deliver higher returns with
lower volatility
A. % of operating areas, excluding the Corporate Centre. LatAm includes Rest of the Group.
B. Calculated using quarterly data from Jan-99 to Q3’25. Source: Bloomberg, with GAAP criteria. Standard deviation of the quarterly EPS starting from the first available data since
Jan-99.
Value creation, driven by higher profitability, underpinned by three tenets:

| Think Value |  |  | Delivering double-digit value creation, on average through-the-cycle |
| Think Customer |  |  | Building a digital bank with branches with well-targeted products and services to grow our customer base |
| Think Global |  |  | Leveraging global and in-market scale, network and tech to deliver world class-services and accelerate profitable growth |

Annual report 2025 12

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Think Value
Delivering double-digit value creation, on average through-the-cycle
→ Delivering on all key Investor Day targets
FY'25 vs. 2025 ID targets (incl. upgrades in Q4’24)

| Strength |
| CET1 13.5% 13% | operating range: 12-13% |

| Shareholder remuneration |
| Payout 50% 50% target payout cash dividend + SBB B | Additional SBB A €6.7bn At least €10bn total SBB 2025-26 B |

| Disciplined capital allocation |
| RWAs with RoRWA > CoE 89% c.85% |

| Profitability |
| RoTE post-AT1 16.3% c.16.5% | RoTE pre-AT1 17.1% 15-17% |

Think Customer
Building a digital bank with branches with well-targeted products and services to grow our customer base
→ We are committed to delivering simple, lovable, life-centric products and experiences for customers

|  |  | 2024 | 2025
Customer centric | Total customers (mn) |  | 173 | 180
Simplification & automation | Efficiency ratio (%) |  | 41.8 | 41.2
Customer activity | Active customers (mn) |  | 103 | 106

A. Share buybacks already executed or launched in 2025 and 2026 to date, against the'at least €10bn Total SBB 2025-26' target. The €6.7bn amount includes i) €1.7bn share
buyback against H1’25 results, already completed on 23 December 2025, ii) €1.8bn share buyback against H2’25 results, announced on 3 February, for which the regulatory
approval has been received, and iii) €3.2bn additional share buyback to distribute approx. 50% of the CET1 capital generated following the completion of the sale of 49% of
Santander Bank Polska to Erste Group on 9 January 2026, as announced on 3 February 2026, for which the regulatory approval has been received. Additionally, €3.3bn against
future results and excess capital are expected to be executed, subject to future corporate and regulatory decisions and approvals.
B. For more details, see section 3.3 ‘Dividends and shareholder remuneration’ in the ‘Corporate governance’ chapter.
Annual report 2025 13

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Think Global
Leveraging global and in-market scale, network and tech to deliver world class-services and accelerate profitable
growth
→ Our transformation and five global businesses structurally deliver higher revenue with lower costs, supporting our ambition to
become the most profitable bank in every market where we operate
Our five global businesses

RETAIL |  | CONSUMER |  | CIB |  | WEALTH |  | PAYMENTS
Global business integrating our retail and commercial banking activities |  | A digital bank that combines state-of- the-art technology with a personal and human touch |  | Our global platform to support corporate and institutional clients |  | Common service models for our private banking, asset management and insurance activities |  | Single infrastructures for payment solutions

We are a global Retail and Consumer powerhouse with 180 million customers
Strong results underpinned by growth across our five global businesses

| 2025 vs. 2024 | Revenue (€ bn) | Contribution to Group revenue | Efficiency | Profit (€ bn) | RoTE post-AT1 | Profitability 2025 targets
| Retail | 31.2 -0% | 50% | 39.4% -0.1pp | 7.7 +9% | 17.7% -0.4pp | c.17% | ü
| Consumer | 13.0 +4% | 21% | 40.6% +0.5pp | 1.7 +8% | 8.6% -0.3pp | c.12% |
| CIB | 8.5 +5% | 13% | 45.5% +0.0pp | 2.8 +7% | 19.1% +1.8pp | c.20% | ü
| Wealth | 4.2 +14% | 7% | 35.3% -2.9pp | 2.1 +27% | 68.5% -8.4pp | c.60% | ü
| Payments | 6.0 +17% | 9% | 39.2% -5.3pp | 0.9 A +50% | PagoNxt EBITDA margin 34.5% +7.0pp | >30% | ü

Note: YoY changes in constant euros.
Contribution to Group revenue as a percentage of total operating areas, excluding the Corporate Centre. Global businesses’ RoTEs are adjusted based on Group’s deployed capital;
targets have been adjusted for AT1 costs.
A. Payments YoY variation excluding the PagoNxt write-downs in Q2’24 of our investments related to our merchant platform in Germany and Superdigital in Latin America
(€243mn, net of tax and minority interests).
Annual report 2025 14

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Retail & Commercial Banking
Driving operational leverage through ONE Transformation, while delivering a differential customer
experience through our digital bank with branches
Note: data and YoY changes in constant euros.
A. Metrics cover all products and employees in the branch network in our 10 main countries.
Digital Consumer Bank
Scaling our digital bank and global platforms while optimizing the funding structure
Note: data and YoY changes in constant euros.
ANEAs: average net earning assets, including renting.
Annual report 2025 15

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Corporate & Investment Banking
Leveraging our strengths to better serve our corporate customers and institutions
Note: data and YoY changes in constant euros.
Wealth Management & Insurance
Accelerating our customers’ connectivity with our global product platforms
Note: data and YoY changes in constant euros.
Assets under management includes deposits and off-balance sheet assets. Revenue including ceded fees includes all fees generated by Santander Asset Management and
Insurance, even those ceded to the commercial network, which are reflected in Retail’s P&L.
Annual report 2025 16

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Payments
Seizing a growing opportunity by capturing scale through global platforms
Note: data and YoY changes in constant euros.
# transactions include merchant payments, cards and electronic A2A payments. Payments volume includes Total Payments Volume (TPV) in Getnet and Cards spending. Like-for-
like excludes perimeter effects, mainly the decision to discontinue the merchant platform in Germany and Superdigital in Q2 2024.

Looking ahead
Santander is now AT SCALE IN ALL OUR CORE MARKETS which will accelerate our value
creation in the next strategic cycle

Targets market dependent
|  | Revenue growth |  | Costs |  | Profit |  | CET1
2026 Excluding Poland, TSB and Webster in 2025-26 |  | Mid-single digit in constant euros |  | Down in constant euros |  | Up vs. €14.1bn in 2025 |  | 12.8-13% operating range: 12-13%
| With fees growing more than NII |  | Resulting in positive operational leverage |  |
2027 including TSB and Webster |  | Double digit in constant euros |  | Positive operational leverage |  | Up mid teens A in constant euros |  | >13% operating range: 12-13%
2028 |  | RoTE B >20%
Assuming CoR stable
At least double-digit TNAVps + DPS growth through the cycle

Note: targets market dependent. Based on macro assumptions aligned with international economic institutions. CET1 targets including all the impacts from inorganic transactions.
A. Excluding the capital gain resulting from the sale of Santander Bank Polska to Erste Group in 2026, as well as TSB and Webster integration and restructuring charges.
B. 2028 RoTE is post-AT1.
Annual report 2025 17

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Sustainability statement
Consolidated non-financial information statement and sustainability information
Annual report 2025 18

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

About this chapter
This report shows the performance of Grupo Santander in 2025 in those environmental, social and
governance issues that have been identified as material (for the purposes of this report, materiality is
aligned with the European Corporate Sustainability Reporting Directive - CSRD).

Scope
The information contained covers the core activities of Banco
Santander and its subsidiaries from 1 January to 31 December
2025 (for more details, see Notes 1 , 2 , 3 and 53 to the consolidated
financial statements and sections 3 and 4 in the 'Economic and
financial review' chapter). The scope of information and changes in
criteria applied with respect to the 2024 Sustainability statement,
when significant, are reflected in each relevant section and
generally in the 'Sustainability note 1' of this chapter.

Regulation, reporting standards and other references
that this chapter addresses
This chapter contains the 'Consolidated non-financial information
statement and sustainability information' of Grupo Santander, in
compliance with Directive (EU) 2022/2464, with regard to the
presentation of information on sustainability by companies,
prepared in accordance with the European Sustainability Reporting
Standards (ESRS) framework, comprising Commission Delegated
Regulation (EU) 2023/2772 and Commission Delegated Regulation
(EU) 2025/1416, and in compliance with Law 11/2018, which
amends Article 49 of the Commercial Code, and the Regulation on
European Taxonomy (Regulation (EU) 2020/852 and Commission
Delegated Regulations 2021/2139 and 2021/2178 as amended by
Delegated Regulations (EU) 2022/1214, 2023/2485, 2023/2486
and 2026/73). Likewise, the information included in the section
2 'Climate, our transition plan' allows the Group to address the
requirements of Law 7/2021 on climate change and Royal Decree
214/2025 of the Spanish legal system.

External validation
PricewaterhouseCoopers Auditores, S.L., an independent firm
charged with auditing the financial statements of Banco Santander
S.A. and the Group, issued a verification report, with limited
assurance, on the Consolidated Non-Financial Information and
sustainability statement required under Act 11/2018 and the
European Sustainability Reporting Standards (ESRS). The report’s
conclusion can be found in the 'Independent verification report' at
the end of this chapter. For more details on the preparation and
levels of control of sustainability information, see the
'Sustainability information' section in the introductory pages of this
consolidated management report 2025, and the 'Sustainability
note 1 and 2' in this chapter.

| For more details, see 'Sustainability information' in the introduction of this Annual report

Annual report 2025 19

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Contents

About this chapter | 18
Sustainability 2025 summary | 20
1. Sustainability at Santander (General information) | 21
1.1 Sustainability strategy | 21
1.2 Materiality assessment | 23
1.3 Stakeholder engagement | 25
1.4 Sustainability governance | 29
2. Climate transition plan (Environmental information) | 31
2.1 Climate Strategy | 31
2.2 Supporting our customers' transition | 33
2.3 Embedding ESG factors in risk management | 39
2.4 Aiming to align our activity with the Paris Agreement Goals | 55
2.5 Further actions and enablers | 68
3. Supporting employees, communities and customers (Social information) | 70
3.1 Our employees | 70
3.1.1 Talent and skills development | 70
3.1.2 Working conditions | 72
3.1.3 Inclusive culture | 75
3.1.4 Employee feedback and experience | 76
3.2 Sustainable development in our communities | 77
3.2.1 Supporting the economic and social development of our communities | 77
3.2.2 Responsible investment and social finance | 77
3.2.3 Management of environmental and social aspects | 80
3.2.4 Community Support | 81
3.3 Our customers | 85
3.3.1 Conduct with customers | 86
3.3.2 Financial inclusion and financial health | 88
3.3.3 Privacy, data protection and cybersecurity | 91

4. Business conduct (Governance information) | 93
4.1 Corporate culture | 93
4.2 Ethical conduct | 94
4.3 Ethical channels | 96
4.4 Our suppliers | 98
Sustainability notes | 99
SN 1. Introduction, basis of the consolidated sustainability statement and other information | 99
SN 2. Sustainability governance | 110
SN 3. Materiality assessment – Detailed methodology | 114
SN 4. Climate transition plan | 123
SN 5. EU Taxonomy | 125
SN 6. Classification system and funding framework | 127
SN 7. Our progress in figures | 129
SN 8. Additional metrics to comply with Spanish Act 11/2018 | 226
SN 9. Alternative performance measures (APMs) | 227
SN 10. Non-financial information Act 11/2018 content index | 230
SN 11. Commission Delegated Regulation (EU) 2023/2772 on sustainability reporting standards content index | 235
Independent verification report | 243
Other sustainability information | 249
Table of equivalence between CSRD and ISSB | 249

Annual report 2025 20

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Sustainability 2025 summary
We help people and businesses prosper

| We contribute to the economic, financial and social development of our communities. |
→ EUR 332.9 billion to help people buy homes, enabling 3.6 million families to access housing. EUR 209.7 billion to purchase other goods. A
→ EUR 318 billion to help set up or grow companies (including 743,000 SMEs and sole traders).B
→ EUR 12.3 billion paid to suppliers. 92% are local and account for 90% of total procurement turnover.
→ EUR 9.6 billion in taxes paid by the Group and EUR 12.5 billion in third party taxes channelled to tax authorities.
→ EUR 163.7 million in community support, helping 9.9 million people and organizations. Since 2023, we have allocated EUR 311 million to promote education, employability and entrepreneurship.

| We help our customers progress in their sustainability goals. |
→ EUR 174 billion in green finance raised and facilitated since 2019, reaching our EUR 120 billion target 18 months early.
→ Additionally, our credit stock in green mortgages and auto aligned with EU Taxonomy grew 8% .
→ We reached EUR 129.9 billion in assets under management in socially responsible investment, reaching our EUR 100 billion target nine months early.

| We offer a range of products and services tailored to our customers’ needs. We follow responsible practices, support their financial inclusion, and protect their information. |
→ 6.3 million new people financially included since 2023, reaching our 5 million target to 2025 half year early. → Our microfinance propositions in Latin America reached 1.8 million underbanked entrepreneurs with EUR 1.26 billion in credit disbursed.

| We help our employees develop by promoting an inclusive culture and lifelong learning, and by providing fair working conditions. |
→ 198,403 employees. EUR 13.6 billion paid in wages and benefits.C → 38.5% of our senior leaders are women.

| We act responsibly through a strong culture, governance and conduct. |

We help people and businesses prosper by providing responsible, accessible financial solutions in the markets where we operate. |  | We take business driven decisions to create sustainable value for our shareholders. |  | We identify and manage material risks in accordance with local law and regulation and our risk appetite to support long-term resilience.
We engage with our stakeholders and consider their views to act in the long-term interests of our business and our customers. |  | We deploy our business model to tackle global challenges creating profit with purpose. We believe economies function best when open, fair and rules-based competition can thrive. |  | Our goals are designed to identify and capture opportunities, aiming to help our customers' in their sustainability goals.

A. Credit stock and mortgage holdings as at 31 December 2025. The credit stock figure excludes information relating to Santander Bank Polska S.A. and its subsidiaries
B. Credit stock as at 31 December 2025. Data for small and medium enterprises (SMEs) and sole traders covers individual customers with an outstanding loan at
2025 year end. The credit stock figure excludes information relating to Santander Bank Polska S.A. and its subsidiaries
C. Does not include information relating to Santander Bank Polska S.A. and its subsidiaries
Annual report 2025 21

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

1. Sustainability at Santander
(General information)
1.1 Sustainability strategy
Grupo Santander’s purpose is to help people and businesses
prosper. We aim to be the best open financial services platform by
acting responsibly and earning the lasting loyalty of our
employees, customers, shareholders and communities.
Grupo Santander serves over 180 million customers worldwide
through our unique combination of global scale and local
leadership. We’re among the top 3 in lending, deposits and mutual
funds in most of our core markets. Our leadership position speaks
to our scale and the competitive advantage that our integrated
model affords.
Our diverse customer base includes individuals, SMEs, large
corporates, high net worth clients and others, all with varying
financial needs and expectations that can change overnight. Our
simple, tailor-made products and services, coupled with our
multichannel proposition, seek to meet those needs.
Santander has c. 200,000 employees and our activities are
organized under five global businesses: Retail and Commercial
Banking; Digital Consumer Bank; Corporate and Investment
Banking; Wealth Management and Insurance; and Payments.

| For more details on the value chain, see SN 1. For more details on the distribution of employees by geographical area, see Table 6 in SN 7.3 Employees

Our sustainability strategy focuses on matters that pose material
opportunity, risk and impact to Santander (see section 1.2
'Materiality assessment') and has five pillars:
1. Help our customers in meeting their goals in their transition to a
low-carbon economy while also managing climate-related risks
and impacts.
2. Help our employees develop by promoting an inclusive culture
and learning and providing fair working conditions.
3. Contribute to the economic, financial and social development of
our communities, with a special focus on education,
employability and entrepreneurship.
4. Be a trusted partner to our customers, with products and
services that adapt to their needs, while applying responsible
practices, supporting their financial inclusion, and protecting
their information.
5. Act responsibly through a strong culture, governance and
conduct.
Our sustainability strategy is informed by the regulatory
frameworks of the markets where we operate, in accordance with
local law and regulation, and it is shaped by public policies. It
embeds the Group’s three action lines: Think Value, Think
Customer and Think Global to drive business growth and become
more resilient to increasing environmental, governance and social
risks.
→ Think Value: Profitable growth makes us resilient and able to
withstand shocks, invest in our employees and customer value
proposition, support our communities, and create value for our
shareholders.
→ Think Customer: Be the partner of choice for our customers by
offering the best products and helping them in their transition to a
low-carbon economy and support their financial inclusion and
financial health (including financial education).
→ Think Global: Use our scale and local leadership to tackle global
sustainability challenges.
Having cemented the foundations of our strategy, the Group is
focusing on a new phase of execution to accelerate operational
transformation, continue our path of customer growth, and
strengthen sustained value creation, leveraging in our global scale.
Embedding our sustainability strategy
Santander’s sustainability strategy forms part of the Group’s
strategic plan, three-year financial plans, and annual budget. Our
Chief Executive Officer (CEO) leads the preparation of our financial
plan every year. The plan includes sustainability targets and
priorities that are consistent with our long-term strategy and the
applicable law and regulation. The strategy committee, executive
committee and the Group board of directors review the plan’s
outcome. Furthermore, all global businesses and each subsidiary
have their own financial plan that is reviewed to make sure it aligns
with the Group plan.
The Risk function conducts an analysis and challenge of the
strategic plan to identify potential threats that may compromise
the achievement of the Group's objectives. The risk control
committee and the board's risk supervision, regulation and
compliance committee discuss the outcome of this analysis.
Additionally, Santander has internal policies that establish the
principles, key processes, roles and responsibilities, and the
governance and tools associated with the management of risks
arising from environmental, social and governance factors. We
base this model on the Group's risk principles and culture; a clear
governance structure; and advanced risk management tools and
procedures.
Annual report 2025 22

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Santander regularly conducts an emerging risks exercise to identify
key threats to our strategic plan under theoretical stress scenarios
with low likelihood of occurrence. This exercise also considers
climate change factors such as physical and transition risk in
accordance with local law and regulation.
We aim to detect, assess and monitor risks that may have a
significant impact on our business model, profitability and solvency
to keep our strategy robust.

| For more details, see chapter 1.4 'Sustainability governance'

The Group’s sustainability strategy is implemented across the five
global businesses and metrics and targets that in some cases form
part of our remuneration schemes.
Corporate and Investment Banking
Our ambition is to be a strategic partner for our customers by
helping them achieve their transition and sustainability goals in a
profitable way.
We support our customers in pursuing those goals by offering
them products and services that follow the strictest integrity
standards. We focus on capturing business opportunities across
strategic transition themes, such as scaling low-carbon
infrastructure, accelerating emerging and enabling clean
technologies, mobilising sustainable capital markets and
supporting sustainable trade, supply chains and working capital.
Please see section 2.2.1 'Corporate and investment banking (CIB)'
for further detail and case studies.
We have been a leader in renewable energy project finance for a
decade. We met our target of EUR 120 billion in green finance
raised or facilitated (between 2019 and 2025) 18 months early. In
2025 we reached a total of EUR 174 billion in green finance raised
or facilitated by year end. We also acted as adviser on several of
the world’s biggest renewable energy financing transactions.
We support our clients by evaluating the robustness of their
transition plans and advising on key levers for improvement,
manage climate risks and progress towards achieving their climate
objectives in high-emitting sectors. Transition planning is assessed
in context, considering developments of local economy plans and
policy backdrop.
Retail and Commercial Banking
Our ambition is to be a driver of sustainable growth and to provide
solutions for all our customers (individuals, SMEs, large
corporates, and institutions).
We offer products and services that are designed to aid the energy
transition of homes and businesses according to best market
practice and to support the profitable and sustainable growth of
our business customers. We adapt our value proposition to each
market to align our action with local demands, regulation,
macroeconomic landscapes, in accordance with local law and
regulation.
We also work closely with multilateral development banks in
initiatives that support sustainable and energy transition in the
markets where we operate.
We measure the emissions of the key commercial and residential
property portfolios in Portugal, Spain and the United Kingdom and
agriculture portfolios in Brazil and identify alignment levers to our
customers' transition.
We also provide financial inclusion and health solutions. In June
2025, six months early, we reached our target to financially include
five million people between 2023 and 2025, giving support to
underbanked individuals through microfinance and banking access.
By year end we reached 6.3 million new people reached through
financial inclusion measures since 2023. Moreover, we run
financial education activities, which often reinforce our financial
inclusion programs.
Additionally, Santander is aiming to provide EUR 400 million in
support to education, employability and entrepreneurship between
2023 and 2026, while increasing the number of people engaged in
these programmes, including through platforms such as Santander
Open Academy.
Digital Consumer Bank
Our ambition is to continue supporting our customers’ transition,
namely in the auto finance market — where we are global leader
with more than 20 million customers — and the consumer finance
market.
We are supporting the transition by financing solutions that drive
fewer emissions, in accordance with local law and regulation. For
instance, through electric vehicle financing in Europe, where our
market share in 2025 stood at over 10%, with EUR 7.3 billion in
loans. An increased share of electric vehicles contributes to the
alignment of the auto financing portfolio in Europe and to our 2030
alignment target.
Wealth Management and Insurance
Our ambition is to address our customers' investment demand,
providing a sustainable proposition through our funds, portfolios,
insurance products and advisory services. In March 2025, nine
months early, we achieved our target of EUR 100 billion in assets
under management in socially responsible investment (SRI). By
year end this figure reached a total of EUR 129.9 billion.
We continue to bolster our sustainable solution proposition for
customers, including a wide range of fixed income, equity, mixed
and alternative funds, as well as themed products focused on
climate, energy transition and social well-being. Moreover, we
have SRI life-savings portfolios and products, as well as the ability
to build customized mandates around specific sustainability
preferences.
Payments
We continue to make headway in lowering the environmental
footprint of our cards by using sustainable materials and
promoting the recycling of cards. In 2025, 97% of the cards we
acquired were made of sustainable materials (recycled PVC / PLA),
which backs our commitment to follow a more environmentally-
friendly payment model.
We are also promoting financial education and health among our
customers through the creative Pay Smarter concept.
PagoNxt aims at continuing contributing to financial inclusion of
individuals, small businesses and sole traders in the communities
where we operate, particularly in South America.

| For more details on how our global businesses implement our sustainability strategy, see section 2.2 Supporting our customers in their transition goals'' and 3.2 Communities' sustainable development

1 We identified and published 32 IROs in annual report 2024. To align material impacts, risks and opportunities with our management throughout 2025, we merged six IROs
into three to give a new total of 29. Merged IROs: E1 opportunities (O Growth in the financing of renewable energy and other energy transition solutions). + O Revenue growth
by providing our customers with sustainable solutions in such sectors as construction, mobility or agriculture), Negative impacts of S3 (I- Finance activities (in any customer
segment) that breach the bank’s policies and jeopardize the well-being of present and future generations. + I- Potentially negative impact on the environment or society by
failing to sufficiently involve appropriate stakeholders or use suitable customer identification and management mechanisms when providing finance to a customer or project),
Negative impacts of S4 (I- Negative impact on the customer if the bank fails to provide sufficient information on the product or service they are signing up for. + I- Negative
impact on the customer by failing to guarantee access to, or the use of, products and services that may present certain obstacles or weak spots).
2 In accordance with local law and regulation
Annual report 2025 23

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

1.2 Materiality assessment
We presented our first double materiality assessment, which
aligns with the CSRD, in 2024. This report is based on the same
analysis disclosed in our previous Sustainability Statement, with
minor amendments to align material impacts, risks and
opportunities with our management throughout 2025. During
2026, we plan to update our DMA to inform our action starting
from 2027.
As regards the CSRD, this assessment sets out the sustainability
topics that are material to Santander. We identify and manage our
material sustainability impacts, risks and opportunities (IROs) by
implementing appropriate governance, policies, actions, metrics
and targets for them. We apply a pragmatic approach that focuses
on supporting our business and resilience, in accordance with local
law and regulation in the markets where we operate.
We identified 29 IROs 1 within the five sustainability topics that are
material to Grupo Santander: E1) Climate change (see section
2. 'Climate transition plan'), S1) Own workforce (see section
3.1 'Our employees'), S3) Affected communities (see section
3.2 'Sustainable development in our communities'), S4) Consumers
and end users (see section 3.3 'Our customers'), and G1) Business
conduct (see section 4. 'Business conduct'). The table below breaks
down the impacts (positive and negative), risks and opportunities
of each topic. We manage them in accordance with local law and
regulation.

|  | Impact materiality |  | Financial materiality
| Sustainability topics (ESRS) | + | – |  | Risk | Opportunity
ÿ | E1: Climate Change |  |  |  |  |
| E2: Pollution |  |  |  |  |
| E3: Water and marine resources |  |  |  |  |
| E4: Biodiversity and ecosystems |  |  |  |  |
| E5: Resource use & circular economy |  |  |  |  |
ÿ | S1: Own workforce |  |  |  |  |
| S2: Workers in the value chain |  |  |  |  |
ÿ | S3: Affected Communities |  |  |  |  |
ÿ | S4: Consumers & end-users |  |  |  |  |
ÿ | G1: Business conduct |  |  |  |  |

ÿ Material | Thresholds: |  |  |  |  |  |

g | Critical | g | Significant | g | Informative | g | Minimal

E1 |  | Climate change
| I+ Contribution to protecting the environment by driving an increase in the use of renewable energy and other low-carbon technologies. I+ Contribution to reducing the Group’s scope 1 and 2 greenhouse gas emissions. I- Adverse impact on climate and the environment due to the bank’s financing of, or investment in, certain non- sustainable assets and activities. O Growth in the financing and investment in transition and clean tech solutions, supporting the economy and key sectors such as energy, construction, mobility and agriculture. R Reputational risk based on the perception of the Bank's progress with Group climate-related policies and objectives in certain jurisdictions and that could lead to other type of risk implications. 2

Annual report 2025 24

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

S1 |  | Own workforce
| I+ Promotion of the health, well-being and security of our employees in a safe and inclusive workplace; facilitate a positive work-life balance between personal and professional life through policies that foster the balance between them. I+ Promotion of a workforce that reflects the society we live in and encourages collaboration and provides opportunities for all our employees, irrespective of personal characteristics and in compliance with the law. I+ Promotion of continuous career development and personal growth through learning and development programmes. I+ Promotion of the general well-being of employees and provide appropriate remuneration under equal conditions based on merit and market rates. I- Harm employees if unlawful discriminatory conduct, inadequate working conditions, harassment or corruption occur. R Potential risk of conflict with employees based on the infringement of their rights.
S3 |  | Affected communities
| I+ Support of economic growth and job creation in the regions where we operate, providing credit to people and businesses. I+ Contribution to sustainable development through financing and investment that promotes sustainable performance in companies, addresses societal challenges, mitigates a specific issue, or pursues better societal outcomes. I+ Contribution to education, employability and entrepreneurship, as well as to community development through support programmes. I- Finance activities (in any customer segment) that breach the bank’s policies and jeopardize the well-being of present and future generations or fail to sufficiently involve appropriate stakeholders or use suitable customer identification and management mechanisms when providing finance to a customer or project.
S4 |  | Consumers and end users
| I+ Positive impact on customers due to the bank’s offer of products and services that adapt to their needs and expectations and promote financial inclusion and health. I+ Education on, and awareness of, cybersecurity to understand potential threats and ways to repel them. I- Negative impact on the customer if they do not have access to complaints channels or if, after making a complaint, the bank fails to take the necessary action. I- Negative impact on the customer if the bank fails to provide sufficient information on products or services or to guarantee access to, or the use of, products and services that may present certain obstacles or weak spots. I- Potential infringement of customers’, employees’ or shareholders’ rights if a lack of appropriate technical or organizational measures to protect their personal data according to law and the practices set by the Group occur. R Potential losses due to fines or a reduction in the number of customers if a failure to detect or respond effectively to breaches of privacy occur. R Potential losses due to complaints or a reduction in the number of customers if substandard customer practices occur.
G1 |  | Business conduct
| I+ Act responsibly and consider investors’ interests and the impact on employees, broader society and the environment; pay taxes to support the distribution of wealth. I+ Protect the confidentiality of users of the bank’s ethical channel and have an effective reporting system in place that follows robust principles and procedures. I+ Promote responsible practices among vendors; engage with them, assess their performance in environmental, social and governance (ESG) matters and give them recommendations and tools to improve. I- Negative impact on the environment or broader society by failing to implement measures to resolve incidents through complaints or reporting channels or due to a lack of continuous improvement actions. I- Harm broader society through bribery or corruption. R Potential risk from failing to ensure the operational resilience of the value chain by assessing vendors’ solvency, reputation and compliance with the law. R Risk stemming from improper conduct that makes illicit funds or assets appear legitimate and, therefore, facilitates illegal activity or to benefit from it.

Key: I+ Positive impact I- Negative impact R Risk O Opportunity
Annual report 2025 25

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

We consider these five sustainability matters non-materia l (given
that none of the impacts, risks and opportunities connected to
them reach the materiality threshold): pollution; water and marine
resources; biodiversity and ecosystems; resource and circular
economy; and workers in the value chain.
However, we address aspects of nature and biodiversity that are
most closely related to climate objectives within our transition
plan.

| For more information, see section 2.3.5 'Our approach to nature and biodiversity'.

We conduct this assessment for the entire Group, including our
own operations and our value chain, using the available
information and tools; and by engaging our key stakeholders (see
section 1.3 'Stakeholder engagement'). We also conducted a
materiality assessment in all our subsidiaries, in accordance with
local law and regulation, the findings of which provided feedback
on the Group's materiality, while the Group's materiality informed
local materiality.
The results reflect a short to medium-term time horizon (~1-5
years) for which most of the information is available. However, a
qualitative analysis suggests that if we used a long-term horizon,
there would be no changes to the results and IROs that are
material.
The materiality assessment is connected to key risk management
processes across the Group. It provides input for the emerging risks
exercise and links to other internal risk exercises.

| For more details, see section 2.3 'Embedding ESG in risk management'

The board of directors upon a proposal submitted by the
responsible banking, sustainability and cultural committee
approved the bank’s double materiality assessment, material
impacts, risks and opportunities, and sustainability strategy.

| For more details, see SN 3. 'Materiality assessment methodology'

1.3 Stakeholder engagement
Santander maintains ongoing engagement with its stakeholders
and does so guided by the principles of transparency, honesty and
impartiality. This dialogue enables us to better understand their
expectations, share our priorities and identify areas for
improvement in our activities.
We embed the insights gathered through this engagement, where
relevant to do so, into the bank’s key processes, including strategy
setting, financial planning and the formulation of objectives. The
corresponding senior management committees at country, global
business and Group level, and, where appropriate, the relevant
governance bodies and the board, review and discuss these
elements when presenting the results of the double materiality
assessment and progress with the management of impacts, risks
and opportunities (IROs).
Our engagement approach is tailored to the characteristics of each
stakeholder group. Through our various communication and
listening channels, we identify key messages and expectations that
inform our management decisions. In addition to these ongoing
processes, we conduct targeted stakeholder engagement as part of
the double materiality and due diligence exercises, which enables a
deeper analysis of the most relevant aspects for each stakeholder
group. The specific actions derived from this information, together
with the associated monitoring mechanisms and governance
model, are described in more detail in the related chapters of this
report, as indicated by the corresponding links. In addition, we
incorporate the perspective of so-called silent stakeholders
(individuals or groups who do not directly participate in dialogue)
through the analysis of external reports, sector studies and market
intelligence.
We adapt our stakeholder engagement objectives for each group:
The section below provides more details on each stakeholder
group, the channels we use to engage with them, and the main
information we collect.

| Employees

We run three main listening exercises:
• Your Voice: our people, culture and organization function is
responsible for the employee listening channel, which
measures engagement and gathers feedback. An independent
third party manages this feedback confidentially and provides
us with aggregated information only to preserve the
anonymity of employees and their responses.

| For more details on the results and actions stemming from 'Your Voice', see section 3.1 'Our employees’.

Annual report 2025 26

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

• Canal Abierto: our compliance function is responsible for
providing an anonymous and confidential channel to enable
employees to report misconduct and breaches of the General
Code of Conduct. This channel also receives reports from third
parties, such as vendors, customers and investors.

| For more details, see section 4.3 'Ethical channels'

• Dialogue with employees’ legal representatives: in addition
to the above mechanisms, employees’ legal representatives
play a key role as a spokesperson for our workforce. That's why
we encourage and maintain permanent, fluid and direct
dialogue, engagement and negotiation with them through
trade unions and works councils. We also channel discussions
on industrial relations through these representatives in the
markets where they exist.
In order that the relationship between the bank and
employees’ legal representatives remains productive and fluid,
we engage with them through:
- Santander's bodies for engagement with employees’ legal
representatives and through formal councils and committees
set up for this purpose;
- Meetings to address specific matters, direct contact and
information exchange platforms.
The Labor Relations function also facilitates mechanisms for
communication between employees’ legal representatives and
the people they represent and those affiliated to trade unions
according to the regulations and agreements that apply in each
market.

| For more details on social dialogue see section 3.1 2'Working conditions’.

| Customers

The listening process varies according to customer type:
• Retail customers: the aim is to measure their satisfaction and
experience in each of our core markets through regular Net
Promoter Score (NPS) surveys following customer interactions.
We also run a customer experience benchmark to help us
identify our competitive positioning, with results twice a year.
Both exercises aim to spot areas for improvement that we pull
together in action plans with the relevant unit´s management
committee oversight.

| For more details on our complaints handling system, see section 3.3 'Our customers'

• Wholesale customers: we identify needs and areas for
improvement as part of our customer relations and dialogue on
an ad hoc basis. Bankers escalate the insights gain that either
need management or provoke actions to adjust our commercial
strategy.
Customer feedback is also collected by customer interaction
teams (customer experience and customer service team, among
others) and fed back into key bank processes overseen by
governance bodies.

| Shareholders and investors

We engage with our shareholders and investors to strengthen ties
and offer a value-added proposition that sets us apart. We use
surveys, events, direct contact and other channels (with digital
channels gaining traction) to enable close dialogue that helps this
group understand the business better and communicate with
senior management. For more details, see section 3.1 'Shareholder
communication and engagement' in the 'Corporate governance'
chapter.

| Communities

To understand the needs and challenges of the communities where
we operate, we gather information from several sources:
• Individuals: The Customer Experience function runs mass
surveys to learn about how the communities we serve perceive
our actions.
• Non-governmental organizations (NGOs): The Sustainability
and Social Action functions engage in two-way communication
with the leading civil organizations in our markets.

| For more details, see section '3.2.4 Community Support'

• Under our Environmental and social (E&S) risk management
policy and the Equator Principles, we conduct analyses on the
environmental and social risks that our activities might have on
our communities, including the rights of indigenous
populations, in accordance with local law and regulation.

| For more details, see section' 3.2.3 Management of environmental and social aspects'

3 In line with our principles of transparency, honesty and impartiality, Grupo Santander may only finance political parties on an exceptional and arm's length basis, and with
approval from the Group executive committee. These standards prohibit making monetary or in-kind donations and contributions to elections. Total or partial debt
cancellation for political parties and their affiliates is strictly prohibited. While Grupo Santander may negotiate the terms of any political party debt, the interest rate charged
must never fall below the market rate.
Annual report 2025 27

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Our 2025 engagement in numbers

Employees 80% participation in our Your Voice survey A 4,507 reports received through ethical channels ( 2% over total headcount) A 141,684 employees answered the survey based on the total number of employees eligible to participate, i.e. employees who have been with the organization for less than 3 months, long-term absentees, employees without access to the corporate intranet, and employees without access to the corporate intranet are excluded. |  | Customers Over 10.4 million surveys to customers 772,780 formal complaints received (4.3 per 1,000 customers)B B Calculated based on the Group’s total customer base at year-end 2025 (180 million). |  | Shareholders & Investors 137,416 responses by retail shareholders and institutional investors through quality surveys and studies 4,673 responses by retail shareholders on Santander's perception 219 events with retail shareholders 1,511 interactions with institutional investors (55 on ESG matters) |  | Our communities 218 interactions with NGOs enabled us to gather and address the needs of the communities where we operate and to understand the impact of our activities

Santander also engages with other stakeholders, including the
political environment and public authorities; supervisors and
regulators; banking sector; ESG rating agencies; as well as other
relevant stakeholder groups.

| Political parties and authorities

We interact in political debate and with authorities in their role as
policymakers on key topics that affect our sector, broader society
and the environment 3.

| Supervisors and regulators

We maintain ongoing dialogue with supervisors and regulators at
local, European and international level, which enables us to
understand their priorities and expectations and to work towards
compliance with applicable requirements and recommendations.
As part of the regulatory debate, we participate in consultations
and initiatives relating to matters relevant to the Group, its
employees, its customers and the communities it serves.
Santander engages in dialogue with authorities such as the Basel
Committee, the Financial Stability Board, the European Banking
Authority, the European Central Bank, the institutions of the
European Union, national central banks, ministerial
representatives, members of government and parliamentarians,
among other actors that contribute to shaping the regulatory
framework, including sustainable finance.
In 2025, the Group responded to 79 international and European
consultations. In addition, Santander was represented at various
meetings and forums related to the evolution of the sustainable
finance framework, including the Brazilian G20 Presidency and
United Nations Climate Change Conference 2025 (COP30) held in
Belém in 2025, which provided opportunities for exchange with the
relevant stakeholders.

| Banking sector

We work closely with sector and non-sector bodies, including the
Institute of International Finance, the Association for Financial
Markets in Europe, the European Banking Federation, Business
Europe and Digital Europe, as well as foundations and think tanks.
We work together to find common ground on issues such as the
implementation of the EU Taxonomy, the framework for
sustainability disclosure and reporting, and ongoing efforts to
pinpoint and manage climate-related risks. We take part in these
debates through consultations, workshops and other channels and
by facilitating the exchange of views between key stakeholders at
events such as the International Banking Conference and other
events that Banco Santander organizes every year.
Annual report 2025 28

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

| ESG rating agencies

In 2025, we maintained our position in MSCI (AA) and Leadership
level in CDP (score changing from A to A-). We scored 9.9 points in
Sustainalytics, improving to ‘Negligible Risk’ category, and
remained in the C+ category in the bi-annual ISS assessment.

é |
Negl | 10 - 0
Low | 20 - 10
Med | 30 - 20
High | 40 - 30
Severe | 100 - 40

= | A
A | Leadership
A-
B | Management
B-
C | Awareness
C-
D | Disclosure
D-

=
AAA
AA
A
BBB
BB
B
CCC

A. In CDP we remain at Leadership level.

| Other relevant sustainability stakeholders

Santander engages as well with other relevant sustainability
stakeholders such as UNEP FI, Global Compact and WBCSD. We
engage with them sharing our progress and gathering their
feedback and guidance.
UNEP FI Principles for Responsible Banking (UNEP FI PRB)
Santander has been a member of the United Nations Environment
Programme Finance Initiative (UNEP FI) since 1992 and a founding
member of the Principles for Responsible Banking (PRBs) since its
launch in 2019. UNEP FI feedback has informed our action during
2025:
– Principle 1: Our sustainability strategy, integrated in the
corporate strategy, is aligned with inclusive and sustainable
growth (see section 1.1 'Sustainability strategy'), and focuses
on matters that pose material opportunity, risk and impact to
Santander. Our operations have the greatest impact on the
SDGs 8, 13 and 16, while support as well the SDGs 1, 4, 5, 7,
10, 11, 12 and 17.
– Principle 2: In our materiality assessment we identified 29
material impacts, risks and opportunities (IROs) in five
sustainability matters (see section 1.2 'Materiality
assessment') . For the impact estimation we used, among
others, the UNEP FI tool. In this Sustainability Statement, we
inform about our progress towards our objectives in climate
(see section 2. 'Climate transition plan') and employees,
customers and communities (see section 3. 'Supporting
employees, communities and customers'), among others.
– Principle 3: Our Responsible Banking and Sustainability
policy sets out the general principles, targets, objectives and
strategy that should guide the Group's progress in
sustainability, including how we support our customers'
transition (see section 2.2 'Supporting our customers'
transition') and financial health and inclusion (see section
3.3.2 'Financial health and inclusion').
– Principle 4: We proactively and continuously engage with our
key stakeholders through various channels, as explained in
this section. This engagement helps us to understand their
priorities and concerns, and act accordingly.
– Principle 5: Sustainability is embedded in our governance
(see section 1.4 'Sustainability governance') . The board of
directors is responsible for approving the sustainability
strategy and the board's committee (RBSCC) oversees the
development of the strategy and policies.
– Principle 6: Our Consolidated non-financial information
statement and sustainability information is verified through a
limited review by an independent third party (see section
'Independent verification report', which can be found at the
end of this chapter).
Global Compact
Santander has been a participant of the UN Global Compact since
2002. This Sustainability statement reflects our progress and
support for the 10 Principles of the UN Global Compact in the areas
of human rights, labour, environment and anti-corruption.
World Business Council for Sustainable Development (WBCSD)
We are members of WBCSD since 2015 and as such we gather
their feedback and comments on our progress around the
membership criteria and our sustainability statement.
Annual report 2025 29

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

1.4 Sustainability governance
The Group's board of directors is responsible, among other things,
for approving the sustainability strategy.
The responsible banking, sustainability and cultural committee
assists, among other matters, in the development and
implementation of the Group's sustainability strategy and
responsible business policies, in support of the board of directors,
through monitoring, supervision and evaluation of these. The
committee works in coordination with other board committees
which also analyse specific sustainability topics. The audit
committee is responsible for supervising and reviewing the
financial and non-financial information process, as well as the
internal control systems. In turn, the risk supervision, regulation
and compliance committee supports and advises the board of
directors in defining and assessing the Group’s risk policies and in
determining the risk appetite — current and forward-looking — as
well as the strategy and culture in this area. For more information
on the composition, operation and activities undertaken in 2025 by
these committees, see ‘Corporate governance’ chapter.
The overseeing of material sustainability issues, as well as the
main lines of action for their management, are periodically
reviewed through the bodies shown below, which together form
the governance of the function:

| Santander Group board of directors Sets the sustainability strategy and prepares annual accounts and management report, which shall include sustainability statement, in accordance with local law and regulation |
| é |  | é |  | é é |
| Risk supervision, regulation and compliance committee Support the board of directors in determining the risk appetite. Oversee the integration of environmental, social and governance risks into management, in coordination with the responsible banking, sustainability and culture committee. |  | Audit committee Reviews Banco Santander and Group financial statements and non financial information, monitor legal requirements compliance and assesses information and internal control systems. Assess the process for preparing and presenting non-financial information, including sustainability information, in coordination with the responsible banking, sustainability and culture committee. |  | Responsible banking, sustainability and culture committee Advise the board of directors on the design of the responsible banking and sustainability strategy and policies. Oversee the integration of ESG risks into management, in coordination with the risk supervision, regulation and compliance committee. Assess the process for preparing and presenting non- financial information, including sustainability information, in coordination with the audit committee. |

| é |  |  | é |  |  | é é |
Executive & management level (main bodies & functions) |
| Risk control committee |  | Accounting, financial management and sustainability information corporate committee |  | Sustainability, risk, ESG Reporting and ESG businesses function |

Defence lines: |
| 1 st line of defence (Business owners, general accounting and management and sustainability function) |  | 2 nd line of defence (Risk & compliance) |  | 3 rd line of defence (Internal Audit) |

¢ Overall responsibility ¢ Supervisory oversight é Reporting é Risk é Impact é Opportunities

| For more details on sustainability governance, see note 'SN 2. Sustainability governance'.

4 The Universal Declaration of Human Rights, the International Labour Organisation Declaration on Fundamental Principles and Rights at Work, the United Nations Guiding
Principles on Business and Human Rights, the OECD (Organization for Economic Cooperation and Development) Due Diligence Guidance for Responsible Business Conduct,
and others.
Annual report 2025 30

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

1.4.1 Integration of sustainability-related
performance in incentive schemes
Grupo Santander’s remuneration policy reflects our strategic and
long-term sustainability objectives and is aligned with the
regulations in the markets in which we operate. Variable pay is
based on pre- determined, specific and quantifiable financial,
sustainability-based and value-creation targets, except where to
do so for local employees would be in conflict with local laws.
Our remuneration scheme integrates sustainability metrics
consistent with Santander strategy, in accordance with local law
and regulation.
The long-term incentives (LTI) scheme applies to our top Groups'
executives, including the Executive Chair and the CEO.
Sustainability has formed part of the LTI schemes since 2022, with
a 20% weighting.
In 2025, 7% of the variable remuneration received by the Executive
Chair and the CEO has been linked to sustainability (vs. 8%) in
2024), while 2% of their total remuneration has been linked to
climate actions as last year.
The sustainability component of short-term variable remuneration
is evolving consistently with ESG risk management. Therefore, we
are incorporating environmental and social risk management
indicators, within the qualitative risk modifier of the Group’s short-
term incentive framework for 2026 in accordance with local law
and regulation (see section 6. 'Remuneration' in the 'Corporate
Governance' chapter.
The board of directors approve these sustainability incentives
schemes on the basis of the proposal made by the responsible
banking, sustainability and cultural committee and the
remuneration committee.
The proposal for 2026-2028 will be subject to vote at the Annual
General Meeting in 2026, in accordance with local law and
regulation (see section 6. 'Remuneration' in the 'Corporate
Governance' chapter.
1.4.2 Human rights due diligence
Santander seeks to respect and protect the human rights of
stakeholders in the operations and countries where it operates,
and these are reflected in management and governance practices.
• the responsible banking and sustainability policy approved by the
board of directors incorporates defence of human rights.
• looking after our employees’ health and promoting decent
employment, the preservation of freedom of association and
collective bargaining and the prohibition of slavery and child
labour.

| For more details, see section 3.1 'Our employees'

• protecting our customers’ human rights through responsible
business practices and the protection of their data.

| For more details, see section 3.3 'Our customers'

• assessing the human rights impact on transactions with
customers through environmental and social (E&S) analysis.

| For more details, see section 3.2.3. 'Management of environmental and social aspects'

• embedding environmental and social aspects, including human
rights, in our supply chain management.

| For more details, see section 4. 'Business conduct'

• Canal Abierto is a key tool to identify, manage and resolve
potential human rights-related incidents or violations to protect
our customers, employees, suppliers and the communities we
serve.

| For more details, see section 4.3 'Ethical channels'

The results of the human rights due diligence exercise informed
the 2024 double materiality assessment. This exercise was carried
out in line with international standards 4, including measures
related to labour rights, customer protection and responsible
business conduct in relevant activities. For more details on our
human rights due diligence, see santander.com/en/our-approach/
policies.
Annual report 2025 31

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2. Climate transition plan
(Environmental information)
2.1 Climate Strategy
2.1.1 Our approach
Santander has identified material impacts, risks and opportunities in the double materiality assessment linked to climate. As required by the
European Corporate Sustainability Reporting Directive (CSRD), below we disclose our transition plan, based on three pillars to support our
customers and the communities we serve in their transition objectives; assess our customers’ climate-related risks to manage the impact on
their business and on our operations; and work to the align our portfolios, in accordance with local law and regulation.
1
Supporting our customers in
their transition goals

We support our customers in the
transition to a sustainable economy.
We’re making headway with our target
of raising or facilitating EUR 220 billion in
green finance between 2019 and 2030,
after having achieved our EUR 120 billion
target eighteen months early. We offer
our customers guidance, advice and
specific solutions, as well as a wide
range of products to invest in according
to their sustainability preferences.
Additionally, in March 2025, we reached
our target of EUR 100 billion in assets
under management (AUM) in socially
responsible investment (SRI) nine
months early.
2
Embedding ESG
in risk management

We embed climate, environmental and
social aspects in risk management from a
regulatory and control perspective,
including a materiality assessment that
feeds into our double materiality
assessment and sustainability strategy.
3
Aiming to align our activity with
the Paris Agreement Goals

We work aiming to align our portfolio
with the Paris Agreement goals to help
limit global warming. We either set
sector portfolio alignment targets or
portfolios under monitoring. We closed
2025 with six targets in five sectors,
additional portfolios under monitoring
and an alignment approach for our asset
management activity. The management
of these targets and portfolios under
monitoring, in line with the rest of the
IROs, is carried out in accordance with
local law and regulation in the markets
where we operate. Their update and
evolution reflect the present and
expected performance of the economies
and customers we serve.
In our own operations we continue to
reduce our impact on the environment by
implementing efficiency measures,
achieving in 2025 our target of 100%
renewable electricity in our main
markets.
To achieve this, we engage with our different stakeholders:
• Customers: developing products/services adapted to their needs;
participating in a collaborative network of institutions to create
financing opportunities; and developing tools to assess the
performance and progress of our customers’ transition plans.
• Key climate actors: participating in local and international
organizations, initiatives and working groups that help us
develop capabilities.
• Authorities: participating in debates with regulators,
policymakers and supervisors on the most important climate-
related developments to the bank and its employees, customers
and the communities where we operate.
• Communities: supporting a number of local initiatives to tackle
climate change and e nvironmen tal challenges, and generate
positive social impact.
Annual report 2025 32

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2.1.2 Context: Challenges and opportunities
The energy transition is progressing with increasing structural
depth and being driven by technological developments and the
growing competitiveness of low-carbon solutions. According to the
World Economic Forum (WEF), the green economy has become
one of the world's most potent drivers of growth (second only to
the technology sector), with renewable energy expanding rapidly
in over 80% of countries. Should this trend persist, installed
renewable capacity could double by 2030, supported by solar
energy, grid modernization, storage and electrification.
According to the International Energy Agency (IEA), investment in
clean energy in 2025 was higher than USD 2 trillion, which is twice
the investment in fossil fuels (around USD 1 trillion) and shows a
shift in the allocation of capital towards low-carbon technologies.
This is evident in the job market, where there are now more people
working in clean energy than in fossil fuels worldwide.
Advances in technology also serve to reinforce this trend.
According to the WEF, economically competitive solutions can
mitigate over half of global emissions, which is enabling many
sectors to set more precise transition pathways to 2030 and 2035.
Several countries have updated their Nationally Determined
Contributions (NDC) with more detailed plans. Some, including
Brazil, Portugal, the UK and the US, have recorded double-digit
declines in per-capita emissions over the past 20 years, driven by
changes in the energy sector and land use.
Nonetheless, global emissions continue to rise, and national
commitments are yet to align fully with a pathway that is
compatible with limiting warming to 1.5°C. Differences persist
across regions and sectors. Global energy demand continues to
grow, which makes it necessary to ramp up secure, affordable and
sustainable wherever possible solutions.
Against this backdrop, there is an opportunity to mobilize capital
towards the transition and to support companies and governments
in drawing up and implementing credible alignment strategies that
are aligned with local laws and policy goals in each jurisdiction.
Innovation, regulation, investment and technical advisory services
will play a key role in turning current momentum into a deep,
global transformation.
2.1.3 Our ambition
Our approach is to help our customers transition to a low carbon
economy by offering finance and advice, while we continue
working towards net-zero carbon emissions by 2050.
The transition will depend on a number of factors beyond our
control, including public policy frameworks and incentives that
accelerate alignment in the real economy, as well as continued
technological developments supportive of the energy transition.
Capital will flow to markets where risk-return and demand for
sustainable technologies work. Policy and regulation are key
enablers for this to happen; and this in turn, is reflected in our
performance and the annual review.
2.1.4 Our objectives A

| 2019 | 2020 | 2021 | 2022 | 2023 | 2024 | 2025 |  | 2025/2030 target |
Green finance raised and facilitated (accumulated EUR bn) B | 19.0 | 33.8 | 65.7 | 94.5 | 115.3 | 139.4 | 174.0 |  | 120 bn by 2025 | ü
| 220 bn by 2030 |
AuM in Socially Responsible Investments (accumulated EUR bn) |  |  | 27.1 | 53.2 | 67.7 | 88.8 | 129.9 |  | 100 bn by 2025 | ü
Thermal coal-related power & mining phase out (EUR bn) |  |  |  |  | 4.4 | 4.2 | 2.3 |  | 0 by 2030 |
Emissions intensity of power generation portfolio C |  |  |  |  | 149 | 88 |  |  | 102 - 124 kgCO 2 e/ MWh in 2030 |
Emissions intensity of oil & gas portfolio C,D |  |  |  |  | 3.08 | 3.15 |  |  | 2.31 - 3.03 tCO 2 e/TJ in 2030 |
Emissions intensity of steel portfolio C |  |  |  |  | 1.47 | 1.51 |  |  | 1.17 - 1.28 tCO 2 e/tS in 2030 |
Emissions intensity of auto-manufacturing portfolio C |  |  |  |  | 135 | 128 |  |  | 80 - 98 gCO 2/vkm in 2030 |
Emissions intensity of auto-lending portfolio C.E |  |  |  | 137 | 133 | 129 |  |  | 70 - 109 gCO 2 e/vkm in 2030 |
Electricity from renewable sources F | 50% | 57% | 75% | 88% | 97% | 96% | 100% |  | 100% by 2025 | ü

In 2025:
→ we continue working to align our key portfolios; we also
disclosed emissions for our mortgages and commercial real
estate portfolios in Portugal, in addition to those of Spain and
the UK;
→ we continued managing our own operations' scope 1 and 2
emissions', with reductions plans and offsetting remaining ones;
and we kept our offices and buildings in our core markets free of
single-use plastics to meet our target.
A. The efforts to meet these targets are in accordance with local law and regulation.
B. Includes Grupo Santander's contribution to green finance: project finance; green bonds; export finance and advisory services to help customers transition to a low-carbon
economy.
C. The figures displayed are the latest available given limited data availability from customers to assess financed emissions. We used Banco Santander's internal calculation
methodology, which is based on the Partnership for Carbon Accounting Financials (PCAF), 2022.
D. It includes scope 1 and 2 emissions from the upstream oil & gas portfolio. Scope 3 is considered in the primary energy mix index monitoring metric.
E. Consumer lending for the purchase of passenger cars in Europe.
F. In countries where we can verify electricity from renewable sources at Banco Santander properties. It considers the 10 core markets where we operate.
For more details of the scope and update of targets, see section 2.4.1 'Aligning our portfolios'.
Annual report 2025 33

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2.2 Supporting our customers' transition
In this section we cover how Santander manages the following
IRO:

| I+ | Contribution to protecting the environment by driving an increase in the use of renewable energy and other low-carbon technologies. |
| O | Growth in the financing and investment in transition and clean tech solutions, supporting the economy and key sectors such as energy, construction, mobility and agriculture. |

As a bank, our main lever is to support customers' transition. We
continue to enhance our sustainable finance and advisory
proposition in our global businesses by:
1. identifying trends and needs in the economies and customer
segments we serve;
2. having commercial teams in place with the skills required to
meet these needs, and
3. developing the support structure for these skills, including our
value proposition, standards, governance, and systems.
In Corporate & Investment Banking (CIB), we have reached EUR
174 billion in green finance raised and facilitated since 2019,
achieving our EUR 120 billion by 2025 target, and are working
towards reaching EUR 220 billion by 2030. In 2025, Wealth
reached EUR 129.9 billion in assets under management (AuM) in
socially responsible investment (SRI), reaching our EUR 100 billion
target nine months early.
We identify business opportunities by assessing key sectors,
working closely with our customers, and harnessing the
knowledge of our sustainability experts.
The Group calculates the ratio of green assets that align with the
European Taxonomy. In 2025, this ratio reached 3.35% (3.28% in
2024). The volume of assets as at 2025 year-end that aligned with
the European Taxonomy was EUR 28.1 billion for mortgages and
EUR 12.0 billion for auto. For more details, see SN 5.'European
Taxonomy'.
Regarding investment through our assets management business
SAM, the top three climate-related opportunities are:
• new climate solutions that include products and services that
boost diversification, competitive advantage and revenue;
• lower-emission energy sources that benefit from less exposure
to greenhouse gas (GHG) emissions, lower costs, and policy
incentives; and
• efficient production and distribution of resources to reduce
operational costs and raise both production capacity and the
value of fixed assets.
Transition finance and just transition
Our role in the transition entails contributing to sustainable
development by supporting customers and economies according to
their specific needs and circumstances. It is vital that the transition
is just and inclusive, and considers regional and sector
particularities to avoid isolating communities and stranding assets.
We aim to embed and promote the just transition through our
engagement approach, our risk management policies and
processes, and our sustainable and investment products, in
accordance with local law and regulation. We consider this
approach when devising our policies and reviewing our Sustainable
Finance and Investment Classification System (SFICS), which covers
activities that aim to address or mitigate social and environmental
issues; bring the spotlight on protecting the Amazon biome (given
our operations in Brazil) and helping local communities.
All transactions and products labelled as sustainable pass through
ESG classification meetings to ensure alignment with the SFICS.
We manage these transactions and products through an
automated corporate tool that we have implemented in our core
markets and that provides full decision traceability and
comprehensive documentary support.
2.2.1 Corporate and investment banking (CIB)
CIB has raised and mobilized 174 billion euros in green finance
globally between 2019 and December 2025. The green finance
target focuses on green use of proceeds (such as renewable
energy) across products where well-recognized public information
is available.

GREEN FINANCE VOLUMES FROM 2019 TO 2025
Raised or facilitated. EUR bn.

174 |  | 220
2019 |  | 2030

2025 GREEN FINANCE VOLUMES (TOTAL EUR 34.6 bn) - SPLIT BY PRODUCT
Raised or facilitated. EUR bn.

DCM (Debt capital markets); M&A (Mergers and Acquisitions)
Information obtained from public sources, such as Infralogic, Dealogic, TXF or
Bloomberg league tables. All roles undertaken by Banco Santander in the same
project are accounted for. Other sustainable finance components, such as financial
inclusion and entrepreneurship, are excluded. Green Finance raised and facilitated is
not a synonym of EU Taxonomy. Information from League Tables extracted by 12
January 2026, at the latest.
Annual report 2025 34

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Santander’s sustainable finance proposition is built on long-
standing expertise in renewable energy and a broad range of
structuring, advisory and financing solutions across products,
sectors and geographies. This approach is underpinned by the
bank’s customer climate tiering methodology, which supports the
identification of priority transition areas at client level and provides
benchmarking to support alignment strategies. In 2025, Corporate
& Investment Banking supported customers through a wide range
of transactions addressing key aspects of the transition to a low-
carbon economy. We ensure that our customer climate tiering
approach remains in compliance with applicable local laws and
regulations in the markets where we operate. The case studies
below illustrate how this activity is deployed across strategic
transition themes.
Scaling low-carbon energy infrastructure
Santander supported the development and expansion of
renewable and low-carbon generation capacity across a wide
spectrum of technologies. This included multiple advisory and
financing roles in solar, offshore and onshore wind projects,
hydroelectric as well as nuclear (Sizewell C in the UK) assets across
our global footprint.
Offshore Wind in Poland
Santander acted as Financial Advisor to Equinor and Polenergia for
Project Rondo in the financing of two offshore wind farm projects
in Poland, with a combined value of over EUR 6 billion and a total
capacity of 1,440 MW. This deal amounts to the largest ever
financing raised in Poland and is Santander’s largest ever project
finance advisory. It is also the first transaction on the market with
the Polish export credit agency KUKE's cover in the form of a Green
Guarantee, for which Santander also acted as Agent, and one of the
largest projects supported by Euler Hermes.
Onshore Wind in Finland
Santander acted as the Sole Underwriter and Bookrunner for
Project Amidala, project financing for two greenfield onshore wind
farms in Finland with a total capacity of 472 MW. The project is
sponsored by OX2 (owned by EQT), and has long term PPAs with a
multinational corporate offtaker. Project Amidala is a landmark
transaction in the Nordics, as the largest renewable energy deal in
Finland to date and one of the largest in the region.
Hydro in the United States
Santander acted as Joint Placement Agent and Sole Structuring
Agent in the market leading Smoky Mountain transaction. A USD
543 million financing of four hydroelectric facilities on the Cheoah
and Little Tennessee rivers in North Carolina and Tennessee. The
deal included a USD 435 million rated USPP alongside a USD 108
million Debt Service Reserve and Letter of Credit Facility. Smoky
Mountain incorporated Santander's Variable Amortization
structure, bringing the technology to a new geography and sector
following its success in European renewables.
Variable Amortization allowed enhanced debt sizing while
derisking debt through a structure which ties amortization to asset
performance, and Santander played a key part structuring the deal
and assisting in the rating process. Smoky was also the first U.S.
Private Placement/Institutional deal incorporating this technology
and Santander was a lead agent, driving a successful placement
process.
Accelerating emerging and enabling technologies
Battery energy storage represented a key focus area for Santander
in 2025, due to its role in enabling renewable integration and grid
stability. Santander advised and financed multiple storage
platforms and projects across our global business platform.
Battery Energy Storage System (BESS) in the United Kingdom
Santander acted as Financial Advisor, Mandated Lead Arranger,
Hedge Counterparty, Account Bank and LC Fronting Bank to Fidra
Energy on the up to GBP 445 million platform equity capital raise,
securing investment from EIG and the National Wealth Fund, as
well as on the GBP 594 million greenfield debt financing of Thorpe
Marsh. The transaction demonstrates Santander’s continued
leadership in advising on, and financing, large battery storage
projects critical for the energy transition. Thorpe Marsh is the UK’s
largest battery energy storage project and the largest BESS
financing in Europe.
Solar and BESS in the United States
Santander acted as Financial Advisor to Origis Energy on Brookfield
& Antin's strategic investment to support the growth of its utility-
scale solar and battery storage platform in the US. This investment
will accelerate the deployment of utility-scale solar and BESS
projects to increase zero-carbon generation and grid-firming
storage capacity. This will strengthen Origis’s ability to deliver
large-scale alignment solutions to customers and support the
integration of more variable renewables. Santander also supported
Origis Energy’s goal to grow its renewable platform by serving as
Green Loan Coordinator in the portfolio project financing of two
renewable energy projects in June 2025, and Co-Green Loan
Coordinator for the project financing of a solar and BESS project in
Q42025.
Supporting capital rotation and platform development
Santander supported customers in executing strategic M&A and
equity transactions to recycle capital and support growth. This
included multiple M&A and advisory roles across different
geographies and green technologies.
Offshore Wind in Germany
Santander acted as sell-side M&A advisor to Iberdrola on the 49%
stake sale of Windanker Offshore Wind Farm, valued at EUR 1.28
billion. This transaction marks another successful offshore wind
farm-down for Iberdrola and further strengthens CIB’s position as a
leading advisor in the offshore wind sector.
Solar and BESS in the United States
Santander served as M&A advisor to Morgan Stanley Infrastructure
Partners (MSIP) on its strategic investment in Torch Clean Energy
to support Torch’s transition from a development platform into an
integrated clean-power platform (scale up development,
construction and asset management across utility-scale solar and
BESS). Santander subsequently supported MSIP and Torch as a
Green Loan Coordinator with an underwrite of the debt facilities to
support a solar and battery energy storage system (BESS) project in
Arizona.
Mobilising sustainable capital markets
Through Debt Capital Markets, Santander supported FIs (Financial
Institutions), SSAs (Sovereigns, Supranationals and Agencies) and a
broad range of corporates across industries in accessing green,
social, sustainable and sustainability-linked funding. In particular,
2025 saw a significant milestone with the first European Green
Bonds (EuGB) issued under the European Green Bond Standard –an
EU regulation coined as the ‘gold standard’ of green bonds. In Latin
Annual report 2025 35

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

America, Santander maintained its leading position in structuring
and executing sustainable financial transactions in the bond
market, ranking as top 1 underwriter for sustainable bonds
according to Bloomberg league tables.
DCM - Green and Sustainability-Linked
Santander helped place numerous inaugural European Green
Bonds from issuers across the corporate, FIG and SSA space.
Santander supported the Italian utility A2A, ASN Bank, ABN Amro,
Terna and Comunidad de Madrid in their inaugural EuGB.
Santander also continued to actively participate in landmark
sustainable debt transactions throughout 2025, including
supporting the Republic of Poland’s return to the green bond
market, acting as Joint Lead Manager on the sovereign’s EUR 1.25
billion 12-year green tranche (as part of a EUR 3.0 billion dual
tranche issuance). Santander also acted as Joint Bookrunner and
Sustainability Structuring Agent on one of the few debut
sustainability-linked bonds seen this year, supporting Żabka Group
– an ecosystem of convenience stores – issue its PLN 1 billion 5-
year sustainability-linked bond, with targets related to sustainable
products and packaging circularity.
Notable sustainable deals that Santander supported in Latin
America this year include our Sustainability Structuring Agent,
Global Coordinator and Joint Bookrunner roles for Colbún – a
Chilean electric utility – on its USD 500 million 10-year green bond;
our Joint Sustainable Structuring Agent and Joint Bookrunner role
in Empresas CMPC’s USD 600m sustainable hybrid transaction,
which won Corporate Sustainable Deal of the Year at the Latin
Finance awards; and a Joint Lead Manager role on Corporacion
Andina de Fomento’s first sustainable bond, with the development
bank placing a EUR 1.5 billion 7-year issuance.
Supporting sustainable trade, supply chains and working
capital
Santander also provided transactional banking solutions for
customers in the form of sustainability-linked transactions and
trade finance solutions.
Sustainability-Linked Receivables in Chile
Santander signed a landmark Sustainability-Linked Receivables
Purchase Program in Chile with Patagoniafresh (subsidiary of
Empresas Iansa), which was selected as Best ESG Working Capital
Initiative at the Working Capital Awards 2025.
Wind in Europe
Santander and the European Investment Bank (EIB) signed a EUR
500 million counter-guarantee agreement that Santander will use
to create a portfolio of bank guarantees of up to EUR 1 billion,
expected to unlock EUR 8 billion of investment to support wind
energy equipment manufacturing companies in Europe. The
agreement is part of the EIB’s EUR 5 billion wind power package to
boost Europe’s wind power manufacturing sector and accelerate
the energy transition. The operation is backed by InvestEU, the EU
programme that aim to mobilize investment of more than EUR 372
billion by 2027.
Financing renewable energy - Overview
Grupo Santander has been a leader in renewable energy finance
for more than 10 years. In 2025, we were among the top banks in
terms of number of transactions and deal value globally, with 100
transactions closed and a 5.58% market share according to
Infralogic:

Top 10 renewable energy financing banks in 2025
Rank | Loan Provider | Vol. (EUR million) | No. transactions | Market Share
1 | Banco Santander | 12,244 | 100 | 5.58%
2 | Bank 1 | 11,018 | 119 | 5.03%
3 | Peer 1 | 8,641 | 98 | 3.94%
4 | Bank 2 | 8,025 | 90 | 3.66%
5 | Peer 2 | 6,852 | 72 | 3.13%
6 | Peer 3 | 6,541 | 76 | 2.98%
7 | Bank 3 | 6,324 | 80 | 2.81%
8 | Bank 4 | 5,765 | 73 | 2.56%
9 | Bank 5 | 4,329 | 49 | 1.92%
10 | Peer 4 | 3,965 | 50 | 1.76%

Peers are BBVA, BNP Paribas, Citi, Crédit Agricole, HSBC, ING, Itaú, Scotia Bank and
UniCredit. Data extracted by 12 January 2026, at the latest.
The greenfield renewable energy projects that we financed or
advised on in 2025 have a total installed capacity of 16.8 GW. We
also helped expand, enhance and sustain renewable energy
brownfield projects that have a total installed capacity of 32.1 GW.
The greenfield renewable energy projects Santander participated
in as financier or advisor in 2025 can power 15.7 million
households per year.
Santander continues to demonstrate a leading role in the fast-
growing battery storage sector, according to Infralogic.
2.2.2 Retail and Commercial Banking
Retail & Commercial Banking’s sustainable finance activity in 2025
combined a range of financing solutions, advisory services and
enabling structures designed to support customers at different
stages of their sustainability journey. This approach included
dedicated green products, sustainability-linked loans (SLL), which
we strive to ensure remain in accordance with local law and
regulation in the markets where we operate, advisory partnerships
and internal capability building. The initiatives below illustrate how
these elements were deployed across our core markets.
Green and transition financing solutions
Santander offered a broad range of green and transition financing
products across markets. In Spain, the ICO Mecanismo
Recuperación y Resiliencia Verde line provided preferential
financing for projects in renewable energy, energy efficiency,
electric transport, the circular economy and social housing. In
Brazil, sustainable operations expanded significantly, driven by
renewable energy, sustainable agriculture and transport; and
Financing lines for solar panel installation further supported
customer-led energy transition projects. In the UK we also provided
funding for a range of renewable energy projects as the first co-
located solar and battery energy storage project finance
transaction within the Santander Group. Santander Chile marked a
Annual report 2025 36

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

milestone in sustainable finance by finalizing the first Receivables
Purchase Program linked to sustainability.
Sustainability-linked loans
Sustainability-linked loans, which we strive to ensure remain in
accordance with local law and regulation in the markets where we
operate, played a key role in incentivising customers to align their
operations with measurable sustainability targets. In Poland,
Santander Bank Polska signed an EUR 110 million SLL with
Heimstaden, linked to emissions reduction objectives in the
residential real estate sector. SLLs also formed a core part of the
proposition for large corporates in Spain.
Advisory, partnerships and customer support
Santander complemented financing with advisory services tailored
to customer maturity. In Spain, sustainability advisory services
were supported by a Sustainability Reporting Guide for SMEs.
Different strategic alliances supported asset alignment, grant
management and carbon footprint offsetting. In Brazil, advisory
and digital platforms such as Fit connected consumers with
renewable energy producers. In UK we further strengthened our
customer support by forming a strategic partnership, offering CCB
customers access to tailored sustainability tools and expert advice;
our 'test and learn' initiatives included cashback offers, in-depth
retrofit advice, and updated energy performance certificates (EPC)
assessments, providing insights into how best to support
households in enhancing energy efficiency.
In Argentina, we enable through partnerships agricultural
producers to access lower environmental-impact inputs and the
financing tools needed to implement them. In Portugal, the
Santander Foundation in partnership with Universidade Católica,
and through the platforms Santander X and Santander Open
Academy, delivered training programs in sustainable finance for
SMEs and Individuals, with a focus on sustainability reporting.
Capability building and market infrastructure
Santander in Spain embedded sustainability culture across its
commercial networks through dedicated training and sustainability
ambassadors. In Brazil, the bank played a prominent role in the Eco
Invest Programme, mobilising private capital for ecological
transition projects. In Colombia, Banco Santander Colombia issued
its first sustainable bond, supporting sustainable mobility, financial
inclusion and energy transition projects.
Working with multilateral institutions
Santander continues to strengthen its strategic collaboration with
multilateral development banks (MDBs) to support our customers
transition in Europe and Latin America. Through these agreements,
the Group mobilizes financing that enables our customers to
undertake green investment, boost energy efficiency and
accelerate alignment, while contributing to global environmental
objectives.
In 2025, we entered into 26 new financing agreements with
MDBs. Of these, 16 include a green component, aimed at
promoting projects linked to the energy transition and climate
change mitigation, for an aggregate amount close to EUR 1,623
million. These agreements will support the construction and
sustainable renovation residential and commercial buildings,
investment in energy efficiency, the expansion of renewable
energy, sustainable agricultural financing, low-emission mobility
and transport solutions, and other initiatives.
Among the most notable transactions of the year was a cash
securitization signed in September in Spain, structured in
collaboration with the European Investment Bank (EIB) and the
European Investment Fund (EIF). This deal combines financing and
guarantee mechanisms to expand the granting of eligible loans to
SMEs and midcaps, and support sustainable companies and the
construction of energy-efficient buildings.
In Brazil, we built on our partnership with the IFC through a Blue
Loan aimed at micro and small enterprises that contribute to
efficient water use and the protection of water resources, as well
as through an AB Loan that expands green financing for
sustainable investment under the Eco Invest programme. These
investments also cover low-emission mobility, sustainable
agriculture, and clean energy. Both transactions significantly
increase the availability of sustainable credit in key productive
sectors in Brazil.
In Chile, Santander agreed on a risk participation facility with the
IFC, which will enable financing for green investment in energy
efficiency, sustainable infrastructure, biodiversity, transport
transition, and other strategic sectors. This significantly expands
the volume of green credit available to Chilean companies and
supports the sustainable modernization of production.
In Uruguay, the IFC approved USD 20 million in financing for
Santander Group to support a solar energy project for the
production of zero-emission hydrogen, positioning the country as a
regional leader in clean energy solutions.
2.2.3 Digital Consumer Bank (Consumer)
At Santander Digital Consumer Bank, we help our customers in
their transition to more sustainable mobility and a low-carbon
economy both in auto and non-auto.
Auto
Our ambition is to continue supporting the transition while
maintaining our leadership position. Our leadership position, which
has enabled us to support the green transition with EUR 7.3 billion
in finance for electric vehicles and reach a market share of 10% in
Europe, as well as contributing to the alignment of our auto
lending portfolio and 2030 target in Europe.
EU regulation has set out the path for the automobile industry to
align through two key measures:
• Emissions targets for manufacturers in relation to new vehicles
sold in a year, with progressive, more restrictive targets for
passenger vehicles of 95 gCO 2/km in 2020-2024 down to 49.5
gCO 2/km in 2030-2034. The penalty for a failure to meet these
targets will amount to EUR 95 for each CO 2 g/km of excess per
vehicle sold. For 2025, the initial target stood at 93.6 gCO₂/km
(Worldwide Harmonized Light Vehicles Test Procedure). Most
manufacturers in Europe are currently above this threshold,
which could lead to penalties across the industry or the need to
restrict sales of combustion-engine vehicles, as well as to set
commercial policies that encourage the sale of low-emission
vehicles or the creation of pools with other brands. Upon
acknowledging the potential impact of this regulation on the
automotive industry, the European Union extended the
compliance period for the 2025 target to 2025–2027, granting
manufacturers additional time to implement alignment
measures.
Annual report 2025 37

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

• The previous ban on selling internal-combustion engine cars
beyond 2035, replaced by a 90% emission-reduction target
compared with 2021. This amendment would allow vehicles that
incorporate combustion engines to continue being marketed
after 2035, provided they meet that target. This change is
pending ratification by the European Parliament.
According to the European Automobile Manufacturers' Association
(ACEA), in 2025, vehicles with some degree of electrification
(electric, plug-in hybrid and hybrid vehicles) accounted for 62.2%
of the European market, confirming the shift towards cleaner
powertrains. Hybrid vehicles led the market with a 34.8% share,
followed by electric vehicles at 18.1%, and plug-in hybrids at 9.3%.
This suggests only a partial shift towards more sustainable
mobility, with perceived barriers to electric vehicles remaining
(largely due to battery autonomy and a lack of charging
infrastructure). Sales of combustion vehicles (petrol and diesel)
continued to decline in 2025, as they did in 2024.
After a decline in electric vehicle registrations in 2024, 2025 saw
sales bounce back with growth of 30% and an increase in market
share of over four percentage points. This is thanks to an increased
supply by manufacturers, who need to reduce their emissions.
Market data also highlight high dependence on public support
measures for the adoption of cleaner solutions. In the absence of a
common incentive scheme in Europe, sales increase in markets
where incentives remain in place and decline where they are
withdrawn. For instance, the discontinuation of incentives in
Germany in 2023 led to a drop in electric vehicle sales in 2024. A
similar effect occurred in France in 2025, where electric vehicle
registrations fell by around 4% year-on-year until the relaunch of
the social leasing scheme in July, following its suspension in 2024.
Plug-in hybrid vehicles experienced particularly strong growth in
2025, increasing by 32% compared to 2024 and gaining two
percentage points of market share. The entry of Chinese
manufacturers into Europe — which are subject to lower tariffs for
plug-in hybrids than for electric vehicles — has reshaped sales
trends. Once considered a transitional technology between
combustion engines and fully electric vehicles, plug-in hybrids
have now overtaken diesel as the fourth most sold powertrain in
Europe.
In this context of regulatory change and heterogeneous
government action, Santander Consumer Finance (SCF) continued
increasing electric vehicle lending, with a market share in Europe
of 10% (above the total Auto market share off 8%). This further
reflects SCF’s leadership in the electric vehicle market. In 2025,
SCF financed 268,945 vehicles (19% of its total business) worth
EUR 7.3 billion (15% of the total auto portfolio). Electric vehicles
account for 26% of new car business in terms of number of
contracts, outperforming the market.
This progress has been helped by signing new financing
agreements with electric vehicle manufacturers; and extending
partnerships with traditional manufacturers that have set a
roadmap and strategic plan to electrify their fleet.
SCF has also come up with innovative, holistic financing solutions
to aid customers’ energy transition, that comply at all times with
applicable local laws and regulations in the markets where we
operate, such as home bundles that include charging points and
solar panels.
We will continue working on the commercial front to establish
partnerships with new electric vehicle manufacturers entering the
European market, as well as with startups across the entire value
chain that demonstrate strong potential to deliver innovative
sustainable mobility solutions.
Nonetheless, the effectiveness of all these measures in the
m edium and long term and SCF’s growth in electric vehicle lending
will depend on external factors that include regulation; the
technological developments needed to reduce production costs
and ensure access to key materials to manufacture green vehicles;
the infrastructure to expand capacity and boost efficiency; and
customer demand and market trends.
Non-auto
Santander Consumer Finance maintains a strong position in the
overall consumer market, with presence at more than 75,000
points of sale across Europe and technological leadership that
enables us to continue operating under a model of financing
products and projects with positive environmental and social
impact.
The sustainable financing within the consumer business spans a
wide range of sectors that include:
• real estate: energy efficiency improvements in homes (solar
panels, sustainable heating and cooling systems, energy-
efficient equipment);
• sustainable mobility: electric bicycles and scooters, charging
points and engine adaptations to reduce emissions; and
• other activities: linked to the circular economy, including
sustainable fashion, electronic device buy-back programmes, and
the use of recycled materials for cards (recycled PVC/PLA).
In the energy market, consumer behaviour has changed
significantly. Demand for residential solar panel installation
declined notably following the general stabilization of electricity
prices after the 2022–2023 peak. Combined with the vast upfront
investment required, this trend reduced consumer interest and the
number of specialized installers. However, new financing
opportunities have emerged in complementary energy
technologies, such as battery and storage systems, particularly in
Nordic countries. These solutions help balance electricity grids
during periods of low generation and open new environmentally
positive financing models that may help renew consumer interest.
The electric bicycle market continues to grow, particularly in urban
areas, where e-bikes offer a viable alternative to combustion
vehicles. Though the initial cost remains a barrier, public incentives
and tailored financing programmes are enabling customers to
adopt cleaner mobility options.
As a notable highlight in 2025, Santander España reaffirmed its
commitment to the Hazte ECO programme, which marked its fifth
anniversary. Through this initiative, the bank continues to allocate
1% of card purchase amounts to environmental projects managed
by the Global Nature Foundation. In 2025, these funds supported
wetland restoration in the Valencia region, an area of high
ecological value recognized as a Special Protection Area for Birds.
The project restored 11.2 hectares and avoided 62 tonnes of CO₂
emissions, while also enhancing water retention capacity, creating
Annual report 2025 38

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

local employment, and promoting nature-based solutions to
climate change.
Engaging customers in the transition
Since 2024, we have offered customers located in Belgium and
Norway the possibility to subscribe to 'green' term deposits. All of
these deposits finance the green assets described above.
Capital market issuances
In 2025, through Santander Consumer Bank Norway, the SCF
Group maintained its presence in ESG capital markets with the
issuance of a five-year bond amounting to NOK 500 million.
2.2.4 Wealth Management & Insurance (Wealth)
Most socially responsible investment (SRI) products, registered as
Article 8 under the SFDR, managed by Santander Asset
Management (SAM), have a sustainable investment objective
ranging from 1% to 50%. Investment products registered as Article
9 have a 100% sustainable investment objective (excluding cash
and derivatives).
The Santander Sostenible Bonos fund, launched in 2019, was a
trailblazer in Spain for investing in green bonds to finance clean
energy, emissions reduction and other green initiatives. The fund
also invests in social, climate change, environmental and other
sustainable bonds.
As part of our SRI range, we offer thematic products that focus on
social objectives (Santander Prosperity), agriculture (Atitlan Atgro),
real estate (Real Estate Coliving Opportunities) and climate
(Santander GO Global Environmental Solutions and Santander
Sostenible Bonos).
In private markets, Santander Alternative Investments offers two
solutions to address climate change:
• Santander Iberia Renewable Energy, a private equity strategy
that invests in solar and wind energy projects in Spain.
• Santander Innoenergy Climate Fund, a venture capital strategy
that invests in climate technology startups that work on
renewable energy, smart grids, energy efficiency, storage
systems, green energy batteries, mobility and the circular
economy.
SAM has an advisory mandate for LA Green, a blended finance fund
to boost the SME green bond market in Latin America, mobilize
large-scale capital, and make a positive contribution to society and
the environment.
SAM’s SRI funds also include a range of six funds that donate part
of their management fee to several NGOs. In 2025, supported
projects focused mainly on vulnerable or socially excluded groups,
job creation linked to the social and green economy, and
development cooperation in such areas as education, youth
employability, access to drinking water, and other causes. Our
Santander Compromiso Solidario fund won 'Best solidarity fund' at
the 2025 Expansión-Allfunds Awards.

| For more details on Socially responsible investment, see section 5.2 'Responsible investment and social finance'.

2.2.5 Payments
In 2025, 97% of the cards we procured were manufactured using
sustainable materials (recycled PVC / PLA). We also continued to
develop solutions that promote more sustainable consumption
habits.
Getnet also drives initiatives aimed at reducing emissions and
promoting the circular economy. Among these, the end-to-end
point-of-sale (POS) terminal recycling processes —already
implemented in Brazil— are particularly noteworthy, as well as the
expansion of Tap on Phone solutions, which enable payment
acceptance without the need to manufacture or use additional
physical devices.
Brazil’s POS recycling programme enables the recovery and
refurbishment of components for their reintegration into new
devices.
Additionally, Getnet continues to make progress in replacing
traditional consumables with more sustainable alternatives, such
as BPA-free paper rolls without plastic tubes, helping reduce
plastic use and minimise waste associated with its operations.
Santander España offers its customers the possibility of depositing
expired or damaged cards at ATMs, initiating a recycling process
through which they are transformed into urban-furniture benches.
Since the initiative was launched in 2023, Santander has donated
167 benches made from recycled cards to various public
institutions in cities such as Valencia, Málaga, Sevilla, Santander
and Astorga. In 2025, Santander España delivered these benches to
the municipalities of Paiporta, Catarroja and Aldaia, demonstrating
its commitment to the recovery of areas affected by the floodings.
Annual report 2025 39

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2.3 Embedding ESG factors in risk management
ESG factors are cross-cutting and may affect different risk types. We manage them by prioritizing environmental and social aspects
according to their relevance and materiality for the Group, and always in accordance with local law and regulation.
We assess governance factors from a dual perspective, Grupo Santander internal governance and our customers governance evaluation,
applying proportionality and materiality criteria.
Environmental and social factors comprise the following categories:

| Transition risk (TR) |
|  |  | Market sentiment Changes in the supply and demand of certain commodities, products and services insofar as climate-related risks and opportunities. |
|  |  | Policy action Laws and regulations mandating carbon pricing mechanisms to reduce greenhouse gas emissions; use of energy sources with lower emissions; energy efficient solutions; and water efficiency measures and more sustainable land use practices. |
|  |  | Technology The need to build and innovate to support the transition to an energy efficient financial system with lower CO 2 emissions. This can have a significant impact on companies as new technology displaces obsolete systems and disrupts some components of the financial system as we know it. |
| Physical Risk (PR) |
|  |  | Acute Intense extreme weather events, such as wildfires, hurricanes or floods. |
|  |  | Chronic Changes in rainfall patterns as well as, extreme weather variability, average temperature rises, severe heatwaves, drought, and rising sea levels. |

| Nature risk (NR) |
|  |  | Dependencies Negative effects on economies, financial institutions and financial systems owing to nature degradation, including biodiversity loss and the decline of ecosystem services. |
|  |  | Impacts The misalignment of companies’ strategies and operations with regulatory, social and market changes that drive the protection and restoration of ecosystems, particularly those related to land and sediments, water and biodiversity. |
| Social factors (SF) |
|  |  | Negative economic impacts arising from restricted access to key resources and services due to environmental events or conflict with communities, as well as the respect of human rights, labor policies, or health security; affecting on the consumer sentiment and companies’ productivity. |

Annual report 2025 40

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

At Santander, we assess the impact of environmental factors on each risk type across several time horizons and based on the average
maturity of the portfolios analysed. At all times, we strive to remain in accordance with local law and regulation in the markets where we
operate. In the table below we set out how we do this, as well as our key achievements in 2025:

Risk type | Environmental drivers A | Time horizon analysed | Potential impact of environmental factors |  | What we’re doing to manage climate and environmental risk |
Credit |  | Short - medium - long term | → Extreme weather can lead to higher retail and corporate loan default and lower collateral value. It can also lead to lower income, harm agriculture, and increase insurance coverage and premiums. The degradation of nature can affect productivity in the agricultural sector. This may increase loan repayments and early asset disposal due to property damage in 'high risk' locations. → Adverse weather conditions can cause significant financial losses, endanger communities, harm the environment, and affect the value of collateral. → The failure of borrowers to adapt their business models to a low-carbon economy could drive up operational costs, heighten credit risk and, therefore, raise the risk of a drop in income or activity that may increase default or lead to a loss of business value. → Stricter disclosure requirements. → The loss of natural resources (water, fertile soil, etc.) can disrupt economic activity in dependent sectors and reduce borrowers' income and ability to repay. |  | → Conducting materiality assessments to identify physical and transition climate change and nature risk in our portfolios. → Monitoring of climate concentration risks by sector and region in the short, medium and long term. → Creating vulnerability heatmaps to assess climate risks in the present day and short, medium and long term via orderly, disorderly and hot house world scenario analyses. → Implementing mitigation measures such as policies, thresholds and insurance to combat risks and their impact. Monitoring risk appetite limits and alerts to manage climate-related sectors. → Conducting scenario analyses and measuring sensitivities to forecast changes in credit ratings, the probability of default (PD) and loss given default (LGD) based on physical and transition risk. → Monitoring portfolios through metrics to control environmental factors in business-as-usual processes. → Assessing environmental and social factors in customer and transaction analysis and embedding them in ratings. |
Market |  | Short term | → High volatility in market factors under stress scenarios. → Changes in market perception leading to wider credit spreads for business in impacted sectors. → Extreme weather conditions could raise concerns about the business plans of companies operating in the impacted sectors and widen their credit spreads. |  | → Reviewing climate stress scenarios and the subsidiaries that apply them regularly. → Conducting stress testing using physical and transition risk scenarios. → Analysing trading portfolios for current exposure to climate-sensitive business activities. → Adapting stress testing to best market practices. |
Liquidity |  | Short term | → Market impact on the value of high quality liquid assets in Santander's liquidity buffer. → More frequent extreme weather that stifles economic growth in countries susceptible to climate change, causing sovereign debt to rise and limiting access to capital markets. → Cash outflows from companies trying to boost their reputation in the market or solve problems with climate scenarios. → Extreme weather conditions could cause financial impact on companies operating in the affected sectors impacting the funds deposited in the bank. |  | → Conducting qualitative and quantitative climate scenario analyses of impacts on highly liquid assets (HQLAs) and financing of exposed companies. → Analysing higher outflows due to changes in market perception of corporations in climate-sensitive business activities. → Adapting stress testing to best market practices, including new liquidity scenarios to measure their impact. |

Annual report 2025 41

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Operational |  | Short - medium - long term | → Severe climate events can cause damage to our assets, including branches, data centres, headquarters and other owned or rented properties. Impacts on our own or our suppliers’ premises can also affect business continuity. → Climate and environmental factors can also lead to operational risk losses from litigation, claims due to inadequate sales or non-compliance with ESG standards. |  | → Conducting self-assessments and operational risk control that include ESG-related risks to weigh up our exposure. → Conducting mandatory operational risk scenario analysis that cover extreme physical and transition risk events. → Including an ESG flag in the operational risk events database to identify events and losses from climate- related and environmental risks. → Including an assessment of climate threats in business continuity scenarios. → Conducting a materiality assessment on climate- related operational risk. → Conducting preliminary analysis on the link between nature and operational risk. → Reviewing local coverage of environmental incidents with Insurance teams. → Updating documentation on embedding of environmental factors in operational risk management. |
Reputational |  | Short - medium - long term | → Customers, investors and other stakeholders could believe that banks aren't doing enough to meet low emissions targets, that they could be acting against their policies, or that their objectives do not meet stakeholders’ expectations. → Stakeholders’ potential perception of inadequate financing and investment in climate and environment- related sectors. → Possible misinterpretation by customers, investors and other stakeholders of institutional disclosures or statements, actions and policies. → Perceived failure to support the climate transition, including insufficient financing of transition-enabling activities. → Risk that our sustainability policies are considered as preventing the provision of financial services to individuals or enterprises based on ideological reasons, or any other reasons deemed improper. |  | → Implementing preventative measures to manage reputational risk and disclose risk data so that governance bodies can make informed decisions when assessing or sanctioning sensitive transactions that entail environmental factors. → Monitoring reputational issues and disputes regularly (including environmental matters) via working groups that involve functions such as legal, sustainability, investor relations, public policy, supervisory and regulatory affairs, risk, and others. → Monitoring the implementation of guides to manage and prevent greenwashing, which define the roles and responsibilities of the key processes, and subsequently establish specific training programmes. → Implementing appropriate materiality assessments to measure relevant risk and developing a methodology to quantify it, which remains in compliance at all times with applicable local law, policy, and regulations. → Our policies aim to identify how these risks may affect the creditworthiness of potential borrowers, and therefore pose a credit risk issue. |
Strategic |  | Short - medium - long term | → Our strategy could be affected if we fail to achieve our environmental and social targets, including those related to the activities we finance and to our own operations. → Regulatory divergence between ESG requirements in the markets where we operate. |  | → Challenging ESG targets in strategic planning. → Monitoring the Group’s ESG indicators regularly. → Monitoring ESG indicators as part of our regular competitor analysis. → Identifying emerging risks that include ESG risk factors and analysing their potential impact under stressed scenarios on the Group’s strategic targets to draw up action plans. → Monitoring ESG-related proposals for the corporate product governance forum (CPGF) and investments forum. |

A. Though all climate drivers impact on risk factors, we have only included the key ones in this table.
Chronic Acute Market sentiment Policy action
Technology Dependencies Impacts
Annual report 2025 42

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Key achievements in 2025
| MATERIALITY |  |  |  | → Progress in identifying and assessing nature-related risks across existing risk types. → In credit risk, we embedded nature materiality assessments in the Klima tool to get a combined view of climate and natural capital risks. → We set specific metrics to manage nature-related risks and conducted in-depth analyses on the most material portfolios by complexity (Brazil) and concentration (UK mortgage portfolio). |
| PANGEA |  |  |  | → Strategic CIB project to assess corporate customer assessment procedures. → Expanded the scope to the entire portfolio by incorporating screening and escalation criteria linked to the Group’s materiality assessment. |
| SCENARIO ANALYSES |  |  |  | → Embedded internal climate models in risk management that enable us to enhance how we quantify the financial impact of transition and physical risk on credit risk variables (PD and LGD). → Update of heatmaps in the credit materiality assessment across different time horizons, calculated using scenario analysis techniques based on our portfolio, models and Network for Greening the Financial System (NGFS) scenarios. |
| PHYSICAL RISK |  |  |  | → Increased geographic granularity in physical risk analysis, down to postcode level in Europe or equivalent in other countries. → Expanded the number of markets we assess. |

2.3.1 Resilience of our business model to
climate change
Managing the risks that stem from environmental and social
factors plays a critical role in strengthening the resilience of our
business model to climate change.
We embed these factors in all stages of the risk management
cycle, in accordance with local law and regulation, by assessing
both our own facilities and our interactions with customers.
Moreover, we include the risks derived from these factors in our
policies, procedures, tools, metrics, mitigating actions, reporting,
governance and culture.
And we do this using a forward-looking approach that covers the
medium and long term through the use of climate scenarios across
different time horizons. The Risk function works to strengthen our
management framework by:
• conducting regular emerging risk assessments to spot key
threats to our strategic plan under theoretical stress scenarios
with low likelihood of occurrence;
• assessing and challenging the strategic plan to spot potential
threats that may stop the Group from achieving its objectives;
and
• using internal ESG risk management policies that enable the
identification, assessment, mitigation, monitoring and reporting
of material risks arising from environmental, social and
governance factors.
Our risk governance bodies regularly review the monitoring of
material topics related to the ESG risk factors identified through
these processes, while at all times complying with applicable local
laws and regulations in the markets where we operate.
Santander understands how environmental and social factors
affect its business environment in the short, medium and long
term. The strategic response to the changes and uncertainties
arising from these factors influences the resilience of the business
model over time. Therefore, climate, environmental and social
changes in the macroeconomic, regulatory and competitive
environment are explicitly considered, and integrated into strategic
processes and escalated to management bodies.
5 Risk management follows a global approach while aligning to local regulatory and legal requirements.
6 European Banking Authority.
7 European Bank for Reconstruction and Development.
Annual report 2025 43

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2.3.2 Risk management cycle 5
At Grupo Santander, we manage the environmental and social factors of our global portfolio by considering all risk types and prioritizing the
most material ones. Below we describe how we embed these factors in the risk management cycle.
Risk management cycle
1. Identification
We conduct regular risk identification exercises to assess events
that could threaten the Group's strategic plan. These exercises
consider environmental risk factors beyond climate, such as nature
and biodiversity, as well as social factors.
Risk identification enables us to understand the internal and
external threats that the environment and climate change pose to
our business model, profitability, solvency and strategy.
We use tools such as the internal risk taxonomy, heatmaps and
materiality assessments, which provide the basis for identifying
and classifying material environmental and social risks across our
portfolios.
In 2025, we determined the social factors that will apply to Grupo
Santander’s loan portfolio and will embed them in our materiality
assessment in 2026, including an assessment of social factors that
may have a potential impact based on regulatory requirements,
international standards and market best practices (EBA 6, EBRD 7,
World Bank, and others). This will be done in a way that at all
times complies with local law and takes into account local policy
where appropriate.
2. Planning
We include E&S risk management in strategic planning, which
spans several time horizons in addition to ad-hoc analysis at each
moment:
• One year for the short term (this is the standard time horizon for
the short term in the Group).
• One to five years for the medium term (financial planning).
• Over five years for the long term (strategic plan).
Specifically, we challenge the strategic plan to identify potential
threats that could prevent us from achieving our objectives.
3. Assessment
At Grupo Santander, we assess how ESG factors may increase risk
over the short, medium and long term. Our assessment of the ESG
factors that could be material due to their potential impact on the
Group’s risk profile considers these aspects:

| 1 | Review of E&S drivers |  |  |  | We use a variety of references (TCFD A, TNFD B, UNEP FI, ENCORE C, SBTN D, NGFS E) and analytical tools F to identify and monitor environmental and social risk factors across risk types.
| 2 | Analysis of transmission channels |  |  |  | We analyse how the factors identified in the previous stage could impact on the risk types included in our risk management framework.
| 3 | Assessment of potential impact on the main risks |  |  |  | We analyse the potential impacts should the risk factors previously identified through the transmission channels materialize, based on qualitative and/or quantitative approaches.
| 4 | Consolidated materiality |  |  |  | We aggregate impact results by risk type in a consolidated materiality using a five-point RAG G scale across short, medium and long-term horizons.

A. Task Force on Climate-related Financial Disclosures.
B. Taskforce on Nature-related Financial Disclosures.
C. Exploring Natural Capital Opportunities, Risks and Exposure (a materiality database of dependencies between production processes and ecosystem services).
D. Science Based Targets Network.
E. Network for Greening the Financial System.
F. Heatmaps, sectoral and environmental materiality, historical information, scenarios and customer assessments.
G. Red, amber and green. (RAG)
8 The need to assess a longer time period for the short and medium term is intended to adequately reflect the impact of physical and transition risks. Additionally, scenarios
have been considered to calculate the different time horizons.
Annual report 2025 44

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

The fol lowing table shows the consolidated results of the m ateriality assessment by risk type and time horiz on 8 as of year-end 2025:

Consolidated materiality assessment
| Transition Risk |  | Physical Risk
ST |  |  |  |  | ST |  |  |
| Climate / Nature |  | MT | LT |  | Climate / Nature | MT |  | LT
Credit risk A |  |  |  |  |  |  |  |  |  |  |
CIB | l | l |  | l | l |  | l | l | l |  | l
Corporate & SME | l | l |  | l | l |  | l | l | l |  | l
Individuals | l | l |  | l | l |  | l | l | l |  | l
Auto Consumer | l | l |  | l | l |  | l | l | l |  | l
Operational risk B | l |  | l | l |  | l | l |  | l
Market risk | l |  | l | l |  | l | l |  | l
Liquidity risk | l |  | l | l |  | l | l |  | l
Reputational risk | l |  | l | l |  | l | l |  | l
l Low l Moderately low l Medium l High l Very high
Short term (ST): <2030 | Medium term (MT): 2030-2040 | Long term (LT): >2040-2050. A. Assessment as of September 2025. B. Assessment as of November 2025.

In 2025, we continued to enhance our materiality assessment by
embedding regulatory requirements, industry best practices and
greater harmonization across risk factors, particularly with regard
to information sources, thresholds and scenarios. Moreover, we
embedded nature-related materiality alongside climate-related
materiality.
The table above shows the consolidated results of the materiality
assessments by risk factor. These assessments use specific tools
and methodologies to assess the potential impact of climate- and
natural capital-related factors. We use this risk factor materiality
assessment to underpin climate risk identification and assessment
as part of our double materiality procedure.

| For more details, see section 1.2. 'Materiality Assessment'.

The materiality assessment's rationale for each risk type is as
follows:
→ 3.1 Credit risk
We conduct regular materiality assessments to identify, assess and
monitor the Group’s environmental credit risks by sector and
geography. This assessment includes both a current-state review
and a forward-looking analysis using scenario analysis techniques
for climate risks.
Internally-developed scenario analysis and climate stress testing
models enable us to calculate impacts and monitor climate
sensitivity across key credit risk metrics, such as probability of
default (PD), across different time horizons, scenarios and with
granular detail by geography and sector.
We complement the materiality assessment with these initiatives:
– Customer assessment for the corporate portfolios that
analyse the key aspects of transition, physical, social and
environmental risk. Our subsidiaries conduct this assessment
locally.
– Sector focus, through specific analyses of key sectors such as
real estate or consumer auto financing.
– Geographical assessment of physical risk, which includes
analyses of acute and chronic physical risks based on
external expert models and considering different scenarios
and time horizons.
The materiality assessment plays a key role in setting our strategy,
risk appetite and other resilience exercises, such as ICAAP (Internal
Capital Adequacy Assessment Process).
Klima

Klima is our internal management tool for identifying, assessing
and monitoring climate and environmental risks at both Group and
subsidiary level.
It collects and processes the information required for materiality
assessments, including risk exposures and vulnerabilities, with a
granular breakdown by sector, subsector, segment and geography.
The tool supports specific portfolio analyses carried out for
physical risk, consumer auto and real estate, among others, and
enables the monitoring of sensitivities through scenario analysis.
We continue to develop new functionalities to enhance credit risk
management, in line with market best practices.

3.1.1 Climate and nature materiality
Climate change and the loss of nature and biodiversity are
inextricably linked. Climate change represents one of the main
drivers of nature loss, affecting ecosystem resilience and limiting
their capacity to regulate the climate and act as carbon sinks.
That’s why we’ve embedded nature-related analysis in our
9 Sectors such as Power - Electricity (conventional) and Mining & Metals do not distinguish activities that do contribute to the transition, due to the NACE classification typology
on which the environmental taxonomy is based.
10 It represents a consolidated view. Implications and management in each market are always informed and in accordance with local law and regulation.
Annual report 2025 45

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

materiality assessment, using various tools as references (ENCORE
and SBTN). This approach has enabled us to identify the sectors
most exposed to transition risk (impacts) and physical risk
(dependencies) across our portfolio.
The results of our 2025 credit risk materiality assessment by sector
are in the table below. For the first time, the assessment includes
nature-related materiality, as well as the wholesale and retail
trade sector within the risk taxonomy, which shows a moderate
risk assessment.
Overall, climate-related materiality follows a similar trend to that
observed in 2024, as the Group’s exposure remains largely
concentrated in sectors that are not highly vulnerable to climate
transition risk. Although the highest risks 9 are concentrated in CIB,
they do not represent a significant weight of the Group’s overall
exposure. Our portfolios continue to show low vulnerability to
physical risk, as they are predominantly located in areas with lower
risk levels. The increase observed in the agriculture sector under
the forward-looking view reflects improvements in data
granularity and updates to the models and scenarios we use for
these forecasts.
With respect to nature-related materiality, we did not identify high
risk levels. However, the assessment shows medium risks, with
agriculture and water and waste management standing out as the
most affected sectors in terms of both dependencies and impacts.
Materiality assessment – Environmental risk portfolio analysis 10

September 2025 (pre-mitigation) - EUR billion | Nature Risks | Climate Risks | Climate Risks
Transition | Physical
| CIB A | Others C | TR | PR | TR | PR | Orderly | Disorderly | HHW
Current | Current | Current | Current | 2040 | 2050 | 2040 | 2050 | 2040 | 2050
Oil & Gas | 21 | 1 |  |  |  |  |  |  |  |  |  |
Mining & Metals | 12 | 7 |  |  |  |  |  |  |  |  |  |
Power - Electricity (Conventional) | 28 | 2 |  |  |  |  |  |  |  |  |  |
Power - Electricity (Renewables) | 15 | 0 |  |  |  |  |  |  |  |  |  |
Wholesale and retail trade | 17 | 40 |  |  |  |  |  |  |  |  |  |
Transport | 27 | 12 |  |  |  |  |  |  |  |  |  |
Auto Consumer B | 0 | 159 |  |  |  |  |  |  |  |  |  |
Agriculture | 2 | 8 |  |  |  |  |  |  |  |  |  |
Manufacturing | 44 | 24 |  |  |  |  |  |  |  |  |  |
Water and Waste | 3 | 1 |  |  |  |  |  |  |  |  |  |
Construction | 16 | 16 |  |  |  |  |  |  |  |  |  |
Real Estate | 6 | 374 |  |  |  |  |  |  |  |  |  |
Total Environmental Sectors | 191 | 645 |  |  |  |  |  |  |  |  |  |
Others Sectors D | 58 | 176 |  |  |  |  |  |  |  |  |  |
Total | 249 | 821 |  |  |  |  |  |  |  |  |  |
Risk level: ¢ Very high ¢ High ¢ Medium ¢ Moderately low ¢ Low
TR: transition risk (effects of the transition to a low-carbon economy, including changes in regulation, technology and market trends). PR: physical risk (it comprises acute and chronic). A. CIB: REC (on and off-balance sheet lending + guarantees + derivatives PFE: Potential Future Exposure). B. Auto Consumer: Auto SCF HQ + Auto US (Santander Bank N.A. + Santander Consumer USA). C. Other segments (drawn amount): Individuals + Private Banking + SCF HQ + Auto US and Corporates & SMEs. D. Other Sectors: CIB, Corporate & SMEs NACEs outside of risk taxonomy perimeter + cards and Other Consumer (Individuals and SCF) + Private Banking products (excl. mortgages). Exposure 0 represents exposure below EUR 500 million.

As the table above shows, we convey the assessment results
through heatmaps that illustrate the vulnerability to
environmental risks. These maps reflect the current view and we
complement them with internal models that apply to credit
portfolios to perform forward-looking analyses over the medium
and long term. These analyses consider impacts based on
probability, magnitude and duration.
Though we present Group level results with a breakdown by
sector, our assessment is considering more granular level of detail
within our portfolios (NACE 4 level). This analysis is intended to
inform risk identification and portfolio monitoring.
11 According to Note 54 'Risk Management': the Group does not believe that additional environmental or climate change risk had a substantial impact on its equity, financial
situation and results in 2025.
12 NGFS scenarios provide a common and up-to-date reference point for understanding the evolution of climate risks and trends in climate policy and technologies over
different time horizons. That's why we use them as a basis for showing impacts on our portfolios by calculating a range of outcomes.
Annual report 2025 46

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3.1.2 Internal climate models
We use scenario analysis techniques to assess the potential impact of climate-related risks on the loan portfolio under different climate
scenarios and time horizons. For this purpose, Santander has developed an internal climate risk model known as GEA, which enables us to
quantify the financial impact 11 of transition and physical risks, monitored through changes in probability of default (PD). The GEA model
comprises these processes:
The model forecasts customers’ costs, revenues and profits by
incorporating the impact of changes in the price of carbon and in
demand patterns associated with transition risks, as well as
productivity losses and asset impairment arising from physical risk.
These are its main features:
A. Scenario Set: Our Research function adapts scenarios based on
NGFS 12 scenarios. The climate scenarios we use (Orderly,
Disorderly, Hot House World and Neutral) include country- and
sector-level detail and provide a comprehensive view of key
macroeconomic and environmental dynamics across the regions
where the Group operates. These scenarios illustrate different
pathways for the global transition towards a low-carbon
economy and their implications in terms of financial impact on
our corporate customers, primarily through two variables: Gross
Value Added and the price of carbon.
B. Physical risk impact: This considers the financial impact of acute
and chronic risks, as well as long-term changes in weather
patterns to give us a wide range of events that we assess at
regional level. For these financial impacts, we use NGFS
scenarios and data from an expert insurance company and
considering different scenarios and time horizons.
C. Transition risk impact: This uncovers changes in such factors as
climate policies, technology, and investor and consumer
sentiment that can affect demand. These factors affect
customers individually.
D. Counterparty projections: These show changes in the financial
ratios included in the credit risk rating models and are based on
forecasted revenues and costs under the different scenarios,
including physical and transition risk impacts. The projected
ratings give us the associated PD to the counterparty.
Annual report 2025 47

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

NGFS scenarios |  |  | RCP climate scenarios |
| Physical and transition risks |  |  |  | Physical risk |
| Orderly, assumes ambitious climate policies implemented early, which gradually become stricter. Therefore, both physical and transition risks are relatively moderate. |  |  |  | RCP 2.6: stringent mitigation scenario with the aim to keep global warming below 2ºC. This is associated with orderly scenarios. |
| Disorderly, climate policies are not introduced until 2030 and may differ between countries and sectors. |  |  |  | RCP 4.5: intermediate scenario where emissions reach their peak in 2040 and then decrease. This is associated with disorderly scenarios. |
| Hot house world (current policies), it is considering that some climate policies are implemented in some jurisdictions, but global efforts are insufficient to stop significant global warming. Serious physical risks and irreversible changes. |  |  |  | RCP 8.5: very high GHG emissions (keep increasing throughout the whole century). This is associated with Hot house world scenarios. |
| Neutral, a theoretical scenario constructed under the assumption that there are no transition or physical risk impacts. |  |  |  |  |

3.1.3. Customer assessment
To strengthen our environmental risk factor management, we
carry out qualitative assessments that we embed in corporate
customer assessments within the CIB and Commercial Banking
portfolios. Local teams perform these assessments and analyse
each customer’s environmental and social situation, in accordance
with local law and regulation.
We include the results of these assessments in credit decisions as
part of the annual customer rating review. Subsidiaries may also
include them in materiality assessments where they consider the
impact to be significant. Moreover, Santander has developed tools
to customize and store ESG questionnaires for customers. These
tools support credit risk management.

| CIB - PANGEA Project |
| In 2025, a strategic project was developed to review the corporate client assessment procedure, with the following objectives: → expand the scope of the assessment to the entire portfolio by adding screening and escalation criteria linked to the Group’s materiality assessment; → draw up approaches to due diligence and monitoring that are proportionate to each customer’s risk level; → introduce new data-driven risk identification tools, including artificial intelligence and controversy screening; → embed E&S factors in credit rating and in credit limit approval; → strengthen infrastructure, systems, processes and enhance reporting capabilities; and → optimise roles and responsibilities across the three lines of defence, as well as within global and local environmental, social and climate change (ESCC) teams. The project will enter into force gradually in 2026. It will remain in accordance with local law and regulation. |

3.1.4. Specific portfolio analyses
We complement portfolio-level materiality assessments with specific analyses of key portfolios:
Consumer Auto

Given our exposure to this segment, and considering its specific
characteristics and regulations, a more granular analysis is
carried out considering key risk factors and drivers including
residual value risk, portfolio maturity, changes in market
sentiment, technological developments, regulation, and
variables such as the type of product, the type of engine (internal
combustion, hybrid or electric vehicle), among others.

Physical risk

To assess physical risk by geographical location, we work with
an insurance provider, which enables us to assess physical risks
(acute and chronic). We analyse the markets where we operate,
with a breakdown by postcode for Europe and municipality for
the rest of the Group’s subsidiaries, and cover all economic
activities in our Risk Taxonomy, as well as the business lines
(such as mortgages and automobiles).
Annual report 2025 48

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Our Klima tool includes a dedicated physical risk module to cover
the markets where we operate and other countries to assess our
customers’ production centres and facilities. It includes forward-
looking that enables us to actively manage these risks through
monitoring, metrics and mitigation measures.
We assess each region to measure the associated physical risks
by rating them on our five-point scale (low to very high). To
assess the frequency and intensity of natural risks, we use
Representative Concentration Pathways (RCP) scenarios across
different time horizons (present day, 2030, 2040, 2050 and
2100).
At Group level, our analysis takes a conservative approach, using
the RCP 4.5 scenario and time horizons that are consistent with
portfolio maturities, such as 2030 for economic activity sectors
and 2050 for collateral. The results are considered in the credit
materiality assessment by region and show that, while certain
sectors are more exposed to physical risks, such as agriculture,
conventional energy and mining, their concentration in the Group
is very low (1-2%). And by contrast one of the lowest impact
comes from our collateralized portfolios with very high
concentration of exposure in the Group.

Real estate

Our real estate portfolio accounts for a significant portion of the
Group’s balance sheet. That’s why we have developed a
dedicated module within the Klima tool that provides a detailed
view of associated transition and physical risks.
Regarding transition risk, we have enhanced both the quality and
quantity of data related to energy performance certificates (EPC)
across the portfolio and boosted data capture. Where actual data
is not available, we use estimates based on internal models or
external providers.
This chart below shows the EPC coverage of our balance sheet
and distribution of actual and estimated EPC labels based on the
standards and regulation in each market where this information
exists.
Residential and commercial real estate EPC data (December
2025)

Distribution of exposure to residential and commercial real estate portfolios by EPC (December 2025)
Distribution based on Portfolio with EPC information. (RAG according EPC Standards)

Regarding physical risk, we analyse acute and chronic risks
across different scenarios and time horizons, using postcode-
level or equivalent geographic granularity. Considering a
forward-looking view across different time horizons, with no
material high risk.

→ 3.2 Operational risk
We assess the potential impact of physical risk through a
combination of specific location-based risk scores, data on the
bank’s own facilities and insurance, and internal scenario analysis
for certain physical risks. We assess the potential impact of
transition risk through operational risk tools and external ESG-
related events.
We assess physical risk as low in the short term and moderately
low in the medium and long term, mainly due to exposure to more
frequent and severe weather events in the regions where we
operate.
We consider transition risk exposure as low across all time
horizons since we have no evidence of a medium- or long-term
increase in legal and compliance risk upon adapting to new
environmental regulations. We continue to monitor these factors
to be able to spot a potential rise in the level of risk.
In 2025, we added a qualitative operational materiality assessment
on nature-related risks. As part of this, we assess the potential
impact of physical risk by combining natural capital dependency
scores by location with the location of the bank's main premises.
We assess the potential impact of transition risk through nature
impact assessment tools, which we supplement with a review of
external events.
This assessment found that the materiality of nature-related
operational risks is low. The predominantly urban location and
financial activity of our buildings and offices back this conclusion,
not to mention the current regulatory and penalty framework,
which does not foresee a significant increase in penalties or legal
action in the short term.
→ 3.3 Market risk
To assess the potential impact of climate factors, we conduct
regular analysis of our trading portfolios to identify the materiality
of positions with potential exposure to market risk climate factors.
Annual report 2025 49

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

We then compare the findings from climate stress scenarios (both
physical and transition risk) to those from internal, stressed and
budget scenarios. This assessment concludes that the materiality is
low or moderately low depending on the time horizon, due to the
low exposure to climate sensitive sectors both in the bond and
equity portfolios.
In 2025, we introduced dedicated monitoring of market risk within
the banking book by analysing the impact of climate stress
scenarios on positions measured at fair value, primarily ALCO
portfolios (Asset Liability Committee). We also embedded nature-
specific scenarios. Given the time horizon over which these impacts
materialize, we assessed them as low materiality for market risk
purposes.
→ 3.4 Liquidity risk
To assess the potential impact of climate factors, we compare the
findings of climate stress scenarios with liquidity stress scenarios.
We have a suite of physical and transition risk scenarios (disorderly
transition scenarios, extreme climate events, historical events, etc.)
whose impacts on liquidity are well below current internal and
regulatory stresses due to their limited effect on high quality liquid
assets (HQLA) and stable retail deposits.
In 2025, we embedded new nature-related scenarios. Given the
time horizon over which liquidity impacts would materialize, we
assessed these scenarios as low materiality.
→ 3.5 Reputational risk
We conduct specific materiality assessments on the potential
reputational impact of climate and environmental factors in the
short, medium and long term under various scenarios. As with our
strategy, policies and management models, we consider the
environment holistically. Thus, our materiality assessment
includes identifying and assessing climate change and other
environmental impacts.
Certain economic agents whose activities are subject to regulations
aimed at promoting sustainable development, or which are directly
affected by the objectives set out in international agreements or
institutions on climate change, may see their activities or their
ability to generate income impacted, either directly or indirectly.
This should be taken into account when assessing the associated
credit risk. Indirect impact refers, in particular, to public perception
that a company is carrying out activities that are inconsistent with
applicable regulations, international objectives, or generally
accepted trends.
In 2025, we updated our reputational risk materiality assessment
approach based on official reports and studies from renowned
organizations. Moreover, we continue working on further
homogenization and synergy between risks in terms of information
sources, thresholds and scenarios, among others.
4. Monitoring
In addition to the processes described above, we continuous
monitor ESG factors:
• At Grupo Santander, we constantly monitor the risk profile and
our compliance with risk appetite limits through control
functions that report to the board. In 2025, we updated and
harmonized risk appetite metrics (limits and alerts) in line with
the Group’s strategy. We also strengthened our risk appetite
statement by embedding new specific metrics for other material
sectors.
• In 2025, we worked on drawing up and designing a Group-level
ESG dashboard to monitor the main ESG risks across our portfolio
to strengthen control through metrics (particularly concentration
metrics).
• We are in permanent contact with our customers to monitor their
transition plans and support implementation.
• We continue to embed ESG risk factors in the credit granting and
monitoring process through our operating model (The Climate
Race) to comply with EBA guidelines across the Group’s
subsidiaries and adapt them at local level. We align this process
at all time with applicable laws and regulations in the markets
we operate.
• Our Sustainability Regulatory Radar enables us to monitor
regulatory and other changes in this area and to assess the
potential efforts and financial impacts associated with their
implementation.
• The Risk and Compliance functions monitor ESG factors in
corporate development transactions presented to the investment
forum, acting under delegated authority from the Board's
Executive Committee, as well as in new products and services
submitted to the Corporate Product Governance Forum.
5. Mitigation
Grupo Santander uses several levers to mitigate the risks
associated with environmental and social factors, ensuring
compliance at all times with local laws and regulations:
• Policies, frameworks and internal procedures that embed
environmental and social factors in risk management and play a
key role in mitigation and adaptation. Our E&S risk management
policy sets out the standards for investing in entities and
providing financial products and services to customers in sectors
with E&S risks identified as material.

| For more details, see section 3.2.3 'Management of environmental and social aspects'.

• Use of the internal taxonomy (SFICS), which enables us to
monitor our sustainable activity, support product development,
and mitigate greenwashing.
• We consider ESG aspects in customer assessments to determine
whether they have an impact on credit quality. Against this
backdrop, we have launched several projects: (i) sector
guidelines to identify the main transition and physical risks that
each subsector faces and how to identify them in customer
interaction; (ii) ESG assessments with varying depth depending
on risk level, including enhanced contextual assessments for
more material cases and automated assessments for others. We
are rolling out this assessment model across commercial banking
portfolios in several subsidiaries; (iii) questionnaires and
assessments library (EQAL), through which we continue to
enhance ESG questionnaire management capabilities. EQAL
enables us to embed ESG customer assessments in risk
management workflows and to collect historical ESG data. These
data may support aggregated analysis under varying criteria and
serve multiple risk management purposes, such as metric setting
Annual report 2025 50

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

or model impacts. EQAL operates in Argentina, Portugal and
Spain, and will become available in CIB and Brazil in the near
future.
• Customer engagement for sectors identified as the most material
through environmental materiality assessments. This enables us
to support customers in their transition to a more sustainable
economy, offer them tailor-made solutions, and create business
opportunities. Moreover, obtaining and verifying data directly
from customers also helps mitigate ESG risk factors.
• Credit committees, which embed environmental, social and
climate change factors in transaction reviews.
• CIB customer ratings, including qualitative environmental, social
and climate change assessments for material sectors.
• Monitoring and management of real estate collateral, which
considers environmental factors that may affect collateral from
transaction inception and throughout its life cycle, such as energy
performance certificates and physical and nature-related risks.
Where we identify material risk levels, we apply management,
adaptation and/or mitigation measures to align exposures with
acceptable risk levels.
• Appropriate documents to support the assessment of
environmental factors in transaction management, customer
assessments and real estate collateral valuation according to
local regulatory frameworks.
• Mandatory insurance coverage in which the bank appears as
beneficiary and which includes coverage for material risks,
including those arising from environmental events.
• CIB due diligence to assess and manage the environmental and
social factors of corporate customers and embed them in credit
approval. We assess customers in applicable sectors through a
questionnaire that the first line of defence completes before a
team of analysts reviews it to perform an overall environmental
risk factor assessment. The findings of these assessments are
escalated to the bank’s risk approval committees and considered
in decision-making. The risk assessment also forms part of
decision-making, with particular focus on greenwashing. Due
diligence consists of assessing the CIB's project finance
transactions according to the Equator Principles.
• A multidisciplinary working group (Legal, Sustainability, Risk and
Compliance) that assesses controversies, including ESG factors.

|  | ESG classification meetings |
| To mitigate greenwashing, we assigned local and global marketing committees and ESG classification meetings to act as the governing bodies responsible for the assessment, classification and monitoring of ESG-focused products and transactions. This governance model operates fully across all global businesses and Group subsidiaries. The corporate centre oversees these bodies through quarterly follow-ups and annual assessments. |  | Their aim is to check that these bodies rely on expert input to interpret and demonstrate the applicable criteria, in accordance with local law and regulation. They also draw on centres of excellence and involve Business, Risk and Sustainability teams. Moreover, we regularly update the sustainable classification model and ensure that sustainable products remain aligned with it. |

6. Reporting
Transparent and regular disclosure of information (both internally
to senior management and externally to stakeholders) supports
the management and control of environmental and social factors.
It also ensures compliance with regulatory requirements and
supervisory expectations. We work to ensure that our information
remains complete and consistent and accurately reflects
Santander’s sustainability strategy and management, while
mitigating potential risks.
Our main reports include key information on how we manage
environmental and social factors. Alongside financial results, the
annual report sets out our sustainability policies and actions, as
well as progress against E&S indicators. Moreover, the ICAAP
exercise embeds the assessment of ESG risks — including physical
and transition risks related to climate change — and analyses their
potential impact on solvency and strategic planning.
The Pillar 3 disclosure report further strengthens transparency by
publishing prudential information related to these factors. It shows
our exposure to environmental and social risks and explains how
we embed them in internal risk management frameworks.
13 Monthly metric. Banco Santander has zero tolerance for very high impact events, including ESG-related ones. Circumstances that could lead to a ‘very high’ impact event are:
i) events that trigger silver or gold crisis management
committees; ii) regulatory requirements that uncover significant weaknesses or shortcomings: very high financial penalties (above EUR 10 million), permanent cessation of
economic activity, capital aggregation, loss of banking licence, restrictions on dividend distribution, etc.; iii) events with a very high impact on public opinion: with widespread
and sustained negative media and TV coverage in a single market and/or in other markets for over one week or very high impact on social media; and iv) suspension of shares
trading or a drop in share price of over 5% in one day on the back of the issue in question.
14 The main potential environmental impact of our offices stems from their maintenance and how we manage the waste we generate. So far, we have not deemed it necessary
to adopt biodiversity mitigation measures in our operations. Nonetheless, on certain occasions we have considered corrective or mitigation measures as part of our customer
lending due diligence and in application of our E&S risk management policy.
Annual report 2025 51

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2.3.3 Reputational risk
This section outlines how we manage this IRO, which is considered
a climate-related transition risk:

| R | Reputational risk based on the perception of the Bank's progress with Group climate-related policies and objectives in certain jurisdictions and that could lead to other type of risk implications. |

Banco Santander manages reputational risk in line with the
Reputational Risk Model and the associated ESG policies and
requirements, which set out the key principles for identifying,
managing and controlling this risk.
Reputational risk may arise from multiple sources and, in many
cases, is derived from other risks, such as strategic, liquidity, or
credit risk. Reputational factors that may be associated with clients
are assessed insofar as they may lead to financial stress and in
accordance with applicable laws and regulations. To assess the
performance and effectiveness of these actions, we define specific
metrics 13 that help determine and manage appropriate actions to
prevent or mitigate reputational impacts related to climate and
environmental risk factors, as shown in the table in section 2.3
'Embedding ESG factors in risk management'.
2.3.4 Potential financial effects
To cover CSRD requirements related to financial effects (E1-9), we
include information on the exposure subject to material physical
risks in the Pillar 3 ESG report. We use the information disclosed in
this report according to the 'Implementing Technical Standards on
prudential disclosures on ESG risks' defined by the EBA.
This report covers information of the banking book portfolio,
including loans and advances, debt securities and equity
instruments and, unlike other non-accounting-based reports,
enables us to reconcile accounting of the total figures presented.
Physical risk:
Below we report on our exposures that are sensitive to impacts
from material acute and chronic physical risks (collateralized and
non-collateralized).
To assess the physical risk of our portfolio, we use an external
provider's methodology. Based on the information it provides, we
make these assumptions to determine the Group’s sensitive
exposures to the impact of physical risk:
i. We apply a conservative criterion that the provider
recommends, considering that an activity within a given
geographic area is sensitive to physical risk impacts when at
least one hazard assessed by the external provider scores 4 or
higher on the scale.
ii. We use the RCP 4.5 scenario, which is between a scenario that
considers that the Paris Agreement objectives as met (RCP 2.6)
and a more specific stress exercise scenario (RCP 8.5).
iii. We consider time horizons that are consistent with the average
maturities of our portfolios, under a conservative approach. For
non-collateralized exposures, we apply a 2030 horizon. For
collateralized portfolios, we apply a 2050 horizon.
iv. For location-based assessment, we look at collateral locations
as well as the headquarters of borrowers for non-collateralized
loans — at postcode level or equivalent across all markets.
According to the assumptions described, our exposure to material
physical risks was EUR 39 billion as at December 2025, which
accounts less than a 2% over Group’s total assets.

Exposure subject to physical risk
EUR bn | Chronic | Acute | Both | Total
Total | 23 | 13 | 3 | 39

The ESG Pillar 3 report discloses physical risk information at
regional level (Europe, South America and North America) and
identifies a higher concentration of material physical risks in
Europe (58%).
2.3.5 Our approach to nature and biodiversity
While our materiality assessment considers 'Biodiversity and
ecosystems' an informative topic, we continue to oversee our
operations and impact on biodiversity and nature in view of our
climate objectives.
Given the Group’s financial activity and the location of its network
of buildings and offices (mainly in urban areas), we have not
initially identified 14 sites located in or near biodiversity-sensitive
areas.
We carry out a double materiality assessment to understand direct
impacts and dependencies on nature and biodiversity associated
with our customers’ business activities and based on the risk
materiality exercise. This assessment looks at both a company’s
impact on the environment and society and sustainability matters
that affect our financial performance.
We used two tools:
• ENCORE: A materiality database of dependencies (physical risks)
between production processes and ecosystem services.
• UNEP FI Impact Analysis Tool: This tool provides an in-built
impact (transition risks) mapping that, combined with our
internal data and context, enables us to identify the most
significant impact areas of the portfolio.
Annual report 2025 52

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Based on the above-mentioned approach, we use a heatmap to
aggregate nature-related dependencies and show the level of
threat of potential events that may affect our corporate portfolio at
Group level.
This exercise also meets disclosure requirements under the
European Sustainability Reporting Standards: ESRS E2 (pollution),
ESRS E3 (water and marine resources), ESRS E4 (biodiversity and
ecosystems), and ESRS E5 (resource use and circular economy), in
relation to ESRS 2 IRO-1. The assessment concluded that no
nature-related topic or subtopic proves material at Group level. We
regularly monitor our nature materiality assessment.
In 2025, we made headway with embedding nature-related risks in
portfolio management, as described in the materiality assessment.
We also strengthened internal processes to identify and assess
impacts on ecosystems and natural resources in some of the most
relevant markets, as outlined below:
• Last year, Santander Brasil took part in a pilot led by the Brazilian
Business Council for Sustainable Development under the Action
for Nature initiative. The initiative aims to promote the
implementation of the TNFD framework and strengthen
corporate disclosure on nature-related risks, dependencies and
impacts. In 2025, Santander Brasil joined the second phase of the
initiative — the Finance and Nature Community of Practice —,
which focuses on embedding nature in portfolio and supply chain
management. Current efforts centre on technical discussions, the
exchange of best practices among financial institutions, and the
development of tools to assess biodiversity-related risks and
opportunities, reinforcing Santander’s commitment to the global
sustainable finance agenda and natural capital valuation.
• Santander UK has begun assessing nature-related risks and
opportunities within its Retail Banking business. Initial
assessments show low exposure, as the portfolio does not
concentrate on high-risk sectors or geographies. In 2025, the
assessment focused on the mortgage portfolio. Though
mortgages typically do not present significant direct nature-
related risks, they represent a material portion of the balance
sheet. The assessment found that nature-related risks may
exacerbate existing climate risks, which highlights the need for
an integrated climate/nature approach. Santander UK will
continue to delve deeper with this assessment and adapt its risk
management approach as industry knowledge and
methodologies evolve.
Biodiversity and nature in our E&S risk management policy
Santander embeds nature and biodiversity conservation measures
in financing and investment policies.

| For more details on our E&S risk management policy, see section 3.2.3 'Management of environmental and social aspects'.

| Nature-based solutions are key to carbon storage and climate resilience. Santander supports several initiatives that foster these solutions: • Biomas (Brazil): Reforestation of two million hectares with two billion native trees over the next 20 years. • Santander España – Motor Verde: Reforestation of three forests covering more than 300 hectares, absorbing 82,000 tonnes of CO₂e. • Santander UK: Continued support for the Net Zero With Nature initiative with UK National Parks, helping develop a platform to mobilize private financing for nature-based solutions. • Santander México: Since 2021, the LikeU programme has enabled customers to support reforestation initiatives in partnership with Reforestamos México. |

Santander and the Brazilian biomes
Santander promotes the protection and sustainable development
of Brazil’s biomes, which is critical to tackling climate change and
conserving biodiversity recognizing that long-term prosperity
depends on a healthy natural ecosystem. We need economic
growth, but it must be sustainable.
Brazil’s emissions are estimated at 2,15 billion tonnes of CO₂e,
representing approximately 4% of global emissions, with land-use
change (42%), mainly deforestation, together with agriculture
(29%), being the main sources. A significant share of deforestation
remains illegal, particularly on undesignated public lands, driven
by speculation and weak land governance, despite recent progress
in reducing these figures. Although Brazil has a strong
environmental legal framework, such as the Forest Code, the main
challenge continues to be its effective implementation and
enforcement to curb deforestation and environmental degradation.
Addressing GHG emissions and biodiversity protection in Brazil
requires a multilateral approach that includes strengthening the
implementation of environmental laws, continuously promoting
sustainable agricultural practices, and enhancing monitoring and
transparency.
Santander supports Brazil’s transition to a low-carbon and resilient
economy by integrating climate and biodiversity considerations
into its business model, promoting sustainable finance, and
fostering innovation that links environmental preservation with
inclusive economic growth. We’ve been working with our
customers to promote sustainable development in Brazil for years.
Santander has been integrating environmental and social risk
analysis into credit assessments since 2002 and in 2016 became
the first bank in Brazil to formally incorporate a sustainability score
into corporate customers’ credit rating.
Environmental and social reviews of companies
Santander Brasil conducts annual environmental and social
assessments for wholesale and SME customers with higher
exposure or credit limits above BRL 7 million, particularly in 14
Annual report 2025 53

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

priority sectors. This makes our financing practices to be aligned
with environmental laws, human rights standards and best
sustainability practices.
Each year, we assess around 2,000 customers through a
standardized E&S questionnaire that evaluates environmental
management, social practices, supply-chain controls and climate
risk exposure. Our team of specialists cross-checks responses
against public data – including government permits, fines,
embargoes, lawsuits and contaminated-land reports – and assigns
a score from 1 to 5 across environmental, social, and climate
dimensions.
The identification of potential risks requires enhanced due
diligence and mitigation plans, and we embed the results in the
customer’s credit assessment and sustainability rating. Regular
monitoring and reviews ensure that customers remain compliant
and progress toward sustainable practices. The E&S assessment
also incorporates climate-related physical and transition risks, such
as water stress, climate resilience and exposure to deforestation-
linked supply chains. For high-impact sectors such as mining,
agriculture, sugar and beef production, we apply additional
safeguards and sector-specific procedures.
Through this structured analysis, Santander promotes responsible
financing, boosts transparency, and supports its customers’
transition to a low-carbon and inclusive economy.

Outcome of the E&S risk analysis in Brazil in 2025

Farmers and ranchers
In Santander Brasil, beyond credit approval, we monitor
approximately 19,000 rural properties (that have been financed or
pledged as collateral in the bank’s operations) by using official data
sources, satellite images, and advanced data tools. Our alerts cover
various risks, including illegal deforestation, government
embargoes, modern slavery, and incursions into protected
territories such as indigenous lands, Quilombola communities,
conservation units, archaeological sites, and public forests.
If we detect any irregularities, we request an explanation from the
customer, regardless of the biome where the property is located. If
we uncover a breach of environmental laws or regulations, our
standard contracts enable us to demand the early repayment of
loans and to take other necessary measures to mitigate risks.
We also use internet-based satellite-imaging tools such as
Copernicus Browser and MapBiomas to track deforestation and
tree cover loss on customers’ farms and ranches over time. These
tools help us strengthen our monitoring capacity and check that
our credit portfolio aligns with our sustainability and risk
management commitments.
Collaborating with initiatives to stop deforestation
Febraban Protocol for livestock in the Amazon
Santander actively collaborates with customers, governments,
regulators and NGOs to tackle illegal deforestation. Santander
Brasil is a member of Febraban’s committee on forestry and
agribusiness.
We have been seeking commitments from beef processing
customers in the Amazon since 2020. In 2021, Santander Brasil
began engaging with more than a dozen of these customers to
tackle illegal deforestation linked to their supply chain by 2025.
Santander Brasil, along with other banks, shared lessons learnt
with Febraban, which lead to the creation of the sectorial protocol -
SARB 026/2023 - in March 2023, which sets the standards for
managing the risk of illegal deforestation in the bovine meat chain.
The protocol set out the guidelines that its signatories were to
adopt.
By signing the protocol, Santander has aligned its ambition with
the Brazilian financial industry, and has been engaging with its
meatpacking customers. This requires beef processing customers
with slaughterhouses in the Brazilian Legal Amazon region to end
illegal deforestation by December 2025, both from direct suppliers
of cattle and Tier 1 indirect suppliers and demonstrate progress
against. They also must meet mid-term milestones.
Signatory banks must monitor the implementation of actions by
the deadlines that the law stipulates, review customers' public
reports on the dates that the protocol establishes, and take
measures based on the content that beef processing customers
publish. Since setting this objective, Santander has actively
engaged with all beef processing customers that the protocol
affects, leveraging our technical expertise to assist in developing
their traceability plans and reports. During 2025, all progress
reports from customers under monitoring were reviewed for
compliance. Those who failed to present the required plans had
their credit limits temporarily suspended and reinstated only upon
compliance. We will continue to act accordingly and monitor
compliance with the milestones set by the Febraban protocol, as
well as checking adherence to the implementation timeline.
Innovative Finance for the Amazon, Cerrado and Chaco (IFACC)
Our participation in IFACC focuses on structuring innovative
financial mechanisms to support deforestation-and-conversion-
free beef and soy production models in the Amazon and Cerrado.
The IFACC framework has enabled disbursements of USD 498.75
million and supported sustainable practices across 341,434
hectares, in addition to agroforestry systems (1,754 ha), ecological
restoration (739 ha) and the protection of native vegetation
(55,613 ha). 2025 saw the formal launch of the Catalytic Capital
for the Agricultural Transition , a blended-finance debt fund (initial
capital of USD 50 million; target size of USD 200 million) that aims
for 1:4 leverage and is expected to support the protection or
recovery of more than 500,000 hectares, avoid up to 240 million
tonnes of CO₂, and directly benefit over 1,000 farmers by 2030.
Nature-based Solutions (NbS) investment collaborative
In 2024, Santander became the first bank to join Brazil’s NbS
investment collaborative, a platform led by global climate
investors and coordinated by Capital for Climate, with anchor
Annual report 2025 54

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

funding from the Finance Hub of the Gordon and Betty Moore
Foundation, and additional support from The Rockefeller
Foundation and Santander. Between 2023 and 2024, the platform
allocated USD 2.1 billion and set a USD 2.67 billion target for 2025,
with aggregated plans totalling USD 10.4 billion by 2027. The
pipeline of investible NbS projects in Brazil is expanding rapidly.
Developers plan to more than double their deployment capacity by
2028, with USD 6.1 billion in capital required to meet projected
needs by 2027. Project opportunities increasingly align with
institutional investment criteria, including scale, replicability, land
tenure security and predictable cash flows. Farmers and project
sponsors are also demonstrating that nature restoration can
enhance both productivity and profitability. The total pipeline is
expected to grow from 5.1 million hectares in 2026 to 9.6 million
hectares by 2028, spanning both primary NbS and conservation-
focused initiatives.
Amazon Finance Network
Since 2023, Santander Brasil has been an active member of the
Amazon Finance Network, a multi-stakeholder platform dedicated
to advancing sustainable finance in the Amazon region. The AFN
brings together more than 50 financial institutions, including
banks, funds, cooperatives, and development finance entities, to
mobilize capital that supports inclusive, resilient and
environmentally responsible growth. In 2025, AFN members
collaborated across four priority areas: financial inclusion,
agrifinance, carbon markets, and innovative finance. Santander
Brasil co-led the carbon markets workstream alongside The World
Bank, contributing technical expertise and strategic guidance to
shape investment frameworks that value nature-based solutions.
One of the key outcomes of this engagement was the joint Call to
Action that outlines practical steps for overcoming barriers to
private sector investment in the Amazon.
Biomas
Santander is a co-founder of Biomas, an ecosystem restoration
company committed to reforesting and protecting two million
hectares of degraded land in Brazil over the next 20 years. The
initiative’s aim is to plant two billion native trees and remove
approximately 900 million tonnes of CO₂e from the atmosphere to
make a material contribution to Brazil’s climate and biodiversity
goals. In 2025, Biomas launched its first large-scale forest
restoration project in southern Bahía, in partnership with Veracel
Celulose (which is providing land and operational support) and
Carbon2Nature Brasil (a joint venture between Iberdrola and
Neoenergia that develops high-integrity carbon credits). Known as
the Muçununga Project, the initiative aims to restore 1,200
hectares of the Atlantic Forest over a 40-year horizon by planting
two million seedlings from more than 70 native species, including
yellow ipe, jatobá and jacarandá-da-bahia.
The project is expected to deliver outcomes across four key areas:
• Climate: Restoration of the Atlantic Forest will help mitigate
climate change by removing carbon from the atmosphere.
• Biodiversity: Reintroducing a wide range of native species will
help rebuild natural habitats and strengthen ecosystem
resilience.
• Social: The initiative promotes inclusive development by
involving local communities and generating employment, skills,
and shared value.
• Carbon markets: The carbon credits issued will adhere to high-
integrity standards and provide measurable environmental and
social co-benefits.
Brazil’s Climate Fund Operation to Support Reforestation in the
Amazon
In April 2025, Santander enabled the first transaction under Brazil’s
Climate Fund to support reforestation efforts led by Mombak, a
Brazilian company that focuses on large-scale carbon removal
through native forest restoration in the Amazon. This marked a
significant milestone for climate finance and nature-based
solutions in Brazil. The Climate Fund is an instrument of Brazil’s
National Policy on Climate Change, managed by the Ministry of the
Environment. It aims to channel financial resources to projects that
contribute to climate change mitigation. Santander issued a bank
guarantee to enable the disbursement of BRL 100 million in
support of Mombak’s reforestation work in the state of Pará. The
funding will help scale the company’s partnership model with rural
landowners, combining high-integrity carbon capture with
financial incentives for sustainable land use. Beyond its
environmental contributions, the project is expected to generate
positive social outcomes by stimulating the regional economy,
creating jobs and strengthening the reforestation value chain.
Social impact
We understand that supporting the socioeconomic development of
the Amazon and other biomes and their residents is fundamental
for their preservation and for Brazil’s development.
Helping local people maintain their livelihoods is key to
maintaining this ecosystem. We want communities and
entrepreneurs to develop further and count on our support as
they do.
Amazon Journey Platform
In 2022, Santander joined forces with other financial institutions
and stakeholders to help launch the Jornada Amazônia platform,
operated by Fundação Certi. This initiative seeks to strengthen the
innovation and entrepreneurship ecosystem of the Amazon region,
with a focus on bioeconomy solutions for forest conservation. The
platform’s core objectives include training 3,000 people and
supporting the creation of 200 startups by the end of 2025.
The results achieved since 2023 reflect the emergence of a
dynamic and maturing innovation ecosystem that is shaped by
technological innovation, talent development, diversity, and a deep
understanding of the region’s social and economic potential.
The initiative has mobilized more than 9,500 people and provided
training to more than 3,000. A total of 1,991 projects have been
registered, of which 185 have received support; in addition, 465
businesses have been registered, 104 were strengthened and
qualified, and 29 start-ups have been ramped up.
As part of our contribution to the platform, we mobilized 20 senior
executives to mentor early-stage ventures and support
entrepreneurs on people management, legal and regulatory
matters, investor access, network development, strategic vision,
and business direction. In 2025 alone, Santander professionals
supported 11 start-ups under the initiative.

| For more details on Santander and the Brazilian Amazon, see santander.com .

15 In accordance with local law and regulation.
16 The scope was also adjusted by excluding short-term trade finance to be better aligned with market practice and have better internal consistency.
Annual report 2025 55

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Santander and COP 30
Throughout 2025, most notably in the lead-up to and during the
United Nations Climate Change Conference (Conference of the
Parties, COP), we took part in key climate and sustainability
discussions in Brazil and globally. Our participation reflects
Santander’s continued commitment to enabling the transition to a
low-carbon economy through financial innovation, strategic
partnerships and capital mobilization aligned with sustainable
development.
Key actions in 2025 included:
• Engaging in more than 50 forums on nature-based solutions,
decarbonization, carbon markets, blended finance, de-risking
innovative mechanisms, and sustainable finance.
• Hosting customer events focused on sectoral transition
strategies, such as transportation and logistics, agribusiness, and
hard-to-abate industries.
• The selection of four Santander Brasil case studies for major
COP-30 related platforms, particularly for nature-based
solutions and innovative sustainable finance.
These actions underscore Santander’s leadership in advancing
sustainability and supporting Brazil’s ecological transformation.
2.4 Aiming to align our activity with the Paris Agreement Goals
In this section we cover how Santander manages the following
IRO:

| I- | Adverse impact on climate and the environment due to the bank’s financing of, or investment in, certain non- sustainable assets and activities. |

We continue to work along the following lines:
▪ Financed emissions from Balance sheet: focusing on scope 3,
category 15 emissions (see sections 2.4.1 'Aligning our
portfolios', 2.4.2 'Monitoring of other portfolios' and 2.4.3
'Measuring and assessing other portfolios').
▪ Asset Management: these are outside of our balance sheet and
thus not considered as scope 3 emissions (see section 2.4.4
'Santander Asset Management’s (SAM) alignment strategy and
approach')
▪ Own operations: direct and indirect emissions including scope
1&2 and material scope 3 (beyond category 15) (see section
2.4.5 'Our environmental footprint').
Ambition and approach
We continue working towards our ambition of net zero carbon
emissions by 2050 by progressively setting specific actions
regarding the footprint of our own operations and to support our
customers in their climate objectives, prioritising the high-emitting
sectors - which also bear high and very high transition risk
according to our climate heatmap. We also focus on energy
security and affordability.
We set targets 15 for the wholesale segment in the power
generation, thermal coal, oil & gas, steel and on the automotive
sector from two perspectives: auto manufacturing (wholesale
segment) and auto lending (consumer loans for the purchase of
passenger cars in Europe).
We update our strategy and targets to incorporate the latest
scientific insights and changes in local regulation. During 2025,
Santander updated its climate alignment targets. We wanted to
ensure these remain credible and consistent, while reflecting the
real pace of transition across the economies in which the Group
operates. Five years after establishing our first targets (all the
details are covered below), this update refined the scope, metrics
and scenarios to reflect better our role as a facilitator of the
transition, as well as how external factors (especially public policy)
determine the pace of the transition.
In particular, the Group refined the perimeter 16 of certain sectoral
targets. In oil & gas, alignment target now focus on Scope 1 and 2
emissions, where customers have greater operational control and
where banks can more effectively support transition efforts, while
Scope 3 emissions are monitored given their scale and their strong
dependency on global policy, technology and demand-side
developments. Following our latest annual portfolio alignment
materiality assessment, aviation has moved from target to
monitoring due to its declining alignment materiality and strong
dependence on policy and technological developments. This
decision is consistent with our dynamic, criteria-based approach to
prioritising sectors where we can have the greatest impact, and
with the treatment applied to other sectors.
The incorporation of target ranges and regional scenarios allow us
to incorporate the differing pace of transition in markets and
sectors, differences in regulatory frameworks, and reflects the
latest science and policy developments. More detail follows.
Progress and dependencies
The climate performance dynamics of all these sectors are heavily
dependent on their regulatory and policy framework, technology
changes and customers behaviours. Both the International Energy
Agency (IEA) and the Intergovernmental Panel on Climate Change
highlight that deep emissions reductions will require the
widespread adoption of technologies that are not yet commercially
available or are only at demonstration scale.
In sectors where corporate customers are making progress, we
have set targets while acknowledging these external
dependencies.
17 The Stated Policies Scenario is designed to provide a sense of the prevailing direction of energy system progression, based on a detailed review of the current policy
landscape.
Annual report 2025 56

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

For the sectors that are heavily dependent on further regulation to
align, and where most of the customers are retail, we are
monitoring their financed emissions; but we will refrain from
setting targets until the regulatory and policy framework is clear,
consistent and supportive of both economic growth and consumer
behaviour changes.
We have been sharing our understanding and experience of these
policy gaps with authorities and other sectors.
Economic growth is essential to finance the transition - and to
ensure it is affordable and fair in both developed and developing
economies. It is therefore important that policies supporting the
transition do not undermine growth, nor the provision of reliable
and affordable energy. We believe the transition is a journey – not
a moment in time – for companies, sectors and countries.
Governments' policies or regulations to affect sudden change are
therefore likely to undermine growth and decrease investor
confidence. A 'one size fits all approach' to the transition ignores
the economic, social and political reality facing different sectors in
different regions. We need a more pragmatic, flexible approach.
Therefore we consider the financial sector should be considered as
an enabler of the transition, but not as the solution, as we cannot
substitute the authorities and public bodies in meeting the
objectives they have established.
Different governments have differing policies. Clarity on these
policies supports investments in the transition. Today, according to
IEA, there is still a large gap between the Stated Policies Scenario 17
projections and Net Zero Emissions by 2050 Scenario. This gap also
exists in Santander's core markets.
Our efforts to pursue our alignment targets also involve engaging
with public bodies whose policy decisions and actions are critical if
companies - including banks like Santander - are to make progress
towards net zero carbon by 2050. If policies (or the lack of them)
remain as they are today, a significant gap will persist between net
zero scenario pathways and what will actually happen.
We also monitor technological, economic and geopolitical factors
that bear on transition, including the energy security and the
variability of approaches in different markets.
When assessing risks and opportunities our decisions are informed
by markets, our stakeholders, and in accordance with local law and
regulation. Our climate targets aim to help our customers meet
their transition goals while keeping a robust and competitive
business model that supports economic growth and energy
security. Target setting also reflects constraints and limitations
faced in different jurisdictions and sectors. The transition must be
just and orderly.
Our ambition is also supported by alignment targets and portfolios
under monitoring. With them we monitor the most crucial part of
each sector’s value chain, focusing on those that are most
emissions-intensive, actionable and where progress can be
measured, also considering the availability of quality data and
market practices.
We prioritize engagement and assess each case individually from a
long-term perspective. This includes evaluating financing needs
across all sectors without applying blanket exclusions or refusing
credit or other services solely based on climate sector
classification, instead we consider credible transition plans and the
context of each customer's operating environment.
We are monitoring the materiality of the capital markets emissions
(facilitated emissions) for the bank, and for the moment we
consider them not material, due to low exposure.
Our focus is on the areas most material to Santander. Sectors like
cement, shipping, aluminium are still deemed non-material due to
low exposure or strong dependence on policy and technological
developments.
We use external data and models from third parties with
recognized market reputation and expertise. Finally, we rely on
financial and non-financial information from our customers.
Though the non-financial information required is becoming more
available as more companies begin to report GHG emissions, it still
falls short in certain sectors and regions. And, where available, it
might not be the most suitable or accurate. In many cases, data is
only available with a significant time lag. If no emissions data exist,
we estimate them based on proxies (average emissions by
industry, country, etc.). Once we obtain our customers' total
emissions, we apply our attribution factor in line with the PCAF
approach to determine Santander’s financed emissions.
Emissions accounting and science-based alignment target
methodologies are still relatively new areas that are improving.
More methodologies need to be developed to inform decisions and
actions.
Putting our vision into practice
We are introducing target ranges applying a weighted average of
the regional scenarios from the IEA to reflect our footprint. These
ranges are based on regional IEA NZE2050 and Announced Pledges
scenarios (APS), which, at present, is 1.7ºC. They also facilitate
incorporating different transition speeds and regulatory
frameworks, as well as to follow the latest science and policy
developments.
In the oil & gas sector, we have also evolved our methodology by
moving from absolute financed emissions to two intensity-based
metrics: (i) an alignment target for operational emission intensity
(scope 1+2), and (ii) monitoring of the primary energy mix, which
reflects the carbon intensity of our global energy supply portfolio.
This approach recognizes the role of producers in reducing
operational emissions while acknowledging that fossil fuel
consumption is primarily driven by demand-side dynamics —such
as electrification of transport, heating and industrial processes,
where we already have targets in the relevant sectors for
Santander.
Overall, these updates help guide what we do, so that our actions
reflect the realities of the markets and economies in which we
operate. We will continue to review our targets annually,
integrating the latest science, regulation, and technological
advances, so that our strategy remains both ambitious and credible
in supporting a just and orderly transition.
Annual report 2025 57

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Alignment targets A |
Sector | Scenario | Metric | Baseline year | 2022 | 2023 | 2024 | 2030 targets | Scope of emissions | Value chain in scope |
| Power generation | NZE2050 - APS B | kgCO 2 e/ MWh | 2023 |  | 149 | 88 | 102 - 124 (-32-17%) | 1 | Upstream / Generation | } | Midstream / Distribution | } | Downstream / End product |
| Oil & gas | tCO 2 e/ TJ | 2023 |  | 3.08 | 3.15 | 2.31 - 3.03 (-25-2%) | 1 + 2 | Integrated / Diversified |
Upstream / Extraction | } | Midstream / Distribution | } | Downstream / Trading |
| Steel | tCO 2 e/ tS | 2023 |  | 1.47 | 1.51 | 1.17-1.28 (-20-13%) | 1 + 2 | Upstream / Materials extraction | } | Manufacturing | } | Downstream / End product |
| Auto manufacturing | gCO 2/ vkm | 2023 |  | 135 | 128 | 80 - 98 (-41-27%) | 3 C | Upstream / Suppliers-Materials | } | Midstream / Manufacturing | } | Midstream / Dealers | } |
| Auto lending Europe D | gCO 2 e/ vkm | 2022 | 137 | 133 | 129 | 70-109 (-49-21%) | 1 + 2 |  |  |  |  |  |  |  |  |  | Downstream / End-users |
| Thermal coal | Phase-out targets to eliminate exposure by 2030 to power generation customers with a revenue dependency on coal of over 10% and thermal coal mining. |
Details on targets' scope are available in the following pages. |

Monitoring of other portfolios |
Sector | Metric | 2023 | 2024 | Scope of emissions | Value chain in scope
| Primary energy mix | tCO 2 e/TJ | 45.1 | 42.0 | 3 C | Upstream / Generation |  | Midstream / Distribution |  | Downstream/End Product |
| Aviation | gCO 2 e/RPK | 83 | 78 | 1 | Upstream / Suppliers | } | Midstream / Construction | } | Downstream / Airliners |
| Commercial Real Estate E | kgCO₂e/m² | 22.89 | 26.14 | 1 + 2 | Upstream / Suppliers | } | Midstream / Construction | } | Downstream / Owners |
| Mortgages F | kgCO₂e/m² | 21.06 | 19.00 | 1 + 2 | Upstream / Suppliers | } | Midstream / Construction | } | Downstream / Homeowners |
| Agriculture G | mtCO 2 e | 8.41 | 7.12 | 1 + 2 | Upstream / Suppliers | } | Midstream / On Farm | } | Downstream / End product |
Details on our progress on alignment available in the following pages. |

| Part of the sector value chain in-scope, due emissions materiality and/or actionability |  |  | Part of the sector value chain out of scope

A. The efforts to meet these targets are in accordance with local law and regulation.
B. NZE2050: Net Zero Emissions by 2050 Scenario. APS: Announced Pledges Scenario. 2024 publication except oil & gas 2023.
C. Use of sold products.
D. Consumer lending for acquisition of passenger cars, covering a significant majority of the exposure in Europe.
E. Financed emissions of the UK, Spain and Portugal CRE portfolios. 2023 data does not include Portugal.
F. Financed emissions of the UK, Spain and Portugal mortgage portfolios. 2023 data does not include Portugal.
G. Financed emissions of part of the Brazil agriculture portfolio. From 2024 onwards, and in line with materiality criteria, the calculation includes only soy, corn and beef cattle.
The 2023 figure was recalculated to ensure comparability.

| For more details on our alignment targets, see note SN 4. 'Our transition plan'.

Implementation strategy
CIB implementation strategy entails several actions to support our
customers in their climate objectives and to achieve our alignment
targets. These actions include an assessment of our customers’
transition plans, customer engagement, segmenting customers
based on a climate tiering approach, and dedicated portfolio
steering governance. We also collect additional data to
supplement the risk analysis process; and conduct E&S risk
management policy reviews. Given our actions relate directly to
our customers’ activity, it is not practical to make quantitative
estimates of how each action contributes to achieving our targets.
All actions described below cover the CIB business globally.
Customer climate tiering
A key element of our implementation strategy is the customer
climate tiering approach, which we align with local government
laws and policies. The outcome of this tiering approach is an
assessment of our customers’ current and expected progress to
align with our climate sector objectives. Over the last few years,
we have implemented this approach for all sectors with alignment
targets (automotive manufacturing, power, oil & gas and steel) and
adapted it where necessary to account for sector differences. We
review the climate tiering assessment for each sector every year to
reflect our customers’ progress.
Our approach aims to facilitate the achievement of our alignment
targets and to develop a strong understanding of our customers’
transition strategies towards low-carbon business models. We
take a business approach and do not apply any individual customer
exclusions solely based on customer climate tiering. This
framework is supported by governance processes, involving
various internal stakeholders, such as front office teams, risk
functions, and senior management to guide the potential portfolio
Annual report 2025 58

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

steering actions (for more details, see the Portfolio Steering
section below). It is structured around four main iterative steps:
Collect, Assess, Engage and Review. We have used several
internationally recognized references as inputs and adapted them
to our requirements and objectives.
Collect: We collect relevant information as part of regular
customer dialogue and engagement. In addition, we source specific
climate related information through tailored requests that contain
transition-focused elements designed to help us better understand
companies’ alignment strategies. We also seek to source reliable
and consistent information from credible third parties to
complement our understanding.
We collect and update this information both at the customer
onboarding stage, and as part of the regular business and risk
assessment review with each customer, which we perform at least
once a year.
Assess: Our assessment consists of a two-step approach designed
to categorize our customers according to their emissions pathway
and perceived quality of their transition strategy.
The first step involves assessing how our customers’ emissions
trajectory aligns with our current sectoral portfolio baseline and
portfolio targets. The second step assesses the quality of each
customer’s transition plan. Our transition plan assessment
methodology focuses on four pillars:
1. Targets pillar: This focuses on the quality and ambition of the
customer’s quantitative GHG emissions targets. Where
possible, we assess both short- and long-term, as well as
absolute and intensity reduction targets.
2. Action plan pillar: This considers the credibility of the
customer’s implementation strategy to achieve its alignment
targets. We assess the business strategic integration of climate
change risks and opportunities; the existence of climate
scenario planning; planned CAPEX for climate solutions; and
time-bound action plans to achieve targets.
3. Disclosure pillar: This focuses on the transparency of reporting
on historical emissions performance across all relevant scopes,
the level of assurance, and the degree of reporting alignment
with leading reporting frameworks such as TCFD.
4. Governance pillar: This considers the level of management
oversight and governance of the customer’s transition strategy.
We assess the level of seniority of executives accountable for
climate strategy, and board committee oversight of climate
change issues.
Our transition plan assessment methodology includes higher
weightings for assessment criteria deemed to be critical to credible
transition plans, compared to lower weightings for those that are
considered supporting criteria. The more highly weighted criteria
are designed to prioritize focus areas for customer engagement.
Ultimately, our customer climate tiering system comprises four
categories (Leader, Strong, Moderate and Weak).

Two step tiering system
GHG emissions profile alignment |  | • Current GHG emissions profile • Future targeted GHG emissions trajectory • Assessment of alignment with Santander’s pathway
↓ |  |
Transition plan quality assessment |  | • Internal methodology to assess perceived quality of transition plans • Developed using established transition plan assessment methodologies

Transition pillar |  | Overview
1. Targets |  | Quality and ambition of quantitative targets to reduce GHG emissions
2. Action plan |  | Depth of alignment strategy to achieve GHG emissions reduction targets
3. Disclosure |  | Transparency on GHG emissions reporting across relevant scopes
4. Governance |  | Management oversight and governance of transition strategy

Tier categories |  | Description
Tier 1 |  | Leader |  | • Emissions profile fully aligned with Santander’s pathway • Strong transition plan
Tier 2 |  | Strong |  | • Emissions profile fully aligned with Santander’s pathway but improvement needed in transition plan; or • Strong transition plan but emissions profile partially aligned with Santander’s pathway
Tier 3 |  | Moderate |  | • Emissions profile partially aligned with Santander’s pathway, but improvement needed in transition plan; or • Emissions profile not aligned with Santander’s pathway, but strong transition plan
Tier 4 |  | Weak |  | • Emissions profile not aligned with Santander’s pathway • Weak transition plan

Senior experts from our ESCC, Portfolio Alignment and
Sustainability Solutions teams delivered internally-organized
briefings to sector- specific relationship managers and ESCC
analysts. These focused on gathering information to complete the
transition plan quality assessment (the second step in our
customer climate tiering system).
Expert resources from our global Sustainability Solutions team are
made available for further education and advice on customers'
transition plans assessment.
Annual report 2025 59

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Engage with customers: Our customer climate tiering system
seeks to facilitate tailored transition dialogue to help lower-tiered
customers move up to higher tiers over time, consistent with their
transition or business strategies.
In 2025, we continued to focus our customer engagement efforts
on lower-tiered customers. We use internal transition assessment
dashboards for relationship managers, designed to help identify of
customer-level priority areas, industry benchmarking, and
opportunities to support our customers in financing their transition.
Of all the customers that are in scope of our targets, approximately
two-thirds included sustainability-related discussions in 2025.
Review: Our relationship managers perform the customer
transition plan assessment in cooperation with ESCC risk analysts.
Our Sustainability Solutions and Portfolio Alignment teams then
carry out portfolio level reviews to determine final tierings. This
portfolio level review is important to help identify key trends and
challenges in each sector, as well as for future transition plan
assessment methodology improvements.
We completed initial assessments for both steps for all sectors
where targets have been set. Subsequently, we reviewed and
enhanced transition plan quality assessments, drawing on updated
reference methodologies and sector-specific research. This led to
improved guidance and a more focused set of questions that
include sector-specific questions to assess transition plan quality.
The figure below shows the breakdown of our climate tiering
system output for all entities in scope of our original sector targets,
by sum of drawn exposures as of the end of 2025. See sections
below for further details on each sector’s portfolio composition and
evolution.

Climate tiering aggregated for the sectors for which we had set targets A

A. Based on 2025 year-end drawn exposure, according to portfolio alignment
methodology, and including project finance, both in operation and under
construction.
Among our corporate customers with drawn exposure and a
transition plan assessed in 2025, around two-thirds have set
quantitative emissions-reduction targets for sector-material GHG
scopes. These companies’ targets cover both the 2030–2039
period and longer-term ambitions towards 2040–2050. The same
proportion have established absolute reduction targets.
Approximately four-fifths have adopted time-bound action plans to
align their business with a low-carbon pathway, while a similar
share conduct climate-scenario analysis and have implemented the
TCFD recommendations.
Over half report or commit to align future CAPEX with low-carbon
solutions. More than four-fifths have obtained third-party
verification of their scope 1 and 2 emissions and have assigned
board- or management-level responsibility for climate oversight.
Portfolio steering
CIB’s portfolio steering governance is designed to identify actions
to support our customers’ transition and manage our portfolio to
achieve our climate targets. A quarterly portfolio steering meeting
operates at the core of our governance. Its scope includes
monitoring progress towards the achievement of our portfolio
targets. All relevant CIB functions are represented at this meeting.
In addition, a monthly portfolio alignment meeting provides
technical support by reviewing methodologies and monthly critical
KPI performance.
Our risk appetite and lending policies are important tools for
monitoring and steering the portfolio towards our financed
emissions targets. Our customer climate tiering assessment
informs our risk appetite for each sector where targets have been
set. We comply with fair access laws and policies where they are
applicable.
In addition, Santander’s E&S risk management policy sets out the
criteria for providing financial products to customers involved in
several of the sectors within the scope of our financed emissions
targets. For all sectors with alignment targets, we’re embedding
customer climate tiering and engagement considerations in annual
credit risk reviews. For one-off transactions (e.g. project finance),
we assess a transaction’s impact on financed emissions targets for
the relevant sector portfolio.

|  | Contributing to integrity in transition finance |
| We contribute to furthering industry knowledge of transition finance as an enabler towards net zero. As part of our long- standing support for education, employability and entrepreneurship, we have collaborated with the University of Oxford, funding the development of the Transition Finance Centre of Excellence for the last three years. This centre aims to play a prominent role in defining aspects of transition finance, such as best practice sectoral transition plans and new tools and insight for practitioners. Research has focused on multiple angles of transition finance, including developing a deeper understanding of assessing companies’ transition plans in emission-intensive sectors, |  | exploring external dependencies in corporate transition plans and assessing transition plans with more granular asset- based approaches as well as equity principles. Research has also included corporate net zero transition plan implications for loan pricing, the development of tools to assess sustainability-linked bond pricing, and other topics such as the economics of critical minerals and climate transition policy. For more details about this collaboration and published research outputs, please see smithschool.ox.ac.uk. |

18 The efforts to meet these targets are in accordance with local law and regulation.
19 For the power sector, we source emissions and production data from GlobalData, the Transition Pathway Initiative (TPI), S&P Trucost, and client disclosures. For all sectors,
we gather financial data from Capital IQ and customers’ official reports. Where data is unavailable, we apply a proxy.
Annual report 2025 60

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2.4.1 Aligning our portfolios 18
Power generation 19
Sector boundaries: For the power generation sector, we assess the
upstream/generation business in the value chain. Our portfolio
includes both corporate customers and project finance
transactions.
Industry dynamics: The demand for electricity is expected to grow
significantly in the coming years, driven by the electrification of
sectors such as transportation and buildings, the increase in AI and
corresponding data centres, and other factors.
The power‑generation sector is adding low-carbon production
capacity to cope with the increased demand and to replace fossil-
fuel power generation. The integration of renewables,
energy‑storage and grid flexibility is a key challenge.
The IEA estimates that to meet the Paris objectives, investment in
energy will need to increase from USD 3.3 trillion today to around
USD 4.8 trillion per year over the next decade, with most of the
increase flowing to clean energy, while fossil investment declines
in relative terms.
Portfolio composition: The exposure to project finance (both in
operation and under construction) outweighs the exposure to
corporate customers. Within the corporate portfolio, around 85%
of the portfolio is classified as tier 1 and 2 customers, typically
leading power companies with existing or strong objectives to
renewables. We observe clear regional differences in climate
tiering (with Europe being the leader), while many emerging
market entities are still developing and disclosing their transition
plans.

Power generation portfolio distribution A

A. Based on 2025 year-end drawn exposure, according to portfolio alignment
methodology, and including corporates and project finance, both in operation and
under construction.
Portfolio evolution: 2024 saw a significant decrease in the
portfolio's overall emission intensity, driven by a reduction in
exposure to high-carbon intensity assets and an increase in the
volume of project finance assets still under construction.
Supporting our customers in their alignment journey implies
investing in both renewable technologies and transition
technologies, which may still lead to temporary increases in
physical emission intensity in the future.

Financed emissions and exposure metrics in power generation
Sector | Year | Exposure (drawn amount billion euros) A | Absolute emissions (MtCO 2 e) | Physical emissions intensity (kgCO 2 e/MWh) | Financial emissions intensity (MtCO 2 e/ EUR bn lent) | PCAF score | 2030 target (kgCO 2 e/MWh) | Reference Scenario
Power | 2023 | 12.79 | 3.88 | 149 | 0.30 | 2.74 | 102 - 124 | IEA NZE2050 - APS (2024)
2024 | 12.16 | 2.07 | 88 | 0.17 | 2.72

A. It includes Corporates and Project Finance in operation and under construction.
20 For the Oil & Gas sector, we source emissions and production data from Wood Mackenzie.
21 For the steel sector, we source emissions and production data from CDP, Transition Pathway Initiative (TPI), Asset Impact and client disclosures.
Annual report 2025 61

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Oil & gas 20
Sector boundaries: For the oil & gas sector, we assess upstream
companies, as well as integrated companies that undertake their
own upstream oil & gas production. We assess physical emission
intensity for operational emissions in scope 1 and 2. For scope 3
emissions see Primary Energy Mix on section 2.4.2 'Monitoring of
other portfolios'.
Industry dynamics: Operational emissions from oil & gas upstream
activities are a material share of global GHG emissions, estimated
at 5 Gt CO 2 e by the IEA. The most important levers to reduce
emissions are the electrification of facilities, methane‑flaring
elimination, and carbon capture, utilisation and storage
deployment. In this sense, 55 national and international oil
companies have signed the Oil & Gas Decarbonization Charter with
the ambition to reach net-zero operational emissions by or before
2050.
Portfolio composition: This portfolio comprises geographically
diverse companies. The climate tiering for this sector follows the
same methodology as all other sectors (see description above),
applying 2030 published commitments from oil & gas companies
to assess step 1.
Portfolio evolution: The physical emission intensity of our portfolio
increased slightly in 2024, rising from 3.08 tCO 2/TJ in 2023 to 3.15
tCO 2/TJ. This was primarily due to an increase in the share of
exposure in tiers 3 and 4, while individual companies' emission
intensities have reduced.

Financed emissions and exposure metrics in oil & gas
Sector | Year | Exposure (drawn amount billion euros) | Absolute emissions (MtCO 2 e) | Physical emissions intensity (tCO 2 e/TJ) | Financial emissions intensity (MtCO 2 e/ EUR bn lent) | PCAF score | 2030 target (tCO 2 e/TJ) | Reference Scenario
Oil & gas | 2023 | 5.84 | 0.75 | 3.08 | 0.13 | 3.04 | 2.31 - 3.03 | IEA NZE2050 - APS (2023)
2024 | 5.44 | 0.71 | 3.15 | 0.13 | 3.04

Steel 21
Sector boundaries: For the steel sector, we assess companies that
attribute over 10% of their revenue to steel production.
Industry dynamics: The main alignment levers for the steel
industry are: shifting to low-carbon energy sources, (e.g.
renewable energy or hydrogen), technological improvements (e.g.
electric-arc-furnaces (EAF), carbon capture), and material
efficiency and recycling. According to the 2025 report by Global
Energy Monitor, EAF-based steelmaking capacity has grown by
nearly 11% since 2020, and half of all steelmaking capacity
currently under development plans to use EAF.
Portfolio composition: The availability of reliable data has
improved since previous reports. We take a conservative approach
by assigning all customers with insufficient data to the lowest
climate tier. This small, concentrated portfolio is sensitive to
changes in composition, which have a noticeable impact on the
overall emission intensity.
Portfolio evolution: The physical emission intensity of our portfolio
increased in 2024, rising from 1.47 tCO 2 e/TS in 2023 to 1.51
tCO 2 e/TS. This increase was due to a change in the composition of
the portfolio, as some repayments were observed in customers
with low emissions profiles.

Financed emissions and exposure metrics in steel
Sector | Year | Exposure (drawn amount billion euros) | Absolute emissions (MtCO 2 e) | Physical emissions intensity (tCO 2 e/tS) | Financial emissions intensity (MtCO 2 e/ EUR bn lent) | PCAF score | 2030 target (tCO 2 e/tS) | Reference Scenario
Steel | 2023 | 1.73 | 1.59 | 1.47 | 0.92 | 3.11 | 1.17-1.28 | IEA NZE2050 - APS (2024)
2024 | 1.47 | 1.36 | 1.51 | 0.92 | 3.04

Automotive sector
According to the IEA, road transport accounts for over 15% of
global energy-related emissions. The switch from internal-
combustion engines (ICE) to electric vehicles (EV) and plug-in
hybrid electric vehicles (PHEV) is the most important alignment
lever for this sector.
We are supporting our auto-manufacturer customers in the
adaptation of their business models and product offering towards
EVs and PHEVs. As a leading auto end-user lender in Europe, we
are also helping our retail customers finance purchases of an
increasing number of EVs and PHEVs.
We aim to align our global auto manufacturing and European auto
lending loan portfolios, with a 2030 target-range and a 2030
target, respectively. Our approach is heavily dependent on
22 For the auto manufacturing sector, we source emissions and production data from JATO, Asset Impact and client disclosures.
Annual report 2025 62

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

supportive public policy frameworks that stimulate consumer
demand.
Progress on both automotive sector portfolio targets will depend
on several external factors such as:
Regulation and policy: Public measures and policies play a pivotal
role. For example, meeting the timelines set for reducing the fleet
wide emissions in the EU would support this shift, as would the
introduction of low-emission zones. Likewise, continued adoption
of EV purchase subsidies has proven important for increasing
market penetration, as demonstrated in the Nordic countries.
Technology: A guaranteed supply of the required materials to
produce EVs and PHEVs at scale is needed to match demand. Also,
reducing EV and PHEV production costs is required to ensure
affordability in comparison with ICEs, and thus ensure a just
transition.
Infrastructure: Reaching a high penetration of EVs and PHEVs will
require a deep transformation of supply chains and the
infrastructure that powers them (increasing the number of
charging points and their performance) to shift from a model of
predominantly ICE cars to an EV and PHEV majority. The
investment needed for this infrastructure will require support from
governments and other actors, which could be affected by
conflicting interests such as energy security.
OEMs commitments: For electric vehicles to become the market’s
number one engine type, manufacturers must fulfil their
commitments regarding their development and the phasing out of
combustion engines.
Auto manufacturing 22
Sector boundaries: Within the automotive sector, CIB focuses on
the manufacturing of passenger cars, i.e. on Original Equipment
Manufacturers (OEMs). The target metric is scope 3 GHG emissions
from OEMs, measured by the average CO 2 intensity per vkm of the
fleet sold in the given year.
Industry dynamics: The switch from ICE to EV and PHEV is the
most important alignment lever for this sector. The uptake of these
technologies depends on multiple external factors.
Portfolio composition: The portfolio consists of large globally
active auto manufacturers plus some pure EV players. Aside from
these pure EV manufacturers, the carbon intensities of the OEMs’
fleets are within a relatively narrow band compared to other
industries.
Portfolio evolution: Emissions intensity improved from 135 gCO 2/
vkm in 2023 to 128 gCO₂/vkm in 2024, mainly due to the change in
the composition of the portfolio, though we also observe an overall
average reduction in the emissions intensity of our customers
during this period.

Financed emissions and exposure metrics in the automotive sector
Sector | Year | Exposure (drawn amount billion euros) | Absolute emissions | Physical emissions intensity | Financial emissions intensity | PCAF score | 2030 target | Reference Scenario
Auto manufacturing | 2023 | 3.77 | 2.56 MtCO₂ | 135 gCO₂/vkm | 0.68 MtCO₂/EUR bn lent | 3.0 | 80 - 98 gCO 2/vkm | IEA NZE2050 - APS (2024)
2024 | 3.65 | 2.15 MtCO₂ | 128 gCO₂/vkm | 0.59 MtCO₂/EUR bn lent | 3.0
Auto lending Europe | 2023 | 62.40 | 6.78 MtCO₂e | 133 gCO₂e/vkm | 0.11 MtCO₂e/EUR bn lent | 2.7 | 70 - 109 gCO 2 e/vkm
2024 | 66.27 | 6.42 MtCO₂e | 129 gCO₂e/vkm | 0.09 MtCO₂e/EUR bn lent | 2.7

Auto lending in Europe
Industry dynamics: The alignment of this sector in Europe is driven
by regulation and is particularly influenced by the emission-
reduction targets imposed by the European Union.
However, the pace of alignment will depend on external factors,
such as government action (for example, subsidies for electric or
low-emission vehicles, the development of charging infrastructure,
automakers’ commercial targets, etc.).
Portfolio evolution: 2024 emissions were 6% below the higher
end of the target curve. SCF monitors key emissions-related
metrics every quarter (total emissions, emissions intensity, auto
lending portfolio exposure, PCAF score, etc.).
It also runs these business-related actions to support the
alignment of the auto lending portfolio:
• Enter into new agreements and build on existing agreements
with electric vehicle manufacturers.
• Renew and build on existing agreements with traditional
manufacturers that have credible transition plans.
• Offer additional bundles of financial products and solutions for
electric vehicles (e.g. installation and financing of home chargers,
solar panels, etc.).
• Implement new risk management methodologies and schemes
for electric vehicles to broaden the range of residual value risk
products and support the sale of electric vehicles under our
agreements with manufacturers.
• Work on loyalty programmes alongside electric car
manufacturers to guarantee multiple cycles of vehicle use and
help extend their useful life through preventive maintenance
programmes, warranty extensions or quality seals that give
confidence to users purchasing a used vehicle and contribute to
reducing waste.
The success of these actions depends entirely on shifts in electric
vehicle supply, demand and regulation; manufacturers’ transition
plans; and such other external factors as technology,
infrastructure, government incentives and tariffs on electric
vehicles. SCF aims to follow general market trends and help
finance electric vehicles according to the transition to this vehicle
type.
SCF is working on automating emissions calculations through
several technology-based tools. All such tools will align with host
country laws, regulations, and policies. The Sustainability,
business, ESG risk and reporting and other teams are monitoring
23 The exposure in Santander Polska in 2025 is EUR 0.5 billion.
24 For Energy Mix, we source emissions and production data from Wood Mackenzie, GlobalData, Transition Pathway Initiative (TPI), S&P Trucost, Asset Impact, and client
disclosures.
25 For the aviation sector, we source emissions and production data from IBA and client disclosures.
Annual report 2025 63

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

action plans and emissions performance, while commercial teams
are performing actions to support alignment plans. Estimating the
present and future resources needed to carry out our action plan is
no easy task given the organizational complexity and scope of
targets (13 countries, 16 units and many areas involved).

Thermal coal phase-out
Sector boundaries: For the thermal coal target, we assess
customers for whom coal fired power generation represents
directly more than 10% of revenues on a consolidated basis; and
customers that own thermal-coal mines worldwide. Please refer to
the Santander E&S risk management policy in section 3.2.3
'Management of environmental and social aspects' for more
details.
Industry dynamics: Power utilities can reduce their usage of
thermal coal power plants by replacing them with other
technologies, e.g. combined cycle gas turbine or renewables.
Thermal coal miners can either responsibly divest their mine or run
down their mining activity, eventually closing the mine
sustainably.
Portfolio composition: Most of our customers in this group already
have plans in place to comply with our policy in 2030.

Exposure in thermal coal-related power & mining
Year | Exposure (drawn amount billion euros)
2023 | 4.4
2024 | 4.2
2025 | 2.3 23

Portfolio evolution: We have been continuously reducing our
exposure to thermal coal customers in scope of our target. Many of
our customers will need financing to transition away from coal.
Transition finance support to these entities may, therefore,
temporarily increase before declining over the longer term as we
aim to achieve our targets.
2.4.2 Monitoring of other portfolios
In addition to alignment targets, we monitor other climate-
relevant portfolios, which include commercial real estate (CRE) and
mortgages in the UK, Spain and, starting this year, Portugal;
agriculture in Brazil; and the aviation and primary energy mix
sectors. We selected these sectors portfolios based on their
portfolio alignment materiality, as well as their dependence on
regulation to align, and their consumption dynamics, both at Group
and country level as part of our sector climate approach.
The objective of our assessments is to gain a better understanding
of these portfolios’ climate profile, support our customers'
transition, and measure progress over time. The exercise includes
setting a baseline for financed emissions, analysing dependencies
and internal and external alignment levers (such as market shifts
and regulatory developments), outlining the governance
continuous monitoring, improve data quality and identify
commercial opportunities to support customers in their transition.

| For more details on our monitoring portfolios, see note SN 4. 'Our transition plan'.

Primary energy mix 24
The world needs energy while reducing the carbon intensity of the
energy it consumes. Moving towards low-carbon energy sources
like renewable power generation, nuclear or hydro is the key
driver. While this transition is essential, our ability to manage the
underlying metric is constrained by external dependencies such as
regulatory frameworks, policy developments and changes in
customer behavior.
Within this context, we assess the physical emission intensity of
global scope 3 emissions from our financing of the different
primary energy sources: oil & gas upstream activities, thermal coal
mining and low-carbon power generation such as nuclear power,
hydro, and renewables. The transition dynamics in these sectors
are predominantly driven by demand-side shifts—for instance, the
switch from ICE to EV in the auto sector, from fossil-based power
generation to renewables or from gas boilers to heat pumps in
buildings.
Our portfolio reflects these broader market trends. Its composition
is shaped mainly by exposure to oil & gas production and to
renewable energy generation, while the share of thermal coal
production remains significantly smaller and less material. The
total exposure decreased from 18.34 EUR bn in 2023 to 17.12 EUR
bn in 2024. As these components evolve, so does the physical
emission intensity of our primary energy mix. In 2024, this
intensity decreased to 42.0 tCO₂e/TJ from 45.1 tCO₂e/TJ in 2023,
driven primarily by a reduction in thermal coal exposure and an
increase in the relative weight of renewable power and gas.
Aviation 25
Exposure to aviation has reduced markedly from its peak in 2020,
reaching in 2024 0.53 EUR bn, compared to 0.70 EUR bn in 2023. It
now constitutes a small and highly concentrated set of long-term
asset-backed financing deals. This structure strongly limits the
possibility to actively manage the portfolio towards a target. As
anticipated in previous sections, and consistent with our portfolio
alignment materiality, aviation therefore moves from an alignment
target to monitoring. This decision follows our annual portfolio
alignment materiality assessment, which is based on dynamic
criteria including financed emissions, exposure, portfolio
management capacity and strategic relevance. Given the sector’s
evolving materiality and its strong dependency on external policy
and technology developments, monitoring now provides a more
appropriate management approach.
Annual report 2025 64

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

In the aviation sector, we focus on commercial passenger airlines,
covering both general purpose lending and aircraft-specific
financing. For dedicated purpose lending, we assess each
transaction at the individual aircraft level. This scope reflects the
structure of our exposure and aligns with the boundaries defined
for this sector in our broader transition strategy.
Recent years have brought increasing concerns about the sector’s
ability to meet its current 2030 targets, a trend now reflected in
the IEA’s updated Net Zero by 2050 Scenario. The expectation on
emissions reductions in the sector has weakened due to the
observed trends for sustainable aviation fuel– high costs and
availability issues - as well as the slow adoption of efficiency
measures such as fleet renewal or use of lighter materials. These
industry dynamics underline the sector’s heavy dependence on
policy support and technological breakthroughs.
The emission intensity of our aviation portfolio continued to
improve, decreasing from 83 gCO₂e/RPK in 2023 to 78 gCO₂e/RPK.
However, the pace of alignment and the levers available to
financial institutions remain highly contingent on the sector’s
technological and regulatory trajectory.
Agriculture in Brazil
Brazil’s agriculture sector accounts for a significant percentage of
its gross domestic product (GDP). Robust measurement of financed
emissions in this sector is challenging because agriculture spans a
long, complex value chain with multiple sources, types and
volumes of GHG emissions. Emission profiles vary by commodity,
farming practice, geography, productivity, and other factors. Since
2022, we have worked with WayCarbon to estimate our financed
emissions in agribusiness using methodologies aligned with widely
used standards — PCAF and the GHG Protocol Agriculture Guidance
— and adapted them to the situation in Brazil using data from
Brazil’s Fourth National GHG Inventory. Estimations focus on retail
credit exposures that support primary production and cover scope
1 and 2 emissions, as well as emissions related to land-use change
(LUC), where we perform farm-by-farm assessments that consider
georeferenced farm polygons available in Brazil’s Rural
Environmental Registry (Cadastro Ambiental Rural) and draw on
20-year historical data as by GHG Protocol. These sources are
characteristic of agriculture and represent a material share of
emissions across the agribusiness value chain.
Our initial estimation covered over 20 commodities. As the
methodology evolved, a subsector materiality assessment aligned
with UNEP FI guidance and PCAF criteria led us to prioritise beef
cattle, soy and corn, which account for most financed emissions
and financial exposure.
For comparability, the 2023 results were recalculated to reflect the
updated portfolio coverage used in the 2024 assessment.
Santander Brasil’s credit exposure to farms engaged in primary
production of soy, corn, and beef cattle amounted to EUR 2.46
billion in 2024. We estimate financed emissions from this portfolio
total 7.12 million tCO₂e/year, compared to 8.41 million in 2023,
representing a reduction of approximately 28%. This decrease
mainly reflects a shift in portfolio composition toward a higher
share of soy cultivation.
Regarding the emissions breakdown for 2024, we estimate 75.7%
from land management (vs. 78.4% in 2023), 24.0% from land-use
change (LUC) (vs. 21.4% in 2023), and less than 1% from energy
consumption, a proportion that remained stable. Accordingly, there
was a decline in the share of land-management-related emissions
and an increase in the share associated with LUC relative to 2023.
The reduction in absolute financed emissions occurred because the
decline in land-management emissions was proportionally larger,
influenced primarily by lower exposure to higher-emitting
activities, especially beef cattle. These developments occurred
organically and may evolve over time, affecting the distribution of
emissions across categories. In 2024 data, the PCAF data-quality
score for soy, corn, and beef-cattle operations remained at 3.00.
In Brazil, land-use change — especially linked to illegal
deforestation — accounts for nearly half of nationwide emissions.
Against this backdrop, we have implemented safeguards to
prevent our lending from being linked to illicit practices and made
it our primary alignment lever. Since 2019, before granting loans
we verify land ownership or lease status and operate a satellite-
based monitoring system that tracks all financed or collateral
properties throughout the life of the facility, monitoring early
indicators of illegal deforestation prior to official embargoes. Upon
a confirmed breach of environmental law, we may exercise
contractual rights to accelerate repayment and implement further
actions to prevent our portfolio from being associated with illegal
deforestation.

| For more details on our monitoring practices to avoid financing illegal deforestation, see Risk Management – Farmers and ranchers

Though we have identified additional alignment levers — such as
pasture restoration, intensification of livestock systems, integrated
production systems and genetic improvement —, broader adoption
depends on farmer incentives and public policy support. Practices
that improve productivity and profitability (such as no-till farming)
are already widely adopted in the field and have strong potential
for further scale-up.
Santander has not set alignment targets for agricultural
commodities due to structural dependencies: (1) Data and method
fragmentation — limited farm-level data, no farmer-level GHG
measurement, absence of a measurement, reporting and
verification (MRV) standard, and no agreed accounting for
agricultural carbon removals; (2) Portfolio dynamics — annual
turnover involving over 50% of financed farms and financial
operations, combined with seasonal, short-tenor lending, which
undermine multi-year predictability.; and (3) Regulatory and
economic landscape — earmarking for low-carbon credit lines
under public financing remains limited, and regulatory instruments
are still fragmented. The Emissions Trading System does not yet
cover primary agricultural production due to the same data and
methodological limitations. The National Mitigation Plan for
Agriculture and Livestock is at an early stage of implementation,
with scope to further specify data sets, targets and delivery
mechanisms.
Meanwhile, we are contributing to key enablers to accelerate the
transition toward low-carbon agriculture, including:
• actively contributing to, and participating in, federal government
programmes aimed at financing land restoration and sustainable
production systems, such as Eco Invest II, while supporting
customers to build a low-carbon agriculture future through
green finance solutions and innovative financial transactions;
• working with local and international partners to foster
agricultural data availability and methodologies, develop
Annual report 2025 65

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

commodity-specific emission pathways, and engage in the
development of Brazil’s national mitigation plan for agriculture
and livestock; and
• offering tailored financial solutions across the agribusiness chain
to support the transition to a low-carbon economy and
sustainable growth.
Commercial real estate and mortgages in Spain, UK and
Portugal
In 2025, we continued to make headway with our CRE and
mortgage portfolio alignment analysis in our core markets where
enough information is available: Portugal, Spain and the UK.
These sectors are highly dependent on regulatory measures
(particularly regarding renovation), energy regulation, the
availability of energy performance certificates (EPC), and volatile
data estimates. Over half of this sector's emissions come from
scope 2. This reaffirms dependence on the alignment of the
electricity mix, which consumers in the real estate sector have little
influence over. The alignment of these portfolios largely hinges on
developments in public policy, such as progress in achieving
government plans, including the roll-out of renewable energy in
the domestic energy mix and consistency between real estate
sector alignment plans and national plans.
We use the PCAF methodology in every market, taking the Carbon
Risk Real Estate Monitor Initiative emissions factors to calculate
financed emissions. We combine actual EPC data with estimates
based on internal models, which consider multiple known property
characteristics, where necessary, in line with market best practices.
We also continue to run initiatives to enhance data quality;
broaden EPC coverage to reduce data volatility; make calculations
more automated; and support our customers in boosting the
energy efficiency of their assets through financial solutions,
partnerships, and technical advisory services.
Spain
Santander España has been monitoring financed emissions in
residential mortgages since 2021 and in CRE since 2022. The main
challenge continues to be a lack of available data, as 80% of
Spain’s properties do not have an EPC and access to actual energy
consumption figures is limited, which can skew results.
Since 2020, we have been working to overcome the non-existence
of a national EPC register and scarce availability of data by:
• requesting an EPC as part of new loan applications;
• purchasing databases from an external provider with all
available registers in Spain; and
• estimating non-existent EPCs using an internal, machine learning
model that includes such variables as year of construction,
climate zone, building type and property register information.
This enables us to obtain actual or estimate EPCs for the entire real
estate portfolio.
As at December 2024, our residential mortgage portfolio, which
amounts to EUR 59.37 billion, had an emissions intensity of 21.03
kgCO₂e/m² and a PCAF score of 4.0. Our CRE portfolio, with a scope
of EUR 7.18 bn, had an emissions intensity of 21.58 kgCO₂e/m²
and a PCAF Score of 4.1.
Local and global governance forums, including the Santander
España board of directors, regularly monitor these results.
In Spain, the 2023-2030 Integrated National Energy and Climate
Plan, the Long-Term Strategy for Energy Renovation in the Building
Sector, and the future National Building Renovation Plan should
drive private investment and stimulate demand for energy
renovation. Moreover, EPC are currently under review to achieve
greater accuracy and harmonization at European level in line with
the EU Directive on energy efficiency in buildings.
At Santander España, we work to help our customers align their
assets (whether residential or commercial), while advocating for
public policy that support this transition. Santander runs an active
advocacy agenda with Spain’s Ministry for the Ecological Transition
and the Demographic Challenge and Ministry of Housing and
Urban Agenda, as well as with European bodies to promote greater
access to real data, EPC with progressive updates, a centralized
register, and possible financial and non-financial property
renovation support instruments to ensure a fair transition.
Santander promotes the energy efficiency of homes under our
residential portfolio through:
• special Banking Environment Initiative (BEI) and European
Investment Fund (EIF) lines of credit with lower interest rates for
the most energy efficient homes;
• consumer loans with special terms and conditions for energy-
related renovation that includes the installation of solar panels,
heating and cooling systems, insulation and other items;
• state-backed loans for owners associations to renovate entire
buildings; and
• an energy efficiency simulator for customers and non-customers
to estimate the work required to renovate their home, including
projected heating bill savings and emissions avoided.
For our CRE portfolio, which is less granular, we performed these
actions individually with customers:
• Agreement with CBRE to advise institutional and commercial
customers on aligning and enhancing the energy efficiency of
their buildings.
• Assistance and support in managing the energy saving certificate
system (CAEs) by entering into agreements with intermediaries,
which enables the recovery of part of the investment made in
energy efficiency measures.
• Agreements to provide sustainability consulting, including
energy analysis and efficiency measures for small businesses to
reduce costs, improve competitiveness, and cut emissions.
• In 2025, Santander España began to market the state-backed
MRR Verde line of credit to support the green transition with
special terms and conditions and to make buildings more energy
efficient through renovation.
• EIF InvestUE line of credit, with a maximum guarantee of 70%
(80% in the case of just transition or cohesion territories), where
one of the eligibility criteria is the renovation or refurbishment of
buildings in accordance with energy efficiency standards.
Annual report 2025 66

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

• New EIB MidCap line of credit, with a guarantee of 50%, where
one of the eligibility criteria is the renovation or refurbishment of
buildings in accordance with energy efficiency standards.
United Kingdom
The emissions intensity of the UK mortgage portfolio as at 31
December 2024 was 20.70 kgCO₂e/m², an improvement of 0.16
kgCO₂e/m² vs. the previous year, due to enhanced data coverage
and a small improvement in EPC ratings across financed properties.
For the commercial real estate portfolio, emissions intensity was
22.00 kgCO₂e/m² , which reveals continued challenges in obtaining
complete asset-level EPC data.
The PCAF data quality score was 3.2 for mortgages and 3.9 for
commercial real estate, with portfolio coverage of approximately
EUR 201.45 billion for mortgages and EUR 10.34 billion for
commercial real estate. We remain reliant on proxy data, which the
overall PCAF score reflects. Enhancing data quality and automating
emissions calculations remain key priorities.
The UK Government plays an essential role in shaping the pace of
the green transition. Financial incentives can make retrofitting
more affordable for homeowners and encourage wider uptake. We
were pleased to see the Government’s Warmer Homes Plan
published in January 2026. Going forward, we will continue to
support the Government to create the stability and momentum
needed to accelerate progress towards a more energy-efficient
housing market.
In 2025, we deepened our research into the barriers to retrofitting
homes, updated our Tomorrow’s Homes report from 2024, with a
new green finance research into energy-efficiency financing
opportunities. According to the report, 53% of respondents
consider energy efficiency important (up from 37%). Nonetheless,
barriers such as a lack of awareness, initial costs and few qualified
professionals, remain.
Our pilot projects taught us that partnerships for residential
property renovation are viable from a commercial standpoint.
Insights from this work are shaping the design of new customer
propositions and our approach to public policy engagement in
relation to the UK housing transition. In particular, we welcome
the increase in funding for the government's Warm Homes Plan
and await further details about its launch.
Moreover, we enhanced our internal analysis by integrating new
elements on climate change, nature and emissions offsetting,
recognizing their importance in supporting long-term resilience
and the wider impacts of our business model. This builds on our
first assessment of nature and biodiversity dependencies within
the mortgage portfolio, which analysed natural capital
dependencies and biodiversity impacts across the UK housing
market.
To support our Corporate and Commercial Banking customers
further, we established a new partnership to provide tailored
sustainability tools and expert advice. This initiative enables them
to identify and implement cost-effective measures to reduce
energy, water and waste consumption, boost operational
efficiency, and lower carbon emissions.
Portugal
Santander Portugal has a real estate portfolio coverage of over EUR
23.31 billion in mortgages and EUR 1.27 billion in CRE. Following
the methodology indicated above, emissions intensity as at 31
December 2024 was 13.70 kgCO₂e/m² and 48.87 kgCO₂e/m²,
respectively.
Santander Portugal embeds the elements of the Roadmap for
Carbon Neutrality 2050 defined by the Portuguese government
into its practices and promotes alignment with Portugal’s climate
targets through:
• the alignment of its financed emissions reduction strategy with
public policy guidelines, supporting assessment and planning
processes;
• climate transition risk assessment, embedding climate and
environmental factors into risk management, adopting a risk-
based approach and considering these factors throughout the
management cycle;
• the offering of products and services that support the transition,
promoting investment in renewable energy, energy efficiency
and other sustainable measures; and
Santander Portugal is developing sustainable finance solutions to
enhance the support provided to customers in reducing their
emissions. Our focus goes beyond financing new buildings.
Through a range of initiatives, we support homeowners across
different EPC ratings in improving their energy performance. We
also engage with companies, deepening our understanding and
strengthening our capacity to support their transition.
These initiatives are delivered under our sustainable offerings and
partnerships and include:
• securitization with the EIB to promote energy-efficient housing in
Portugal; with the benefit of a discounted rate;
• European Investment Fund and Banco de Fomento credit lines to
support the financing of sustainable investments for SMEs;
• consumer loans with preferential terms and conditions for
energy-related renovations, including the installation of solar
panels, heating and cooling systems, insulation and other energy
efficiency improvements;
• the SIBS ESG Ecosystem, enabling the sharing of ESG-related
information between companies and credit institutions to obtain
non-financial data supporting risk management; and
• the EIB Green Gateway workshop, in partnership with the
European Investment Bank, focused in part on understanding the
retrofitting market to help build effective sustainable finance
solutions.
2.4.3 Measuring and assessing other portfolios
We are expanding the scope of the portfolios measured to
understand and assess the alignment dynamics of each one of
these portfolios maintaining our focus on our sectorial climate
approach. There is a clear lack of available data to measure
financed emissions, especially in retail and commercial segments
and in some regions. Some of the information needed to assess the
level of emissions and potential alignment of our customers
properly is either not being measured or not available for our
customers. For instance, energy performance certificates of real
estate assets in Latin America and emissions calculated and
reported by corporates and, in particular, SMEs, etc. We’re working
on reducing these data gaps to measure financed emissions in a
26 Scope 1 reduction ambition vs. 2020: 7% by 2030; scope 2 reduction ambition: 91%. For more details on our targets, see section SN 7.1 'Green transition'.
Annual report 2025 67

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

way that can be useful towards steering the alignment of other key
climate portfolios and to try to implement alignment levers in our
financed portfolios.
2.4.4 Santander Asset Management’s (SAM)
alignment strategy and approach
SAM’s climate objective, framed within its fiduciary duty, focuses
on identifying, assessing and managing the risks and opportunities
arising from climate change and the energy transition. Our strategy
is centred on supporting our customers in their transition and
alignment processes, taking into account the different
jurisdictional frameworks and offering investment solutions
aligned with their preferences. To this end, we integrate climate
considerations into our investment processes, stewardship
activities and risk management, mobilising capital towards an
orderly transition and contributing to long-term value creation.
In light of the evolving regulatory and political environment, SAM
is updating its approach and internal criteria for company
alignment analysis, as well as its scope and roadmap, aiming for a
pragmatic and credible approach.
2.4.5 Our environmental footprint
In this section we cover how Santander manages the following
IRO:

| I+ | Contribution to reducing the Group’s scope 1 and 2 greenhouse gas emissions. |

Regarding our own operations, we disclose and manage our direct
and indirect emissions (scope 1, 2 and 3) since 2011, as well as
other climate-relevant metrics such as energy consumption, and
the compensation of our scope 1 and scope 2 emissions.
Our strategy to lessen the environmental impact of our operations
involves reducing our CO 2 e emissions and offsetting those we're
unable to reduce through credits beyond our value chain; reducing
and handling supplies and waste responsibly; and raising
employees’ and other stakeholders’ awareness of environmental
issues.
We’ve been measuring our environmental footprint since 2001.
Since 2011, our energy efficiency and sustainability initiatives have
helped us cut our scope 1 and 2 emissions by 88%. We continue to
follow the ambition of achieving a 72 % reduction in emissions 26 by
2030 from our own operations compared to 2020 on a like-for-like
basis and 88% compared to 2011.
These targets are managed with the following levers:

Operational emissions reduction levers 2024-2030
Alignment lever | Scope 1 (tCO 2 e) | Scope 2 location- based (tCO 2 e) | Scope 2 market- based (tCO 2 e)
i. Renewable energy and self-production measures |  | 2,000 | 9,000
ii. Energy efficiency and consumption reduction measures | 1,600 | 20,000 | 3,000
iii. Direct emissions reduction measure | 600 |  |
Total | 2,200 | 22,000 | 12,000

The balance of projects undertaken in 2024 and 2025 shows a
trend that closely aligns with meeting these targets, with the
following theoretical emission reductions already achieved or in
progress upon publication date of this report:

Estimation of operational emissions reductions in 2024-2025
Alignment lever | Scope 1 (tCO 2 e) | Scope 2 location- based (tCO 2 e) | Scope 2 market- based (tCO 2 e)
i. Renewable energy and self-production measures | 0 | 1,807 | 7,580
ii. Energy efficiency and consumption reduction measures | 1,870 | 8,492 | 1,731
iii. Direct emissions reduction measure | 2,065 | -501 A | 88
Total | 3,935 | 9,799 | 9,399

A.The increase in Scope 2 emissions is due to the replacement of natural gas with
electric systems, whose reduction in Scope 1 is even greater, resulting in a net
decrease in emissions.
The cumulative execution of these efficiency projects in the first
year accounts for total investment of over EUR 33 million in
buildings and offices, and external consumption efficiency of 52
GWh of electricity (6% compared to 2024), 1,900 tonnes of natural
gas (23% compared to 2024), and 90,000 GJ of district heating,
which is widely used in many of Grupo Santander’s central
European markets.
In 2025 for the first time, Grupo Santander has achieved 100%
renewable electricity in its 10 core markets to meet the target set
in 2020, with 2.2% of that energy self-generated in our own
buildings (16 GW).
Among the most salient projects completed in 2025 is the
installation of over 9 MW of solar capacity at the Santander Group
City in Spain, which covers 100% of electricity consumption across
its nine office buildings that house some 8,000 employees.
Annual report 2025 68

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Similarly, another key lever the Group is promoting across its
geographies is the progressive reduction of natural gas use in
buildings and offices, replacing it with heat pumps, a more efficient
and modern technology. Branch networks such as Spain and
Argentina will cease using natural gas entirely in the short term.
Other notable environmental projects include the achievement of
more ISO 14001 and ISO 50001 certifications. Particularly
noteworthy is the achievement, for the first time, of ISO 50001
certification at the offices of Santander Consumer AG in Germany.
Countries such as the United Kingdom and Argentina also have part
of their networks certified under ISO 50001, including among
these branches the Ushuaia office (Argentina), the Group’s
southernmost branch. At year-end, 42% of Santander employees
were working in buildings certified under environmental standards
(ISO, LEED, BREEAM, green certifications).
Scope 3
The assessment we conducted to determine the materiality of
indirect GHG emissions (scope 3) found that the only material
category under this scope was category 3.15 (financed emissions),
with a weighting of 99% of the total.
The supply-chain-related categories listed below are considered
material based on their volume, management capacity and,
therefore, potential to reduce them (see SN 7 for their emissions
data). Our progress in numbers:
• 3.1 Purchased goods and services.
• 3.2 Capital goods.
• 3.4 Upstream transportation and distribution.
• 3.6 Business travel.
• 3.7 Employee commuting.
• 3.9 Downstream transportation and distribution.
2.5 Further actions and enablers
2.5.1 Strategy for engagement with other key
stakeholders
While banks are enablers of the transition, they should not be
considered its sole drivers.
Favourable conditions must be in place for banks to support their
customers’ transition. Our aim is to contribute constructively to the
transition debate by providing our expertise and so that policy
evolves to support sustainable growth. The overarching regulatory
and 'finance-centric' approach to the net zero transition that has
been taken to date must be reconsidered; while it should point to
the financial sector as an enabler, it cannot be the sole driver of
investment towards a low-carbon transition.
Moreover, banks’ support in achieving the transition of high-
emitting companies to cleaner production models must be seen as
a priority. Though this could mean that our financed emissions
increase during transition, it does not indicate misalignment, but
rather our commitment to the transition — we’re helping our
customers transform; we’re not divesting from them or from the
economies we serve.
There is a key opportunity to put in place the appropriate levers to
facilitate the global transition. This is the approach that the
European Commission has adopted through the Omnibus package,
which aims to simplify the regulatory framework to embed a
competitiveness objective and make regulation compatible with
the sustainability framework. The review of the CSRD, the
Corporate Sustainability Due Diligence Directive (CSDDD) and the
taxonomy is a clear illustration of how this debate has turned into
concrete measures. As Mario Draghi wrote in his report,
sustainability objectives need industrial policy that enables their
achievement. Reducing complexity and regulatory burden will
improve framework implementation and strengthen
competitiveness and business growth.
A framework that supports the transition should not demand
higher capital requirements linked to ESG risks since Pillar I already
considers their impact. Increasing capital requirements would be
counter-productive and could jeopardize the transition, especially
in emerging economies and sectors that need to transition.

| For more details on our strategy for engagement with authorities, supervisors, NGOs, etc. see 1.3 'Stakeholder engagement'.

Partnerships and sector working groups
Partnerships with businesses and governments can help us share
best practice and accelerate progress. Grupo Santander takes part
in organizations, alliances and working groups. We engage with
international and local stakeholders (sector associations, think
tanks, universities, peers and others) to make headway with global
and company goals, in line with SDG 17 (Partnerships for the
goals).
We also engage with leading organizations to enhance banks’
stewardship of climate change and nature, such as World
Economic Forum, UNEP FI, Banking Environment Initiative,
Partnership for Carbon Accounting Financials (PCAF), TNFD Forum,
Energy Efficiency Financing Coalition and Carbon Measures.
Annual report 2025 69

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2.5.2 Governance & policies
Roles, responsibilities, and remuneration
Climate change and transition oversight
The management and oversight bodies described in sustainability
note 2 approved our transition plan, as part of this report. Also, the
responsible banking, sustainability and cultural committee (RBSCC)
reviewed our portfolio alignment targets, which the board of
directors then approved. These bodies also receive regular updates
on progress with our targets and our climate agenda.
Other bodies such as the audit committee, the financial accounting
and reporting committee, the management committee and the
sustainability committee take part in overseeing sustainability
disclosures. The risk control committee and the risks supervision
commission review risk appetite proposals before their approval.

| For more details on our ESG governance model, see note SN 2. 'Sustainability governance '.

Climate in incentive schemes
Since 2020, the Group’s variable pay scheme and, since 2022, our
long-term incentives, have considered green finance and the
progress made with climate and other sustainability targets.
In 2025, the sustainability metrics consistent with our objectives
for long-term incentives for senior executives for the 2025–27
period were approved at the Annual General Meeting, with a
weighting of 20%). 50% of the sustainability scorecard is linked to
supporting the transition to a low-carbon economy through green
financing raised and facilitated by the Group, including improving
climate data, progress on actions to align our portfolios, enhance
sustainable product offering to address market needs, further
embed climate and environmental risk, and aim to support policy
action and market developments.

| For more details on the integration of climate-related performance in incentive schemes, see section 1.4 'Sustainability governance'.

Main areas involved in implementing our climate change
strategy
In 2025 we continued to embed climate management in business
as usual across different areas such as business, risk and
sustainability. For instance, CIB has a team that works on portfolio
alignment with the relevant governance, while Wealth continued
to reinforce and update the working groups and policies that
oversee and coordinate its SRI strategy, described in section 3.2.2
'Responsible investment and social finance'. SCF has several
working groups that meet monthly to address sustainability
projects and matters, and quarterly to review progress with the
sustainability agenda.
Beyond these global businesses, numerous local units engage in a
process that the Group Sustainability area coordinates. The aim is
to make headway with the alignment agenda, promote the sharing
of knowledge and expertise, and seek synergy in the design of
reliable transition plans. These local units comply with fair access
laws and other relevant local laws and regulations.
Other corporate-level initiatives and groups that support
governance meet regularly to implement our climate change
agenda and report on regulation updates. For instance, our
sustainability public policy working group updates on upcoming
climate and sustainability regulation; a regulatory radar
governance working group meets quarterly to monitor the status
of implementation of sustainability regulations; an environmental
footprint working group measures our footprint and reviews ways
to reduce it; and a sustainable bonds working group oversees the
sustainable bonds that the Group and its subsidiaries issue.
Sustainability Reporting & Internal Control
The Internal Control and Finance Execution team, in the Financial
Accounting & Management Control division oversees the
disclosure, supervision and control of the ESG information the
Group uses to meet regulatory requirements and stakeholder
expectations. In 2025, the team worked, together with each
responsible area, to strengthen the process for gathering
information and the governance and control of disclosed
information. The emission reduction objectives of our own
operations emissions (scopes 1 & 2) have been reviewed in the
Group’s Sustainability Reporting Forum.
ESG classification meetings
As part of the assessment and tagging of transactions under
sustainability criteria, we hold global and local classification
meetings led by the risk function and/or sustainable business. For
more details, see 'ESG classification meetings' in section 2.3.2 'Risk
management cycle'.
Internal Audit
The internal audit function reviews climate risk, for more details,
see note SN 2. 'Sustainability governance'.
Policies and guidance
The Group has different frameworks and policies that establish the
principles, processes and responsibilities for managing ESG criteria
throughout Santander Group.
The Group establishes ESG policies, procedures and guidelines
adapted to local regulations and applied to all units. We
systematically review the scope of the policies to adopt ESG
standards in accordance with international best practices. The main
ones are the E&S risk management policy and the Responsible
banking and sustainability policy.

| For more details on our ESG governance model see note SN 2. Sustainability governance '.

| For more details on our E&S risk management policy, see section 3.2.3 'Management of environmental and social aspects'.

Climate training and skills development
Particularly in climate, we have developed different initiatives to
enhance capabilities, beyond the training on sustainability detailed
in section 3.3.1 'Talent and skills development'.
27 For more information on employee dialogue, see section 1.3. 'Stakeholder engagement' and 3.1.4. 'Employee feedback and experience'.
28 For more information about our culture, see section 4.1.' Corporate culture'.
29 The following are not included as Employees: a) Interns; b) Salaried employees on leave or career breaks whose employment contracts are suspended under the respective
local employment regulations; c) Non-salaried individuals with temporary employment contracts through an external provider (NACE78) performing similar tasks to in-house
staff, who do not receive salaries or benefits paid by Santander, nor self-employed workers; d) Other workers engaged in different tasks within the value chain under service
contracts. Additional information on the characteristics and distribution of our employees is provided in the 'Sustainability Notes'.
30 For more information on staff cost that supports our employee strategy, see Note 46.
Annual report 2025 70

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3. Supporting employees,
communities and customers
(Social information)
3.1 Our employees
We attract and retain the best talent by 27 :
→ offering an attractive employee value proposition that offers real opportunities to grow and harness potential; innovative ways of
working; projects that inspire; and a shared culture;
→ providing optimal conditions that safeguard employee health and well-being, with fair and competitive remuneration and initiatives that
allow a better work-life balance; and
→ promoting an inclusive and meritocratic culture 28 where everyone feels valued.
3.1.1 Talent and skills development
This section outlines how we manage the following IRO:

| I+ | Promotion of continuous career development and personal growth through learning and development programmes. |

For the purpose of this annual report and in line with previous
years, Santander defines employees as people who have an
employment contract with any of the companies that comprise our
consolidated group and whose contract remains in force at the
time of publication. 29

198,403 employees |  | Europe 42.2%
| North America 20.1%
| South America 37.7%

Attracting, managing and developing talent is addressed through
initiatives that support employee capabilities and professional
growth in line with the Group’s strategic and operational needs. 30
i. Attracting talent
Our talent attraction strategy focuses on positioning ourselves as
an employer of choice. In 2025, we welcomed 27,872 new
employees to the Group.
We launched several automation and artificial intelligence projects
as part of our talent attraction and recruiting programmes. They
aim to boost operational efficiency and optimize the candidate
experience, while reducing human bias and basing pre-screening
primarily on skills and career experience.
We also launched new editions of three editions of our Graduates
global programmes through which over 330 early-career
professionals joined our global businesses: Corporate &
Investment Banking, Wealth Management & Insurance, and Retail
& Commercial Banking.
These initiatives seek to attract and develop talent globally,
highlight the Group’s digital transformation, foster entry into the
labour market through internship and first-employment
programmes for graduates, and strengthen our employee value
proposition.
ii. Talent management
We offer programmes and experiences for our employees’
personal and career development:
• Development programmes adapted to different levels and
businesses within the organization.
• Temporary and permanent domestic and international mobility
and functional experiences.
• Training based on lifelong learning.
31 YourVoice response to the question: 'Overall, I am satisfied with the learning experiences Santander makes available to me (if not, please tell us how we could improve).'
Annual report 2025 71

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Developing talent potential
Our potential review model enables us to delve deep into the skills,
expertise and aspirations of some 110,756 employees. It also
means we can draw up career development plans based on each
person’s needs.
We developed a leadership profile and a common leadership
assessment methodology to foster transformational and
collaborative leadership that aligns with our strategy; and to gain
deep, objective and comparable knowledge of our executives. This
also enables us to support their development and make key
decisions for the Group.
Mobility matters
Our global international mobility policy, which the human
resources committee approved (by decision of the Group board), is
an essential employee development tool, with the objective of
contributing to the development of talent in the Group; strengthen
succession plans; attract external talent; encourage a global
mentality; facilitate international movement to satisfy business
needs; and share — in a transparent manner — mobility standards
with our workforce.
iii. Learning and development
At Santander, developing our people’s capabilities is key to
executing our strategy and accelerating the transformation. Our
global learning and development policy establishes the
framework governing all our actions in this area. Our goal is to
ensure that all employees are future-ready by providing access to
high-quality, relevant and personalised learning experiences, while
fostering a culture of accountability and continuous learning.
During 2025, our digital learning ecosystem, Dojo, continued to
grow at a global level. That year 176,010 employees accessed our
global learning systems, with content aligned to their profiles,
roles and development needs. Powered by artificial intelligence,
Dojo enables each employee to progress at their own pace in
developing critical skills, promoting individual growth, and
supporting the Group’s strategic priorities.
Against this backdrop during 2025, we placed a special focus on
strengthening training in data and artificial intelligence, launching
new learning pathways designed for different profiles and areas
across the Group. These initiatives combine digital modules, in-
person workshops, masterclasses, and experimentation spaces
such as hackathons, bringing artificial intelligence applications
closer to the day-to-day work of our teams. Through this approach,
we promote the responsible use of technology and enable our
professionals to develop the capabilities needed to seize the
opportunities offered by innovation in the financial sector.
Leadership and agile transformation
We strengthened our leadership development initiatives with
tailored experiences for all levels. Elevate, our global platform for
leaders, continues to be a space for connection, inspiration and
strategic learning.
We launched new experiences aimed at all Group managers, which
combine digital learning, peer workshops and even an AI-based
coach to help turn feedback into a daily leadership habit.
Moreover, we continued to build agile capabilities through learning
pathways, bootcamps and workshops designed to promote new
ways of working, facilitate agile decision-making, and foster a
culture of continuous improvement across the organization.
Future-ready talent
In 2025, 170,360 employees received training in technology,
banking, human and other key skills, which are essential for a
sustainable, diverse and high-performing organization. In
recognition of these achievements, more than 17,000 employees
obtained certificates that formally validate the skills they acquired
and open up new professional development opportunities beyond
their current roles.
In line with our global learning strategy, we aim to maintain a
balance between scalability and adaptation to the specific needs of
each profile and market. We embed common frameworks with
adaptable solutions, foster a culture of continuous learning, and
promote the translation of acquired knowledge into real impact.
Responsible banking skills
Mandatory training continues to prove a key lever for
strengthening our corporate culture and ensuring regulatory
compliance in every market. In 2025, our employees completed
training in 13 topics that the global compliance committee
approved, including sustainability, Code of Conduct, cybersecurity,
financial crime prevention, data protection, and inclusion. Each
subsidiary supplemented this training with content tailored to local
legislation and business needs.
We also continue to make progress in sustainability-related
training. Our Retail & Commercial Banking teams took part in
sustainable finance learning pathways that country-specific
modules complemented. Moreover, employees completed training
on the practical integration of ESG principles in their daily activities.
The board of directors received specific training on recent
regulatory developments in sustainability, including the
implementation of the Corporate Sustainability Reporting Directive
(CSRD) and the European Banking Authority (EBA) guidelines on
the management of ESG risks.
We continued to promote our ESG Talks, sessions led by internal
experts that strengthen cross-functional knowledge on
sustainability. In addition, we expanded our training catalogue to
include content on climate risks, inclusive banking, health,
wellbeing and ethical leadership.
Additionally, on 5 June 2025, we held Sustainability Day at Banco
Santander, coinciding with World Environment Day, with both
global and local activities.
We will continue to invest in developing our employees’ skills,
curiosity and growth so they can lead Santander’s transformation
and contribute to a more responsible, sustainable and future-ready
organization.
Employee rating on training
8.6 (out of 10)
Learning: applicability and skills
development 31
32 For more details on absenteeism and health, see the 'Sustainability notes'.
33 Adherence to global policies is monitored in 18 of the countries with the largest number of employees, which account for 98.5% of Santander’s Group workforce.
34 YourVoice response to the question: 'I am satisfied with the benefits and services available at Santander to take care of my health and well-being (if not, please tell us how
we could improve).'
Annual report 2025 72

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3.1.2 Working conditions
In this section we cover how Santander manages these IROs:

| I+ | Promote the health, well-being and security of our employees in a safe and inclusive workplace, while supporting work–life balance through policies that foster a healthy balance between professional and personal life. |
| I- | Harm employees through unlawful discriminatory conduct, inadequate working conditions, harassment or corruption. |
| I+ | Promotion of the general well-being of employees and provide appropriate remuneration under equal conditions based on merit and market rates. |
| R | Potential risk of conflict with employees based on the infringement of their rights. |

i. Employee health and well-being
Our support for employees’ health is embedded in our culture and
corporate strategy, under which our people and senior managers
work together to protect and promote each other’s health, safety
and well-being.
Based on our strategy, we:
• implemented safety and prevention systems;
• launched proactive initiatives to boost the overall well-being of
employees;
• fostered a safe and supportive working environment when it
comes to health; and
• offered flexible work alternatives to enhance work-life balance.
Our general health, safety and well-being policy aims to promote a
healthy lifestyle and create long-term value for employees and
society. It applies to all our subsidiaries and follows local laws in
the markets where we operate to the letter.
Occupational health 32
The sector-level and company collective agreements that we sign
up to consider employee health and occupational risk prevention.
We offer regular medical check-ups and tests after extended
absences in every market where we operate. We also work with
local public health authorities, employees’ legal representatives
and occupational risk insurers. Employees in our main countries
are covered under occupational health and safety systems and
policies in compliance with local risk prevention standards and best
practices. 33
We revise our occupational risk prevention plans with employees'
councils through:
• regular assessments of risk factors and preventative measures to
handle or mitigate them;
• prevention through design in new workspaces and tools;
• procedures regarding safe and quality working conditions and
certifications;
• emergency and evacuation plans to protect employees,
customers, suppliers and visitors to our facilities, including
emergency response; first aid training;
• measures to detect and minimize risk due to postural hygiene;
• accident investigation to avoid reoccurrence; employee safety
representatives actively participate in health and safety
committees.
Well-being
We aim to raise awareness about health and well-being through
our global BeHealthy programme, which celebrated its ninth year
in 2025.
In 2025, we updated this programme to align it with best practices
in health and well-being; and with the concept of circular health.
The programme is now structured around four pillars: physical,
mental, social and financial well-being. Over 50,000 employees
took part in local BeHealthy initiatives across the Group during the
year.
Employee rating on health
8.6 (out of 10)
Satisfaction with the benefits and services to
support employees’ health and well-being. 34
In April, we held BeHealthy Day (to coincide with World Health
Day), where we brought health and well-being to the focus of the
Group worldwide through in-person and virtual events. We also
joined global initiatives run by the World Health Organization,
including World Mental Health Day, Women’s Health Month, and
World Heart Day.
These initiatives gave our employees access to mental health and
emotional well-being support services, as well as to sports centres,
nutrition and mental health apps, specialist health and
preventative care, and other free or discounted services.
In 2025, we also launched the REACT programme, a continuation
of the PESA study, which provided 8,000 employees and their
families with the opportunity to participate in a leading
international research study on cardiovascular disease prevention.
This study is conducted in collaboration with Spain’s National
Centre for Cardiovascular Research.
35 In total 9,834 unique employees (4.8% of Santander's total workforce) exercised their right to any family-related leave in 2025. By gender, this accounted for 5.92% of our
women employees and 3.62% of our male employees.
36 YourVoice response to the question: 'I am satisfied with the flexible work options available to me'.
37 In some countries, leave is shared between both parents, in accordance with the applicable legislation.
38 See our commitment to human rights (which is included as well in our Responsible Banking and Sustainability policy) and international mechanisms of application in section
1.4.2. 'Human rights due diligence'.
39 These rules are monitored in 18 countries, which account for 98% of employees where trade union representation may exist in accordance with local rules (by company,
location or individual membership). In those countries except for the UK, where data on trade union membership cannot be disclosed, 65% of our employees work in
establishments with union representation.
40 For more details on our employees provisions, see Note 25 of this report.
Annual report 2025 73

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Work-life balance
Santander promotes employee work-life balance. Employees
across all companies are entitled to parental, adoption and
newborn care leave, and leave to care for family members is also
widely available. In 2025, 8,208 employees took paternity,
maternity or adoption leave and 1,778 took other family care-
related leave. 35
In recent years, in line with digital transformation and societal
change, Santander has maintained policies and arrangements that
support flexi-work for its employees. Currently, across our ten
main markets, a high percentage of employees in central services
can now adapt their working hours and location to fit with their
personal circumstances. This includes working remotely or
adjusting their entry and exit times. These measures are
continuously reviewed at team level, taking into account customer
needs, productivity, and employee engagement and experience.
Employee rating on flexibility
8.5 (out of 10)
Satisfaction with flexibility at Santander 36
Social protection
At Santander we offer our employees protection against a loss of
income due to sickness, accidents at work, acquired disability and
parental leave.
Santander employees are provided with public or private coverage
against loss of income resulting from illness or acquired disability,
in accordance with, and at least meeting, applicable local legal
requirements. On top of public health services, we offer additional
private cover in our core markets, under which employees usually
receive full pay during periods of illness.
Because employee care and respect for their rights are important to
Santander, 98% of our workforce have a permanent contract. In
every market, employees have coverage against loss of income due
to unemployment, in compliance with applicable local laws and
regulations.
Our employees have appropriate pay protection in the event of an
occupational accident. In some countries, as Spain, we supplement
the financial benefit they receive up to their entire salary in
situations of temporary ill health.
The Group has a minimum standard in each unit of fully paid
parental leave. All employees are entitled to a minimum of 14 and
up to 52 weeks of paid maternity or adoption leave for the primary
caregiver. The secondary caregiver is generally entitled to a
minimum of 4 weeks of fully paid paternity or adoption leave 37. As a
result of these inclusion measures and flexible return-to-work
arrangements, 74 % of women continue working at Santander 12
months after returning from birth, adoption or pregnancy-related
leave.
Our employees have retirement coverage through public or private
pension schemes in every market where we operate. Santander
supplements this with defined contribution pension plans for our
employees in our core markets.
Collective bargaining and social dialogue
Santander promotes respect for the rights of employees 38,
including freedom of association and the right to collective
bargaining. Our Responsible banking and sustainability policy
considers forming or joining unions and other representative
bodies a basic right of workers, in accordance with Article 10 of our
General Code of Conduct.
We also encourage respect for freedom of association, trade
unions, collective bargaining and protection for employees’
representatives under the laws of each market where we
operate 39. At 2025 year end, 129,875 employees worked at
premises or in companies with union representation.
We continued promoting and complying with the International
Labour Organization’s Fundamental Conventions and have a
European work council that meets regularly — Group senior
executives and employees’ legal representatives from Italy,
Poland, Portugal, Spain, the UK and other European countries
attend. At the meeting held in May 2025, participants shared
information on the Group’s economic and financial situation,
outlook and overall results in the European Union, as well as other
current topics related to sustainability, compliance, cybersecurity
and artificial intelligence.
We also remained in constant dialogue with employees’ legal
representatives in bilateral and special committee meetings in our
subsidiaries where all parties could discuss reporting, queries and
negotiations about working conditions and employee benefits. We
reached key agreements in our core markets in 2025, including
committees on occupational health and safety, monitoring of
gender balance plans in alignment with local regulations,, control
of pension plans, training, updates to collective bargaining
agreements, and also other bilateral meetings with union
representatives. Notable outcomes of collective bargaining include
the signing of equality plans, such as the equality plan for
Santander Global Technology and Operations, and the Group
equality plan that applies to 15 companies in Spain. Moreover, the
collective procedures carried out during the year were conducted
by consensus with employees’ legal representatives.
In Brazil, Santander and other local banks implement preventive
measures to minimize the risks from individual labour-related
claims, which are common in this market. We have sufficient
provisions to cover these risks 40. In order to minimize these claims,
we continue with internal monitoring, establishing preventive
measures to promote an environment with suitable working hours
and remuneration for all positions in the same location according
to local labour legislation and previous court rulings. We have also
continued to make progress in the digitalisation of working time
tracking and have strengthened policies and guidance for
employees to ensure their correct use.
41 Other remuneration that complements our employees’ salary: benefits, pensions, other fixed remuneration, incentives, and short or long-term variable remuneration.
42 Climate targets account for 2% of executive directors’ total remuneration, while sustainability targets account for 7% of executive directors' variable remuneration.
43 See Note 46 of the annual accounts. Excludes information relating to Santander Bank Polska S.A. and its subsidiaries.
44 Material risk-takers.
45 Measured with EPG - equal pay gap ratio, which compares the average remuneration between men and women who perform similar tasks. 2025 result for the entire Group.
46 YourVoice response to the question: 'In my own experience, employees who perform well are recognized for it'.
47 Employees who did not take part in MyContribution were new hires, employees of joint ventures, and employees in some customer service, debt recovery and contact centre
roles who are subject to similar performance management schemes but with shorter and more continuous cycles due to the nature of their work. Among employees at year-
end, 78,076 women ( 76% of the total number of women in our workforce at year-end) and 77,165 men (81% of the total number of men). Due to statistical significance, we
don't inform other gender percentages. In 202 4, the employees with performance review was 177,081 (86%). Of these, 90,998 were women (84% of the total number of
women at year-end) and 86,071 were men (87% of the total number of men employed).
48 For more details on our behaviours, see section 4.1 ‘Corporate culture’.
Annual report 2025 74

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Protection of employee data
We process employee data under the protection of labour laws and
based on the legal obligations or legitimate interests that data
protection regulation covers. As the controller of this data,
Santander has appropriate procedures, tools, and controls that
draw on the Group's data processing policies.

| For more information on data protection, see section 3.3.3 `Privacy, data protection & cybersecurity'.

ii. Remuneration and corporate benefits
Adequate remuneration
Our remuneration framework combines fixed and variable pay
schemes based on the performance of employees and the Group.
Our remuneration and performance policies, as well as our General
Code of Conduct, forbid differential treatment that is not based on
merit and corporate behaviours. It also promotes appropriate pay.
Specifically, the remuneration policy lays the foundations for non-
discriminatory practices (related to performance and internal
consistency), as well as the principles, processes and criteria for
granting fixed and variable remuneration to create long-term value
through risk management.
To set pay, we strictly abide by the practices, regulations and
collective agreements in force in each market where we operate.
All Santander employees receive a salary equal to or higher than
the legally established minimum in each of our markets and we
comply with all local legislations and applicable collective
agreements. Almost all employees (96%) receive other forms of
remuneration 41 that supplement their salary. This demonstrates
our pledge to provide fair, competitive remuneration and the
appropriate combination of fixed and variable pay.
All our businesses and subsidiaries have short-term variable
remuneration schemes to reflect what we have accomplished and
how, according to Group-wide quantitative and qualitative goals as
well as individual and team goals, behaviour, leadership,
sustainability, commitment, growth and risk management. These
schemes promote meritocracy, recognize individual and team
contributions, and promote employee growth and well-being. Our
executive directors’ variable remuneration, which aligns with our
sustainability goals, includes achieving our sustainability and
climate targets as part of its weighting 42.
In 2025, we paid EUR 13.6 billion in employee wages and
benefits 43.
Reflecting EU regulation on remuneration and to manage risk
correctly, we identified 1.336 employees 44 who are subject to a
deferred variable pay scheme because their decisions can have a
material impact on Santander's results. The majority of them are
subject to a deferral policy of a significant portion of their variable
remuneration (ranging from 40% to 60% depending on their level
of responsibility) for four to five years, which is paid out at least
50% in shares and the rest in cash, and is subject to possible
reduction (malus) or recovery (clawback).

| For more information on remuneration, see SN 7.3 'Employees'.

Equal pay
Our remuneration practices promote non-discriminatory salary
management in terms of gender (gender neutral) and an
equivalent remuneration, especially in cases where employees
perform the same or similar work (equally remunerated for equal
work or work of equal value).
T he pay gap between women and men who perform similar
functions remains below 1%, in line with last period, with market
remuneration practices, consistent with the trend observed in
recent years 45. In certain units we continue to review the pay equity
regularly and make adjustments where necessary.
We also analysed the overall gender pay gap (GPG), which
compares median remuneration for all men and women, and
which stood at 26% in 2025 (an improvement of 4.5 percentage
points over the past three years).
To measure the suitability and acceptance of our policies, we
consult employees acros s the Group, whose perceptions of
recognition and meritocracy are consistent with recent levels of
employee acceptance and the competitiveness of our
remuneration plans.
Employee rating on recognition
8.2 (out of 10)
Satisfaction with performance recognition at Santander 46
MyContribution
MyContribution is our global performance management model.
In the last financial year, 155,249 (78%) 47 of the employees had
their performance assessed under this model in 2025.
Each employee’s performance review reflects the degree to which
they have achieved the objectives they set together with their
manager during the year – which in turn align with the
organization's overall strategy – and how they have achieved them.
We assess how they demonstrate the behaviours under our
corporate culture and leadership traits, as well as the correct
management of risks associated with their activities. 48
49 For more details on our workforce, see SN 7.3 'Employees'.
50 Including Group Sr.Executive VP, Executive VP, VP, Director, Manager, Expert and Branch Manager.
51 At year-end 2024, the Group employed 4,828 people with disabilities, representing 2.3% of the total workforce. As in previous years, we follow local regulations for the
calculation and recognition of employees with disabilities. In most countries, disabilities are recorded at the employee's request with the support of a certificate issued by
social services (e.g. degree and date of disability). In the UK, disabilities are recorded at the employee's request and do not require a certificate.
52 LGBTIQ+: Lesbian, gay, bisexual, transgender, intersex, or questioning.
53 In 12 of the countries in which we operate, employees have the right to report their gender identity, subject to applicable confidentiality rules and appropriate handling of
information.
Annual report 2025 75

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3.1.3 Inclusive culture
In this section we cover how Santander manages these IROs:

| I+ | Promotion of a workforce that reflects the society we live in and encourages collaboration and provides opportunities for all our employees, irrespective of personal characteristics and in compliance with the law. |

Inclusion as a strategic pillar of our culture
An inclusive culture is an essential pillar of our strategy and
corporate culture, as well as a cross-cutting principle in the Group’s
management.
Through this approach, we promote merit, equal opportunity and
inclusion, driving the best diverse talent and ensuring compliance
with local regulations, in line with international standards of
conduct and responsible business practices.
Fostering an inclusive culture is critical to our success in every
market where we operate. The diversity of our teams, together
with the creation of safe environments that value and respect
differences, strengthens our relationships with customers, drives
innovation, and improves decision-making.
The highest level of corporate governance supports this approach.
Matters related to our inclusive culture fall under the remit of the
board of directors, which reviews them regularly through its
committees.
These principles are integrated into the main global policies and
processes guiding talent management, meritocracy and
professional conduct, including succession, appointments,
selection and the assessment of the suitability of directors, as well
as performance and remuneration processes.
Our strategy and actions combine a global vision and align with the
regulatory frameworks, realities and priorities of each market
where we operate to ensure consistency and effectiveness of our
inclusive approach across the Group.
Diverse teams that reflect the society we serve 49
Gender
• Women account for 52% of our total workforce, a figure that has
remained stable. In 2025, 51% of new hires were women.
• 40% of Banco Santander’s board of directors are women, in line
with our objective to maintain a balanced representation
between 40% and 60%, which will also become a legal
requirement in some jurisdictions from 2026.
• With this approach, we expect to progress gradually and
sustainably towards gender balance, moving closer to c.40% of
our executives 50 being women by 2030. In 2025 38.5% of our
executives were women and 61.5% were men.
People with disabilities
• We strive for the successful inclusion of our 4,854 employees
with disabilities in the Group (representing 2.5% of our global
workforce, reflecting an increase vs. prior years 51).
• In at least eight of our largest markets where we operate,
legislation requires the inclusion of people with disabilities in the
workforce. We comply with these regulations and reinforce them
through active inclusion, accessibility and awareness policies.
Diversity in other groups
We monitor the representation of ethnic groups in our markets,
where this topic is material and regulated. Employees who identify
themselves as part of these groups account for 32.2% of the
workforce there, which is consistent with the ethnic and racial
make-up of those countries.
Among employees who have voluntarily chosen to share information
related to their gender identity, 2.2% identify as part of the LGTBIQ+
community. 52,53
We promote inclusive leadership and diverse talent.
To foster inclusive and diverse leadership, senior management has
specific objectives linked to team composition and succession
plans. Beyond gender diversity, these objectives also cover career
diversity and experiences across technology and digital and
functional areas, which reflects our belief that a variety of
perspectives strengthens the Group’s leadership capacity and
naturally cascades throughout the organization.
Moreover, among the key skills for all Group executives, we
include the responsibility to create environments that foster
everyone’s development, build trust through integrity and
empathy, and promote a working environment that encourages
experimentation and learning.
Our model to attract, develop, promote and retain diverse talent is
based on meritocracy and equal opportunity. We promote the
growth of the best talent in diverse teams that reflect the richness
of our environment and the communities we serve.
To reinforce this inclusive culture, especially in the areas of
business and technology, we promote gender balance and the
incorporation of diverse talent from the earliest stages through
programmes such as 'Summer internships' and 'Graduate
Programmes' to ensure a solid and diverse future talent pipeline.
Some notable initiatives include:
• Global programmes that aim to strengthen women leadership,
such as the 'SCIB Women Leadership Program' and 'InvestHer'.
• Club Digital Girls Santander, an initiative that seeks to spark
interest in technology among girls aged 8 to 18, daughters and
relative of employees.
54 Consider race and ethnicity, colour, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national or social origin, among others.
55 Average employee rating of the YourVoice question: 'I can be myself at Santander'.
Annual report 2025 76

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

• A training bootcamp at Openbank for people with disabilities that
focuses on technology-based skills with a 100% hiring rate for
those who completed the program.
We also take active part in leading global initiatives such as the
Women’s Empowerment Principles (UN Women) and The Valuable
500, which drive gender equality and the inclusion of people with
disabilities in organizations.
Building an increasingly inclusive and engaged
environment
We promote an inclusive working environment that is free from
harassment and discrimination 54 and where every individual is
valued and respected. In 2025, 60,126 employees completed
trainings on harassment prevention and 87,004 in unconscious
bias, which are updated in line with the Global protocol against
discrimination and the General Code of Conduct, which provide a
common framework for respect, fairness and ethical behaviour.
When we ask our employees whether they feel they can be
themselves at Santander, the results are consistently high across
different groups, confirming an inclusive environment.
Employee rating on inclusion 55
8.9 (out of 10)
Satisfaction with diversity and inclusion at Santander
We have several employee networks that promote inclusion and
diversity across the Group, among which three global initiatives
stand out:
Santander Women Network, with over 8,800 members, which
promotes the professional development of women; E nable, with
nearly 3,000 members, f ocused on the inclusion of people with
disabilities; Embrace, our LGTBIQ+ network, with more than 4,300
members, which promotes awareness and visibility.
Other communities, such as Reach, Bold and Talento Não Tem Cor,
with 4,400 members, also boost the representation of diverse
backgrounds and experiences.
Throughout the year we celebrate key days such as International
Women’s Day, Pride Month and the International Day of Persons
with Disabilities, developing initiatives that reinforce our culture of
respect and awareness across de organization, as well as the
deployment of inclusive and accessible workspaces in our
facilities, that align with the diversity and needs of our people.

| For more information on protocol on workplace and sexual harassment and moral integrity at work, see santander.com/es/nuestro-compromiso/ nuestra-cultura/diversidad-equidad-inclusion

3.1.4 Employee feedback and experience
As detailed in section 1.3 'Stakeholder engagement', YourVoice is
our regular listening strategy to gather employees’ feedback. It
includes specific questions to assess their perceptions, experiences
and comments made on material items.
Employees can share their views and provide comments on each
question. In addition, each area has access to its own aggregated
results, thus maintaining confidentiality, in order to identify
improvement actions and continue strengthening the employee
experience and value proposition, thereby supporting engagement
and satisfaction levels.
More broadly, cross-cutting action plans are also established at
country and global business level.
Since the implementation of YourVoice, we have observed a
positive trend in results, with a participation rate of 80%.

Overall Engagement |  | Engagement How likely is it that you would recommend Santander as a place to work? |  | 8.6 (out of 10)
8.5 (out of 10) In the middle range and +0.3 compared to the financial sector | NPS 61 In the top 5% and +21 points compared to the financial sector A |  | Advocacy How likely is it that you would recommend Santander’s products or services to friends and family? |  | 8.7 (out of 10)
| Satisfaction Overall, how satisfied are you working for Santander? |  | 8.6 (out of 10)
| Loyalty If you were offered a similar job (with the same conditions) at another organization, how likely is it you would stay at Santander? |  | 8.2 (out of 10)
Engagement measures the level of employees’ involvement and enthusiasm towards their job and the organization, and in the YourVoice survey it is calculated based on four main dimensions: Engagement, Belief, Satisfaction and Loyalty. A. Based on the service provider's 'true benchmark'.

For more details on processes to repair negative impacts and our channels for employees to express their concerns, see section 4.3 'Ethics
Channels'
56 Credit stock as at 31 December 2025. Excludes information relating to Santander Bank Polska S.A. and its subsidiaries.
57 Credit stock as at 31 December 2025. Data for small and medium enterprises (SMEs) and sole traders covers individual customers with an outstanding loan at 2025 year-
end. Excludes information relating to Santander Bank Polska S.A. and its subsidiaries.
58 Does not include SAM funds distributed by Private Banking to avoid double counting.
Annual report 2025 77

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3.2 Sustainable development in our communities
Affected communities are those where Santander has a presence as an entity, either through its businesses or its community support
activities, and includes any specific groups mentioned in this chapter.
3.2.1 Supporting the economic and social
development of our communities
This section outlines how we manage the following IRO:

| I+ | Support of economic growth and job creation in the markets where we operate, providing credit to people and businesses. |

i. We help people and businesses prosper
We help people and business prosper through finance and
investment:
→ EUR 332.9 billion to help people buy homes and EUR 209.7
billion to purchase other goods. 56
→ EUR 318.3 billion to help set up or grow companies (including
743.000 SMEs and sole traders). 57
→ EUR 129.9 billion in assets under management in socially
responsible investment, reaching our EUR 100 billion target 9
months early.
→ 6.3 million new people reached through financial inclusion
measures since 2023, reaching our 5 million target to 2025 half
year early.
→ Our microfinance propositions in Latin America reached 1.8
million underbanked microentrepreneurs with EUR 1.26 billion in
credit disbursed.
As well through our community support initiatives:
→ EUR 163.7 million in community support, including 102.1 million
to promote education, employability and entrepreneurship (the 3
Es), through Santander Universities.
3.2.2 Responsible investment and social
finance
This section outlines how we manage the following IRO:

| I+ | Contribution to sustainable development through financing and investment that promotes sustainable performance in companies, addresses societal challenges, mitigates a specific issue, or pursues better societal outcomes. |

i. Social finance
Santander's financing supports social activities such as building
hospitals, universities and homes for vulnerable people. We tag
these activities as social to enhance the identification,
management and reporting of this type of financing, following the
same operating model and system that we use for environmental
and sustainable finance.
Under this concept, we consider the microfinance businesses that
the bank has in Latin America (Prospera in Brazil and Colombia,
Tuiio in Mexico, and Surgir in Peru), through which we granted EUR
1.26 billion in microcredit in 2025. These businesses, which we
cover in more detail in the financial inclusion and financial health
section of this report, often stretch beyond financing by providing
access to a bank account and other services such as microinsurance
for underbanked microentrepreneurs. In 2025, 1.8 million
microentrepreneurs benefitted from this type of financing.
In 2025 we entered into 18 agreements with Multilateral
Development Banks that include sustainable finance
commitments. 6 of these agreements, with a total value of EUR
1,729 million, include specific social financing commitments and
focus primarily on extending access to credit for women-led SMEs,
young farmers and other underserved segments. These loan,
securitization and guarantee agreements will support the growth
of businesses and entrepreneurs who face greater barriers to the
financial system in Spain, Portugal, Brazil and Argentina.
ii. Socially responsible investment
Assets under management (AuM) in socially responsible
investment (SRI) within Santander Wealth Management reached
EUR 129.9 billion in 2025: EUR 71.5 billion managed by Santander
Asset Management (SAM) and EUR 58.4 billion in third-party funds
within Private Banking, portfolios and direct assets 58. This growth
reflects our efforts to offer a diversified product range and to
incorporate EU regulatory requirements, and in accordance with
local law and regulation in each market.
We calculate, process and store SRI AuM within Wealth in a
dedicated repository to which we apply monthly control and
validation. The Group’s Sustainability data office receives an
automated report on these data every quarter. These data are
subject to an annual limited assurance audit prior to disclosure.
Our investment product and service proposition meets the
transparency obligations of the Sustainable Finance Disclosure
Regulation (SFDR), which require disclosure of information on the
embedding of sustainability risk, analysis and management of
adverse impacts on sustainability, ESG factors, and sustainable
investment targets.
Wealth defines SRI as the volume of AuM classified under Articles
8 (promoting environment and social characteristics) and 9 (with
distinct sustainability objectives) of Regulation (EU) 2019/2088
Annual report 2025 78

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

(SFDR), except illiquid investment in Private Banking, which we
report as committed capital. SRI includes: i) assets that SAM and
other Group asset managers in the EU (and other regions where
the SFDR doesn’t apply, using equivalent criteria) manage or advise
on; and ii) third-party funds and advisory assets considered
sustainable investment according to the SFDR (Article 2.17) or
under SFICS.
SAM has these governance policies in place: a socially responsible
investment (SRI) policy, an engagement policy, and a voting policy,
all of them applied in accordance with local law and regulation.
The SRI policy sets out SAM’s socially responsible investment
approach and the standards we consider to embed ESG variables in
our investment analysis and decision-making. The Engagement
policy outlines the principles and guidelines for active dialogue
with issuers and other counterparties (such as investors and
regulators) to promote transparency and better environmental,
social and governance performance. The Voting policy outlines the
principles and guidelines regarding the right to vote in portfolio
companies, which facilitates alignment with the SRI policy to
promote the strong performance of long-term investments.
The SAM board of directors approves and oversees the SRI policy.
SAM’s SRI team informs the local units of any revision of, or
amendment to, this policy so that they adopt it correctly and,
where appropriate, adapt it to local needs. Moreover, SAM’s SRI
strategy and monitoring forum oversees the monitoring and
coordination of SAM’s SRI strategy, as well as compliance with the
SRI policy and monitoring and control of all activities to embed SRI
in SAM.
SAM publishes its policies on its official website, as well as on the
Intranet, and are available to all stakeholder. The third-party
regulations and initiatives that SAM has pledged to uphold or that
inspire our policies feature in section 3 of our SRI policy, appendix II
of our Voting policy, and section 3 of our Engagement policy. SAM
España and Santander Pensiones have achieved full alignment
with the Spanish stock market authority's (CNMV) Stewardship
code (to which they have been signatories since 2023), reporting
annually on the activities they carry out to comply with each of its
principles. Moreover, SAM published its second SRI report in 2025,
which strengthened transparency around SRI, voting and
engagement practices in Europe and is consistent with local
regulations in other areas.

AuM in Socially Responsible Investments in Wealth (accumulated EUR bn)

46.3%
2025 (vs. 2024)

Santander Asset Management
Seeking to meet our customers’ needs, SAM offers SRI products for
customers with sustainability preferences, alongside a broader
range of investment solutions.
As at December 2025, SAM held EUR 71.5 billion in SRI assets
(13% year on year) spread across eight countries. This accounts for
28% of SAM’s total assets under management. SAM won Best
National ESG Asset Manager at the 2025 Expansión–Allfunds Fund
Awards.
In 2025, we continued to expand our SRI product and service
offering. We launched several new funds classified as Article 8: in
alternatives - Real Estate Coliving Opportunities SCR and Atitlan
Atgro-, three Target Maturity funds in Spain/Luxembourg, and 3
fixed income solutions in Spain/Portugal/Luxembourg. We also
transformed two fixed-income portfolios in Spain We continued to
strengthen voting and engagement methodologies and policies
across our asset managers outside the EU.
In 2025, we continued to focus on engaging with portfolio
companies in high emitting sectors.
SAM’s governance backs the execution of its SRI strategy. It follows
environmental (including climate change), social and corporate
governance (ESG) standards and is organized around i) an SRI
strategy and oversight forum; ii) a voting and engagement forum;
and iii) an investment and sustainability forum that our global
team of SRI experts leads. At divisional level, the Wealth
Management & Insurance ESG classification meeting, which brings
together representatives from strategy, business, sustainability,
risk and compliance, oversees and monitors key performance
indicators across SAM, Private Banking and Insurance.
SAM's ESG policies and relationship with the Group’s
sustainability documents

Other Group policies: • Defence policy • Environmental, social risk | | | Banco Santander responsible banking and sustainability policy
| Ä
} | SAM SRI policy
|  | Ä |  | Ä
|  | SAM Voting policy |  | SAM Engagement policy

| Banco Santander conflict of interest policy A
Ä
SAM Conflict of interest policy

A. The Conflict of Interest Policy provides employees, directors, and Group
Santander entities with guidelines to prevent and manage conflicts of interest
that may arise as a result of their activities. For more information, please see
santander.com/en/our-approach/policies-and-initiatives.
SAM has a global, multidisciplinary team of SRI experts that
develops and implements our ESG methodology, engagement and
voting activity and SRI policies, among other tasks. There is also a
local network of ESG experts for each of the markets where we
operate.
Annual report 2025 79

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Moreover, we have a network of experts who are key to
embedding sustainability in our investment and reporting both
globally and locally.

| For more details on our ESG approach in SAM, see santanderassetmanagement.com/sustainability.

| For more information on our engagement and voting strategies, see santanderassetmanagement.com/ sustainability/es/content/ view/11966/file/SAM_Informe_Stewardship_221123_ES.pdf

SAM’s SRI products
SRI products in SAM’s core markets
ESG methodology and business engagement
SAM runs systematically its SRI policy that restricts or prevents
investment in certain sectors that pose greater risks from a
sustainability perspective, in accordance with local law and
regulation.
It also has its own analysis methodology based on market
benchmarks and core international frameworks and standards,
which enables it to assess the ESG performance of assets through
ratings awarded to issuers.
We define ESG factors based on the relative impact of each
industry and its exposure to associated risks and opportunities that
arise from changes in policies and regulations, technology, supply
and demand, and stakeholder perception. We assign the ESG
factors identified for each industry a weighting within the model,
based on their materiality.
The final ESG rating is the sum of the weighted average of each key
matter.
SAM uses its own criteria to determine whether an issuance can be
considered sustainable investment according to Article 2.17 of the
SFDR in order to meet the minimum percentage of sustainable
investment that characterizes the fund or investment or savings
solution.
This analysis draws on the information provided by ESG data
providers and SAM's weighting and materiality assessment
methodology.
Our methodology identifies a long list of key ESG matters where
issuers can generate environmental or social externalities that
could translate into material impacts for the issuer and, therefore,
pose risks and potential opportunities.
Our ESG rating analysis, always compliant with applicable local
laws and regulations, comprises these elements:
• Environmental factors: Any component of the issuer’s activity
that may pose an environmental issue such as greenhouse gas
emissions, resource depletion, pollution, water management,
and others.
• Social factors: Society-related matters that include workplace
issues, labour standards, talent management, relationships with
local communities, data privacy and security, and human rights.
• Governance factors: Assessment of the quality of the issuer’s
management, culture and ethics; the effectiveness of its
governance systems to minimize the risk of mismanagement;
and its ability to anticipate operational and legal risks that could
lead to non-compliance.
We conduct multidimensional analysis on how each company
manages these factors. It includes the existence of policies, target
analysis, integration of management systems, performance of key
performance factors, and other elements.
Outside the EU, we are making progress in training investment
teams to embed ESG assessment and sustainable investment
methodologies and standards with an approach that makes sense
in each market, as well as increasing the coverage of our data
providers in certain markets (especially Latin America and always
in compliance with local regulation).
Engagement comprises constructive dialogue with investees to
gain a better understanding of how they manage ESG-related risk
and opportunity, as well as their alignment with set investment
objectives. This exercise can have varying aims: i) drive greater
transparency and quality of information; ii) support better risk
management and ESG opportunities; and iii) help achieve
investment objectives. Our Engagement policy, approved by SAM's
ExFo, sets out internal procedures, forms of engagement, and
escalation procedures where targets are not achieved.
Last, SAM exercises its right to vote independently in the
companies it invests in under the scope and criteria outlined in its
policy, which strengthens its influence on ESG and sustainability
issues, in accordance with local law and regulation.
Insurance
In 2025, we continued to focus on developing products to
safeguard vulnerable groups and reflect situations in specific
contexts or markets that have little protection. We’ll continue to
cooperate with our partners to promote this product offering and
boost the management of our insurers’ SRI investments.
Private Banking
Our SRI AuM amounted to EUR 58.4 billion, including committed
capital to alternative funds. Our global list of funds that are subject
to client advisory services comprised mostly SFDR Article 8 and 9
funds in the EU. Moreover, we included five new ESG portfolios in
the independent advisory service to bolster our sustainability
proposition.
In 2025, we continued to publish thematic articles for our
customers on our global website, addressing issues such as
Annual report 2025 80

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

sustainability vs. AI, energy storage, or GSS+ (green, social,
sustainable and sustainability linked) bonds.
We also made progress in forming teams of bankers who
specialize in sustainability, with specific ESG experts. This helps
improve dialogue with customers, identify their sustainability
needs, and promote their awareness of sustainable investment.

| For more details, see santanderprivatebanking.com

3.2.3 Management of environmental and
social aspects
In this section we cover how Santander manages these IROs:

| I- | Finance activities (in any customer segment) that breach the bank’s policies and jeopardize the well-being of present and future generations or fail to sufficiently involve appropriate stakeholders or use suitable customer identification and management mechanisms when providing finance to a customer or project. |

i. Our E&S risk management policy
Our Environmental & Social (E&S) risk management policy is
structured around principles that reflect our support for a fair and
sustainable transition that is driven by growth, while
acknowledging the specific realities of each region and in
accordance with local law and regulation.
This policy, which we review annually and make publicly available,
sets out the criteria that we apply to investment in entities and the
provision of financial products and services to customers in the oil
& gas, electricity generation and distribution, mining, and
metallurgy sectors, as well as to activities that relate to
agricultural commodities. This policy, while remaining in
accordance with local law and regulation, also places particular
emphasis on biodiversity conservation and focuses on potential
deforestation risks associated with customers in the agribusiness
sector who operate within the Amazon biome and on nature
degradation. It also dictates restriction criteria and enhanced due
diligence requirements for specific activities within these sectors.
From a social perspective, the E&S risk management policy follows
international standards and benchmarks such as the United
Nations Global Compact, the Universal Declaration of Human
Rights, the International Labour Organisation Declaration, the
Convention on the Rights of the Child, the Rio Declaration on
Environment and Development, the United Nations Convention
against Corruption, the Equator Principles, and the standards for
social and environmental performance and the explanatory notes
of the International Finance Corporation (IFC). Against this
backdrop, the policy sets out restriction criteria and analysis
requirements for these cases (which we apply in compliance with
local regulations):
• Projects or activities for oil & gas extraction, power generation or
transmission, mining, manufacturing, plantations or other major
infrastructure projects that put areas classified as Ramsar Sites,
World Heritage Sites or categories I, II, III or IV by the
International Union for Conservation of Nature at risk.
• Projects that require free, prior and informed consent according
to IFC Performance Standard 7 – Indigenous Peoples, and that
fail to meet the standard, with no credible action plan to achieve
compliance.
In view of the principles and criteria that our policy dictates,
analysts assess customers and projects on a case-by-case basis ,
based on the specific risks associated with both the customer and
the transaction, and in compliance with applicable local laws and
regulations.
ii. Equator Principles
The Equator Principles (EP) are a voluntary framework for financial
institutions to identify, assess and manage environmental and
social risks when financing projects. We have been a signatory to
the EP framework and applied these principles, while still in
accordance with local law and regulation, to project-related
transactions (especially project and export finance) since 2009
according to their scope.
The Group has an internal procedure to manage the environmental
and social (E&S) aspects of project-related transactions. This
procedure guides the application of the EP. The assessment of
transactions that potentially require us to apply the EP starts with a
preliminary assessment that the Front Office conducts. The area
that manages ESCC risk under the EP sits in CIB. CIB’s ESCC Risk
team oversees the Front Office’s preliminary assessment and
provides it with ad-hoc training and support. We conduct an
environmental and social review for applicable transactions, based
on the preliminary assessment findings. This review follows these
guidelines:
• For projects with minimal or no adverse environmental and social
risks and/or impacts (category C), the preliminary assessment is
sufficient.
• For projects with potential limited adverse environmental and
social risks and/or impacts that are few in number (generally
site-specific, largely reversible and readily addressed through
mitigation measures — category B) in designated countries, the
Front Office must complete a due diligence questionnaire that
includes the findings of the E&S risk assessment.
• For category A (with potential significant adverse environmental
and social risks and/or impacts that are diverse, irreversible or
unprecedented) and B (projects that involve high-risk factors or
are in non-designated countries), the ESCC risk area manages the
due diligence procedure and prepares an E&S risk assessment
report.
The findings of the E&S assessment form part of the financing
application that the risk approval committees receive before a
decision is made.
If approved, we continue to apply the Equator Principles when
preparing all subsequent contractual documents, closing the
transaction, and monitoring it.
Monitoring comprises compliance with the E&S clauses, the
implementation of the corresponding E&S action plans, and
compliance with the applicable E&S standards. When a material
59 Includes universities, institutions and organizations that have an agreement with Santander Universities, Universia and Fundación Banco Santander. Excluding Universia, the
figure is 812 entities in 11 countries
Annual report 2025 81

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

breach or incident is identified during the term of the transaction,
measures could be taken in accordance with the provisions in the
financing agreement (e.g. requirement to implement a corrective
action plan).
In 2025, we analysed 24 projects that fell within the scope of the
Equator Principles (for more details, see SN.7.1 'Green transition',
table 5. 'Equator Principles').

|  | Management of risks and impacts on communities |
| As part of our due diligence under the EP framework, we assess and ensure that projects properly identify and manage environmental and social risks and impacts, and that constructive relationships are maintained with local communities in line with international standards. Regarding potential impacts on communities, we pay particular attention to these situations and ensure their appropriate management: • Involuntary resettlement or displacement (physical or economic) of people. • Risks to the health and safety of neighbouring communities. • Impacts on indigenous communities. In such cases, projects must obtain free, prior and informed consent in accordance with IFC Performance Standard 7. |

iii. Management of principal adverse impacts
(PAIS)
Asset management can generate unintentional adverse impacts on
society and the environment. Banco Santander and its asset
management businesses disclose and manage the potential
adverse impacts that stem from the management of its portfolios
through the measurement of KPIs that cover the material
sustainability factors as detailed in SAM's PAIS procedure.
Upon detecting an adverse impact, we assess several aspects to
put mitigating mechanisms in place. We consider impact severity,
frequency, success rate of dialogue initiatives, level of exposure,
and other factors.
3.2.4 Community Support
This section outlines how we manage the following IRO:

| I+ | Contribution to education, employability and entrepreneurship, as well as to community development through support programmes. |

i. Our approach
At Santander, we run community support programmes in the
markets where we operate to contribute to respond to their main
needs and challenges.
Santander's community support focuses on education,
employability and entrepreneurship, which we supplement with
support for financial education and to vulnerable people.
Moreover, we have a strong track record in supporting cultural and
other social initiatives, such as responses to recover from
humanitarian crises.
We deliver this support through donations and other contributions
to initiatives and projects, many of which are distributed through
Santander’s own platforms to achieve global scale. We provide
support both independently and in collaboration with universities
and other educational institutions, non-profit organizations and
entities that pursue similar objectives.
Santander has a Sensitive issues policy that covers donations and a
Guide on community support and people helped that centres on
the Business for Societal impact (B4SI) standards. This Guide sets
out the methodology for quantifying the contributions that both
the parent company and our subsidiaries make. We also have a
humanitarian crisis guide that outlines Santander’s response to
events or disasters with a social impact.
ii. Support for education, employability and
entrepreneurship

102.1 | 4.6 | 1,045
million euros of support | million people and organizations helped | partnerships with universities and entities in 13 countries 59

Santander has supported education, employability and
entrepreneurship for nearly 30 years.
During this period, we have invested over EUR 2.5 billio n in
partnership with more than 1,000 universities and entities from 13
countries, and helped over 8.3 million people, businesses and
universities.
In 2025 alone, we allocated EUR 102.1 million to promote
education, employability and entrepreneurship, and helped 4.6
million people and organizations.
This enables us to make headway with our target of contributing
EUR 400 million to community support initiatives in these three
pillars between 2023 and 2026. So far, we’ve contributed EUR 311
million between 2023 and 2025.
We sign agreements with prestigious international higher
education institutions to strengthen the university ecosystem. We
provide scholarships and economic grants to adults so they can
access and complete higher education.
Annual report 2025 82

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

We also encourage lifelong learning through the acquisition and
continuous updating of skills that provide better professional
opportunities. We offer training, resources and access to benefits
for SMEs, startups, scaleups and entrepreneurial projects to help
them grow and strengthen their businesses.
1. Education
Our support for education involves grants and scholarships for
students and researchers to help them access and complete their
higher education studies. We also help universities address their
main challenges and strengthen their transformation in several
areas, with a special focus on digitalization. We do this through:
→ Scholarships and grants awarded in collaboration with
prestigious international universities and institutions to help
with access to university, academic mobility, research and
internship opportunities.
→ Campus Digital, which transforms university life through a
secure digital service that facilitates the daily activities of
academic communities. The platform includes such features as
digital credential, administration procedures (tuition payments,
grade checking, class schedules, etc.), news and benefits within
a single space.

1.7
million people helped through Campus Digital

| For more details, see mycampusdigital.com

→ Universia Network, which provides a global space for meetings,
cooperation and joint reflection between universities in the
Ibero-American higher education area. It is present in 8
countries.
→ MetaRed a collaborative initiative that involves leaders from
both public and private Ibero-American higher education
institutions, and is governed by the universities themselves. It
focuses on three key challenges that universities are facing:
digital transformation (MetaRed TIC), university
entrepreneurship (MetaRed X) and sustainability (MetaRed ESG).

| For more details, see metared.org

2. Employability
We support lifelong learning through upskilling and reskilling as
part of our purpose to help people prosper. We believe that
continuous education is key to respond more effectively to current
and future challenges and to meet the needs of businesses and
society.

|  | Santander Open Academy |  |
| Santander Open Academy is a free global online learning and professional development platform that is open and available to everyone, with no requirement to be a bank customer. It provides access to diverse and flexible training offering through courses, scholarships, and content, enabling people to improve their employability by acquiring and updating professional skills and competencies that are most in demand in the labor market. The type of courses offered vary from limited places to open access courses. The catalogue of nearly 900 programmes, includes training in languages, technological tools, data, cybersecurity, artificial intelligence, soft skills, as well as health and wellbeing. In partnership with prestigious academic institutions, the platform offers programs with a large number of places, such as English courses with the British Council, or programs aimed at strengthening professional skills and business fundamentals developed together with Harvard Business Impact, which also collaborates on a training program focused on identifying best practices in university teaching. In addition, free places are available to access a wide range of courses from the Coursera catalogue. |  | Santander Open Academy also offers a broad range of programs with unlimited places, whose content has been created in collaboration with professionals, organizations, and institutions such as Google (AI applied to productivity, marketing, and the use of advanced tools like Gemini), Instituto Cervantes (Spanish language learning), the University of Pennsylvania (improving English for professional contexts), the University of Chicago (digital marketing and storytelling techniques), IE University (how to lead in the digital environment), and Cambridge Judge Business School (development of practical skills to generate impact in sustainability). One of the most prominent programs, internationally recognized, is Santander W50, which has established itself as one of the bank’s flagship initiatives to promote female talent and leadership in the countries where it operates. SW50 has been running for 15 years and is currently delivered in collaboration with the London School of Economics and Political Science. Santander Open Academy also includes scholarship calls to access and complete higher education studies, to support academic mobility, and to promote research. |
|  |  | For more details, see santanderopenacademy.com |

Annual report 2025 83

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

→ Universia is a free and open platform that enables students and
graduates to boost their careers by accessing job opportunities
and professional internships. It allows them to build their
curriculum vitae guided by a tool that relies on artificial
intelligence and offers them digital tests to evaluate their skills.

| For more details, see universia.net

→ Fundación Universia, is a renowned national organization that
also participates in international forums such as the United
Nations and the International Labour Organization on topics
related to inclusive culture. We drive a better quality of life for
people with disabilities and other vulnerable groups in
educational and work environments.
Since 2025, Fundación Universia has offered international
programmes to promote awareness of social and labour
inclusion for people with disabilities.

6,329
people helped through Fundación Universia A initiatives
A. The total number of people supported by Fundación Universia equals the sum of 304 individuals supported through education programmes, 2,128 through employability programmes and 3,920 through social and labour inclusion awareness programmes, eliminating duplications. This taxonomy has applied since 2025.

| For more details, see fundacionuniversia.net

3. Entrepreneurship
Supporting entrepreneurship is one of our core objectives, with the
aim of enabling businesses to digitalize, grow and transform.
→ Santander X is a global initiative that helps entrepreneurs and
companies grow and transform their businesses. It offers a
comprehensive value proposition that includes training
programmes, challenges and awards, networking and tailored
financial solutions.
We promote and showcase outstanding projects and enable
them to connect with other entrepreneurs, investors and
companies through Santander X 100, the global community with
the Santander X most remarkable businesses that also provides
access to unique benefits and services.

| For more details, see santanderx.com

→ Global challenges for entrepreneurship. Innovation and
cooperation are key to addressing society’s major challenges. At
Santander, we search companies that promote responsible
innovation, talent and collaboration to build a better future and
we help them to boost their projects.
In 2025, we launched two global contests for companies in 11
countries, through Santander X. The first sought to support the
most innovative companies that focus on improving the quality
of life and digital inclusion of senior citizens, a key group in the
current demographic transformation. The second centered on
transitioning to a circular economy, reducing waste, and
promoting the responsible use of resources.
Santander X Global Challenge | Reimagine Silver Age recognized
startups and scaleups that focus on digital health,
neurorehabilitation, smart monitoring and early disease
detection using technologies that improve mobility, autonomy
and quality of life.
Santander X Global Challenge | Circular Economy Revolution
handed out prizes to companies that focus on the circular
economy, with solutions that optimize resource use, reduce
environmental impact and promote the reuse, recycling and
innovation of sustainable materials to drive a fair and
responsible ecological transition.
The winners of each contest received a cash prize, access to the
Santander X 100 global community and Fintech Station (Banco
Santander's open innovation space), and other benefits.

| For more details, see santanderx.com/en/sites/reimagine-silver-age.html For more details, see santanderx.com/en/sites/circular-economy- revolution.html

4. Featured Projects and Awards
Santander’s support for education, employability, and
entrepreneurship contributes to the progress of individuals and
businesses. Our global programs, international partnerships, and
recognitions reflect this ambition to generate impact.
→ SW50 Summit: A forum for women leaders. Santander W50
brought together nearly 500 women from around the world in
London to explore what it means to lead with purpose today. In
this annual meeting, participants pour over how to lead ethically
in a constantly changing landscape. The topics under discussion
in this year's edition were people management, crisis
management, diversity and inclusion, and the use of AI in
decision-making.

| For more details, see santanderopenacademy.com/en/sites/ SantanderW50.html

→ Tomorrow’s Skills report: Skills for future jobs. In 2025, we
presented the Tomorrow’s Skills report in Brussels, sharing the
conclusions of a global assessment of the skills that the labour
market is demanding most amid digital transformation and
sustainable transition.
The study involved 15,000 participants from 15 countries, who
gave voice to the major challenges that are transforming
education, employment, and competitiveness.
The report highlights lifelong learning and artificial intelligence
as key drivers of future employability. It also identifies the
learning formats best suited to labour market needs and the
most sought-after skills, which include digital, AI and soft skills.

| For more details, see santanderopenacademy.com/en/sites/tomorrow- skills.html

→ International recognition. Fortune’s 'Change the World' list
praises companies that generate positive social impact through
activities that form part of their business strategy.
Santander has appeared on the list for the third consecutive year
thanks to its support for education, employability and
entrepreneurship, with global initiatives such as Santander
Open Academy playing a central role.
60 Includes the social contributions of the foundations linked to the Group.
61 Based on the internal 'People Helped' methodology, which considers international best practices. Calculated with partners’ certified data or with conservative estimates
based on recognized conversion factors. The figure of people and organizations helped through Santander Polska in 2025 is 1.1 million.
62 santander.com/en/stories/santander-releases-the-report-the-currency-of-learning-global-perspectives-on-financial-education
63 The figure of people helped through financial education initiatives by Santander Polska in 2025 is 0.8 million.
Annual report 2025 84

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

iii. Other community support action
We bolster our support for education, employability and
entrepreneurship with financial education and helping vulnerable
people.

61.7 |  | 5.2
million euros in other community support programmes 60 |  | million people and organizations helped 61

Financial education | Vulnerable people | Arts and culture
Enhancing knowledge and understanding of financial products and services | Reducing risk of exclusion and better quality of life for vulnerable people | Promoting cultural events and programmes

On top of direct community action, we cooperate with, and channel
our support through, local non-governmental organization (NGOs),
social charities, and corporate volunteering. In some cases,
cooperation is through foundations that the bank runs in several
markets, including Argentina, Mexico, Poland, Portugal, Spain, and
the UK.
We target our support to different groups depending on their
needs. Our support for vulnerable people focuses on sensitive
groups (due to gender, disability, age, lack of digital skills, financial
difficulty, and other reasons). We usually target cultural activities
at the general public, though we also include vulnerable groups to
facilitate their access to events and programmes.
Financial education
We continue to reinforce financial education as a strategic lever for
progress that boosts financial health and social inclusion in the
markets where we operate.
In 2025, we carried out a simplification and alignment exercise in
all our markets Group, which prioritized initiatives with greater
reach, quality and evidence of impact. We combine solutions based
on target audiences and intended outcomes: on the one hand,
more efficient and scalable digital initiatives; and on the other, in-
person initiatives that focus on vulnerable groups.
In 2025, we presented the 'The Currency of Learning' report in
London, which includes the results of a global survey on financial
education conducted in over 10 markets. The findings of this report
have been instrumental in guiding our strategy. They highlight the
importance of scaling digital learning, improving results
traceability, and embedding financial education in the customer
journey, particularly during key customer interaction. The full
report is available to the public at santander.com 62.
Guided by the OECD Principles and the Corporate Guide to
Financial Education, we continue to strengthen common standards
for measuring and reporting beneficiaries. In 2025, 3.4 million
people took part in or accessed our financial education initiatives
and content 63, which in social media terms means people engaging
with the content (not just the scope of the activity).

| For more details on financial education, see santander.com/es/nuestro- compromiso/crecimiento- inclusivo-y-sostenible/educación-financiera

Humanitarian crises
As a global financial institution that operates in several regions and
markets, Santander is fully aware of the impact that disasters with
significant social consequences can have on the well-being of
individuals and communities. Against this backdrop, the Group has
since 2023 a Humanitarian Crises Guide to provide a structured
framework for responding effectively to such events. Through our
protocol, we offer coordinated support to affected citizens,
customers and employees.
Over the past two years, the Group has played an active role —
including financial assistance — in relief efforts amid several
humanitarian crises. These include the dana (flash floods) in
Valencia, Spain; wildfires in Valparaíso, Chile; floods in Rio
Grande do Sul, Brazil, and in the southern provinces of Lower
Silesia and Opole, Poland;, the humanitarian crisis in the Gaza
Strip; and earthquakes in Gansu and Qinghai, China.
In 2025, Santander reaffirmed its commitment to communities
affected by humanitarian emergencies by continuing to focus on
promoting economic recovery, social stability and sustainable
development. Recent initiatives include support to the people
affected by the floods in Valencia, Spain, and Bahía Blanca,
Argentina.
Charitable foundations
Fundación Banco Santander, which is based in Spain, works to
build a fair, inclusive and sustainable society by financing and
running several cultural, educational, social and environmental
projects. Dividends from shares donated by the bank enable it to
cover the costs (at least partially) associated with fulfilling its
founding purposes. Among its activities, it manages the bank’s art
collection and finances cultural productions and activities in
theatres, auditoriums, museums and cultural centres, as well as
providing support to NGOs and third-sector organizations. Over the
past year, a particularly key initiative was the transformation of the
bank’s former headquarters on Paseo de Pereda in the city of
Santander into Faro Santander, a space to showcase the bank’s art
collection alongside research-, technology- and culture-related
exhibitions and activities. Moreover, Fundación Banco Santander
promotes the development of Spanish universities through
collaboration agreements.

| For more details, see fundacionbancosantander.com/es/fundacion/ transparencia.

64 The figure of employees participation in Santander Polska in 2025 is 882.
65 For more details on customer dialogue, see section 1.3. 'Stakeholder engagement'.
66 The actions outlined in this section are specific to Santander and not sector-wide.
Annual report 2025 85

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

We have other Santander foundations in markets where we
operate (Argentina, USA, Mexico, Poland, Portugal and the UK),
which add to the number of initiatives we run. While their primary
focus is cultural and social, they also align with the bank’s
community support priorities.

| For more details on our foundations in other countries, see esg.santander.pl (Poland), fundacionsantander/argentina (Argentina), and fundacaosantanderportugal.pt (Portugal).

Corporate volunteering
At Santander we encourage our employees to volunteer in
initiatives that help the communities where we have a presence.
These initiatives, which the Group promotes and supports, seek to
get employees to dedicate their time and use their skills and talent
to support charitable causes, non-profit projects and organizations
that benefit society.
Corporate volunteering is a valuable way for employees to engage
with the community and contribute to a social cause. In particular, it
aims to:
→ contribute to the Group’s community support objectives through
the direct involvement of Group employees in volunteering
programmes;
→ foster a culture of inclusion by breaking down prejudices and
stereotypes;
→ enhance our employees’ skills and work environment through
collaboration; and
→ contribute to the well-being of our employees through
experiences that provide satisfaction, purpose and pride of
belonging.

59.8 k | 15.5 k
working hours volunteered | employees who have volunteered 64

We have a global corporate volunteering guide that sets out a
common framework for this activity. At local level, each subsidiary
runs initiatives that are tailored to the specific needs of its region to
strengthen community ties and maximize positive impact.
Within this framework, our volunteering programmes are primarily
structured around education, employability, entrepreneurship,
social inclusion and financial education, which account for the
majority of the initiatives carried out across the different
geographies. Alongside these areas, we also promote community
support actions in other fields, such as environmental initiatives,
which complement our work and strengthen the positive impact in
the territories where we operate.
We also promote volunteer activities in the context of team events,
where in addition to supporting social causes, we foster skills such
as collaboration, teamwork, empathy, and communication.
3.3 Our customers
Our customer-centric approach is a fundamental lever to create
sustainable value, 65 build a digital bank with branches, and provide
a multi-channel proposition that covers all of our customers'
financial needs. We operate through five global businesses that
serve various customer types, including individuals, SMEs, large
corporations and public entities. 66 .
This chapter focuses on individual customers who use the products
and services that the Group offers and enter into a contractual
relationship with us. This includes customers who, due to their
circumstances, may be particularly vulnerable to the marketing of
products and services.
For more details on the main impact that stems from relationships
with corporate customers, see section 3.2.3 ‘Management of
environmental and social aspects’.
67 For more information on our human rights commitment to our customers, see section 1.4 on our commitment to human rights.
Annual report 2025 86

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3.3.1 Conduct with customers
In this section we explain how Santander manages these IROs with
regards to conduct towards customers:

| R | Potential losses due to complaints or a reduction in the number of customers because of inadequate customer practices. |
| I- | Negative impact on the customer if the bank fails to provide sufficient information on products or services. |
| I- | Negative impact on the customer if they do not have access to complaints channels or if, after making a complaint, the bank fails to take the necessary action. |

i. Customer conduct principles
Customer conduct risk model
Our customer conduct risk model promotes transparency, fairness,
and responsibility in all customer engagement, including product
design, pricing, complaint handling, and financial education, while
preventing over-indebtedness and protecting vulnerable
customers 67.
This model outlines the governance, key processes and
instruments that enable us to mitigate and manage customer
conduct risk at every stage of our relationship with them.
Model principles
→ End-to-end product and service
approval and monitoring cycle that,
cover design, sales, and post-sale; fair
treatment; customer- focused product
and service design; and transparency in
all customer engagement.
→ Responsible pricing and sales practices.
→ Special focus on vulnerable customers
or those under special circumstances,
and prevention of over-indebtedness.
→ Protection of customers’ personal data
and use exclusively for authorized
purposes.
→ Easy, fair, secure and efficient access
to complaint mechanisms.
→ Promotion of financial literacy so
consumers can understand financial
products and risks, make informed
decisions, and ensure suitable
protection.
→ Ensure strong controls and secure
mechanisms to protect consumers’
assets.
Key processes
→ Robust approval and ratification of
products and services.
→ Customer conduct training.
→ Sales oversight, with special focus on
the classification and suitability of
products and services; advertising and
monitoring throughout the product
lifecycle; and complaints handling
(Customer service and dissatisfaction
management policy).
→ Conduct-related remuneration of sales
and support teams with regards to
proper conduct behaviours
(Remuneration policy).
→ Risk and control self-assessment on
conduct risks.
Governance and remit
→ Our Conduct risk management team
within Compliance develops and
oversees how we engage and manage
risk with our customers according to
the Conduct with customers risk
model.
→ The board of directors approves the
Approval of products and service
policy, while local and Group product
governance forums assess and approve
products and services.
→ The board is also responsible for
approving of the Group Remuneration
policy, while the remuneration and risk
committees, with the support of the
Human Resources and Compliance
functions, monitor this policy’s
compliance.
Our conduct risk identification and assessment seeks to proactively
identify behaviours or practices that may lead to regulatory
breaches, customer detriment, or reputational harm. Ensuring fair
customer outcomes takes a coordinated approach that involves the
first and second lines of defence to ensure a comprehensive risk
assessment.
Through the continuous monitoring of risks, indicators and
mitigation tools, the Group ensures early detection and effective
response to situations that may compromise customer protection.
The Group has strengthened complaints handling through further
monitoring of the customer voice by analysing complaints and
conduct events through key metrics, enabling early identification
of risks and trends and supporting timely mitigation actions.

| For more details on internal conduct events, see Note 25 of the annual accounts.

ii. Product and service marketing and design
Product and service governance
The Approval of products and services policy regulates the product
approval process at local and Group level by defining roles and
responsibilities and setting criteria for product assessment,
approval and monitoring, which builds on the conduct risk with
customers management model. Santander has a well-established,
robust and consistent product governance, that the Group
Compliance team owns and manages. It is an end-to-end cycle that
regulates the approval and monitoring of products and services,
Annual report 2025 87

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

covering their design, sale, and post-sale stages and ensuring
approval of proposals according to regulatory requirements,
ethical principles and market conduct, both at local and Group
level.
Product governance forums are responsible for implementing this
policy when approving products and services, as well as defining
approval requirements and coordinating validation, which includes
monitoring and reporting to senior management. We only approve
products and services once we've assessed all risks and forum
members are unanimously in favour.
Conduct training
Training is key to boosting knowledge to foster consumer
protection. The Compliance function, with the support of People &
Culture, draws up mandatory refresher training for all employees
on managing and mitigating customer conduct risk.
All units ensure strict compliance with local requirements;
supported by robust training.
Quality and conduct metrics in sales teams’ remuneration
The Group establishes requirements to ensure we link variable pay
to service quality and conduct metrics. This approach promotes
greater awareness and proactive management of customer
relationships, encourages high levels of transparency, and
supports the identification of appropriate target audiences.
Sales monitoring
The Group has mechanisms to monitor products and services
throughout their life cycle. These enable us to detect and manage
(as early as possible) potential deterioration, failures in marketing,
and non-compliance with the terms and conditions under which
they were approved. We analyse and monitor:
• Customer voice: Queries, complaints and surveys are a key
source of information to identify deficiencies in marketing and
customer engagement, and to draw up improvement plans; and
• Sales metrics and controls: Monitoring the percentage of product
or service cancellations shortly after sign-up.
iii. Post-sales
Complaints handling
The Customer service and dissatisfaction management policy
outlines the principle of making multiple channels available to
avoid the potential impact of not having suitable means for
customers to convey their issues or dissatisfaction and to promote
the fact that we have channels that adapt to our customers’ needs
and preferences.
Additionally, customers can escalate complaints through external
channels when they are in place, such as the Financial
Ombudsman, regulatory bodies, and consumer agencies, if they
are not satisfied with how we have handled the complaint.
Units continue investing in digital channels to speed up case
resolution and help customers self-manage certain queries. Root-
cause analysis and mitigation plans are an essential component of
complaints handling that is continuously being strengthened.
In 2025, the total number of formal complaints received was
772,780 for a total customer base of 180 million. For further
information, see NS 7.4 'Customers' (Table 24. Total complaints).
iv. Vulnerable customers
In this section we cover how Santander manages this IRO:

| I- | Negative impact on the customer by failing to guarantee access to, or the use of, products and services that may present certain obstacles or weak spots. |

Vulnerable customers are those who, due to personal, social,
economic, educational, cultural or health-related factors, whether
temporary or permanent, experiences difficulties in understanding,
accessing or exercising their rights as a consumer on an equal
basis, and therefore requires adapted support to ensure their
inclusion and effective protection.
Given the wide range of challenges, we have developed a
comprehensive approach of support them – in terms of how
products are developed, communicated and in all interactions.
We look to identify and consider customer vulnerabilities through
specific standards and dedicated procedures, and try to prevent
and mitigate any detriment. In 2025, the Group strengthened its
approach to vulnerable customers, defining common minimum
standards across all markets while allowing local adaptation in line
with local regulation, commitment and strategy. This includes local
and Group-level processes to identify and monitor customers
under special circumstances.
In 2025, Santander Spain reached a landmark by becoming the first
IBEX-listed company to certify a 360º accessibility commitment by
AENOR, covering physical and digital channels and ensuring that all
products, services and relationship channels are accessible for all
customers, regardless their diverse physical, sensory, cognitive, or
age-related abilities.
68 For more details, see santander.com/informe-inclusion-financiera.
Annual report 2025 88

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3.3.2 Financial inclusion and financial
health
This section outlines how we manage the following IRO:

| I+ | Positive impact on customers due to the bank’s offer of products and services that adapt to their needs and expectations and promote financial inclusion and health. |

i. Financial inclusion and health as a key driver
of social progress
Financial health and inclusion are a priority for Santander in
contributing to social progress and promoting prosperity and
entrepreneurship.
We use the World Bank's Global Findex Database to calculate the
number of unbanked, underbanked and financially distressed
people due to access and financing issues in the markets where we
operate as a retail bank. In particular, we:
• consider several components of financial exclusion and
aggregate indicators to cover all our target audiences;
• define an inclusive financial system as one that maximizes the
use of financial products and services, access and financing;
• measure involuntary financial exclusion through barriers that
people who do not participate in the formal financial system
perceive; and
• apply a correction factor that matches our business penetration
rate in the markets where we operate.
Thanks to our financial inclusion efforts, we achieved our objective
of reaching five million new people with at least one financial
inclusion measure during the period 2023-2025 reaching 6.3
million people. This ambition aligns with our market penetration
levels and the gaps identified in our exclusion analysis.
Our processes pinpoint the needs of customers facing financial
difficulty so we can develop products and services and train our
teams. 68
These processes are consistent with our customer conduct model,
vulnerable customer policy, and responsible banking and
sustainability policy.
In 2025, we updated our Corporate Financial Inclusion guide to
reflect best practice. We also changed how we monitor and
measure progress, differentiating between financial inclusion and
financial health. The updated guide continues to enable the
homogeneous measurement of access and financing initiatives
across markets and sets out these common definitions:
• Unbanked: People who do not have a bank account or access to
any banking services.
• Underbanked: People who, despite having a bank account, have
difficulty accessing basic services (e.g. making deposits and
withdrawals) or who source financing informally.
• People in financial distress: People who earn less than their
country’s legal minimum wage or who are unable to cover basic
living expenses.
The guide also provides a consistent metrics system for monitoring
and managing access and financing initiatives. Though we have
achieved our ambition, we will continue working to increase
access, improve the use of financial services, and strengthen our
support for vulnerable individuals and communities.

New people benefiting from financial inclusion measures A,C | Target
+5 mn B
1.8 m | 4.3 m | 6.3 m
2023 | 2024 | 2025

In 2025, we financially included nearly 1 million people through
access initiatives; and 1 million people through finance
initiatives.
A.Based on our internal financial inclusion methodology. This includes the
principles, definitions and standards we use consistently across our footprint to
count the number of people we include financially through initiatives, products
and services for access and finance.
B. Cumulative figure since 2023.
C. The figure of people financially included through Santander Polska in 2025 is 0.5
million.
Annual report 2025 89

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Access
c. 1 million
new people benefiting from access-related
financial inclusion measures
We help unbanked and underbanked people enter the financial
system and gain access to basic financial services, encourage them
to use financial services that are tailored to their needs and
barriers, have greater control over their finances, and enjoy faster
and more secure transactions.
In 2025, our initiatives continued to:
• adapt to developing and mature market needs:
▪ In developing markets, we focus on providing access to bank
accounts and cash deposit and withdrawal services to
unbanked and underbanked people. Our stand-out initiatives
include partnerships with merchants in Mexico to offer
Santander services and financial inclusion branches in
Argentina.
▪ In mature markets with high account penetration but an
exodus of people from rural areas and an ageing population,
we focus on continuity in access to basic financial services.
Stand-out initiatives include Correos Cash and the waiving of
fees for vulnerable customers in Spain.
• offer access amid humanitarian crises. We make mobile
branches available to remain close to our customers in the most
affected areas and keep key financial services running, such as
cash withdrawals, salary advance and payment holiday requests,
and insurance claims. For more details on our actions during
humanitarian crises, see section 3.2.4 'Community support'.
• promote inclusion. We are constantly adapting branches,
products, services and channels for people with disabilities and
senior citizens to be able to access them both in person and
online.
We do all of this by harnessing technology to drive financial inclusion
and overcome some of the barriers that prevent unbanked and
underbanked people from accessing financial products and services.

Access initiatives and services:
Basic financial solutions Promote access to the financial system for unbanked individuals (accounts, insurance, etc.) and maintain access for potentially excluded groups, such as the elderly or others facing vulnerabilities. |  |  | Basic accounts A
|  | Support to senior citizen customers B
Promoting access to cash and transactions Facilitate community access to cash through our branches and ATMs in remote areas, and partnerships with public and private entities that extend our reach. |  |  | Branches in underbanked and remote regions C
|  | Digital wallets and points of sale D
|  | Partnerships to reach underserved communities E

Beyond retail and commercial banking solutions, the Payments
business provides through Getnet digital payment solutions to
individuals and merchants, particularly those who are
underserved or underbanked, with a strong presence in Latin
America.
Annual report 2025 90

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Finance
1 million
new people benefiting from finance-related
financial inclusion measures
We finance underbanked SMEs and entrepreneurs, as well as the
basic needs of low-income households through products and
services that we tailor to their needs.
Our microfinance proposition supports inclusive growth and
economic development in Latin America, where the financial
inclusion gap is wide. We have been offering microfinance services
to low-income and underbanked entrepreneurs since 2002. We
help our customers set up small businesses, which drive economic
growth and social mobility.
Through these initiatives, available in Brasil, Mexico, Peru and
Colombia, we offer loans to boost new ventures’ income-
generating capacity and help microentrepreneurs safeguard their
businesses through financing that meets their working capital
needs. A large portion of the customers under these initiatives are
women, who are less likely to access financial services in
developing markets.
In 2025, we continued to:
• build on our business proposition from microcredit to
microfinance by extending our customer value proposition
through solutions that go beyond credit (basic accounts, financial
education, microinsurance and other services);
• make business models more efficient, without jeopardizing the
social impact of our proposition. For instance, we leveraged the
use of technology to open low-cost mobile branches and
improved handling procedures to minimize the time from
microloan application to making funds available to our
customers; and
• combine the group and individual credit model to adjust it to our
customers’ circumstances and needs, leaning towards the
in dividual model in Peru and Colombia and growing — albeit at a
lower rate — in Mexico.

Other finance-based initiatives and services
Support for entrepreneurs and SMEs Financing programs for entrepreneurs, start-ups, and SMEs with limited access to the financial system and credit. |  |  | Products oriented to providing credits to SMEs
Financing low-income households' basic needs We offer products and services that enable low-income households to access housing and meet other basic financial needs. |  |  | Affordable housing supply F
|  | Support for low-income households and people with difficulty accessing credit G

A. In some countries, we have basic bank accounts that go beyond regulation in order to serve the bottom of the pyramid. For instance, the Cuenta LIfe in Chile or the no-fee
account for vulnerable customers in Spain.
B. We have value propositions aimed at the elderly in several countries. For instance, tailor-made products for retirees in Mexico and Argentina; services such as SuperLinha
Senior in Portugal to help seniors with limited digital skills; and third-party access initiatives in the UK to support seniors who need to be cared for.
C. In Spain, branches in remote (or sparsely populated) areas to facilitate access to credit and combat social exclusion in communities of less than 10,000 inhabitants. In
Portugal, branches in low-income, small or isolated regions, such as the Azores and Madeira. In Argentina, we have financial inclusion branches and remote agents in the
marginal environment of Buenos Aires and vulnerable communities. In Poland, ATMs in municipalities where there is no Santander branch or partner point of sale. In
Uruguay, we have installed three mobile branches (the first in 2020) to reach areas with low levels of banking penetration.
D. In Poland, we included the Cashless Poland programme to promote the use of payment terminals in places where the use of digital media is low, as well as the use of our
associated Partner Outlets points of sale. In Chile, we included Mas Lucas.
E. Agreements with Correos Cash in Spain, partnerships with retailers such as Oxxo and 7Eleven in Mexico, and agreements with third parties in Uruguay (e.g. Abitab, Red
Pagos).
F. In Spain, the bank participates in the Social Housing Fund, which facilitates renting for people on low income. It also has affordable rental housing. In the US, as part of its
Communities plan, Santander US provides support for the construction, maintenance and rehabilitation of homes for low- and moderate-income households.
G. We have initiatives to help groups with difficulties in accessing credit; among them, in Spain, we lend to SMEs at their risk limit; in the US, we lend to small businesses
operating in low- and moderate-income communities; in Argentina, we lend to entrepreneurs with little credit history. In Mexico, we offer special credit programmes to
people at the bottom of the pyramid.
ii. Progress on financial health
In 2025, we continued to strengthen a common financial health
approach in all the Group’s markets. We define financial health as
individuals’ ability to manage their finances in a way that enables
them to meet short-term needs while planning for and achieving
long-term goals, generating stability, and reducing the risk of
financial hardship.
Throughout the year, we made headway with identifying and
building on initiatives that help customers’ develop financial skills.
We combined global tools — such as goal-setting solutions and
planning resources within our banking app in certain countries —
with local action, including tailored financial education content and
practical guidance that align with market-specific needs.
As part of this, we came up with a common financial health
definition and measurement guide that will enable homogeneous
and comparable progress assessment across markets. Our
framework directly complements our financial education and
inclusion efforts and ensures that individuals not only gain access
to the financial system but also acquire the knowledge and tools
needed to use it responsibly and effectively.
In 2025, the Pay Smarter concept was introduced to promote a
more informed use of credit cards as a financial management tool.
This approach is structured around three pillars aligned with
Annual report 2025 91

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

financial health objectives (benefits, control and security) and has
already been deployed in most retail markets through our owned
channels (website, mobile app, branches and contact centres).
In 2026, its rollout will continue under a phased plan to reinforce
message consistency and support a common understanding of the
responsible use of payment instruments among customers and
employees. This expansion includes extending digital content and
providing training to commercial teams to promote consistent
communication.
For more details on our financial education programmes for
customers and non-customers alike, see section 3.2.4 ‘Community
Support’.
3.3.3 Privacy, data protection
and cybersecurity
This section outlines how we manage these IROs:

| I- | Potential infringement of customers’, employees’ or shareholders’ rights due to a lack of appropriate technical or organizational measures to protect their personal data in accordance with applicable law and Group standards. |
| I+ | Education and awareness on cybersecurity issues to understand potential threats and mechanisms to avoid them. |
| R | Potential losses due to fines or a reduction in the number of customers because of a failure to detect or respond effectively to breaches of privacy. |

i. Privacy and data protection
The use of new technologies and progress with the digitalization of
businesses have led to a rapid increase in the processing of
personal data.
Our commitment to complying with regulation on the protection of
personal data throughout their life cycle is key in this regard. Our
corporate policies and standards remain consistent with data
protection and privacy laws at all times, with ethical and
transparent management of personal data to enable individuals to
exercise greater control over their data.
We apply measures to obtain and use only the data that is strictly
necessary to process personal data for legitimate purposes. The
aim of these technical and organizational measures is to preserve
the confidentiality, integrity, availability and resilience of the
systems and services that we use to process data, to achieve the
correct protection of data subjects’ rights and freedoms, and to
boost individuals’ and broader society’s trust.
We created our compliance programme by following the privacy
standards to manage data protection risk correctly. It is based on:
• local units’ responsibility to abide by the General Data Protection
Regulation (GDPR) and/or local regulation on data protection;
and
• a robust governance model that comprises:
1. corporate and local data protection policies;
2. a data protection officer (DPO) and/or privacy champions in
each unit. We formally disclose DPO appointees to local
authorities; and
3. a corporate oversight programme based on the monitoring of
management indicators and annual reviews.
Other measures that strengthen our data protection management
are:
• procedures to manage security incidents and the risks arising
from actual or suspected unauthorized access, disclosure, or use
of personal data, with area-owned action plans when required;
• cooperation with third-party service providers that must comply
with data protection regulation. Data processors are subject to a
suitability test that we monitor through management indicators
and review regularly;
• reviews on our compliance with data protection laws, which our
Internal audit area performs as part of its annual programme;
• corporate tools that help us manage data protection-related
tasks by bringing together and monitoring control information
through indicators and the annual review programme. For
instance, we regularly update our data processing inventory and
report on indicators and security incidents; and
• employee training and awareness campaigns on data protection,
which form part of our mandatory annual curriculum and that we
monitor through management indicators.
ii. Cybersecurity
Cybersecurity provides vital support to our purpose of helping
people and businesses prosper and our aim to provide customers
with first-rate digital services.
The Group operates under a cybersecurity framework that Banco
Santander’s board of directors approved and the subsidiaries’
governing bodies adopted. This framework sets out the
governance, functions, roles and responsibilities for cybersecurity
management across the Group, including the role of the global
Chief Information Security Officer. A set of cybersecurity policies,
which align with international standards and we review
continuously, supports this framework to maintain and enhance
security levels.
To assess how we’re doing on cybersecurity within the industry, we
monitor the security rating that an independent third party
provides us. Bitsight Company gives us with a score between 250
and 900 (with 740-900 considered 'Advanced') based on public
information and externally visible network traffic and systems. In
2025, we scored 800 points, which put us in the upper quartile
among our peers and meant that we hit our target.
Protecting our customers’ and employees’ information is the
responsibility of every Santander employee. We outline this in
another policy under our cybersecurity framework: Cybersecurity
standards for the protection of Santander, which sets out the
principles that we must follow.
In 2025, we continued to strengthen cybersecurity awareness
across our teams by:
Annual report 2025 92

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

• conducting regular ethical phishing exercises for all employees,
with targeted simulations for higher-risk groups such as IT
administrators and payment agents;
• reinforcing key protective behaviours through the Cyber First
campaign, emphasising the importance of reporting suspicious
incidents or communications;
• updating mandatory cybersecurity training to address emerging
threats, including malicious emails, messages or calls,
deepfakes, identity theft and social engineering;
• updating specialized training for high-risk groups such as
payment agents, IT professionals and developers, digital asset
owners, board members, and executives and their support
teams.
• delivering targeted fraud prevention training for case
management teams in call centres and branches;
• issuing mandatory guidelines for specific groups — developers,
IT administrators, call centre staff and other critical profiles — to
reinforce good security and compliance practices; and
• introducing the Cyberrisk Score indicator for team leaders to
embed individual cybersecurity results in annual performance
reviews.
To help customers protect themselves better online, we combine
education, in-person experiences and awareness campaigns with
impact measurement mechanisms that enable us to adapt content
to market needs. In 2025, the digital campaign detailed below
achieved an engagement rate of 74%, which was up on the
previous year.
• Santander Open Academy. An open education platform for large-
scale digital learning. In 2025, we launched the course 'Digital
Safety for Daily Life', an eight-hour programme comprising four
modules on essential online protection habits and fraud
prevention strengthening access to cybersecurity education
content for the general public.
• Santander WorkCafé. In-person workshops for retail and
corporate customers on digital risks and prevention. In 2025, we
ran these workshops in Brazil, Mexico, Poland, Portugal, Spain
and the UK, and achieved a satisfaction rating of over 9 out of 10.
• Global awareness campaigns. The Group ran two creative
initiatives under the 'Everyday Cyber' platform: 'Obvious
Passwords', which focused on choosing secure passwords; and
'Deepfakes: The new wolves', a new take on Little Red Riding
Hood that warns about the risks of impersonation through AI. We
rolled out each of these initiatives, which combined an innovative
narrative and practical guidance, across all our markets.
• Local innovation. In Spain, we launched a dedicated WhatsApp
channel for digital awareness, surpassing 30,000 followers in
under one year. In Brazil and the UK, the Security Hub (part of the
mobile app), provides interactive and accessible cybersecurity
content.
• Titania and Protocolo Alice. Our fiction podcast Titania, which
won the Global Ondas Podcast Award for Best Branded Content,
expanded its reach through the Brazilian version Protocolo Alice,
exceeding 37 million views in 2025.
In 2025, we continued to promote collaboration with public and
private organizations on cybersecurity and online fraud prevention:
• We continued to play a key role in the Financial Services
Information Sharing and Analysis Center (FS-ISAC) for the
exchange of cybersecurity information in Europe and remained a
member of it European board. Headquartered in The Hague, the
FS-ISAC has over 1,000 members from 174 entities, including
major banks, Swift and Europol.
• Santander is part of the leadership team of the US Ransomware
Task Force, whose objective is to improve prevention and
response capabilities against ransomware attacks. We helped set
up the Brazilian Ransomware Task Force alongside the
Government of Brazil and the Organization of American States,
and are working on the same initiative in Mexico.
• We contributed to World Economic Forum initiatives on
cybersecurity and the fight against cybercrime. This includes
taking part in ATLAS and Partnership Against Crime and in various
working groups that focused on using AI to combat cybercrime,
reducing the cybersecurity talent gap, and strengthening
capabilities through public-private partnerships.
• We’re part of several initiatives alongside such international
organization as the Institute of International Finance (IIF),
European Financial Services Round Table, European Banking
Federation, DigitalEurope, and the European Cyber Security
Organisation.
• We organised the third Horizon Conference in London, bringing
together over 100 organizations from 14 sectors for two days of
collaboration and intersectoral crisis simulation exercises.
• We play a global leadership role in the field of post-quantum
security, as founder and current chair of the Europol Quantum
Safe Financial Forum. Moreover, we play an active role in the
main forums that outline the mechanisms of the transition,
including FS-ISAC, G7 Cyber Experts Group, EFR, NIST, IIF, and
Centre for European Policy Studies (CEPS).
Annual report 2025 93

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

4. Business conduct
(Governance information)
4.1 Corporate culture
Our culture
The Santander Way sets out the common standards and values we
want to prevail across the Group. These are reflected in our Global
Culture Policy. In 2025, we strengthened our culture by promoting
new ways of working and professional development:
1.Deliver, Develop, Transform. In 2025, we launched three new
principles that guide the way we work and lead at Santander.
These principles, co-created with professionals across the
Group, were initially rolled out to managers, with the ambition
of extending them to the entire organization during 2026. They
provide practical guidance for leading in an environment of
constant transformation.
2. Learning and development: We have increased our efforts to
give our employees the necessary tools and resources to
enhance their skills and employability, aligning us with the most
critical business and market demands.
3.We promote flexible and agile working models that enable our
teams to grow and participate in transformational projects —
such as the adoption of AI — to drive innovation and efficiency
across the Group.
4.We foster an inclusive culture built on diverse and
complementary teams. Our aim is for teams to reflect the
diversity of the environments in which we operate.
5.We care for our people through a well-being strategy that
promotes healthy habits and work–life balance.
6.We encourage our employees to take part in volunteering
initiatives on financial education, inclusion, education,
employability, entrepreneurship and other local needs.
7.Through YourVoice, we listen to our teams and implement
action plans that help us continue to build the best place to
work.

| Our behaviours |
| Our principles → Deliver • Think Value A • Think Customer B • Make the right decisions at the right time → Develop • Build high-performing teams • Set clear goals and provide feedback • Ensure a positive working environment → Transform • Lead change • Think Global C • Trust and collaborate • Foster a strategic mindset |
| Our strong risk management culture |
A. We want to become the leading bank across our footprint and to maximize shareholder value. B. We want to be our customer’s bank of choice. C. We’re building ONE Santander to harness our unique combination of global strength and local leadership.

69 The Conflicts of Interest Policy has been updated to align it with the General Code of Conduct (updated in 2024) and to simplify it. In addition, the Procurement Management
Conduct Policy has been integrated into this policy.
Annual report 2025 94

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

4.2 Ethical conduct
In this section we cover how Santander manages this IRO:

| I+ | Act responsibly and consider investors’ interests and the impact on employees, broader society and the environment; pay taxes to support the distribution of wealth. |
| I- | Harm broader society through bribery or corruption. |
| R | Risk stemming from improper conduct that makes illicit funds or assets appear legitimate and, therefore, facilitates illegal activity or to benefit from it. |

4.2.1 Conduct standards
Our General Code of Conduct (GCC) sets out the behaviours and
values that all Grupo Santander employees must abide by when
engaging with colleagues, customers, vendors and broader society.
It helps promote a solid risk management and compliance culture
and acts as a mechanism to prevent the risks we are exposed to. It
is available on our corporate website for all stakeholders to read.
The GCC promotes equal opportunity, non-discrimination, zero
tolerance for sexual or work-related harassment, respect for
others, work-life balance and human rights.
The Grupo Santander board of directors approves the GCC, which
all Group employees — general workforce, top management and
members of the management bodies of the units that make up
Grupo Santander — must be aware of and comply with.
The GCC’s core implementation mechanisms are:
i. mandatory training for employees on the GCC through an
annual course that instils the guidelines they must follow in
their day-to-day to prevent possible risks, such as the Group’s
criminal responsibility; how to handle conflicts of interest
according to our policy, 69 and what to do if they receive gifts
and invitations from people outside Grupo Santander. We
supplement GCC training with a statement that reinforces our
employees’ pledge to comply with it;
ii. campaigns via email, Intranet and other media to boost
employees’ awareness of the GCC, as well as of Canal Abierto
and the latest whistleblower protection laws;
iii. the Compliance area, which deals with employees’ queries on
the enforcement of the GCC;
iv. Canal Abierto, our whistleblowing channel where employees
and stakeholders can report violations of the GCC and of our
corporate behaviours; and
v. Breaches to the GCC are managed and sanctioned in
accordance with applicable regulations.
Moreover, mandatory training forms part of our employees’ annual
performance review, which acts as an incentive to complete it in
due time.
We also use another management metric to identify how many
incidents reported to the Group’s ethical channels are linked to
violations of the GCC.

| For more details, see section 7.2 ‘Compliance and conduct risk management’ in the ‘Risk management and compliance’ chapter.

4.2.2 Responsible taxation
The principles that guide the Group’s tax practices are consistent
with its purpose and aligned with business strategy. The board of
directors approves our tax strategy and revises it regularly.
The Group’s tax risk management and control, which draws on our
internal control model, sets out the actions to follow our tax
strategy and the principles that underpin it.
We participate in cooperative compliance initiatives that tax
authorities run. Since 2010, we've adhered to the Spanish Code of
Good Tax Practices and the UK Code of Practice on Taxation for
Banks and, more recently, to the Portuguese Code of Good Tax
Practices in 2022. Since 2015, we've voluntarily submitted an
annual tax transparency report to Spain's tax authority.
The principles of Grupo Santander’s tax strategy must enable us to
make appropriate contributions according to the value creation in
each of the markets where we operate, as well as to comply with
local laws.
Core principles of Santander’s tax strategy

• Meet our tax obligations based on a reasonable interpretation of
tax laws, grounded on their spirit and intention.
• Respect the rules on transfer pricing and pay taxes in each
market according to our operations, assumed risk, and profits.
• Not give tax advice or planning strategies when marketing and
selling financial products and services. Not engage in
transactions or activities that enable unlawful tax avoidance by
our customers.
• Disclose Santander's total tax contribution clearly, distinguishing
between taxes borne by the Group and by third parties in our
core markets.
• Not create, or acquire a stake in entities registered in countries or
territories considered 'non-cooperative jurisdictions' without
board approval; and properly monitor the Group's operations in
such territories.

| For more details on the Group’s tax strategy, see santander.com.

The Group’s tax contribution and the key role that our subsidiaries
play in the effective application of the tax systems of their
respective markets are a vital component of the Group’s
contribution to sustainable and inclusive growth.
70 People in special situations (non-exhaustive list): individuals living in extremely rural areas, those residing in care facilities or pensioners, people unable to manage their
financial affairs, gender expression, students and young people, individuals living in shelters or refuges, prisoners and those on parole, international students, economic
migrants, refugees, and isolated individuals.
Annual report 2025 95

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

In 2025, the Group paid EUR 22.1 billion in taxes, of which EUR 9.6
billion account for taxes we paid directly to the tax authorities
(46.3% of profit before taxes) and the rest in taxes collected from
our business operations with third parties.
The taxes the Group paid directly are part of the cash flow
statement and mainly correspond to the income tax paid in 2025
(EUR 5 billion at an effective rate of 24.0%).
There is usually a mismatch in the taxes we pay directly and those
recorded in the financial statements because the payment date set
by the laws of each country is often different to the accrual date of
the income or the transactions subject to tax. The income tax
expense recorded for the year amounts to EUR 5.1 billion, which
means an effective rate of 24.9% (see Note 27 to the consolidated
report).

| For more details on the Group's tax contribution, see SN 7.7 'Tax contribution'.

4.2.3 Financial crime compliance (FCC)
Grupo Santander is firmly committed to the fight against financial
crime and compliance with financial crime prevention regulation in
every market where we operate.
Our Group board-approved and unit-ratified Corporate financial
crime compliance (FCC) framework sets out the key principles for
preventing financial crime, which underpin these programmes: the
anti-money laundering and terrorism financing prevention
programme (CFT); the sanctions programme; and, since 2023, the
anti-bribery and anti-corruption programme (ABC). This framework
is available to all employees and interested third parties.
Moreover, we use information channels to raise awareness of the
importance of financial crime compliance. We reach out to all our
stakeholders through annual training programmes,
communications channels (corporate and unit Intranet sites),
awareness campaigns, internal newsletters and best practices so
that they can learn about and understand their responsibilities
across the Group’s entire operations.
We draw up the policies that build on this framework (including
customer due diligence — CDD — procedures) according to
domestic and international financial crime regulation to manage
and mitigate the impacts and risks related to FCC and protect the
Group’s integrity in all our businesses and operations. We
constantly review and update our policies to remain consistent
with regulatory amendments and new and ever-changing external
threats.
Moreover, we have a common oversight methodology that enables
us to verify that all our operations comply with this framework
under the most demanding, standardized criteria that the
centralized and technical FCC function in our markets endorse. This
function also plays a crucial role in promoting FCC culture and
awareness to all Grupo Santander employees.
The central and unit-based Financial Crime Prevention teams
engage in constant dialogue with all the Group’s businesses and
functions to identify new risk types, overcome emerging
challenges to prevent those risks, and implement risk
management, control and mitigation best practice. Some of the
salient responsible banking topics to highlight are: People in
special situations, and People trafficking and exploitation and
environmental crime.

| For more details on our provisions, see Note 25 of this report.

People in special situations
Our FCC onboarding supports the Group’s ambition to help people
in special situations 70 get access to financial services and requires
business units to mitigate the potential financial crime risk related
to these groups, based on objective criteria and compliance with
FCC regulation.
Our mandatory FCC procedures (identification, risk segmentation
and due diligence) for people in special situations to access
banking services and the document updates we perform under our
FCC framework are free of bias and subject to strict compliance
with the law. Moreover, the Group has been and will continue to
run remote and in-person onboarding that gives equal access and
opportunity that best adapt to each customers’ circumstances.
People trafficking and exploitation and environmental
crime
Our customer risk assessment considers the risks stemming from
the sectors that our customers operate in. To categorize a sector,
we consider exposure to corrupt practices, people trafficking,
modern slavery, labour exploitation, child abuse and
environmental crime. We subject these sectors to further know-
your-customer due diligence to be absolutely sure of their level of
exposure or link to those types of practices. We also have
transaction control systems that enable us to detect irregular
movements that may come from or be related to such practices.
Grupo Santander plays an active role in public-private sector
initiatives and specialist forums where we provide financial crime
prevention knowledge, expertise and analysis. As a global bank
that offers a wide range of financial products and services, we have
a deep understanding of the risks related to our sector. We are
firmly committed to the integrity of the financial system and the
development of effective solutions to boost cooperation between
the public and private sectors in tackling complex and global
challenges.
Bribery and corruption
The Group reviewed and refined its ABC framework to strengthen
its practical application and ensure clear accountability within the
relevant functions, reinforcing a culture of integrity and
responsible conduct.
The Group conducts regular Risk and Control Self-Assessments
(RCSA) across all units to identify and evaluate residual financial
crime risks within the organization. This process assesses the
inherent risks of business activities — including those related to
money laundering, terrorist financing, bribery, corruption, and
others — and the suitability of the controls in place to mitigate
them.
71 The data reflect the Group’s aggregated annual metric 'Number of cases reported to the regulator or Suspicious Activity Reports (SARs)', where SARs refer to reports filed by a
Financial Institution to notify the authorities of transactions or activities that may be linked to money laundering, terrorist financing, or other financial crimes.
72 Investigations refer to the analysis carried out by the Second Line of Defence (2LoD) of sensitive or potentially suspicious activities that do not result in a report to the
authorities, as the analysis concludes that no further escalation is required (i.e. the activity is clarified and assessed as non-suspicious, or the authorities are already aware of
the event).
73 Reference is made in this Sustainability statement to judicial and administrative proceedings that have reached a conclusion during 2025 with a firm conviction, sanction or
fine against an entity of the Group and which are significant to the Group due to their materiality.
Annual report 2025 96

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

In 2025, the Group continued to strengthen its awareness and
training strategy through its Global Mandatory Training
Programme, which ensures consistent coverage of all Financial
Crime Compliance (FCC) risk areas, including (ABC). This
programme combines foundational training for all employees with
tailored sessions for specific functions and risk profiles.
Additionally, the members of the board of directors also receive
specialised training in this area.
Training remains a key performance indicator of the Group’s
commitment to mitigating bribery, corruption, and other financial
crime risks, ensuring that all employees—across the first, second,
and third lines of defence—understand their roles and
responsibilities in managing FCC.
As one of our KPIs, the number of employees we train in the Group
highlights our firm commitment to mitigating bribery, corruption
and other FCC risks. This covers all risk takers functions. In
particular:
◦ 146,586 employees trained in FCC.

| For more details on this topic, see section 4.4 'Our suppliers' .

Detecting and managing FCC incidents
In 2025, the Group maintained a robust system for detecting,
investigating, and managing financial crime incidents, in full
compliance with applicable FCC laws and regulations. Financial
Intelligence Units (FIUs) across all markets continued to identify,
assess, and report suspicious transactions — including those with
potential indicators of bribery or corruption — to the competent
authorities.
This system is supported by clearly defined internal controls,
independent investigation mechanisms, and governance structures
designed to ensure impartial and effective incident management.
The outcomes of investigations are regularly reported to the
Group’s management and oversight bodies to ensure transparency
and accountability.
Highlights of key detection activities and cooperation with
authorities’ in 2025 include:
• 311,613 disclosures to authorities 71
• 503,838 investigations conducted 72
Moreover, our whistleblowing channel, which we manage
according to the General Code of Conduct and Canal Abierto policy,
is where individuals can report violations of laws and internal
compliance regulations related to the fight against financial crime
(FCC).
In accordance with the established criteria 73, and consistent with
2024, no convictions, fines or sanctions were received in this
reporting period for corruption or anti-bribery matters, nor for anti-
money laundering and countering the financing of terrorism (AML/
CFT), that are considered material in the context of the Group’s
activities.
4.3 Ethical channels
In this section we cover how Santander manages these IROs:

| I+ | Protection of the confidentiality of users of the bank’s ethical channel and have an effective reporting system in place that follows robust principles and procedures. |
| I- | Negative impact on the environment or broader society by failing to implement measures to resolve incidents through complaints or reporting channels or due to a lack of continuous improvement actions. |

4.3.1 Canal Abierto
Canal Abierto is an anonymous and confidential Grupo Santander
channel to report alleged unethical conduct. It protects
whistleblowers by expressly prohibiting reprisals or any negative
consequence against them. Every unit in the Group administers its
own ethical channel according to the common standards set out in
the Canal Abierto policy.
Minimum standards applicable to all channels include
communication to employees of the importance of using the
channel; information on how incidents have been handled and
lessons learned; easy access to the channel and anonymity (if
desired); external providers to receive reports according to best
practice; mechanisms to manage conflicts of interest in internal
investigations of reports; and regular internal audits.
The board of directors approved the Canal Abierto policy and the
related use and operation procedure, and designated the Chief
Compliance Officer to oversee Canal Abierto of Banco Santander.
These policies and procedures are available to Group employees
and stakeholders on our corporate website and the Canal Abierto
platform.
Canal Abierto is available to employees on Santander Now
(Intranet) and to other persons legally entitled as provided by law
through our corporate website and the Canal Abierto platform.
Canal Abierto receives reports that cover conduct issues related to:
→ unlawful acts at the workplace;
→ irregularities or breaches of the General Code of Conduct (GCC)
and its implementing regulation that may be subject to
disciplinary action;
74 It refers to environmental, social, including human rights, and governance issues. These topics are listed in the EU Corporate Sustainability Reporting Directive (CSRD)
2022/2464 and its implementing legislation in Spain.
75 Reference is made in this Sustainability statement to judicial and administrative proceedings that have reached a conclusion during 2025 with a firm conviction, sanction or
fine against an entity of the Group and which are significant to the Group due to their materiality.
Annual report 2025 97

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

→ improper accounting or auditing practices, internal control or
influence on external auditors (Sarbanes-Oxley Act);
→ breaches of securities market regulations,
→ irregularities related to sustainability matters, 74
→ infringements of anti-money laundering and terrorist financing
regulations, internal procedures to ensure compliance with
them, or bribery and corruption;
→ conduct that may involve an act that infringes the law or any
other regulation and, in particular, a serious or very serious
criminal or administrative offence or infringement of European
Union law; and
→ acts or conduct that go against the Group’s corporate
behaviours.
Santander handle reports received through Canal Abierto in a
diligent, independent and objective manner for the benefit of the
parties involved. The following criteria, which we set out in the
Group’s Canal Abierto policy, reflect that pledge:
→ Appropriate handling of the reports received, notwithstanding
their possible rejection should they fall under any of the cases
provided for in internal regulations or if it is considered that
there are no grounds for a case.
→ 60-day processing time, which could be extended by up to 30
days for cases that are considered especially complex.
→ Conflict of interest management during the investigation of
cases, in which anyone who may have a conflict of interest with
the persons involved in the matter will refrain from taking part.
The usage and operation procedure details the teams tasked
with investigating each case in relation to the type of report.
→ The prohibition of reprisals against employees or other
stakeholders who report, in good faith, breaches of internal or
external regulations or conduct that does not align with our
corporate behaviours, for having merely accessed an ethical
channel.
Every year, our employees undertake a mandatory training course
on the General Code of Conduct (GCC) that includes a module on
the importance of using Canal Abierto.
Moreover, we raise awareness of Canal Abierto among our
employees on the handling of the reports received, the channel’s
features, when to use it, and other information.
Every year, the compliance function prepares a report for the risk
supervision, regulation and compliance committee and the audit
committee to informing their members about the activity of the
Group’s channels, key statistics, and other matters related to Canal
Abierto. With the aim of providing a holistic view of incidents
related to the GCC, this report has been enhanced by including
more granularity and transparency of the information including
data of incidents related to the GCC coming from other sources
different than Canal Abierto as well as breakdown of cases by
Global Businesses.
We collect data on the Group’s ethical channels every quarter in
relation to the number and type of reports received, and the
measures taken.
An external auditor reviews those data regularly to ensure their
traceability and integrity.
In 2025, we received 4,507 reports, including 362 from third
parties (307 from customers and 55 from vendors).

Canal Abierto
| 2025 | 2024
Reports received | 4,507 | 4,437
reports received over total headcount | 2% | 2%
Categories of received reports |  |
Breaches to the Code of Conduct A | 2,432 | 2,286
Harassment B | 975 | 1,094
Equality and fair treatment | 140 | 132
Breaches to corporate behaviours and labour regulations C | 1,839 | 1,754
Other types D | 236 | 397
Dismissals | 480 | 393
Dismissals over total headcount | 0.2% | 0.2%

A. Includes but is not limited to harassment, equality and fair treatment, conflicts
of interest and activities outside the Group, privacy, information security and
confidentiality of information, marketing of products and services and internal
fraud, among others.
B. Harassment, according to CSRD, is defined as a situation where unwanted
conduct related to a protected ground of discrimination (for example, gender
under Directive 2006/54/EC of the European Parliament and of the Council (15),
or workplace harassment, among others) occurs with the purpose or effect of
violating the dignity of a person, and of creating an intimidating, hostile,
degrading, humiliating or offensive environment.
C. Includes reports relative to breach of corporate behaviors, labour regulations
and serious acts of disrespect.
D. Includes unclassified cases and categories below de minimis thresholds
(including external fraud and internal policy breaches).
As in 2024, the Group has no record of any judicial proceedings
initiated by employees or their representatives in relation to
incidents of discrimination or breaches of fundamental rights, nor
of any employee-related cases referring to serious human rights
incidents that would be considered material to the Group. 75
76 Applicable in accordance with local regulations.
77 6% more than in 2024.
78 Main companies of the Group in: Argentina, Brazil, Chile, Colombia, Germany, Mexico, Portugal, Poland, Peru, Spain, United Kingdom, United States and Uruguay, and other
geographies in which Digital Consumer Bank operates such as Italy and Nordics.
79 At year-end 2024, it was 15 days.
80 In line with the applicable methodological criteria defined by the Group, the average payment period has been calculated on the basis of invoices actually paid during the
year. At year-end 2024, it was 81%
81 Reference is made in this Sustainability statement to judicial and administrative proceedings related to non-payment to suppliers which are ongoing at year-end 2025 and
are relevant to the Group due to their materiality.
Annual report 2025 98

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

4.4 Our suppliers
In this section we cover how Santander manages these IROs:

| I+ | Promotion of responsible practices among vendors; engage with them, assess their ESG performance and give them recommendations and tools to improve. |
| R | Potential risk from failing to ensure the operational resilience of the value chain by assessing vendors’ solvency, reputation and compliance with the law. |

4.4.1 Acting responsibly towards suppliers
Our outsourcing and third-party management model and
outsourcing strategy policy (which apply in all our markets) provide
a methodology for our suppliers to comply with the Group’s
minimum standards and with regulation to avoid risks that stem
from substandard operational resilience, solvency, reputational
control and regulatory compliance.
Moreover, to promote responsible practices in our supply chain, we
have a supplier ESG certification methodology 76 that aims to
identify the suppliers that pose the greatest risk in terms of
sustainability. This methodology also helps us determine which
controls to adopt according to the risk identified.
Sustainability in procurement
The Group’s ESG supplier assessment methodology enables us to
g ive our suppliers a final ESG risk classification as low, medium or
high by adjusting the pre-classification with a survey that considers
other factors such as country risk, number of employees, and
company-specific environmental traits.
As at 2025 year-end, we had assessed 876 suppliers identified with
ESG risk. This assessment includes such ESG aspects as carbon
footprint calculation, inclusion in terms of gender and people with
disabilities, flexi-working, minimum wage and good governance
practices, codes of conduct and anti-corruption policies, human and
labour rights recognition, and other elements set out in
international standards such as the United Nations Global
Compact.
Based on certification outcomes and where required, we
supplement supplier assessments with remediation plans to
ensure compliance with internal standards and applicable
regulations.
Other key aspects
• The Group has a corporate tool to enhance and standardize the
certification of higher risk suppliers in all our core markets as
well as to review key risks such as cybersecurity, business
continuity, physical security, facilities and data protection, anti-
bribery and corruption and other additional risks.
• We have made headway in embedding ESG standards in
procurement negotiations and ESG risk assessments in line with
the existing methodology, which continues to evolve to reflect
regulatory changes and practical experience.
• We’re working to extend our ethical channels for suppliers to the
rest of our core markets.
4.4.2 Supplier payments practices
EUR 12.3 billion paid to suppliers 77. 92% are local and account for
90% 78 of total procurement volume.
The Group fully complies with the maximum payment terms
prescribed by law. The current average payment period in the
Group is 16 days 79 and 82% of invoices were paid by the
deadline 80. In 2025, as in previous years, no significant differences
were identified in payment terms across the existing supplier
categories.
Likewise, as in 2024, the Group has no record of any judicial or
administrative proceedings related to non-payment to suppliers
that would be considered material to the Group. 81
Annual report 2025 99

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Sustainability notes
SN 1. Introduction, basis of the consolidated sustainability statement
and other information
a) Introduction
This report is the 'Consolidated non-financial information
statement and sustainability information' of Banco Santander, S.A.
and its subsidiaries'. It provides detailed information in compliance
with Directive (EU) 2022/2464, with regard to the presentation of
information on sustainability by companies, prepared in
accordance with the European Sustainability Reporting Standards
(ESRS) framework, comprising Commission Delegated Regulation
(EU) 2023/2772 and Commission Delegated Regulation (EU)
2025/1416, and in compliance with Law 11/2018, which amends
Article 49 of the Commercial Code, and the Regulation on European
Taxonomy (Regulation (EU) 2020/852 and Commission Delegated
Regulations 2021/2139 and 2021/2178 as amended by Delegated
Regulations (EU) 2022/1214, 2023/2485, 2023/2486 and
2026/73). Likewise, the information included in the section '2
Climate, our transition plan' allows the Group to address the
requirements of Law 7/2021 on climate change and Royal Decree
214/2025 of the Spanish legal system.
In relation to the information on the EU Taxonomy (including the
Green Asset Ratio – GAR), and in accordance with the transitional
regime set out in Commission Delegated Regulation (EU) 2026/73,
the Group has opted to defer the application of the new templates
until 2026, and therefore, for financial year 2025, it has continued
to use the templates and disclosure requirements in force as at 31
December 2025.
The Sustainability statement forms part of the consolidated
directors’ report of Santander Group and the board of directors
approved it on 25 February 2024.
b) Scope of information
The scope of this document covers the core activities of the Group
and its subsidiaries from 1 January to 31 December 2024 and is
prepared following the same consolidated basis (principles,
accounting policies and criteria) as the financial statements and
with the criteria differences set out in this table:

Topics |  | Scope of information
Climate, our transition plan (Environmental information)
Supporting our customers in the green transition
Green finance |  | Corporate & Investment Banking.
Financing of electric vehicles |  | Digital Consumer Bank auto loan portfolio.
Purchase of cards made of sustainable materials |  | Main companies of the Group in: Argentina, Brazil, Chile, México, Poland, Portugal, Spain, United Kingdom and Uruguay.
Embedding ESG in risk management
Portfolio exposure to climatic sectors |  | Full Group scope.
Equator Principles |  | Corporate & Investment Banking.
Aiming to align our activity with the Paris Agreement Goals
Climate alignment |  | Corporate & Investment Banking for thermal coal, power generation, oil & gas, aviation, steel and auto manufacturing portfolios. Digital Consumer Bank for the auto loan portfolio. Commercial banking perimeter of Brazil for the agro portfolio (only soy, corn and beef cattle). And perimeter of commercial banking in Spain, United Kingdom and Portugal for the portfolio of residential mortgages and real estate.
Environmental footprint |  | Full Group scope. Except for the calculation of Scope 3 emissions (categories 1, 2, 4 and 9) for which the information of main companies of the Group in: Argentina, Brazil, Chile, Colombia, Germany, Mexico, Portugal, Poland, Peru, Spain, United Kingdom, United States and Uruguay, and other geographies in which Digital Consumer Bank operates such as Italy.
EU Taxonomy
Green Asset Ratio (GAR) |  | Scope based on the prudential consolidated group, in accordance with the Commission Delegated Regulation (EU) 2021/2178.
Supporting employees, communities and customers (social information)
Acting responsibly towards our employees
Headcount |  | Full Group scope.

Annual report 2025 100

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Remuneration |  | Full Group scope.
Training |  | Full Group scope.
Employee engagement survey |  | Full Group scope.
Communities sustainable development
SRI AuMs |  | Wealth Management & Insurance: SAM and Private Banking.
Support for higher education, employability and entrepreneurship |  | Main companies of the Group in: Argentina, Brazil, Chile, Germany, Mexico, Poland, Portugal, Spain, United Kingdom, United States and Uruguay, as well as Foundations associated with the Group.
Other community support programmes |  | Main Group companies in: Argentina, Brazil, Chile, Colombia, Mexico, Perú, Poland, Portugal, Spain, United Kingdom, United States, Uruguay and the rest of the countries in which Digital Consumer Bank operates, as well as Foundations associated with the Group.
Acting responsibly towards customers
Customers, offices and channels |  | Full Group scope. For digital customers, Openbank Mexico is excluded.
NPS (customer satisfaction) |  | Main Group companies in: Argentina, Brazil, Chile, Spain, United States, Mexico, Poland, Portugal, United Kingdom and Uruguay.
Customer complaints |  | All Group entities (>1% of reported claims volume in 2025).
Financial health and inclusion |  | Main companies of the Group in: Argentina, Brazil, Chile, Colombia, Mexico, Peru, Poland, Portugal, Spain, United Kingdom, United States, Uruguay and the rest of the countries in which Digital Consumer Bank operates.
Business conduct (governance information)
Corporate governance
Corporate governance |  | Banco Santander, S.A.
Communications with shareholders and investors |  | Banco Santander, S.A.
Ethical conduct
Mandatory training on the GCC |  | Full Group scope.
Tax contribution |  | Full Group scope.
Financial crime compliance |  | Main Group companies with FCC obliged parties within the perimeter of Group Financial Crime Compliance.
Litigation and penalties |  | Full Group scope.
Ethical channels
Ethical channel |  | Group companies in Argentina, Brazil, Chile, Spain, Mexico, Poland, Portugal, United Kingdom, United States, Uruguay, Colombia, Peru, Switzerland, Bahamas, and subsidiaries and branches of CIB, Consumer, PagoNxt and Wealth.
Acting responsibly towards suppliers
Payments to suppliers |  | Main companies of the Group in: Argentina, Brazil, Chile, Colombia, Germany, Mexico, Portugal, Poland, Peru, Spain, United Kingdom, United States and Uruguay, and other geographies in which Digital Consumer Bank operates such as Italy and Nordics.
Evaluated suppliers identified with ESG risk |  | Main companies of the Group in: Argentina, Brazil, Chile, Colombia, Germany, Mexico, Portugal, Peru, Spain, United Kingdom and Uruguay, and other geographies in which Digital Consumer Bank operates such as Italy.

Information relating to Santander Bank Polska, S.A. and its
subsidiaries (Santander Polska)—whose sale was completed on 9
January 2026—is presented in this sustainability statement on a
combined basis with the other entities within Grupo Santander’s
reporting perimeter, unlike in the financial statements, where the
Group has reclassified the assets of Santander Polska and TFI in the
consolidated balance sheet as of 31 December 2025, to the
heading 'Non-current assets held for sale', and their liabilities to
the heading 'Liabilities associated with non-current assets held for
sale' (see note 3.b) of financial statements). Where its contribution
to the Group total is material, we will include, for information
purposes, a footnote with Santander Polska specific figures.
Significant changes in criteria with respect to the 2024
Sustainability Report are reflected in the corresponding section of
this chapter, and generally in section h) of this note.
For a list of subsidiaries included in the consolidation that are
exempt from individual or consolidated sustainability reporting
pursuant to article 19a or 29a(8) of Directive 2013/34/EU, see
Annex 1. Subsidiaries of Banco Santander, S.A. in the ‘Audit report
and consolidated annual accounts'. Of this list, the following
companies are required to report sustainability information under
CSRD:
• Santander Consumer Bank AS (in Norway)
• Stellantis Banque France (in France)
Additionally, Santander Consumer Bank Spólka Akcyjna (Poland)
also meets the requirements to be subject to the obligation to
prepare a sustainability statement; however, the transposition of
the CSRD in Poland provides an exemption for subsidiary
82 Resources that develop and/or help create products and enable us to operate as a bank (e.g. employees; capital; buildings, offices and other physical infrastructure;
technology; and others).
Annual report 2025 101

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

undertakings that are already included in their parent group’s
consolidated sustainability statement.
Other companies that meet the requirements established by the
standard but are located in countries where the Directive has not
been transposed are not considered obliged to report under the
CSRD.
Moreover, the Group has not applied the exemption in relation to
the breakdown of information on upcoming events or matters
under negotiation.
From 1 January 2025 to the date on which we prepared this
Consolidated non-Financial Information Statement, there were no
additional events that could have a significant impact on the
information set out in this report other than those described in the
consolidated annual accounts.
For more details, see Notes 1 , 2, 3 and 53 to the consolidated
report and sections 3 and 4 of the ‘Economic and financial review’
chapter.
c) Value chain
Banco Santander has a defined value chain that identifies all the
actors involved in it. It considers the entire consolidation scope set
out in the bank’s annual report. This chart illustrates our value
chain. It is split into three main groups (upstream, own operations
and downstream) and shows the actors in each one:
To define t he value chain, the Group considered the indications of
Regulation 2022/2464 (paragraph 33); Delegated Regulation
2023/2772 (ESRS 1); and the EFRAG (European Financial Reporting
Advisory Group) Value Chain Implementation Guidance.
These are the definitions we used:
Upstream: Set of activities or p rocesses carried out by companies
that are part of the bank’s upstream phases and that provide the
inputs 82 that we use for the development and marketing of
products and services. This includes companies with which the
bank has a direct and indirect commercial relationship.
• Financial institution s: Monetary institution and public entity
responsible for setting monetary policy that will impact on
Banco Santander; regulating currency circulation; supervising
the interbank market in which the bank operates; and providing
liquidity, where required, for solvency purposes. For instance,
the European Central Bank, Banco de España, Bundesbank,
Narodowy Bank Polski, etc.
• Product and service providers: Companies that provide
products and services that are subsequently marketed in later
phases of the bank’s value chain or that the bank uses to carry
out its operations. For instance, insurance companies (e.g.
suppliers of products that are marketed in the bank’s
downstream phase), technology providers, external audit and
consulting service providers, materials suppliers and office
landlords.
The Group continuously oversees the correct management and
maintenance of its supplies to offer a high value added service to
customers and to guarantee business continuity.
Own operations : Activities that the bank’s functional areas and
employees carry out in our markets and subsidiaries.
• Assets : Assets and properties that the bank owns. For instance,
tangible assets such as offices.
• Geographies: Places where the bank and its subsidiaries carry
out their operations. For instance, Brazil, Spain, United States,
the United Kingdom, and Mexico.
• Cross-cutting areas/functions: Departments and areas within
the bank whose function is to manage and develop the bank’s
operations. For instance, Compliance, Risk, Strategy, Human
Resources, Procurement.
83 See sections 2.4.5 Our Environmental footprint , 3.1.1 Talent and Skills Development and 3.2.4 Community Support for this chapter; and notes 46 and 47 of the Annual
Accounts.
Annual report 2025 102

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Downstream: Commercial relationships and the products and
services that the bank sells to meet the needs of its customers and
end users.
• Retail and Commercial Banking: focuses on meeting financial
needs and offering a variety of products and services that are
accessible and tailored to specific customer requirements. It
integrates the retail banking business and commercial banking
(individuals, SMEs and corporates), except private banking
clients and business originated in the consumer finance and the
cards businesses. For instance, savings accounts, mortgages,
credit cards and financial services for SMEs.
• Digital Consumer Bank: aims to convert single product
customers into complete banking customers through other
products. This business comprises all business originated in the
consumer finance companies, plus Openbank, Open Digital
Services (ODS) and SBNA Consumer. For instance, auto loans
and consumer loans.
• Corporate & Investment Banking (CIB): offers products and
services on a global scale to corporate and institutional
customers, and collaborates with other global businesses to
better serve our broad customer base. It includes Global
Transaction Banking, Global Banking (Global Debt Financing
and Corporate Finance) and Global Markets. For instance,
advice on mergers and acquisitions (M&A), corporate finance,
investment banking, asset management and risk management.
• Wealth Management & Insurance (Wealth): provides
specialized financial services to high net worth customers and
those seeking to protect their assets through insurance. It
includes the corporate unit of Private Banking and International
Private Banking in Miami and Switzerland (Santander Private
Banking), the asset management business (Santander Asset
Management), the insurance business (Santander Insurance)
and the unit that manages the investment platforms and
stakes that complement Wealth's traditional business (the new
vertical, Portfolio Investments).
• Payments: comprises the Group's digital payments solutions,
providing global technological solutions for our banks and new
customers in the open market. It is structured in two
businesses: PagoNxt (Getnet, Ebury and PagoNxt Payments)
and Cards (cards platform and business in the countries where
we operate).
• Joint ventures, associates and other investments: Entities that
are not globally integrated in the annual accounts but in which
the Group has decision-making capacity over their operating
activities that have not been previously considered in the value
chain.
• Retailers: Sales channels for companies in the final phases of
the value chain that, through their own commercial network,
are responsible for selling the bank’s products and services to
their customers. For instance, car dealerships.
d) Information not disclosed
In response to the request set out below, the Group has disclosed
partial information. It is not possible to make further disclosure
because it is confidential and sensitive information on the Group's
strategy
• ESRS 2. Minimum Disclosure Requirement - Actions MDR-A -
Actions and resources in relation to material sustainability
matters. Paragraph 69 regarding disclosure of operating
expenses (OpEx) or capital expenditure (CapEx) allocated to
action plans.
The Group discloses certain metrics such as staff costs (wages
and salaries, social security contributions, provisions and
contributions to pension funds, and other personnel expenses),
energy efficiency initiatives and investment in community
support, found in the corresponding sections of this report and
our annual accounts. 83
There is no other classified or sensitive information, or information
relating to intellectual property, know-how or innovation results,
that the Group has not included in the report.
e) Time horizons
In preparing this Sustainability statement (including the analysis of
double materiality), we used the following time horizons:
• One year for the short term (this is the standard time horizon for
the short term in the Group).
• One to five years for the medium term (financial planning).
• More than five years for the long term (strategic plan).
These horizons coincide with those provided for by the ESRS
standards. We expressly indicate the different time horizons we
use for processes or metrics described in this report.
f) Significant estimates and assumptions
The Group discloses metrics that incorporate value chain
information, which includes both direct data sources (from
customers or investees) and estimated data from third-party data
providers or sector averages. In some instances, these estimates
draw on factors that the Group is unable to influence and that may
have a significant impact on the information disclosed.
The most significant estimates and assumptions relate to the
Group’s disclosure of GHG emissions, the measurement of which is
subject to considerable uncertainty due to methodology and data
limitations, including reliance on third-party data. Our analysis and
climate target-setting uses estimates based on the recognized
frameworks available at the time. As methods and data evolve, our
data sources and figures may become outdated, and updates to
methodologies and assumptions could lead to different
conclusions. Thus, greenhouse gas emission factors are expected
to increase once data becomes available and the corresponding
companies are included in the calculations.
Climate-related targets, actions and initiatives require forward-
looking parameters and long-term horizons. Our forward-looking
statements reflect our current view of future events and are based
on expectations, projections and estimations. These involve
significant uncertainty and risk due to such factors as scientific
developments, methodology developments, standards variation,
future market conditions and technological advances (which vary
across industries), as well as challenges in data availability and
Annual report 2025 103

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

accuracy and regulatory changes. These assessments must evolve
and should not be considered reliable indicators of future
performance.
We expect improvements in data quality, coverage and availability
in the coming years, driven by increased sustainability information
reporting and disclosure obligations and other elements. We also
expect new guidance, industry standards and scientific research in
this area. For that reason, Grupo Santander reserves the right to
review and update its targets, methodologies and approach
regularly and as necessary.
The disclosure of EU Taxonomy reporting is also subject to
uncertainty over data quality and the use of third-party data. For
more details, see section NS 5. EU Taxonomy of this Sustainability
Statement.
g) Comparative information, changes in the preparation or
presentation of sustainability information
In 2025; we refined our climate-alignment approach to better
reflect the realities of the markets and regions where we operate,
and to incorporate the latest scientific evidence as well as the
economic and regulatory contexts relevant to our activity.
• Portfolio alignment. We updated our sectoral alignment targets,
introducing target ranges that use a weighted average of the
International Energy Agency (IEA) regional scenarios to reflect
our geographic footprint.
In the oil & gas sector, we also updated our methodology,
moving from absolute financed emissions to two intensity-based
metrics: (i) an alignment target for operational emissions
intensity (Scopes 1+2) and (ii) monitoring of the primary energy
index (see further detail below).
• Portfolio monitoring.
• We began tracking the primary energy index, which reflects the
carbon intensity of our global energy supply portfolio.
• Aviation moves from target to monitoring given its declining
portfolio alignment materiality and the strong dependence on
policy and technological developments.
• The mortgage and commercial real estate portfolios now also
include Portugal (2024).
• Santander Brasil’s agriculture portfolio, from 2024 and based
on materiality criteria, includes only soy, corn and beef cattle.
The 2023 figure has been recalculated to ensure comparability.
For further information, see sections ‘2.4 Aiming to align our
activity with the Paris Agreement Goals’ and ‘NS 4. Climate
transition plan’.
Additionally, we evolved the taxonomy used to classify the
community support and people and organisations supported
through local community support initiatives. Therefore, the
breakdowns by typologies for 2025 are not comparable with the
information reported in 2024. The Group-level total, however, is
comparable. For further information, see section ‘NS 7.6
Community support’.
Regarding information disclosed in previous periods, the Group
identified an interpretation error in Brazil in applying the corporate
methodology and calculation criteria for the Scope 1 greenhouse
gas (GHG) emissions metric, which has a significant impact on the
Group’s 2024 consolidated figure. After consistently applying the
corporate methodology, 2024 Scope 1 emissions increase from
35,503 tCO₂e to 40,670 tCO₂e, equivalent to a 14.6% increase for
this scope, which is also reflected in the Group’s total emissions.
For further information, see section ‘NS 7.1 Green transition’ (Table
3. Gross GHG emissions Scopes 1, 2 and 3 and total GHG
emissions).
h) Incorporation by reference
This report includes all the information necessary to comply with
the requirements established in the ESRS, except in those cases in
which such information is already included in the Group's audit
report and consolidated annual accounts. In these cases, which are
detailed below, the disclosure will be made by reference to that
report.
• ESRS 2 - Disclosure requirement BP-1, paragraph 5.b).ii.
Reference is made to Appendix I of the Group's consolidated
annual accounts and audit report for the list of subsidiaries of
Banco Santander, S.A.
• ESRS 2 - Disclosure Requirement SBM-3, paragraph 48.d).
Reference is made to note 25.e) of the Group's consolidated
annual accounts and audit report to complete the information
relating to the financial effects derived from the amount of
convictions or penalties. As well as to note 54, which provides a
breakdown of climate risk management.
• ESRS 2. Minimum Disclosure Requirement - Actions MDR-A -
Actions and resources in relation to material sustainability
matters. Paragraph 69 regarding disclosure of operating
expenses (OpEx) or CapEx allocated to action plans. Reference is
made to notes 46 and 47 of the Group's audit report and
consolidated annual accounts for more details on the connection
of sustainability information with annual accounts information.
• ESRS 2 - Minimum Disclosure Requirement - MDR-M parameters,
in relation to the positive impact of 'Act responsibly and consider
investors’ interests and the impact on employees, broader
society and the environment; pay taxes to support the
distribution of wealth'. Reference is made to note 27 of the
Group's audit report and consolidated annual accounts for more
details on the Group's tax information.
• ESRS S1 - Disclosure Requirement S1-17, paragraphs 103(c),
104(b) and AR 105. Reference is made to note 25.e) of the
Group's annual report and Consolidated Financial Statements to
complete the disclosures regarding serious human rights
incidents involving the company's personnel.
• ESRS S3 - Disclosure Requirements S3-1, paragraph 17 and AR
12; and S3-4, paragraph 36. Reference is made to note 25.e) of
the Group's Consolidated annual report and Accounts for
supplementary information on serious human rights incidents
relating to affected groups.
• ESRS S4 - Disclosure Requirements S4-4, paragraph 35.
Reference is made to note 25.e) of the Group's Consolidated
annual report and Accounts for supplementary information on
serious human rights incidents relating to consumers or end-
users.
• ESRS G1- G1-4, paragraphs 24.a) and 25.d). Reference is made to
note 25.e) of the Group's annual report and Consolidated
Annual report 2025 104

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Financial Statements to complete the information regarding
convictions and fines for breaches of anti-corruption and anti-
bribery laws.
Sustainability note 11. 'Directive (EU) 2022/2464 content index'
provides the sections of this report and of the Group's annual
report and Consolidated Financial Statements where the
information that responds to each of the requirements defined by
the ESRS can be found.
i) Use of phase-in provisions in accordance with Appendix
C of ESRS 1
The following table details those requirements for which Grupo
Santander has opted to continue not disclosing in accordance with
the Commission's delegated regulation (EU) 2025/1416, which
amends the previous Delegated Regulation (EU) 2023/2772.

Disclosure requirements not reported due to phase-in provisions (ESRS 1 Appendix C)
ESRS | Disclosure requirement | Description
ESRS 2 | SBM-1, paragraph 40, b( and c) | Total revenue/Revenue by significant ESRS Sectors
ESRS 2 | SBM-3, paragraph 48 e) | Potential financial effects
ESRS E1 | E1-9 | Potential financial effects from material physical and transition risks and potential climate- related opportunities
ESRS S1 | S1-7 | Characteristics of non-employee workers in the undertaking’s own workforce
ESRS S1 | S1-14 | Health and safety: information on non-employee workers
ESRS S1 | S1-15 | Work-life balance

Annual report 2025 105

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

List of datapoints in cross-cutting and topical standards that derive from other EU legislation
The table below illustrates the data points covered by ESRS 2 and the thematic ESRS derived from other EU legislation. For
each data point, in the last column, it is indicated whether or not it is material and if it is, where in the report the information
is located.

Disclosure Requirement and related datapoint | SFDR (1) reference | Pillar 3 (2) reference | Benchmark Regulation (3) reference | EU Climate Law (4) reference | Materiality of the data point and location in the report
ESRS 2 GOV-1 Board's gender diversity paragraph 21 (d) | Indicator number 13 of Table #1 of Annex 1 |  | Commission Delegated Regulation (EU) 2020/1816 (5), Annex II |  | Sustainability notes. SN2. Sustainability governance
ESRS 2 GOV-1 Percentage of board members who are independent paragraph 21 (e) |  |  | Delegated Regulation (EU) 2020/1816, Annex II |  | Sustainability notes. SN2. Sustainability governance
ESRS 2 GOV-4 Statement on due diligence paragraph 30 | Indicator number 10 Table #3 of Annex 1 |  |  |  | 1. Sustainability at Santander 1.4 Sustainability governance (1.4.2 Human rights due diligence)
ESRS 2 SBM-1 Involvement in activities related to fossil fuel activities paragraph 40 (d) i | Indicators number 4 Table #1 of Annex 1 | Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 (6) Table 1: Qualitative information on Environmental risk and Table 2: Qualitative information on Social risk | Delegated Regulation (EU) 2020/1816, Annex II |  | Sustainability notes. SN 11. Commission Delegated Regulation (EU) 2023/2772 on sustainability reporting standards content index (SBM-1 – Strategy, business model and value chain)
ESRS 2 SBM-1 Involvement in activities related to chemical production paragraph 40 (d) ii | Indicator number 9 Table #2 of Annex 1 |  | Delegated Regulation (EU) 2020/1816, Annex II |  | Not material
ESRS 2 SBM-1 Involvement in activities related to controversial weapons paragraph 40 (d) iii | Indicator number 14 Table #1 of Annex 1 |  | Delegated Regulation (EU) 2020/1818 (7), Article 12(1) Delegated Regulation (EU) 2020/1816, Annex II |  | Not material
ESRS 2 SBM-1 Involvement in activities related to cultivation and production of tobacco paragraph 40 (d) iv |  |  | Delegated Regulation (EU) 2020/1818, Article 12(1) Delegated Regulation (EU) 2020/1816, Annex II |  | Not material
ESRS E1-1 Transition plan to reach climate neutrality by 2050 paragraph 14 |  |  |  | Regulation (EU) 2021/1119, Article 2(1) | 2. Climate transition plan Sustainability notes. SN 4. Climate transition plan
ESRS E1-1 Undertakings excluded from Paris-aligned Benchmarks paragraph 16 (g) |  | Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book-Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity | Delegated Regulation (EU) 2020/1818, Article12.1 (d) to (g), and Article 12.2 |  | Sustainability notes. SN 4. Climate transition plan

Annual report 2025 106

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Disclosure Requirement and related datapoint | SFDR (1) reference | Pillar 3 (2) reference | Benchmark Regulation (3) reference | EU Climate Law (4) reference | Materiality of the data point and location in the report
ESRS E1-4 GHG emission reduction targets paragraph 34 | Indicator number 4 Table #2 of Annex 1 | Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metrics | Delegated Regulation (EU) 2020/1818, Article 6 |  | 2. Climate transition plan 2.4 Aiming to align our activity with the Paris Agreement Goals Sustainability notes. SN 4. Climate transition plan
ESRS E1-5 Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) paragraph 38 | Indicator number 5 Table #1 and Indicator n. 5 Table #2 of Annex 1 |  |  |  | Not material
ESRS E1-5 Energy consumption and mix paragraph 37 | Indicator number 5 Table #1 of Annex 1 |  |  |  | Sustainability notes. SN 7.1 Green transition (Table 2. Environmental footprint)
ESRS E1-5 Energy intensity associated with activities in high climate impact sectors paragraphs 40 to 43 | Indicator number 6 Table #1 of Annex 1 |  |  |  | Not material
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions paragraph 44 | Indicators number 1 and 2 Table #1 of Annex 1 | Article 449a; Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book – Climate change transition risk: Credit quality of exposures by sector, emissions and residual maturity | Delegated Regulation (EU) 2020/1818, Article 5(1), 6 and 8(1) |  | Sustainability notes. SN 7.1 Green transition (Table 3. Gross scopes 1, 2, 3 and total GHG emissions)
ESRS E1-6 Gross GHG emissions intensity paragraphs 53 to 55 | Indicators number 3 Table #1 of Annex 1 | Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metrics | Delegated Regulation (EU) 2020/1818, Article 8(1) |  | Sustainability notes. SN 7.1 Green transition (Table 3. Gross scopes 1, 2, 3 and total GHG emissions)
ESRS E1-7 GHG removals and carbon credits paragraph 56 |  |  |  | Regulation (EU) 2021/1119, Article 2(1) | Sustainability notes. SN 7.1 Green transition (Table 3. Gross scopes 1, 2, 3 and total GHG emissions)
ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks paragraph 66 |  |  | Delegated Regulation (EU) 2020/1818, Annex II Delegated Regulation (EU) 2020/1816, Annex II |  | Phase-in (partially) 2. Climate transition plan 2.3.4 Potential financial effects

Annual report 2025 107

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Disclosure Requirement and related datapoint | SFDR (1) reference | Pillar 3 (2) reference | Benchmark Regulation (3) reference | EU Climate Law (4) reference | Materiality of the data point and location in the report
ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a) ESRS E1-9 Location of significant assets at material physical risk paragraph 66 (c). |  | Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 paragraphs 46 and 47; Template 5: Banking book - Climate change physical risk: Exposures subject to physical risk. |  |  | Phase-in (partially) 2. Climate transition plan 2.3.4 Potential financial effects
ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes paragraph 67 (c). |  | Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 paragraph 34; Template 2:Banking book -Climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral |  |  | Phase-in (partially) 2. Climate transition plan 2.3.4 Potential financial effects
ESRS E1-9 Degree of exposure of the portfolio to climate- related opportunities paragraph 69 |  |  | Delegated Regulation (EU) 2020/1818, Annex II |  | Phase-in
ESRS E2-4 Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil, paragraph 28 | Indicator number 8 Table #1 of Annex 1 Indicator number 2 Table #2 of Annex 1 Indicator number 1 Table #2 of Annex 1 Indicator number 3 Table #2 of Annex 1 |  |  |  | Not material
ESRS E3-1 Water and marine resources paragraph 9 | Indicator number 7 Table #2 of Annex 1 |  |  |  | Not material
ESRS E3-1 Dedicated policy paragraph 13 | Indicator number 8 Table 2 of Annex 1 |  |  |  | Not material
ESRS E3-1 Sustainable oceans and seas paragraph 14 | Indicator number 12 Table #2 of Annex 1 |  |  |  | Not material
ESRS E3-4 Total water recycled and reused paragraph 28 (c) | Indicator number 6.2 Table #2 of Annex 1 |  |  |  | Not material
ESRS E3-4 Total water consumption in m 3 per net revenue on own operations paragraph 29 | Indicator number 6.1 Table #2 of Annex 1 |  |  |  | Not material
ESRS 2- SBM 3 - E4 paragraph 16 (a) i | Indicator number 7 Table #1 of Annex 1 |  |  |  | Not material
ESRS 2- SBM 3 - E4 paragraph 16 (b) | Indicator number 10 Table #2 of Annex 1 |  |  |  | Not material
ESRS 2- SBM 3 - E4 paragraph 16 (c) | Indicator number 14 Table #2 of Annex 1 |  |  |  | Not material
ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) | Indicator number 11 Table #2 of Annex 1 |  |  |  | Not material

Annual report 2025 108

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Disclosure Requirement and related datapoint | SFDR (1) reference | Pillar 3 (2) reference | Benchmark Regulation (3) reference | EU Climate Law (4) reference | Materiality of the data point and location in the report
ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) | Indicator number 12 Table #2 of Annex 1 |  |  |  | Not material
ESRS E4-2 Policies to address deforestation paragraph 24 (d) | Indicator number 15 Table #2 of Annex 1 |  |  |  | Not material
ESRS E5-5 Non-recycled waste paragraph 37 (d) | Indicator number 13 Table #2 of Annex 1 |  |  |  | Not material
ESRS E5-5 Hazardous waste and radioactive waste paragraph 39 | Indicator number 9 Table #1 of Annex 1 |  |  |  | Not material
ESRS 2- SBM3 - S1 Risk of incidents of forced labour paragraph 14 (f) | Indicator number 13 Table #3 of Annex I |  |  |  | Not material
ESRS 2- SBM3 - S1 Risk of incidents of child labour paragraph 14 (g) | Indicator number 12 Table #3 of Annex I |  |  |  | Not material
ESRS S1-1 Human rights policy commitments paragraph 20 | Indicator number 9 Table #3 and Indicator number 11 Table #1 of Annex I |  |  |  | 1. Sustainability at Santander (1.4.2 Human rights due diligence)
ESRS S1-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 21 |  |  | Delegated Regulation (EU) 2020/1816, Annex II |  | 3.1 Our employees - Cross reference to: 1. Sustainability at Santander (1.4.2 Human rights due diligence)
ESRS S1-1 Processes and measures for preventing trafficking in human beings paragraph 22 | Indicator number 11 Table #3 of Annex I |  |  |  | Not material
ESRS S1-1 Workplace accident prevention policy or management system paragraph 23 | Indicator number 1 Table #3 of Annex I |  |  |  | 3.1 Our employees 3.1.2 Working conditions (i. Employee health and well-being)
ESRS S1-3 Grievance/complaints handling mechanisms paragraph 32 (c) | Indicator number 5 Table #3 of Annex I |  |  |  | 3.1 Our employees 3.1.4 Employee feedback and experience
ESRS S1-14 Number of fatalities and number and rate of work- related accidents paragraph 88 (b) and (c) | Indicator number 2 Table #3 of Annex I |  | Delegated Regulation (EU) 2020/1816, Annex II |  | Sustainability notes. SN 7.3 Employees (Table 20. Occupational health & safety)
ESRS S1-14 Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e) | Indicator number 3 Table #3 of Annex I |  |  |  | Sustainability notes. SN 7.3 Employees (Table 20. Occupational health & safety)
ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a) | Indicator number 12 Table #1 of Annex I |  | Delegated Regulation (EU) 2020/1816, Annex II |  | Sustainability notes. SN 7.3 Employees (Table 14. Remuneration ratios)
ESRS S1-16 Excessive CEO pay ratio paragraph 97 (b) | Indicator number 8 Table #3 of Annex I |  |  |  | Sustainability notes. SN 7.3 Employees (Table 14. Remuneration ratios)

Annual report 2025 109

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Disclosure Requirement and related datapoint | SFDR (1) reference | Pillar 3 (2) reference | Benchmark Regulation (3) reference | EU Climate Law (4) reference | Materiality of the data point and location in the report
ESRS S1-17 Incidents of discrimination paragraph 103 (a) | Indicator number 7 Table #3 of Annex I |  |  |  | 3.1 Our employees 3.1.3 Inclusive culture 4. Business conduct 4.2 Ethical conduct
ESRS S1-17 Non- respect of UNGPs on Business and Human Rights and OECD paragraph 104 (a) | Indicator number 10 Table #1 and Indicator n. 14 Table #3 of Annex I |  | Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818 Art 12 (1) |  | 3.1 Our employees 3.1.3 Inclusive culture 4. Business conduct 4.2 Ethical conduct
ESRS 2- SBM3 – S2 Significant risk of child labour or forced labour in the value chain paragraph 11 (b) | Indicators number 12 and n. 13 Table #3 of Annex I |  |  |  | Not material
ESRS S2-1 Human rights policy commitments paragraph 17 | Indicator number 9 Table #3 and Indicator n. 11 Table #1 of Annex 1 |  |  |  | Not material
ESRS S2-1 Policies related to value chain workers paragraph 18 | Indicator number 11 and n. 4 Table #3 of Annex 1 |  |  |  | Not material
ESRS S2-1 Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines paragraph 19 | Indicator number 10 Table #1 of Annex 1 |  | Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1) |  | Not material
ESRS S2-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 19 |  |  | Delegated Regulation (EU) 2020/1816, Annex II |  | Not material
ESRS S2-4 Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36 | Indicator number 14 Table #3 of Annex 1 |  |  |  | Not material
ESRS S3-1 Human rights policy commitments paragraph 16 | Indicator number 9 Table #3 of Annex 1 and Indicator number 11 Table #1 of Annex 1 |  |  |  | Not material
ESRS S3-1 non-respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines paragraph 17 | Indicator number 10 Table #1 Annex 1 |  | Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1) |  | Not material
ESRS S3-4 Human rights issues and incidents paragraph 36 | Indicator number 14 Table #3 of Annex 1 |  |  |  | Not material
ESRS S4-1 Policies related to consumers and end-users paragraph 16 | Indicator number 9 Table #3 and Indicator number 11 Table #1 of Annex 1 |  |  |  | 3.3 Our customers
ESRS S4-1 Non-respect of UNGPs on Business and Human Rights and OECD guidelines paragraph 17 | Indicator number 10 Table #1 of Annex 1 |  | Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1) |  | 3.3 Our customers - Cross reference to: 1. Sustainability at Santander (1.4.2 Human rights due diligence)

84 The figures have not changed compared with 2024.
85 The diversity ratio is calculated by dividing the number of women by men. The figure has not changed compared with 2024.The percentage of each gender vs. total
membership is 40% women and 60% men.
Annual report 2025 110

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Disclosure Requirement and related datapoint | SFDR (1) reference | Pillar 3 (2) reference | Benchmark Regulation (3) reference | EU Climate Law (4) reference | Materiality of the data point and location in the report
ESRS S4-4 Human rights issues and incidents paragraph 35 | Indicator number 14 Table #3 of Annex 1 |  |  |  | Not material
ESRS G1-1 United Nations Convention against Corruption paragraph 10 (b) | Indicator number 15 Table #3 of Annex 1 |  |  |  | 4. Business conduct 4.2 Ethical conduct (4.2.3 Financial crime compliance)
ESRS G1-1 Protection of whistle- blowers paragraph 10 (d) | Indicator number 6 Table #3 of Annex 1 |  |  |  | 4. Business conduct 4.3 Ethical channels
ESRS G1-4 Fines for violation of anti- corruption and anti-bribery laws paragraph 24 (a) | Indicator number 17 Table #3 of Annex 1 |  | Delegated Regulation (EU) 2020/1816, Annex II) |  | 4. Business conduct 4.2 Ethical conduct (4.2.3 Financial crime compliance)
ESRS G1-4 Standards of anti- corruption and anti- bribery paragraph 24 (b) | Indicator number 16 Table #3 of Annex 1 |  |  |  | 4. Business conduct 4.2 Ethical conduct (4.2.3 Financial crime compliance)

(1) Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector
(Sustainable Finance Disclosures Regulation) (OJ L 317, 9.12.2019, p. 1).
(2) Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and
amending Regulation (EU) No 648/2012 (Capital Requirements Regulation 'CRR') (OJ L 176, 27.6.2013, p. 1).
(3) Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts
or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014 (OJ L 171, 29.6.2016,
p. 1).
(4) Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework for achieving climate neutrality and amending
Regulations (EC) No 401/2009 and (EU) 2018/1999 (‘European Climate Law’) (OJ L 243, 9.7.2021, p. 1).
(5) Commission Delegated Regulation (EU) 2020/1816 of 17 July 2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as
regards the explanation in the benchmark statement of how environmental, social and governance factors are reflected in each benchmark provided and published (OJ L 406,
3.12.2020, p. 1).
(6) Commission Implementing Regulation (EU) 2022/2453 of 30 November 2022 amending the implementing technical standards laid down in Implementing Regulation
(EU) 2021/637 as regards the disclosure of environmental, social and governance risks (OJ L 324,19.12.2022, p.1.).
(7) Commission Delegated Regulation (EU) 2020/1818 of 17 July 2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as
regards minimum standards for EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks (OJ L 406, 3.12.2020, p. 17).
SN 2. Sustainability governance
Board of directors
It consist of 15 members, of which 13 are non-executive directors
and 2 are executive directors. The majority are independent
directors (66.67% of the total members of the council). 84
Our policy on the selection, suitability assessment and succession
of directors promotes a robust balance of technical skills,
experience and diversity in terms of gender, age, geographic origin,
career path and knowledge. It also ensures that selection
procedures are free from implicit biases that could result in any
form of discrimination on grounds such as disability, race or ethnic
origin.
The board currently has a balanced presence of both genders
(women -men) with a diversity ratio of 67%. 85 In terms of
geographical origin/ international track record, 93% of the
directors come from, studied or have international experience in
continental Europe, US/UK, 60% also in Latin America, and 33% in
other regions. The Board also has extensive international
experience, mainly in the markets where we operate (European
market, US and UK markets, and Latin American markets). The
Board also has the skills and experience to monitor materiality
issues (e.g. on issues related to sustainability, human resources,
culture, talent and remuneration, as well as to business conduct
and risk management). For more details, se e 'Board skills and
diversity matrix' in the 'Corporate governance' chapter. None of the
directors are currently assigned a specific employee representation
role.
The board of directors as the highest decision-making body in the
Group performs the following functions:
• approves the Responsible Banking agenda and set the strategy;
• approves the culture policy and related policies on responsible
business and sustainability matters and, in particular, on
environmental and social matters;
• supervise that the responsible banking strategy is consistent
with Group strategy;
• reviews the performance against the public objectives and that
the metrics are covered within the responsible banking agenda;
• tracks key initiatives; and
• reviews subsidiaries’ strategies.
Annual report 2025 111

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

For more details, see the Rules and Regulations of the board of
Directors, available on the Group's corporate website; and section
4.2 'Board composition' in the 'Corporate governance' chapter.
Responsible banking, sustainability and cultural
committee
The responsible banking, sustainability and cultural committee
(RBSCC) assists the board in fulfilling its supervisory
responsibilities regarding the responsible business strategy and
sustainability issues of Banco Santander and its Group. In
particular, it has, among others, the following functions:
(i) advise the board on the design of the strategy and policies on
responsible business and sustainability, in particular
environmental and social matters, and supervise the monitoring
and evaluation of them;
(ii) advise the board of directors on formulating the Group’s
strategy for its relationships with stakeholders, and oversee
stakeholder engagement and corporate reputation, analysing and
reporting to the board on social, environmental and sustainability
matters, as well as responsible and ethical conduct;
(iii) ensure that adequate control processes are in place for
responsible banking practices, and that sustainability-related risks
and opportunities are identified and managed, in coordination with
the other board committees, as appropriate;
(iv) to report regularly to the board on the progress made by the
Group on responsible business practices and sustainability.
The responsible banking, sustainability and culture committee
consists of five independent directors, 80% of whom are women.
All of them have been appointed by the board of directors taking
into account their knowledge, qualifications a nd experience in the
areas for which the committee is responsible. Thus, its members
have competence in issues relevant to this function as strategy and
human resources, culture, talent and remuneration, responsible
business and sustainability, risk management and also in issues
related to education and universities.
In 2025, the committee held four meetings. In addition, resolutions
in writing were adopted on one occasion without a session being
held. The following topics were discussed, among others.
Environmental issues:
• Reviewed the Group's climate strategy and constructively
challenged it to ensure our objective of supporting our customers
in achieving their transition goals, assessing their climate risks in
order to manage the impact on both their business and our
operations, and progress in the alignment of our portfolios, in
accordance with applicable local regulation.
• Reviewed the plans of the global businesses to ensure their
alignment with market, regulatory and supervisory context, as
well as with the commercial strategy.
• Reviewed the ongoing work to develop the prudential transition
plan required under Directive 2013/36/EU on access to the
activity of credit institutions and the prudential supervision of
credit institutions, and under the EBA Guidelines (2025/01) on
ESG risk management, in coordination with the risk supervision,
regulation and compliance committee.
• Monitored the progress made in embedding climate-related and
environmental risks in line with supervisory expectations, and
monitored the implementation of controls and processes to
mitigate ESG risks.
• Reviewed the specific internal controls and risk management
measures applied to Santander Brasil’s relationships with certain
companies operating in the Amazon.
• Reviewed the sustainable finance strategy across global
businesses and its execution, including priorities related to
socially responsible investment.
• Oversaw the sustainability strategy, including support to our
customers in their transition and financial inclusion and health
solutions.
Social issues:
• Oversaw progress on the implementation of our community
support model, to reinforce the Group's contribution to key areas
such as education, including financial education, employability,
entrepreneurship and support to vulnerable groups, as well as
the resulting impact from associated initiatives, assessing their
scope and relevance.
• Received information on about corporate communication
initiatives on social matters.
Governance issues:
• Verified that the proposed sustainability agenda and targets
remained aligned with the Group's strategy.
• Assisted the board in ensuring that sustainability targets and
metrics were embedded in the Group's remuneration schemes
and reviewed, in coordination with the remuneration committee,
the proposed sustainability element of the long-term incentives
for 2026-2028.
• Reviewed engagement with stakeholders such as investors,
proxy advisors, ESG rating agencies and NGOs.
• Reviewed the priority areas for action based on the outcomes of
the double materiality exercise and the associated impacts, risks
and opportunities (IROs), including progress on their integration
into management and governance to facilitate their monitoring,
in coordination with the audit committee.
• Reviewed progress made towards the objectives announced at
the 2023 Investor Day under its remit and discussed
sustainability targets for the next three years in the areas of
green financing, investment in education, employment and
entrepreneurship initiatives, and financial inclusion.
• Supported the audit committee on the supervision and
assessment of the process to prepare and present non-financial
information according to applicable regulation and international
standards.
• Reviewed this 2025 Group statement on non-financial
information.
• Reviewed the Green Bond Report in coordination with the audit
committee prior to its submission to the board for approval.
• Reviewed the main European and international financial
regulatory and supervisory initiatives and priorities related to
Annual report 2025 112

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

sustainability and how they impacted the Group, including
legislative proposals promoted by the European Commission
aimed at streamlining sustainability-related disclosure, due
diligence, and taxonomy.
• Reported favourably to the board on the update of internal
regulation within its remit, in coordination with risk supervision,
regulation and compliance committee, as required.
For more details, see the Rules and Regulations of the board of
Directors, available on t he Group's corporate website; and sections
4.2 'Board composition' and 4.9 'Responsible banking,
sustainability and cultural committee activities in 2025' in the
'Corporate governance' chapter.
Board audit committee
The board audit committee assists the board in overseeing and
reviewing the financial and sustainability information process, as
well as internal control systems.
The audit committee consists of five independent directors, 60% of
whom are women. All of them have been appointed by the board
of directors based on their knowledge, qualifications and
experience in the areas of finance, accounting and auditing,
internal control, information technology, business or risk
management.
In 2025, the committee held 15 meetings, including four joint
sessions with the risk supervision, regulation and compliance
committee and one with the nomination committee. With regard
to sustainability reporting, the committee oversaw the
sustainability reporting process, receiving regular updates from the
Group's Chief Accounting Officer (CAO) and the main functions
responsible for sustainability reporting.
For more details, see the Rules and Regulations of the board of
Directors, available on the Group's corporate website; and sections
4.2 'Board composition ' and 4.5 'Audit committee activities in
2025' in the 'Corporate governance' chapter.
Risk supervision, regulation and compliance committee
The risk supervision, regulation and compliance committee
supports and advises the board in defining and assessing risk
policies that affect the Group and in determining the current and
future risk appetite and the strategy and culture in this area,
including proposing appropriate changes in view of internal or
external circumstances that impact on the Group (both financial
and non-financial risks), among other functions.
The risk supervision, regulation and compliance committee
consists of five directors, out of which 40% are women, all of them
external with three independent members, including its chair. All
of them have been appointed by the board of directors based on
their knowledge, qualifications and experience in the areas for
which the committee is responsible. Thus, its members have
competence in issues relevant to this function as banking,
accounting, auditing and financing, strategy, risk management,
governance and control, as well as in human resources, culture,
talent and remuneration.
In 2025, the committee held 14 meetings, including four joint
sessions with the audit committee and one joint session with the
remuneration committee. It reviewed relevant topics on customer
data protection, aspects of customer conduct, complaints and
internal whistleblowing. Issues such as risks culture and internal
control are also addressed.
For more information, see the Rules and Regulations of the board
of directors, available on the Group's corporate website; and
sections 4.2 'Board composition' and 4.8 'Risk supervision,
regulation and compliance committee activities in 2025' in the
'Corporate governance' chapter.
Other committees of the Group board, such as the Nomination and
remuneration committees, also support and review sustainability-
related issues. For further details, see sections 4.6 'Nomination
committee activities in 2025' and 4.7 'Remuneration committee
activities in 2025' in the 'Corporate governance' chapter.
Other governance bodies
The corporate accounting and financial reporting, management
and sustainability committee performs these functions (among
others):
• Approve the content and scope of the disclosure in the areas
where it applies, as well as the overall style and tone of the
narrative within regulatory reporting.
• Analyze and validate or, when applicable, propose the approval
of all significant sustainability information.
This committee meets monthly, or on an extraordinary basis when
deemed appropriate.
The CCR is composed of senior management members in the
functions of risk, compliance, financial and general intervention,
among others.
The risk control committee (CCR) is responsible for controlling
risks and providing a holistic view of them. Determines whether
lines of business are managed according to the risk appetite
approved by the board. It also identifies, tracks and evaluates the
impact of current and emerging risks on the Group’s risk profile.
Other forums and support functions
First line of defence
Business functions and all other functions that generate risk
exposure are the first line of defence. The first line of defence
identifies, measures, controls, tracks and reports the risks that
originate and applies the policies, models and procedures that
regulate risk management. Risk generation must be adjusted to the
approved risk appetite and associated limits. The head of each unit
that generates a risk has primary responsibility for managing it.
The corporate sustainability function works continuously to
define, execute and monitor our sustainability strategy, and
coordinates and drives the responsible banking agenda, with
support from a senior adviser on responsible business practices
who reports directly to the executive chair, as well as with the
sustainability network in our core markets, global businesses and
corporate functions.
Annual report 2025 113

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

The accounting and management control function, is responsible
for (among others):
• establishing and maintaining the internal control system on the
financial and sustainability information generated by the
function; and
• Implementing the standards and policies reflected in the
sustainability information sent to the Corporation.
It is the responsibility of the functions involved in executing the
strategy and preparing information on sustainability (for example:
Technology, Operations, Risks, People, Culture and Organization,
Tax, and others) that the information provided is true and reliable,
establishing the necessary controls and correcting any
weaknesses.
Second line of defence
Risk and compliance functions, as the second line of defence, will
provide independent challenge and oversight of the risk
management activities performed by the first line of defence. This
second line of defence should control, within their respective
domains of responsibility, that risks are managed in accordance
with the risk appetite defined by senior management and promote
a strong risk culture throughout the organization.
The internal control function within the Enterprise Wide Risk
Management function will be responsible for establishing the
criteria and monitoring the implementation and effectiveness of
the Santander Group Internal Control System. This will help to the
adequacy and integrity of the internal controls established by the
different functions to provide reasonable assurance in the
achievement of the defined objectives (which include, among
others, the reliability of financial and sustainability reporting).
Third line of defence
The internal audit function periodically assesses that policies,
methods and procedures are adequate and effectively applied for
the management and control of accounting, financial and
management information. The annual audit plan, which was
carried out on the basis of a robust risk assessment process (Top-
down & Bottom-up methodology), provides reviews of the main
aspects contained in this report.
In this way, issues related to climate risk and disclaimers are
regularly verified as well as compliance with the rules and
procedures established in the General Code of Conduct (GCC),
independently monitoring their adequacy and effectiveness and
those of their local developments. The Open Channel is reviewed
and specifically evaluates compliance with data protection
regulations.
The audit function reports to the audit committee, which, among
other functions, assists the board in the supervision and evaluation
of the process of preparing and presenting financial and non-
financial information, as well as internal control systems.
Risk management and internal controls over sustainability
information
In order to control the quality and reliability of the information
included in the Sustainability statement, Santander implemented
an internal control system that complies with the most demanding
international standards and complies with the guidelines
established by the Committee of Sponsoring Organisations of the
Treadway Commission.
The most material risks have been identified, and the operation of
the established controls has been monitored, ensuring compliance
with sustainability disclosure requirements.
The most significant aspects taken into account in the process of
preparing sustainability information are the following:
• Identification and definition of quantitative and qualitative
criteria that emanate from regulatory interpretation or our
impacts risks and opportunities in areas where there are no
consolidated market practices.
• The hypotheses, judgments, estimates and approximations used
in the calculation and preparation of certain metrics.
• Ensuring the completeness of information and establishing
perimeters for each metric or group of metrics.
• Difficulties in having, in certain respects, third-party information
necessary for the construction of our narrative or metrics,
especially in the value chain (emissions information from our
portfolio, alignment information, supplier information, etc.).
• Calculation, processing and consolidation of both quantitative
and qualitative information.
In addition, we also began to prepare reasonable assurance of
several of the metrics to convergence in the quality standards of
financial and sustainability information.
Similarly to the control of financial information, the
implementation and supervision of the control system of
sustainability information is carried out through the following
bodies: board of directors, Audit committee, Risk Control
committee and Corporate Accounting and Financial, Management
and Sustainability Reporting committee.
For more details, see 'Sustainability information' of the
consolidated management report; section 8. 'Internal control over
financial reporting (ICFR)' in the 'Corporate governance' chapter;
and section 1.5 'Internal control system' in the 'Risk management
and compliance' chapter.
Annual report 2025 114

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Control system for sustainability information
Control culture
Basis of Internal
Control. Essential to
provide reasonable
assurance in achieving
the objectives defined
by the Group, acting
responsibly.
Risk Assessment
(RCSA)
Dynamic process of
evaluating the risks
associated with
achieving the
organization's
objectives.
Control Activities
Actions established by
policies and
procedures that help
that management
instructions are
carried out to mitigate
identified risks.
Information and
Communication
Accurate and timely
information for
decision-making,
facilitating the
escalation and
governance of
improvements and
incidents.
Monitoring activities
Mechanisms and
instruments to
monitor the correct
implementation and
effectiveness of the
internal control
system, promoting a
continuous evaluation
of the same.
Cross-cutting regulations to embed ESG standards in our
business model
Responsible banking framework
Establishes responsible banking as a strategic topic for Grupo
Santander and all local units.
Accounting and Financial Reporting, Management and
Sustainability information framework
Sets out the principles, Directives and guidelines regarding the
preparation of accounting, financial and management information
that must be applied by all Group subsidiaries as an essential
element of proper governance.
Responsible banking and sustainability policy
Sets out our sustainability principles, targets and strategy
(including human rights protection) to create long-term
stakeholder value.
Responsible banking model
Sets out the roles and responsibilities of the first, second and third
line of defence in all responsible banking-related activity to drive
our sustainability agenda, embed ESG standards and achieve our
goals.
In addition to these regulations, which apply to all the Group’s
units and businesses, the following section of this chapter details
the regulations that apply specifically to the management of each
of the material topics and associated IROs:
• Climate change (see section 2. 'Our climate transition plan');
• Own workforce (see section 3.1 'Our employees');
• Consumers and end users (see section 3.3 'Our customers');
• Affected communities (see section 3.2. 'Communities'
sustainable development'),
• Business conduct (see section 4. 'Business conduct').
All regulations (corporate frameworks, models, policies and
procedures) help maintain a high level of governance, and the
highest standards in terms of their drafting, approval, and in the
monitoring of their local transposition.
The approval of the regulations is responsibility of the board of
directors or its committees, when the regulated matter falls within
their scope of responsibility according to their rules and
regulations. Corporate frameworks in all cases must be approved
by the board of directors. The regulations approved by the board
are as follows:
→ Relevant corporate frameworks related to sustainability:
Responsible Banking, Risk; Cybersecurity; Compliance; Financial
Crime prevention; People and culture.
→ Relevant policies related to sustainability: Responsible banking
and sustainability; Code of conduct; Code of conduct in securities
markets; Corporate Defence; Environmental, social and climate
change risk; Tax; Conflict of interest; Defence sector; Anti-money
laundering and countering the financing terrorism;
Remuneration; Performance management; Group Succession;
Culture.
For more details on the Group's key regulatory documents on
sustainability, see our corporate website santander.com.
SN 3. Materiality assessment – Detailed methodology
The double materiality assessment conducted across Grupo
Santander and its subsidiaries followed European Sustainability
Reporting Standards (ESRS) 1 and 2 and EFRAG’s double materiality
guidance. The results of the 2024 assessment remain in force and
are presented in this report, with minor wording adjustments to
align the description of material impacts, risks and opportunities
with how they were managed during the year. To confirm their
continued validity, Banco Santander reviewed all methodological
components and validated the relevance of inputs and outcomes
across the phases of the process. This review found no significant
changes that would warrant updating the assessment. In line with
paragraph 25 of ESRS 1, it is therefore appropriate to retain the
2024 assessment as the basis for 2025 reporting. The exercise will
be reviewed in 2026.
86 ENCORE: a materiality database of dependencies between production processes and ecosystem services.
Annual report 2025 115

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Our assessment comprised these phases:

|  | 1. Background and stakeholder analysis |
|  | 2. Identification of IROs |
|  | 3. Assessment of IROs |
|  | 4. Materiality thresholds |
Ä |  |  |

1. Background and stakeholder analysis
General view of the bank, its operations and main lines of business,
based on:
→ Information on the entity : Sources include strategic and
financial plans, financial statements and other published reports.
This analysis considers operations, products and services,
geographical footprint, business relationships and the value
chain.
→ External information: Public documents on sector trends,
analyst and supervisor papers, and peers’ sustainability reports.
To enhance this background analysis, we also use these external
sources:
1. The UNEP FI impact analysis tool to uncover the impact of the
Group’s financing operations, including those related to climate
change. This tool provides a in-built impact mappings that
combined, with our internal data and context, enables us to
identify the most significant impact areas of the portfolio.
2. The ENCORE 86 (environmental risk assessment) database to
obtain information on the bank customer’s environmental
dependencies.
3. Human rights due diligence to spot the actual and potential
impact of the bank’s operations on human rights throughout the
value chain. In line with regulatory requirements, as part of the
review of the analysis scheduled for 2026, the due diligence
process will be conducted for both environment and human
rights.
We use the stakeholder analysis to identify directly affected
stakeholders (customers, employees and investors) and readers of
the report (supervisors and regulators, our communities and
NGOs). We analyse information gathered during stakeholder
engagement exercises and conduct surveys on sustainability
matters to use as part of our materiality assessment.
2. Identification of impacts, risks and
opportunities
The background analysis uncovered approximately 150 IROs. We
categorize every IRO and assign them to a topic, sub-topic or sub-
sub-topic under ESRS 1, AR 16. For each IRO, we detail:
→ the part of the value chain they touch and over what time frame.
→ the dependencies between impacts and risks, assessing how
each impact can lead to new risks and opportunities, with a
special focus on the negative impacts of the human rights due
diligence exercise; and
→ who in the organization manages it.
→ What is the type of financial effect for risks and opportunities.
3. Assessment of impacts, risks and
opportunities
The methodology we use to measure materiality follows the
EFRAG implementation guidance. After applying that methodology
in this phase, 29 IROs were material.
Impact
We analyse the materiality of actual and potential impacts based
on the likelihood and severity of occurrence and, in the case of
negative impacts, include irreparable impacts.
→ Scale (size of impact): split into five categories: Low, moderately
low, medium, high, very high.
→ Scope: split into four categories: Local, national, international,
global.
→ Irreparable impact (when negative): split into four levels;
reparable, reparable with moderate effort, difficult to repair, and
irreparable.
We estimate the likelihood of impact on a scale of 1 to 5.
Risks
We adapted our methodology according to the maturity of
quantifying environmental and social risks.
→ The climate materiality assessment includes a climate risk
assessment (transition and physical) across several time
horizons to align with the EBA’s Guidelines on the management
of ESG risks and other EU risk management Directives. We used
this information to quantify the materiality of credit, market,
operational, reputational and other risks.
→ We assess other environmental risks related to Pollution, Water
and marine resources, Biodiversity and ecosystems and Resource
use and circular economy through the exercise described in the
section 2.3.5. 'Our approach to nature and biodiversity'. This
assessment seeks to identify connection between our portfolios
and nature in line with target 15 of the Kunming-Montreal
Global Biodiversity Framework adopted at the United Nations
Climate Change Conference 2022 (COP15).
→ For social and governance risks, we use the Sustainability
Accounting Standards Board’s (SASB) financial materiality and
internal financial information.
Opportunities
We base the opportunities assessment on forecasts for all our
global businesses. We map out projected ESG revenue against the
identified opportunities and compared it to the Group’s revenue on
a scale of 1 to 5.
Stakeholder views
We supplement IROs assessments with stakeholder views
(affected groups and readers of the report).
87 The two key functions at Group level monitoring these aspects were consulted.
Annual report 2025 116

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

The number of specific inputs received within this exercise is detailed below. These inputs are part of the constant dialogue with our
stakeholders, as detailed in section 1.3. 'Stakeholder engagement'.

Retail Customers |  | Investors |  | NGOs |  | Senior management |  | Employees |  | Regulators and supervisors 87
N = 9000+ |  | N = 8 |  | N = 3 |  | N = 8 |  | N = c.200 |  | N = 2

The survey results show agreement in prioritizing three areas: the
fight against climate change and supporting the green transition;
protecting customer data; information transparency and fostering
financial inclusion. Specifically:
• Retail customers prioritize social (privacy and personal data
security) and governance matters (transparency and honesty).
• Employees and senior management prioritize each ESG area
equally.
• Investors, regulators and NGOs prioritize environmental
matters.
4. Materiality thresholds
We set a threshold of 3.5 on a scale of 1 to 5 to classify an IRO as
material (for impact perspective and financial materiality). This
means that we consider IROs that sit between medium (3) and high
(4) as material. Taken as a reference the score calculation for the
impacts, the score values greater than 3.5 represent events of
medium-high severity and events with medium-high probability of
occurrence.
We also assess the reasonability and coherence of the list of IROs
identified as material. In quantitative terms assuming that the
distribution of the events materiality follows a normal distribution
(average=3 and standard deviation = 0.5), the probability of a score
value of 3.5 is around 16%, which is considered reasonable for a
material event.
Annual report 2025 117

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Information on impacts, risks and opportunities (IROs)

ESRS | IRO description | IRO type | Value chain | Summary of current/ potential effects (narrative) | People/ environment | Strategy- and business model-related impacts | Time horizon 1 | Linked to impact due to own operations or business relations 2 | Systemic/ specific | Core activities that lead to positive impacts | Risks and/or opportunities stemming from impacts | More details
E1 - Climate change | Contribution to protecting the environment by driving an increase in the use of renewable energy and other low-carbon technologies. | Positive impact | Downstream | - Promote the development of innovative, clean technology and our customers’ transition | Environment | 1. Help our customers in their green transition while also managing climate-related risks and impacts | Short/ medium term | Business relations | N/A | N/A | N/A | 2.2 'Supporting our customers' transition'
E1 - Climate change | Contribution to reducing the Group’s scope 1 and 2 greenhouse gas emissions. | Positive impact | Own operations | - Reducing our environmental footprint | Environment | 1. Help our customers in their green transition while also managing climate-related risks and impacts | Short/ medium term | Own operations | N/A | N/A | N/A | 2.4 'Aiming to align our activity with the Paris Agreement Goals' - 2.4.5 'Our environmental footprint'
E1 - Climate change | Adverse impact on climate and the environment due to the bank’s financing of, or investment in, certain nonsustainable assets and activities. | Negative impact | Downstream | - Adverse environmental impact | Environment | 1. Help our customers in their green transition while also managing climate-related risks and impacts | Short/ medium term | Business relations | N/A | N/A | N/A | 2.4 'Aiming to align our activity with the Paris Agreement Goals'
E1 - Climate change | Growth in the financing and investment in transition and clean tech solutions, supporting the economy and key sectors such as energy, construction, mobility and agriculture. | Opportunity | Downstream | Support clean technology through our financial product proposition and grow our revenue by providing sustainable solutions in several sectors and partnering our customers in their transition | N/A | N/A | N/A | N/A | N/A | N/A | ✔ | 2.2 'Supporting our customers' transition'
E1 - Climate change | Reputational risk based on the perception of the Bank's progress with Group climate-related policies and objectives in certain jurisdictions and that could lead to other type of risk implications. | Risk | Own operations and downstream | - Potential reputational damage if risks materialize | N/A | N/A | N/A | N/A | N/A | N/A | ✔ | 2.3 'Embedding climate in risk management'- 2.3.3 'Reputational risk'
S1 - Own workforce | Promotion of the health, well-being and security of our employees in a safe and inclusive workplace; facilitate a positive work-life balance between personal and professional life through policies that foster the balance between them. | Positive impact | Own operations | - Contribute positively to a workplace that promotes flexible working, health and well-being | People | 2. Help our employees develop by promoting diversity and learning and providing fair working conditions. | Short/ medium term | Own operations | N/A | Global health and well- being strategy that sets out how we protect the health, safety and well- being of our employees and promote a healthy lifestyle. | N/A | 3.1 'Our employees' - 3.1.2 'Working conditions'

Annual report 2025 118

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

ESRS | IRO description | IRO type | Value chain | Summary of current/ potential effects (narrative) | People/ environment | Strategy- and business model-related impacts | Time horizon 1 | Linked to impact due to own operations or business relations 2 | Systemic/ specific | Core activities that lead to positive impacts | Risks and/or opportunities stemming from impacts | More details
S1 - Own workforce | Promotion of a workforce that reflects the society we live in and encourages collaboration and provides opportunities for all our employees, irrespective of personal characteristics and in compliance with the law. | Positive impact | Own operations | - Contribute positively to an inclusive environment that offers equal opportunity for all | People | 2. Help our employees develop by promoting diversity and learning and providing fair working conditions. | Short/ medium term | Own operations | N/A | Global inclusive culture strategy for 2020-2025 that drives us to act ethically, purposefully and transparently. | N/A | 3.1 'Our employees' - 3.1.2 'Working conditions', 3.1.3 'Inclusive culture'
S1 - Own workforce | Promotion of continuous career development and personal growth through learning and development programmes. | Positive impact | Own operations | - Promote training, development and personal growth among employees | People | 2. Help our employees develop by promoting diversity and learning and providing fair working conditions. | Short/ medium term | Own operations | N/A | Create talent programmes to promote individual growth while considering business demands. | N/A | 3.1 'Our employees' - 3.1.1 'Talent and skills development'
S1 - Own workforce | Promotion of the general well-being of employees and provide appropriate remuneration under equal conditions based on merit and market rates. | Positive impact | Own operations | - Promote appropriate and equal remuneration | People | 2. Help our employees develop by promoting diversity and learning and providing fair working conditions. | Short/ medium term | Own operations | N/A | Remuneration framework that combines fixed and variable pay schemes based on targets for employees and the Group. | N/A | 3.1 'Our employees' - 3.1.2 'Working conditions'
S1 - Own workforce | Harm employees if unlawful discriminatory conduct, inadequate working conditions, harassment or corruption occur. | Negative impact | Own operations | - Potential harm to employees through an inadequate working environment and conditions. | People | 2. Help our employees develop by promoting diversity and learning and providing fair working conditions. | Short/ medium term | Own operations | Systemic | N/A | N/A | 3.1 'Our employees' - 3.1.3 'Inclusive culture'
S1 - Own workforce | Potential risk of conflict with employees based on the infringement of their rights. | Risk | Own operations | - Potential harm if risks materialize | N/A | N/A | N/A | N/A | N/A | N/A | ✔ | 3.1 'Our employees' - 3.1.2 'Working conditions'
S4 - Consumers and end users | Positive impact on customers due to the bank’s offer of products and services that adapt to their needs and expectations and promote financial inclusion and health. | Positive impact | Own operations | - Promote customer inclusion through products and services that adapt to their needs | People | 4. Be a trusted partner to our customers, with products and services that adapt to their needs, while applying responsible practices, supporting their financial inclusion, and protecting their information. | Short/ medium term | Own operations | N/A | Develop products and services and special programmes to achieve financial health and inclusion | N/A | 3.3 'Our customers' - 3.3.2 'Financial health and inclusion'
S4 - Consumers and end users | Education on, and awareness of, cybersecurity to understand potential threats and ways to repel them. | Positive impact | Own operations | Knowledge and awareness of cybersecurity matters to help reduce online threats | People | 4. Be a trusted partner to our customers, with products and services that adapt to their needs, while applying responsible practices, supporting their financial inclusion, and protecting their information. | Short/ medium term | Own operations | N/A | Interactive campaigns, awareness workshops, corporate sponsorship, podcasts | N/A | 3.3 'Our customers' - 3.3.3 Privacy, data protection and cybersecurity

Annual report 2025 119

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

ESRS | IRO description | IRO type | Value chain | Summary of current/ potential effects (narrative) | People/ environment | Strategy- and business model-related impacts | Time horizon 1 | Linked to impact due to own operations or business relations 2 | Systemic/ specific | Core activities that lead to positive impacts | Risks and/or opportunities stemming from impacts | More details
S4 - Consumers and end users | Negative impact on the customer if they do not have access to complaints channels or if, after making a complaint, the bank fails to take the necessary action. | Negative impact | Own operations | - Potential breakdown of trust and long-term relationships with customers | People | 4. Be a trusted partner to our customers, with products and services that adapt to their needs, while applying responsible practices, supporting their financial inclusion, and protecting their information. | Short/ medium term | Own operations | Systemic | N/A | N/A | 3.3 'Our customers' - 3.3.1 'Conduct with customers'
S4 - Consumers and end users | Potential infringement of customers’, employees’ or shareholders’ rights if a lack of appropriate technical or organizational measures to protect their personal data according to law and the practices set by the Group occur. | Negative impact | Upstream | - Potential breakdown of trust and long-term relationships with customers | People | 4. Be a trusted partner to our customers, with products and services that adapt to their needs, while applying responsible practices, supporting their financial inclusion, and protecting their information. | Short/ medium term | Business relations | Systemic | N/A | N/A | 3.3 'Our customers' - 3.3.3 Privacy, data protection and cybersecurity
S4 - Consumers and end users | Negative impact on the customer if the bank fails to provide sufficient information on products or services or to guarantee access to, or the use of, products and services that may present certain obstacles or weak spots. | Negative impact | Downstream and own operations | - Potential breakdown of trust and long-term relationships with customers | People | 4. Be a trusted partner to our customers, with products and services that adapt to their needs, while applying responsible practices, supporting their financial inclusion, and protecting their information. | Short/ medium term | Business relations and own operations | Systemic | N/A | N/A | 3.3 'Our customers' - 3.3.1 'Conduct with customers'
S4 - Consumers and end users | Potential losses due to fines or a reduction in the number of customers if a failure to detect or respond effectively to breaches of privacy occur. | Risk | Downstream | - Potential harm if risks materialize | N/A | N/A | N/A | N/A | N/A | N/A | ✔ | 3.3 'Our customers' - 3.3.3 Privacy, data protection and cybersecurity
S4 - Consumers and end users | Potential losses due to complaints or a reduction in the number of customers if substandard customer practices occur. | Risk | Downstream | - Potential harm if risks materialize | N/A | N/A | N/A | N/A | N/A | N/A | ✔ | 3.3 'Our customers' - 3.3.1 'Conduct with customers'

Annual report 2025 120

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

ESRS | IRO description | IRO type | Value chain | Summary of current/ potential effects (narrative) | People/ environment | Strategy- and business model-related impacts | Time horizon 1 | Linked to impact due to own operations or business relations 2 | Systemic/ specific | Core activities that lead to positive impacts | Risks and/or opportunities stemming from impacts | More details
S3 - Affected communities | Contribution to education, employability and entrepreneurship, as well as to community development through support programmes | Positive impact | Own operations | - Enhance education, employability and entrepreneurship opportunities, and contribute positively to addressing social needs in the communities we serve | People | 3. Contribute to the economic, financial and social development of our communities, with a special focus on education, employability and entrepreneurship. | Short/ medium term | Own operations | N/A | - Education: Grants and scholarships for students and researchers to access and complete their studies; and support to universities in overcoming their key challenges (i.e. digitalization) - Employability: Support lifelong learning; and facilitate access to employment in the early stages of people’s career. - Entrepreneurship: Provide access to the training, advice and resources (including benefits). | N/A | 3.2 'Sustainable development in our communities' - 3.2.4 'Community Support'
S3 - Affected communities | Drive economic growth and job creation in the regions where we operate and provide credit to people and businesses | Positive impact | Downstream | - Grow the economy by helping people and businesses | People | 3. Contribute to the economic, financial and social development of our communities, with a special focus on education, employability and entrepreneurship. | Short/ medium term | Business relations | N/A | Lending to create or grow businesses; microloans to microentrepreneurs to support the start-up and expansion of their businesses; and mortgages and loans for other items. | N/A | 3.2 'Sustainable development in our communities' - 3.2.1 'Supporting the economy and social development of our communities'
S3 - Affected communities | Contribution to sustainable development through financing and investment that promotes sustainable performance in companies, addresses societal challenges, mitigates a specific issue, or pursues positive societal outcomes | Positive impact | Downstream | - Grow the economy, with a focus on activities that promote ESG performance; address social challenges; mitigate a specific social issue; or pursue positive social outcomes | People | 3. Contribute to the economic, financial and social development of our communities, with a special focus on education, employability and entrepreneurship. | Short/ medium term | Business relations | N/A | - Label operations. - Propose investment that covers ESG factors and sustainability objectives. | N/A | 3.2 'Sustainable development in our communities' - 3.2.2 'Responsible investment and social finance'

Annual report 2025 121

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

ESRS | IRO description | IRO type | Value chain | Summary of current/ potential effects (narrative) | People/ environment | Strategy- and business model-related impacts | Time horizon 1 | Linked to impact due to own operations or business relations 2 | Systemic/ specific | Core activities that lead to positive impacts | Risks and/or opportunities stemming from impacts | More details
S3 - Affected communities | Finance activities (in any customer segment) that breach the bank’s policies and jeopardize the well-being of present and future generations or fail to sufficiently involve appropriate stakeholders or use suitable customer identification and management mechanisms when providing finance to a customer or project. | Negative impact | Downstream and own operations | - Potential damage to people’s well-being and/ or to the environment | People/ environment | 3. Contribute to the economic, financial and social development of our communities, with a special focus on education, employability and entrepreneurship. | Short/ medium term | Business relations and own operations | Systemic | N/A | N/A | 3.2 'Sustainable development in our communities' - 3.2.3 'Management of environmental and social aspects'
G1 - Business conduct | Act responsibly and consider investors’ interests and the impact on employees, broader society and the environment; pay taxes to support the distribution of wealth. | Positive impact | Own operations | - Promote decision- making that considers all stakeholders’ interests | People/ environment | 5. Act responsibly through a strong culture, governance and conduct. | Short/ medium term | Own operations | N/A | N/A | N/A | 4.2 'Ethical conduct'
G1 - Business conduct | Protect the confidentiality of users of the bank’s ethical channel and have an effective reporting system in place that follows robust principles and procedures. | Positive impact | Own operations | - Availability of mechanisms for stakeholders to escalate confidentially and/or anonymously (and according to regulatory requirements) substandard practices by the bank and its people | People | 5. Act responsibly through a strong culture, governance and conduct. | Short/ medium term | Own operations | N/A | N/A | N/A | 4.3 'Ethical channels'
G1 - Business conduct | Promote responsible practices among vendors; engage with them, assess their performance in environmental, social and governance (ESG) matters and give them recommendations and tools to improve. | Positive impact | Own operations | - Promote responsible practice in our value chain | People/ environment | 5. Act responsibly through a strong culture, governance and conduct. | Short/ medium term | Own operations | N/A | N/A | N/A | 4.4 'Our suppliers'
G1 - Business conduct | Negative impact on the environment or broader society by failing to implement measures to resolve incidents through complaints or reporting channels or due to a lack of continuous improvement actions. | Negative impact | Own operations | - Potential harm to people and/or the environment; loss of stakeholders’ trust in the channel’s effectiveness | People/ environment | 5. Act responsibly through a strong culture, governance and conduct. | Short/ medium term | Own operations | N/A | N/A | N/A | 4.3 'Ethical channels'

Annual report 2025 122

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

ESRS | IRO description | IRO type | Value chain | Summary of current/ potential effects (narrative) | People/ environment | Strategy- and business model-related impacts | Time horizon 1 | Linked to impact due to own operations or business relations 2 | Systemic/ specific | Core activities that lead to positive impacts | Risks and/or opportunities stemming from impacts | More details
G1 - Business conduct | Harm broader society through bribery or corruption. | Negative impact | Own operations | - Potential loss of customers’ and other stakeholders’ trust | People | 5. Act responsibly through a strong culture, governance and conduct. | Short/ medium term | Own operations | N/A | N/A | N/A | 4.2 'Ethical conduct'
G1 - Business conduct | Potential risk from failing to ensure the operational resilience of the value chain by assessing vendors’ solvency, reputation and compliance with the law. | Risk | Own operations | - Potential harm if risks materialize | N/A | N/A | N/A | N/A | N/A | N/A | ✔ | 4.4 'Our suppliers'
G1 - Business conduct | Risk stemming from improper conduct that makes illicit funds or assets appear legitimate and, therefore, facilitates illegal activity or to benefit from it. | Risk | Own operations | - Potential harm if risks materialize | N/A | N/A | N/A | N/A | N/A | N/A | ✔ | 4.2 'Ethical conduct'
1. For more information on time horizons, see section 1.2 'Materiality assessment'. 2. Own operations are the bank’s internal activities; Business relations primarily centre on upstream and downstream value chain activities.

88 The Climate transition plan and the climate content of the Sustainability statement takes into account the recommendations of Glasgow Financial Alliance for Net Zero
(GFANZ) and Task Force on Climate-related Financial Disclosures (TCFD)
89 The net-zero and APS reference scenarios used as reference, as well as the values considered for 2030, are those published by the IEA in its 2024 World Energy Outlook
report. For oil and gas, the 2023 edition was used, as the 2024 report does not include an update of operational emissions for oil and gas. For own emission reduction
reference data for 2030 is 104,400 ton (-42% vs. 2020).
90 PCAF: 'Partnership for Carbon Accounting Financials' is a global partnership of financial institutions that work together to develop and implement a harmonized approach to
assess and disclose the greenhouse gas (GHG) emissions associated with their loans and investments. Santander joined PCAF in 2021.
Annual report 2025 123

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 4. Climate transition plan 88
i. Alignment targets details
Target types : To help our customers’ transition to a low-carbon
economy, we employ physical emissions intensity for setting
targets in the oil & gas, power generation, steel and auto sectors.
Since transition pathways differ significantly across geographies,
sectors and regulatory contexts, we use target ranges for our
sectoral alignment. We prioritize engagement over divestment.
We recognize that in certain situations, establishing alignment
targets may inadvertently discourage the transition, for example,
when customers increase their leverage to undertake significant
CapEx programs to align their operations, while the alignment
benefits will only materialise over the medium term. To prevent
undesirable outcomes like the one described, we evaluate each
case individually and base our decisions on a long-term
perspective. However, due to the absence of a widely accepted
'transition finance taxonomy', we consider alignment targets to be
an effective tool for informing portfolio decisions, provided that
each case is managed individually. For the different targets’ design
choices taken, we considered inputs from several different internal
and external stakeholders.
Scenarios : 89 To set science-based alignment targets for our
financed sectors to 2030, and recognising that transition pathways
differ significantly across geographies, sectors and regulatory
contexts, we use regional NZE2050 and APS scenarios from the
IEA, both consistent with the Paris Agreement goal of keeping
global warming to 1.5ºC and 1.7°C respectively. These target
ranges enable us to account for different transition speeds and
regulatory frameworks, and to adjust annually in line with the
latest scientific and policy developments. Our scope 1 and 2 own
emission reduction objective by 2030 aligns with the cross-sector
absolute reduction method considered by SBTi, which goes beyond
the minimum ambition of a linear annual reduction of 4.2%
between the base year and target year. The reduction plan for
2030 is consistent with the Paris Agreement and in line with
Regulation (EU) 2021/1119.
Target coverage: All CIB portfolio targets and metrics are global
and include our core subsidiaries. SCF's target is European and
includes its passenger car portfolio (including loans and leasing) in
16 units (13 countries in Europe). This is the same scope we use to
measure emissions performance and progress with our targets,
though we are working on obtaining information and tracking
emissions for other vehicle types.
Baseline years: We use 2023 as the baseline year for the four CIB
targets and 2022 for auto lending in Europe, respectively. We
chose those years to be representative of our portfolios following
this year’s target review. For our own operations emissions (Scopes
1 & 2) reduction objectives, we use 2020 as the baseline
considering the deadline of the plan set to 2030, and the guidelines
criteria for setting science-based targets.
Financed emissions: According to the methodology and design we
chose for each target we calculate financed emissions based on
PCAF 90. Since the emissions information of our customers or
financed assets is not available in the same way as their financial
information, there is a lag of at least one year in the emissions
data.
ii. Disclosed financed emissions
Santander discloses financed emissions from its loan portfolio for
different uses. In the context of portfolio alignment, we calculate
the financed emissions of the portfolios of the most relevant
sectors, following market standards and practices, focusing on the
parts of the value chain of each industry that are most polluting
and actionable through alignment strategies. For this purpose it is
necessary to use information to monitor alignment strategies and
their effectiveness.
Additionally, obligations arising from regulatory or supervisory
requirements need to cover financed emissions from wider
perimeters. For this, we also use other sources and methodologies,
including average emission factors per sector based on market-
recognised methodologies (such as PCAF).
We also calculate the financed emissions of our long-term
investments in equity and sovereign debt, which represent
material exposures in our balance sheet.
Annual report 2025 124

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2. Financed emissions for alignment A
Sector | Year B | Exposure (drawn amount EUR bn) C | Emissions scope | Absolute emissions D | Physical emissions intensity | Financial emissions intensity | Overall PCAF score E
Power generation | 2023 | 12.79 | 1 | 3.88 mtCO₂e | 149 kgCO₂e/MWh | 0.30 mtCO₂e/EUR bn lent | 2.7
2024 | 12.16 | 2.07 mtCO₂e | 88 kgCO₂e/MWh | 0.17 mtCO₂e/EUR bn lent | 2.7
Oil & Gas | 2023 | 5.84 | 1 + 2 | 0.75 mtCO₂e | 3.08 tCO₂e/TJ | 0.13 mtCO₂e/EUR bn lent | 3.0
2024 | 5.44 | 0.71 mtCO₂e | 3.15 tCO₂e/TJ | 0.13 mtCO₂e/EUR bn lent | 3.0
Steel | 2023 | 1.73 | 1 + 2 | 1.59 mtCO₂e | 1.47 tCO₂e/tS | 0.92 mtCO₂e/EUR bn lent | 3.1
2024 | 1.47 | 1.36 mtCO₂e | 1.51 tCO₂e/tS | 0.92 mtCO₂e/EUR bn lent | 3.0
Auto - manufacturing | 2023 | 3.77 | 3 F | 2.56 mtCO₂ | 135 gCO₂/vkm | 0.68 mtCO₂/EUR bn lent | 3.0
2024 | 3.65 | 2.15 mtCO₂ | 128 gCO₂/vkm | 0.59 mtCO₂/EUR bn lent | 3.0
Auto - lending G | 2023 | 62.40 | 1 + 2 | 6.78 mtCO₂e | 133 gCO₂e/vkm | 0.11 mtCO₂e/EUR bn lent | 2.7
2024 | 66.27 | 6.42 mtCO₂e | 129 gCO₂e/vkm | 0.09 mtCO₂e/EUR bn lent | 2.7
Primary energy | 2023 | 18.34 | 3 F | 14.85 mtCO₂e | 45.1 tCO₂e/TJ | 0.81 mtCO₂e/EUR bn lent | 3.0
2024 | 17.12 | 12.65 mtCO₂e | 42.0 tCO₂e/TJ | 0.74 mtCO₂e/EUR bn lent | 2.9
Aviation | 2023 | 0.70 | 1 + 2 | 0.58 mtCO₂e | 83 gCO₂e/RPK | 0.83 mtCO₂e/EUR bn lent | 3.0
2024 | 0.53 | 0.46 mtCO₂e | 78 gCO₂e/RPK | 0.87 mtCO₂e/EUR bn lent | 3.0
Agro H | 2023 | 2.87 | 1 + 2 | 8.41 mtCO₂e | 6.87 tCO₂e/ton | 2.93 mtCO₂e/EUR bn lent | 3.0
2024 | 2.46 | 7.12 mtCO₂e | 6.56 tCO₂e/ton | 2.89 mtCO₂e/EUR bn lent | 3.0
Mortgages I | 2023 | 262.45 | 1 + 2 | 1.93 mtCO₂e | 21.06 kgCO₂e/m² | 0.01 mtCO₂e/EUR bn lent | 3.5
2024 | 284.13 | 2.19 mtCO₂e | 19.00 kgCO₂e/m² | 0.01 mtCO₂e/EUR bn lent | 3.6
Commercial Real Estate J | 2023 | 18.26 | 1+2 | 0.19 mtCO₂e | 22.89 kgCO₂e/m² | 0.01 mtCO₂e/EUR bn lent | 4.0
2024 | 18.82 | 0.31 mtCO₂e | 26.14 kgCO₂e/m² | 0.03 mtCO₂e/EUR bn lent | 4.0

A.These financed emissions should not be confused with the EBA Pillar 3 exercise financed emissions calculations, as the perimeter and therefore, supporting data of the two
exercises are different. In the case of corporate business loans, Banco Santander calculates the Total Value of the Company (used to obtain the emissions attribution factor)
by adding the total equity and debt of the company in order to avoid the high volatility in market capitalization.
B.Obtaining emissions data from our customers is a challenge. As they disclose more non-financial information worldwide, the quality of our reporting on financed emissions
will improve. In some other retail sectors, we rely on availability of emissions information for the different asset types as well as business information.
C.For power generation it includes Corporates and Project Finance in operation, and under construction. Exposure in Santander Polska in 2024: EUR 0.76 bn in Power
Generation and EUR 0.61bn in Auto Manufacturer. Exposure in remaining CIB sectors not material.
D.Absolute financed emissions 2024 in Santander Polska 0.33 mtCO 2 e in Auto Manufacturer. Absolute financed emissions in other CIB sectors not material.
E. In line with PCAF’s data source hierarchy, this score is assigned to financed emissions calculations, ranging from 1 ( company-reported and verified data) to 5 (proxy or
industry-average data).
F.Scope 3 - category 11: use of sold products.
G.Consumer lending for the acquisition of passenger cars, covering a significant majority of the exposure in Europe..
H.Agriculture portfolio in Brazil. From 2024 onwards, and in line with materiality criteria, the calculation includes only soy, corn and beef cattle. The 2023 figure was
recalculated to ensure comparability.
I.Mortgage portfolio in the United Kingdom and Spain for 2023; United Kingdom, Spain and Portugal for 2024. Assessment includes Scope 1 and 2 emissions based on actual
(where available) and modelled EPC's.
J. Commercial real estate portfolios in the United Kingdom and Spain for 2023; in the United Kingdom, Spain and Portugal for 2024. Assessment includes Scope 1 and 2
emissions based on actual (where available) and modelled EPC's.
More detail regarding other financed emissions calculations from our balance sheet, see section SN 7.1 'Green transition'.
iii. Internal carbon pricing
Internal carbon pricing is a tool that helps internalize the external
costs of carbon emissions and align operations with broader
sustainability objectives. We consider setting an internal carbon
price is not the most appropriate approach for our type of
operations and core business model as we strive to help our
customers go green. Nonetheless, we do consider carbon pricing in
several of our internal review and assessment tools, such as
scenario analyses and transition risk calculations. These processes
reflect the 'real world' costs in our prices. A 'fictitious' internal
carbon price would cause disparity between the customer’s actual
ability to pay debt and internal valuations. We encourage the
creation of carbon prices in real economies to facilitate the
transition to a low-carbon economy.
Grupo Santander’s strategy to lessen the environmental impact of
our operations involves reducing CO 2 e emissions and offsetting the
emissions that we’re unable to reduce. We follow a strict carbon
credits selection process that includes due diligence on compliance
and consistency with our environmental, social and climate change
policy. Credits are certified under some of the industry's most well-
known standards. Moreover, the carbon credits we purchase are
ratified by an independent rating agency to validate their integrity.
We actively monitor the voluntary carbon credit market to adapt
our offsetting strategy to best practice.
Offsetting serves to internalize the cost of emissions (scopes 1 and
2) from our own operations.
iv. EU Paris-aligned benchmarks
Because of our financing and investment operations, Santander is
not excluded from the EU Paris-aligned benchmarks. These
benchmarks are designed to align investment with the Paris
Agreement’s goals and include undertakings that meet special
91 Estimates of future GHG emissions that could arise during the useful life of a company’s key assets. The term 'key assets' refers to existing or planned assets that a company
owns or controls (e.g. fixed or mobile installations and equipment) and that are direct or indirect energy-related sources of GHG emissions.
92 Estimates of future GHG emissions as the direct GHG emissions from the use of products sold throughout their useful life (category 3.11).
93 Does not include information on Santander Bank Polska S.A. and its subsidiaries.
94 These are: 1) climate change mitigation; 2) climate change adaptation; 3) sustainable use and protection of water and marine resources; 4) transition to a circular economy;
5) pollution prevention and control and protection; and 6) restoration of biodiversity and ecosystems.
95 The CSRD applies to large companies, listed companies, banks, or insurance companies that meet certain criteria, such as having a balance sheet total greater than EUR 20
million, a turnover greater than EUR 40 million, or an average number of employees greater than 500 during the fiscal year.
96 Balance sheet total excluding exposures to sovereign debt, central banks and the trading book.
97 Calculation for the two climate-related objectives. For the flow of volumes, the Green Asset Ratio is 3.29% (turnover-based) and 3.85% (CapEx-based).
98 Eligibility for the climate-related targets is 31.2% based on turnover and 31.3% based on CapEx. For the remaining four targets, is 0.04% based on turnover and 0.03% based
on CapEx.
Annual report 2025 125

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

sustainability standards. They exclude undertakings that do not
meet those standards.
We disclose our exposure to undertakings excluded from those
benchmarks in section ‘10.4 Credit quality of exposures‘ of our
Pillar 3 disclosures report in accordance with points (d) to (g) of
Article 12(1) and (2) of Regulation (EU) 2020/1818.
v. Locked-in GHG emissions
Our double materiality assessment shows that our direct emissions
do not have a negative impact on, or pose material risk to, the
environment. Regarding locked-in GHG emissions from key
assets, 91 the nature of our financing and investment activity means
that none of our key assets are sources of scope 1 and 2 emissions.
Nonetheless, the Group takes carbon footprint reduction measures
to help make a positive contribution to the environment.
As detailed in the 2.4.5 ‘Our environmental footprint’ section
regarding indirect GHG emissions (scope 3), the only material
category under this scope was category 3.15 (financed emissions),
with a weighting of over 99% of the total scope 3 emissions.
Regarding locked-in GHG emissions from key products, 92 the
category Scope 3.11 'Use of sold products emissions' is not
material to the bank.
With regard to locked-in GHG emissions in category 3.15, there is
currently no information available to have a reliable estimation due
to lack of information from counterparties. In future exercises, its
evaluation will be assessed based on the availability of data.
SN 5. EU Taxonomy 93
Information on Article 8 of the EU Taxonomy
Regulation
In 2020, the European Union adopted the Taxonomy Regulation
that sets out a list of activities that can qualify as environmentally
sustainable 94 and stipulates that companies subject to the
Corporate Sustainability Reporting Directive 95 must disclose how
their operations align with the EU Taxonomy.
In this context, and in accordance with the transitional regime set
out in Commission Delegated Regulation (EU) 2026/73, the Group
will defer until 2026 the application of both the new templates and
the associated calculation methodologies (including the criteria
applicable to the numerator and denominator of the Taxonomy
KPIs, such as the Green Asset Ratio); accordingly, for the 2025
fiscal year the templates, calculation methodologies and disclosure
requirements are maintained.
→ GAR, financial institutions:
Financial institutions have been disclosing their Green Asset Ratio
(GAR) since 2023. This ratio measures the financing granted to
Taxonomy-aligned activities as the numerator and the total
balance sheet as the denominator. 96
To be considered aligned, activities must meet specific taxonomy
criteria and ensure that they do no significant harm (DNSH) to any
of the other environmental objectives and meet minimum social
safeguards (MSS).
Santander's GAR is 3.17% (turnover-based) 97
and 3.35% (CapEx-based) 98
The European Taxonomy criteria do not reflect the full reality of
companies’ transition efforts. Many activities that contribute to the
transition to a greener economy do not meet the Taxonomy’s
alignment criteria. Thus, we cannot include them in the ratio (for
instance, certain types of hybrid cars, which, despite being an
undoubted improvement on petrol cars, are not admitted in all
cases).
Moreover, the limitations in the design of the ratio and in financial
institutions’ implementation of the Taxonomy lead to reduced
numbers:
• The numerator and denominator are not symmetric. While the
denominator reflects the balance sheet total, the numerator only
includes financing in relation to four portfolios: financial
institutions; non-financial institutions subject to the CSRD;
households (mortgages, auto and renovations); and local
governments. Thus, the numerator does not consider green loans
to SMEs or the majority of non-European entities.
• The available data is limited. In Latin America and even in
European countries, energy efficiency certificates are either non-
existent or very limited, which makes it impossible to account for
aligned mortgages in the ratio. There are also significant gaps in
companies’ alignment information.
• DNSH (do no significant harm) and MSS (minimum social
safeguards) implementation criteria are complex and in no way
reflect the reality of a bank. These criteria compel financial
institutions to collect evidence that shows the counterparty
99 For the asset management and insurer KPI, we included eligible and aligned transactions based on the eligibility and alignment ratios of counterparties (both in terms of
CapEx and turnover).
100 C/2024/6691
101 Eligibility for climate-related targets is 7.9% based on turnover and 7.4% based on CapEx. For the remaining four objectives, eligibility is 1.88% based on turnover and
0.23% based on CapEx.
102 European Commission requirements dictate the disclosure of a KPI relating to investment and underwriting. Since the Group does not engage in underwriting relating to
non-life insurance (but only markets these products), we only disclose an investment KPI.
103 Eligibility for climate-related targets is 12.7%based on turnover and 9.6%based on CapEx. For the remaining four objectives, eligibility is 2.62% based on turnover and
0.50% based on CapEx.
104 Based on turnover and CapEx, with weightings according to the proportion of revenue stemming from the activities covered by the corresponding KPI in their total turnover.
Annual report 2025 126

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

meets certain standards for each transaction. This results in an
inability to include specific aligned financing (e.g. project finance)
in the numerator.
Based on a voluntary approach and to mitigate the first limitation
mentioned above, we complement disclosure, we complement the
GAR with an additional ratio (European and symmetric), 9.02%:
• The numerator follows the same criteria than the previous ratio
but only covers European exposures aligned with the Taxonomy.
• The denominator is symmetric and only includes portfolios
where we can currently label exposures as environmentally
sustainable: European financial and non-financial corporations
subject to the CSRD, households, and local governments. We
excluded (non-exhaustive list): Non-CSRD companies (since they
do not have reporting obligations), cash & interbank loans,
derivatives, goodwill and others.

(EUR million) | 2025 | 2024
GAR stock A | 3.17% | 3.04%
Taxonomy aligned activities | 43,150 | 39,656
Total GAR denominator | 1,359,362 | 1,306,542
European & Symmetric - GAR A | 9.02% | 7.90%
Taxonomy aligned activities | 42,962 | 39,287
Total GAR denominator | 476,536 | 497,604
A Turnover-based ratio

→ Other businesses’ GAR (asset management, insurance and
investment services):
In addition to the credit institutions GAR that has already been
published, we included the GAR for asset management, insurance 99
and investment services businesses according to the European
Commission's requirements 100
→ Our key performance indicator for asset management is 2.44%
(based on turnover) and 3.48% (based on CapEx). 101
→ Our key performance indicator for insurance 102 is 1.70% (based
on turnover) and 2.09% (based on CapEx). 103
→ Regarding the investment services KPI, we analysed the turnover
of the Group's companies in relation to the total, noting that it
accounts for less than 3% and is, therefore immaterial.
Accordingly, as in the previous year, it has been decided not to
disclose the related templates.
→ Consolidated KPI:
Last, per the European Commission's communiqué, we publish a
consolidated KPI of all businesses, calculated as the weighted
average of the applicable KPI of each business (credit institutions,
asset management, insurance and investment services) based on
turnover and CapEx, with weightings according to the proportion of
revenue stemming from the activities covered by the
corresponding KPI in their total turnover. 104
Our consolidated KPI is 3.10% (based on turnover) and 3.30%
(based on CapEx).
We considered net interest income and fees for the weighting of
the turnover-based KPI.
Please find the complete disclosure on the following pages,
including the templates set out in the Taxonomy Regulation.

| For more details on how our financial strategy, product design and relations with customers and counterparties comply with the EU Taxonomy, please see the sections 2. 'Supporting the green transition' and 10.9 'GFANZ transition planning' .

| For more details about GAR, please see the section 'SN 7.2 EU taxonomy tables '.

Annual report 2025 127

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 6. Classification system and funding framework
Sustainable finance and investment classification system (SFICS)

Sustainable finance is key to meeting our climate ambition. We
continue to build on our sustainable finance guidelines, which we
first published in February 2022, and that we continue updating
based on developments in regulation and market practice. Since
2024 it also includes socially responsible investment standards
and is now called the Sustainable finance and investment
classification system (SFICS).
The SFICS outlines common standards to consider an asset or
activity as environmental, social or sustainable in all the Group’s
units and businesses. It draws on such international market
guidelines, standards and principles as the EU Taxonomy (including
the four new environmental targets for 2023), ICMA (International
Capital Market Association) Principles, LMA (Loan Market
Association) Principles, UNEP FI Framework and the Climate Bonds
Standard.
The SFICS enables us to track our sustainable activity, support
product development and mitigate greenwashing risk.
In 2025, we have continued incorporating new criteria, focusing on
finance supporting the transition, as well as social finance criteria,
and in accordance with local law and regulation.
In 2025 we updated the SFICS based on lessons learned
and market trends. It now features:

| A sustainability approach for customers that complements the activity-based approach.
| Additional details on activities needed or supporting the transition to a low carbon economy, sustainable agriculture, food security and support to cooperatives.
| New activities that come to light on the back of developments in the EU Taxonomy and other local taxonomies, covering environmental goals related to water, waste, the circular economy and biodiversity.

We will continue working to evolve the SFICS in line with market
developments and business practice, to have a comprehensive set
of criteria that enables us to classify green and transition activities
that support our customers transition and contribute to our climate
ambition, as well as classifying activities as sustainable or social.

Internationally recognized sector principles and guidelines that the SFICS draws on
EU taxonomy | ICMA Green/ Social Bond Principles | LMA Green Loan Principles | LMA Sustainability Linked Loan Principles |  | ICMA Sustainability Linked Bond Principles | Local taxonomies (Colombia, Mexico, Chile, Brazil) | UNEP FI framework | Climate Bond Standards
Eligible products
Dedicated purpose |  | Sustainability-linked financing
→ Proceeds go towards eligible environmental and social activities and initiatives . → Eligibility criteria: Activities with a specific environmental and social purpose under accepted standards that follow internationally recognized sector guidelines and principles (ICMA, LMA, Climate Bonds Standard) and the EU taxonomy. |  | → Sustainability-linked transactions designed to help our customers achieve their ESG objectives. → Transaction structured to achieve pre-determined sustainability performance targets (ESG ratings and metrics). → Alignment with sector standards (ICMA and LMA).

Annual report 2025 128

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Green, social and sustainability funding global framework

Up dated in 2023, this framework is the reference for all
environmental, social and sustainability-labelled funding
instruments traded in sustainable capital markets and enables all
Grupo Santander entities to issue based on it. It replaces our
previous Global sustainable bond and Green bond frameworks.
Consistent with best market practice and investor expectations, it
covers use of proceeds, project assessment and selection,
management of proceeds and reporting in line with the
International Capital Market Association’s (ICMA) and Loan Market
Association’s (LMA) guidelines. It is also consistent with the SFICS.
There are 15 labelled bonds available which have been issued
under this framework, with 6 of them issued in 2025.

Available green, social and sustainable bonds issued based on this framework*
Label | Issuance Date | Issuer | Product | Nominal | Maturity
Green | Oct-19 | Banco Santander S.A. | Senior Preferred | EUR 1 bn | 7 yrs
Green | Jun-20 | Banco Santander S.A. | Senior Non Preferred | EUR 1 bn | 7 yrs
Green | Jan-21 | Santander Consumer Bank AS | Senior Preferred | SEK 500 mn | 5 yrs
Green | Jun-21 | Banco Santander S.A. | Senior Non Preferred | EUR 1 bn | 8NC7
Green | Nov-21 | Santander Consumer Bank AS | Senior Preferred | NOK 250 mn | 5 yrs
Social | Jun-24 | Banco Santander (Brasil) S.A. | Senior Unsecured | USD 250 mn | 3 yrs
Green | Sep-24 | Santander Consumer Bank AS | Senior Preferred | SEK 500 mn | 3 yrs
Green | Oct-24 | Santander Consumer Bank AS | Senior Preferred | SEK 300 mn | 3 yrs
Green | Nov-24 | Santander Consumer Bank AS | Senior Preferred | NOK 300 mn | 3 yrs
Green | Jun-25 | Banco Santander Chile | Senior Unsecured | USD 10 mn | 5 yrs
Green | Jul-25 | Banco Santander Chile | Senior Unsecured | JPY 10 bn | 3 yrs
Green | Aug-25 | Santander Consumer Bank AS | Senior Preferred | NOK 500 mn | 3 yrs
Sustainability | Oct-25 | Banco Santander de Negocios Colombia S.A. | Senior Unsecured | COP 150,000 mn | 2 yrs
Sustainability | Oct-25 | Banco Santander de Negocios Colombia S.A. | Senior Unsecured | COP 200,000 mn | 4 yrs
Green | Dec-25 | Banco Santander Chile | Senior Unsecured | USD 10 mn | 5 yrs

*Information disclosed in our quarterly fixed income reports
Annual report 2025 129

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 7 . Our progress in figures
SN 7.1 Green transition 130
Table 1. Green finance 130
Table 2. Environmental footprint 130
Table 3. Gross scopes 1, 2, 3 and total GHG emissions 131
Table 4. GHG mitigation projects financed through
carbon credits 134
Table 5 Equator principles 134
SN 7.2 EU taxonomy tables 135
SN 7.3 Employees 217
Table 6. Employees by region 217
Table 7. Employees by gender 217
Table 8. Employees by management group and gender 218
Table 9. Employees by age bracket 218
Table 10. Employees by employment contract 219
Table 11. Collective bargaining coverage
and social dialogue 219
Table 12. Turnover by region 219
Table 13. Average remuneration by management group,
gender and age bracket 220
Table 14. Remuneration ratios 220
Table 15. Average remuneration of senior management 220
Table 16. Average remuneration of senior
management linked to long-term objectives 220
Table 17. Senior management composition 220
Table 18. Training 221
Table 19. Hours of training by gender and management
group 221
Table 20. Occupational health and safety 221
SN 7.4 Customers 222
Table 21. Group customers 222
Table 22. Dialogue by channel 222
Table 23. NPS ranking by country 223
Table 24. Total complaints 223
SN 7.5 Financial inclusion 223
Table 25. People financially included 223
Table 26. Microfinance 224
SN 7.6 Community support 224
Table 27. Community support 224
Table 28. People and organizations helped 224
SN 7.7 Tax contribution 225
Table 29. Total taxes paid 225
Annual report 2025 130

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 7.1 Green transition

1. Green finance A
EUR bn | 2025 | 2024 | 2023 | 2022 | 2021
Raised and facilitated | 34.6 | 24.1 | 20.9 | 28.8 | 31.9
Accumulated since 2019 | 174.0 | 139.4 | 115.3 | 94.5 | 65.7

A. From January to December 2025, CIB contributed EUR 34.6 billion to the green finance target. Information obtained from public sources, such as Infralogic, Dealogic, TXF or
Bloomberg league tables. All roles undertaken by Banco Santander in the same project are accounted for. Other sustainable finance components, such as financial inclusion
and entrepreneurship, are excluded. Green Finance raised and facilitated is not a synonym of EU Taxonomy. Information from League Tables extracted by 12 January 2026, at
the latest.

2. Environmental footprint
| 2025 | 2024 | Var. 2025-2024 (%)
Consumption |  |  |
Total internal energy consumption (MWh) | 914,344 | 1,012,554 | -9.7
Total fossil energy consumption (MWh) | 140,993 | 179,258 | -21.3
Share of fossil sources in total energy consumption (%) | 15.4% | 17.7% | -12.9
Consumption from nuclear sources (MWh) | 1,466 | 6,457 | -77.3
Share of nuclear sources in total energy consumption (%) | 0.2% | 0.6% | -74.8
Total certified renewable energy consumption (MWh) | 760,720 | 793,136 | -4.1
Share of certified renewable sources in total energy consumption (%) | 83.2% | 78.3% | 6.2
Fuel consumption by renewable source, such as biomass (MWh) A | 5,358 | 0 | —
Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh) | 738,945 | 780,356 | -5.3
Consumption of self-generated non-fuel renewable energy (MWh) | 16,417 | 12,780 | 28.5
Total not certified renewable energy consumption (MWh) | 11,165 | 33,703 | -66.9
Share of not certified renewable sources in total energy consumption (%) | 1.2% | 3.3% | -63.3
Total electricity (millions of kwh) | 774.54 | 856.65 | -9.6
Electricity from non-renewable sources (millions of kwh) | 19.17 | 63.52 | -69.8
Electricity from renewable sources (millions of kwh) | 755.36 | 793.14 | -4.8
Percentage of contractual instruments (contracts for renewable electricity guaranteed by utility) used for the procurement of renewable electricity. | 53% | 53% | 0.3
Percentage of contractual instruments (PPAs_Power Purchase Agreements) used for the purchase of renewable electricity | 9% | 9% | 0.5
Percentage of contractual instruments (IRECs (International Renewable Electricity Certificates or DoO) used for the procurement of renewable electricity | 38% | 38% | -0.5
Water (m 3)B | 1,952,392 | 1,961,149 | -0.4
Paper (t) | 6,106 | 6,023 | 1.4
Recycled or certified paper (t) | 5,144 | 5,000 | 2.9

A. The total amount of renewable fuel reported is based on the purchase of biogas certificates in the United Kingdom, equivalent to Guarantees of Origin associated with the
gas consumed in our facilities.
B. Santander consumes water basically from public water supply networks.
Annual report 2025 131

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3. Gross scopes 1, 2, 3 and total GHG emissions (excluding financed emissions)
| Retrospective | Milestones and target years G
| Base year (2020) G | Comparative (2024) | N (2025) | % N / N-1 | 2025 | 2030 | 2050 | Annual Target % / Base Year
Scope 1 GHG emissions A,B |  |  |  |  |  |  |  |
Gross scope 1 GHG emissions (tCO 2 e) | 41,158 | 40,699 | 40,173 | (1.3%) | - | 38,499 | - | 0.6%
Scope 2 GHG emissions A,C |  |  |  |  |  |  |  |
Gross location-based Scope 2 GHG emissions (tCO 2 e) | 297,621 | 194,276 | 165,781 | (14.7%) | - | 172,276 | - | 4.2%
Gross market-based Scope 2 GHG emissions (tCO 2 e) | 144,038 | 24,350 | 11,524 | (52.7%) | - | 12,350 | - | 9.1%
Significant scope 3 GHG emissions D |  |  |  |  |  |  |  |
Total Gross indirect (Scope 3) GHG emissions (tCO 2 e) | - | 1,116,061 | 1,408,798 | 26.2% | - | - | - | -
1 Purchased goods and services E | - | 698,768 | 1,133,547 | 62.2% | - | - | - | -
2 Capital goods E | - | 216,388 | 72,145 | (66.7)% | - | - | - | -
4 Upstream transportation and distribution E | - | 52,835 | 61,135 | 15.7% | - | - | - | -
6 Business travel A,F | - | 52,150 | 41,216 | (21.0)% | - | - | - | -
7 Employee commuting A,F | - | 82,569 | 82,347 | (0.3)% | - | - | - | -
9 Downstream transportation E | - | 13,350 | 18,408 | 37.9% | - | - | - | -
Total GHG emissions (excluding financed emissions) A,H |  |  |  |  |  |  |  |
Total GHG emissions (location-based) (tCO 2 e) | - | 1,351,008 | 1,614,753 | 19.5% | - | - | - | -
Total GHG emissions (market-based) (tCO 2 e) | - | 1,181,082 | 1,460,495 | 23.7% | - | - | - | -

A. The entities listed under ESRS Requirement E1, paragraph 50.b) (investees with operational control), are not material to Santander.
B. These emissions include those derived from direct energy consumption: Natural gas, diesel as well as the fuel consumption of the fleets where it is applicable and fugitive
emissions of refrigerant gases according to the GHG Protocol standard. For the calculation of these emissions, emission factors from DEFRA (Department for Environment,
Food and Rural Affairs) 2025 for the financial year 2025 and DEFRA 2024 for the financial year 2024 have been applied. Santander does not directly use biomass as fuel and
therefore does not produce direct biogenic emissions. Santander does not manage emissions subject to regulated Emission Trading Schemes, including the EU-ETS, national
ETS and non-EU ETS. The direct emissions in tCO 2 e disaggregated by country are: Argentina 1,533 , Brazil 5,859, Chile 536 , Germany 2,138 , Mexico 7,008 , Poland 6,688 ,
Portugal 542, Spain 5,739, UK 2,354, USA 5,949, Others 1,826.
An interpretation error was identified in Brazil regarding the methodology and calculation criteria for Scope 1 emissions in the 2024 exercise. After applying the corporate
methodology consistently, Scope 1 emissions for 2024 increase from 35,503 tCO₂e to 40,699 tCO₂e, equivalent to a 14.6% rise in this scope, which is also reflected in the
Group’s total emissions, as well as in an equivalent adjustment to our 2030 target.
C. These emissions include those derived from electricity consumption and the use of district heating and correspond to Scope 2 defined by the GHG Protocol standard. In 2025
they have been calculated with emission factors of the 2025 edition of the IEA, for 2024 the emission factors of the 2024 edition were used. For the calculation of district
heating in Poland and Norway, local public emission factors for 2025 different from DEFRA were used. Data on biogenic emissions is not included as information on these
emissions is not available in the IEA emission factor database.
◦ Indirect emissions Electricity – market-based: For the calculation of these emissions, only renewable electricity is considered as renewable electricity that can be certified
by any type of contract or product recognized as such, but not the share of the country energy mix obtained from IEA data (i.e. where non-renewable electricity is
purchased expressly).
◦ Indirect Emissions Electricity – location-based: The IEA emission factor for each country has been applied for all electricity purchased, regardless of its source of origin
(renewable or non-renewable).
The indirect emissions in tCO 2 e disaggregated by country are:
◦ Market-based: Argentina 0, Brazil 0, Chile 0 , Germany 798, Mexico 0, Poland 6,843, Portugal 0, Spain 0, UK 0, USA 0, Others 3,883.
◦ Location-based: Argentina 10,336 , Brazil 13,458, Chile 4,529 , Germany 5,112, Mexico 57,194, Poland 20,865, Portugal 1,817, Spain 21,194 , UK 13,006, USA 14,035,
Others 4,238.
D. The assessment we conducted to determine the materiality of indirect GHG emissions (scope 3) found that the only material category under this scope was category 3.15
(financed emissions), with a weighting of 99% of the total.. The other categories are identified as not relevant, given its low representativeness. In addition, the categories
disclosed in this table are defined as relevant, and the following categories are identified as not relevant, given their low representativeness: 3.3 - Fuel and energy-related
activities (not included in Scope 1 or 2); 3.5 - waste generated in operations; 3.8 - upstream leased assets; 3.10 - processing of sold products; 3.11 - use of sold products;
3.12 - end-of-life treatment of sold products; 3.14 - franchises.
Biogenic emissions are not included as information on these emissions is not available in the databases we use to calculate any of the categories.
E. Supply chain emissions are calculated using a spend-based approach considering the payments to our suppliers in the current year. For that non primary data obtained from
suppliers has been used. These are calculated using the Supply Chain Greenhouse Gas Emission Factors v1.3 from the U.S. Environmental Protection Agency. Our supplier
taxonomies are mapped to the sectors considered in the database and then converted into emissions through spend-based emissions factors. Then, different spending
taxonomies are grouped based on the GHG scope 3 categories based on their nature (purchased goods and services, capital goods, upstream and downstream
transportation)
F. For the calculation of these emission factors DEFRA 2025 for fiscal year 2025 and DEFRA 2024 for fiscal year 2024 have been applied. For Brazil’s specific fuels, emissions
factors from the Brazilian GHG Protocol Program have been applied.
G. Our reduction objectives have been externally assured only in the verification process of the present report.
H. To comply with the regulatory requirements we have extended the financed emissions calculations, in most cases based on factors and other proxies. More details, see table
below 3.2. The total absolute financed emissions (scope 3, categories 15 and 13) of this broad scope, including scope 1, 2 and 3 are 222.4 mtCO2e. And the total GHG
emissions market-based are 223.9 mtCO 2 e (285.0 mtCO 2 e in 2024), and 224.0 mtCO 2 e location-based (283.8 mtCO 2 e in 2024). With this figure, the ratio of 'GHG total
emissions / Total income' both market and location-based is: 3.8 mtCO 2 e/EUR bn (Total income figure as disclosed in the Consolidated Income Statements), (4.6 mtCO 2 e/EUR
bn in 2024).
To address the Royal Decree 214/2025, the Scope 1 and Scope 2 (market-based) emission data for Spain calculated using the emission factors published by MITECO are 5947
and 0 respectively.
Annual report 2025 132

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3.1. Financed emissions of non-financial corporations, as disclosed in Pillar 3 (2025)
Sector | Gross carrying amount (€bn) | GHG financed emissions (scope 1 and scope 2 of the counterparty) (mtCO 2 e) | GHG financed emissions (scope 3 of the counterparty) (mtCO 2 e) | GHG emissions: gross carrying amount percentage of the portfolio derived from company-specific reporting
Exposures towards sectors that highly contribute to climate change A | 238.5 | 39.7 | 129.6 | 11.3%
A - Agriculture, forestry and fishing | 7.5 | 6.7 | 3.3 | 0.7%
B - Mining and quarrying | 10.8 | 4.9 | 29.8 | 17.1%
C - Manufacturing | 46.0 | 10.6 | 47.1 | 13.2%
D - Electricity, gas, steam and air conditioning supply | 14.4 | 6.8 | 5.0 | 26.2%
E - Water supply; sewerage, waste management and remediation activities | 1.5 | 0.8 | 0.4 | 5.9%
F - Construction | 18.6 | 0.7 | 6.6 | 3.6%
G - Wholesale and retail trade; repair of motor vehicles and motorcycles | 71.7 | 5.1 | 32.8 | 17.1%
H - Transportation and storage | 16.1 | 2.5 | 2.9 | 7.9%
I - Accommodation and food service activities | 10.6 | 0.5 | 1.4 | 1.0%
L - Real estate activities | 41.3 | 1.0 | 0.3 | 1.6%
Exposures towards sectors other than those that highly contribute to climate change A | 91.5 |  |  |
K - Financial and insurance activities |  |  |  |
Exposures to other sectors (NACE codes J, M - U) | 91.5 |  |  |
TOTAL | 330.0 | 39.7 | 129.6 |

A. In accordance with the Commission delegated regulation EU) 2020/1818 supplementing regulation (EU) 2016/1011 as regards minimum standards for EU Climate
Transition Benchmarks and EU Paris-aligned Benchmarks -Climate Benchmark Standards Regulation - Recital 6: Sectors listed in Sections A to H and Section L of Annex I to
Regulation (EC) No 1893/2006.

3.1. Financed emissions of non-financial corporations, as disclosed in Pillar 3 (2024)
Sector | Gross carrying amount (€bn) | GHG financed emissions (scope 1 and scope 2 of the counterparty) (mtCO 2 e) | GHG financed emissions (scope 3 of the counterparty) (mtCO 2 e) | GHG emissions: gross carrying amount percentage of the portfolio derived from company-specific reporting
Exposures towards sectors that highly contribute to climate change A | 259.3 | 58.6 | 159.3 | 10.1%
A - Agriculture, forestry and fishing | 8.5 | 8.1 | 3.8 | 0.5%
B - Mining and quarrying | 11 | 11.8 | 41.5 | 28.2%
C - Manufacturing | 53.7 | 13.7 | 63.2 | 14.3%
D - Electricity, gas, steam and air conditioning supply | 13.9 | 10.7 | 7.2 | 23.6%
E - Water supply; sewerage, waste management and remediation activities | 1.7 | 1.1 | 0.5 | 3.8%
F - Construction | 18.7 | 0.9 | 4.8 | 2.7%
G - Wholesale and retail trade; repair of motor vehicles and motorcycles | 77.7 | 6.1 | 31 | 12.1%
H - Transportation and storage | 17.3 | 4.4 | 5.6 | 9.4%
I - Accommodation and food service activities | 11.3 | 0.5 | 1.4 | 1.3%
L - Real estate activities | 45.6 | 1.3 | 0.3 | 1.0%
Exposures towards sectors other than those that highly contribute to climate change A | 79.2 |  |  |
K - Financial and insurance activities | 0 |  |  |
Exposures to other sectors (NACE codes J, M - U) | 79.2 |  |  |
TOTAL | 338.5 | 58.6 | 159.3 |

A. In accordance with the Commission delegated regulation EU) 2020/1818 supplementing regulation (EU) 2016/1011 as regards minimum standards for EU Climate
Transition Benchmarks and EU Paris-aligned Benchmarks -Climate Benchmark Standards Regulation - Recital 6: Sectors listed in Sections A to H and Section L of Annex I to
Regulation (EC) No 1893/2006.
Annual report 2025 133

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3.2. Financed emissions estimated from balance sheet A (2025)
Asset | Gross carrying amount assessed (EUR bn) | GHG financed emissions (scope 1 and scope 2) (mtCO 2 e) | GHG Scope 1 and 2 (mtCO 2 e)/ exposure (EUR bn) | GHG financed emissions (scope 3) (mtCO 2 e) | GHG Scope 3 (mtCO 2 e)/ exposure (EUR bn) | PCAF Score G
Non-financial corporations (Pillar 3) B | 238.5 | 39.7 | 0.17 | 129.6 | 0.54 | 4.7
Mortgages c | 324.6 | 3.0 | 0.01 | 0 | 0.00 | 3.6
Motor vehicle loans D | 151.1 | 16.2 | 0.11 | 0 | 0.00 | 3.9
Sovereign debt E | 152.0 | 34.0 | 0.22 | 0 | 0.00 | 4.0
TOTAL F | 866.2 | 92.8 | 0.11 | 129.6 | 0.15 |

A. This includes scope 3 - category 13 and 15 emissions for regulatory purposes. Santander Polska exposures are excluded as they are classified as assets held for sale.
B. These are the financed emissions reported under the EBA Pillar 3 exercise, which should not be confused with the portfolio alignment financed emissions, as the scope and
supporting data of the two exercises is different.
C. Mortgage financed emissions. Calculated as of 2024, for the UK and Spain, and Portugal. Also extending calculation to rest of group's mortgage portfolio (2025 data).
D Motor vehicle loans financed emissions from loans and leases. That includes the current auto-lending alignment target scope, calculated as of 2024, and other auto
exposures within EU consumer finance business and auto-lending in America, calculated with 2025 financial data.
E. Sovereign debt at fair value or amortized cost. Financed emissions calculated covers scope 1 including 'Land Use, Land-Use Change and Forestry', following the
recommendations by PCAF methodology and using the United Nations Framework Convention on Climate Change official reported emissions factors from the PCAF
database.
F. Other less emissive assets exposure were calculated last year but deemed not material, in financed emissions terms, and no longer included in the calculations. These
emissions represents less than 1% of the total financed emissions.
G. As explained below, we had to extrapolate the emissions calculations for some of the exposure assessed for 'Financed emissions estimated from balance sheet'. The PCAF
score is an approximation assuming the extrapolations account for PCAF score 5 (worse quality), and the rest is calculated following the PCAF standard recommendations.

3.2. Financed emissions estimated from balance sheet A (2024)
Asset | Gross carrying amount assessed (EUR bn) | GHG financed emissions (scope 1 and scope 2) (mtCO 2 e) | GHG Scope 1 and 2 (mtCO 2 e)/ exposure (EUR bn) | GHG financed emissions (scope 3) (mtCO 2 e) | GHG Scope 3 (mtCO 2 e)/ exposure (EUR bn) | PCAF Score G
Non-financial corporations (Pillar 3) B | 338.5 | 58.6 | 0.18 | 159.3 | 0.66 | 4.8
Mortgages c | 350.5 | 3.6 | 0.01 | 0.0 | 0.01 | 3.8
Motor vehicle loans D | 170.2 | 27.0 | 0.16 | 0.0 | 0.16 | 4.2
Sovereign debt E | 155.2 | 33.9 | 0.22 | 0.0 | 0.22 | 2.2
TOTAL F | 1014.4 | 123.1 | 0.12 | 159.3 | 0.16 |

A. This includes scope 3 - category 13 and 15 emissions for regulatory purposes.
B. These are the financed emissions reported under the EBA Pillar 3 exercise, which should not be confused with the portfolio alignment financed emissions, as the scope and
supporting data of the two exercises is different.
C. Mortgage financed emissions. Calculated as of 2023, for the UK and Spain, and as of 2024 for Poland. Also extending calculation to rest of group's mortgage portfolio (2024
data).
D Motor vehicle loans financed emissions from loans and leases. That includes the current auto-lending alignment target scope, calculated as of 2023, and other auto
exposures within EU consumer finance business and auto-lending in America, calculated with 2024 financial data.
E. Sovereign debt at fair value or amortized cost. Financed emissions calculated covers scope 1 including 'Land Use, Land-Use Change and Forestry', following the
recommendations by PCAF methodology and using the United Nations Framework Convention on Climate Change official reported emissions factors from the PCAF
database.
F. Other less emissive assets exposure were calculated last year but deemed not material, in financed emissions terms, and no longer included in the calculations. These
emissions represents less than 1% of the total financed emissions.
G. As explained below, we had to extrapolate the emissions calculations for near 20% of the exposure assessed for 'Financed emissions estimated from balance sheet'. The
PCAF score is an approximation assuming the extrapolations account for PCAF score 5 (worse quality), and the rest is calculated following the PCAF standard
recommendations.
Santander discloses the financed emissions from our balance sheet in this annual report, extending the scope from the emissions calculated
with PCAF methodology to a broader scope to cover almost all balance sheet exposures subject to financed emissions calculations, with the
only purpose of complying with the disclosure regulation. In the 'SN. 4 Our transition plan' we disclose the financed emissions of portfolio
alignment with reasonable quality of data, with the aim of managing our portfolios with alignment purposes. In this section, we prioritize
the completeness of the sustainability information disclosed. This means that the calculations where primarily supported by emissions
factors, proxies or approximations, instead of actual reported emissions, to extend the calculation of financed emissions as reasonable as
possible. This calculation helps us reach the figures we disclose, although we will continue to work on improving the available data and
calculations in the future.
For all these reasons, we could expect some volatility in the financed emissions disclosed as better information becomes available over time
or as some of the proxies/factors provided by external parties are updated.
Annual report 2025 134

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

4. GHG mitigation projects financed through carbon credits |
Carbon credits cancelled and used for scopes 1+2 compensation | N (2025) | Comparative (2024)
Total (tCO 2 e)A | 51,700 | 59,858
Share from removal projects B (%) | 26% | 15%
Share from reduction projects (%) | 74% | 85%
Share of projects validated by Verra’s VCS | 12% | 13%
Share of projects validated by Climate Action Reserve | 26% | 15%
Share of projects validated by Gold Standard | 62% | 72%
Share from projects within the EU (%) | —% | —%
Share of carbon credits that qualify as corresponding adjustments (%) | —% | —%

A. Since emissions offsetting is done by country, the upward rounding of tCO 2 e means that the total amount of credits is slightly higher than the total sum of emissions.
B. In 2025, all GHG phase-out mitigation projects are nature-based (biogenic) solutions projects. Santander cancels all credits after purchase in the year. In 2025, 39500 new
credits were acquired and cancelled: 33.3% validated by Climate Action Reserve (removal projects) and 66.7% validated by Gold Standard (reduction projects). The existing
contractual agreements Santander has in different countries will enable us to obtain 81,073 carbon credits between from now to 2073 year. Cancellation of such credits will
be based on the mitigation approach at the time.
Banco Santander remains offsetting scope 1 and 2 emissions. As part of our voluntary carbon credit market monitoring, every year we
analyse and select a list of initiatives, usually in our core markets. We follow a strict carbon credit selection process that includes due
diligence and compliance of our policies. Projects are also certified under some of the industry's most well-known standards. Moreover, all
the carbon credits we purchased in 2025 were ratified by an independent rating agency to validate their integrity.

5. Equator Principles
Number of projects | Project Finance |  | Project Related Corporate Loans |  | Project-Related Refinance and Project-Related Acquisition for Project Finance
Category | A | B | C |  | A | B | C |  | A | B | C
TOTAL 2025 | 7 | 7 | 5 |  | 1 | 4 | 0 |  | 0 | 0 | 0
TOTAL 2024 | 3 | 9 | 3 |  | 2 | 3 | 1 |  | 0 | 0 | 0
Sector |  |  |  |  |  |  |  |  |  |  |
Mining | 0 | 0 | 0 |  | 0 | 0 | 0 |  | 0 | 0 | 0
Infrastructure | 0 | 0 | 0 |  | 0 | 1 | 0 |  | 0 | 0 | 0
Oil & gas | 2 | 0 | 0 |  | 0 | 0 | 0 |  | 0 | 0 | 0
Power | 5 | 6 | 5 |  | 0 | 1 | 0 |  | 0 | 0 | 0
Others | 0 | 1 | 0 |  | 1 | 2 | 0 |  | 0 | 0 | 0
Region |  |  |  |  |  |  |  |  |  |  |
Americas | 2 | 2 | 1 |  | 1 | 2 | 0 |  | 0 | 0 | 0
Europe, Middle East & Africa | 5 | 4 | 4 |  | 0 | 1 | 0 |  | 0 | 0 | 0
Asia pacific | 0 | 1 | 0 |  | 0 | 1 | 0 |  | 0 | 0 | 0
Type |  |  |  |  |  |  |  |  |  |  |
Designated countries A | 6 | 6 | 5 |  | 0 | 3 | 0 |  | 0 | 0 | 0
Non-designated countries | 1 | 1 | 0 |  | 1 | 1 | 0 |  | 0 | 0 | 0
Independent review |  |  |  |  |  |  |  |  |  |  |
Yes | 7 | 6 | 4 |  | 1 | 3 | 0 |  | 0 | 0 | 0
No | 0 | 1 | 1 |  | 0 | 1 | 0 |  | 0 | 0 | 0

A. In accordance with the definition of designated countries included in the Equator Principles, with solid environmental and social governance, legislation and institutions to
protect their inhabitants and the environment.
Category A – Projects with potential significant adverse environmental and social risks and/or impacts that are diverse, irreversible or unprecedented;
Category B – Projects with potential limited adverse environmental and social risks and/or impacts that are few in number, generally site-specific, largely reversible and readily
addressed through mitigation measures;
Category C – Projects with minimal or no adverse environmental and social risks and/or impacts.
105 Perimeter calculation for GAR, in accordance with the Commission Delegated Regulation (EU) 2021/2178, is based on the prudential consolidated group. In this context, the entities within the Santander Group are consolidated using the full consolidation
method, except for jointly controlled entities, which are proportionately consolidated. Companies that cannot be consolidated due to their activity are included using the equity method. The difference between the total assets of the public and prudential
perimeters is not significant. This difference is due to the exclusion of non-financial entities and the inclusion of multi-group and intergroup entities, in accordance with this consolidation criterion.
Annual report 2025 135

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 7.2 EU taxonomy tables 105
0. Summary of KPI to be disclosed by credit institutions under Article 8 Taxonomy Regulation - 2025

|  | Total environmentally sustainable assets (1) | KPI (3) | KPI (4) | % coverage (over total assets) (5) | % of assets excluded from the numerator of the GAR (Article 7.2 and 7.3 and Section 1.1.2. of Annex V) | % of assets excluded from the denominator of the GAR (Article 7.1 and Section 1.2.4 of Annex V)
Main KPI | Green asset ratio (GAR) stock | 43,150 | 3.17 | 3.35 | 70.9 | 37.3 | 29.1
|  | Total environmentally sustainable assets (2) | KPI | KPI | % coverage (over total assets) | % of assets excluded from the numerator of the GAR (Article 7.2 and 7.3 and Section 1.1.2. of Annex V) | % of assets excluded from the denominator of the GAR (Article 7.1 and Section 1.2.4 of Annex V)
Additional KPI | GAR (flow) | 11,682 | 3.29 | 3.85 | 67.8 | 41.5 | 32.2
| Trading book(6) |  |  |  |  |  |
| Financial guarantees | 296 | 1.70 | 3.40 |  |  |
| Assets under management | 3,533 | 1.90 | 2.70 |  |  |
| Fees and commissions income(6) |  |  |  |  |  |

(1) Total environmentally sustainable assets used for the Turnover KPI. The total environmentally sustainable assets used for the CapEx KPI amount to EUR 45,573 million.
(2) Total environmentally sustainable assets used for the Turnover KPI. The total environmentally sustainable assets used for the CapEx KPI amount to EUR 13,678 million for the GAR stock, EUR 611 million for financial guarantees and EUR 5,077 million for assets under management.
(3) Based on the counterparty’s Turnover KPI.
(4) Based on the counterparty’s CapEx KPI, except in the case of lending activities, where, for general purpose loans, the Turnover KPI is used.
(5) Percentage of assets covered by the KPI relative to banks’ total assets.
(6) The KPIs for fees and commissions and for the trading book will only become applicable as from 2026.

Annual report 2025 136

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

0. Summary of KPI to be disclosed by credit institutions under Article 8 Taxonomy Regulation - 2024

|  | Total environmentally sustainable assets (1) | KPI (3) | KPI (4) | % coverage (over total assets) (5) | % of assets excluded from the numerator of the GAR (Article 7.2 and 7.3 and Section 1.1.2. of Annex V) | % of assets excluded from the denominator of the GAR (Article 7.1 and Section 1.2.4 of Annex V)
Main KPI | Green asset ratio (GAR) stock | 39,656 | 3.0 | 3.3 | 69.8 | 34.0 | 30.2
|  | Total environmentally sustainable assets (2) | KPI | KPI | % coverage (over total assets) | % of assets excluded from the numerator of the GAR (Article 7.2 and 7.3 and Section 1.1.2. of Annex V) | % of assets excluded from the denominator of the GAR (Article 7.1 and Section 1.2.4 of Annex V)
Additional KPI | GAR (flow) | 7,862 | 2.63 | 3.35 | 65.9 | 40.7 | 34.1
| Trading book(6) |  |  |  |  |  |
| Financial guarantees | 249 | 1.47 | 3.46 |  |  |
| Assets under management | 2,047 | 1.3 | 2.14 |  |  |
| Fees and commissions income(6) |  |  |  |  |  |

(1) Total environmentally sustainable assets used for turnover KPI. Total environmentally sustainable assets used for Capex KPI amounts to EUR 42,834 million.
(2) Total environmentally sustainable assets used for turnover KPI. Total environmentally sustainable assets used for Capex KPI amounts to EUR 10,009 million for GAR flow, EUR 585 million for financial guarantees and EUR 3,360 million for assets under management .
(3) Based on the Turnover KPI of the counterparty.
(4) Based on the CapEx KPI of the counterparty.
(5) % of assets covered by the KPI over banks´ total assets.
(6) Fees and Commissions and Trading Book KPIs shall only apply starting 2026.

106 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 137

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

1. Assets for the calculation of GAR (Capex) - 2025 106

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 640,063 | 425,367 | 45,540 | 40,112 | 12,135 | 2,212 |  | 72 | 33 | 0 | 21 |  | 425,439 | 45,573 | 40,112 | 12,135 | 2,233
2 | Financial undertakings | 26,147 | 4,820 | 1,459 | 0 | 54 | 506 |  | 10 | 3 | 0 | 0 |  | 4,830 | 1,463 | 0 | 54 | 506
3 | Credit institutions | 17,570 | 2,581 | 283 | 0 | 22 | 29 |  | 5 | 1 | 0 | 0 |  | 2,587 | 284 | 0 | 22 | 29
4 | Loans and advances | 16,746 | 2,447 | 256 | 0 | 21 | 28 |  | 5 | 1 | 0 | 0 |  | 2,452 | 257 | 0 | 21 | 28
5 | Debt securities, including UoP (Use of Proceeds) | 824 | 134 | 26 | 0 | 1 | 1 |  | 0 | 0 | 0 | 0 |  | 134 | 26 | 0 | 1 | 1
6 | Equity instruments | 0 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
7 | Other financial corporations | 8,578 | 2,239 | 1,177 | 0 | 32 | 477 |  | 5 | 2 | 0 | 0 |  | 2,244 | 1,179 | 0 | 32 | 477
8 | of which investment firms | 1,842 | 611 | 313 | 0 | 0 | 112 |  | 2 | 1 | 0 | 0 |  | 613 | 313 | 0 | 0 | 112
9 | Loans and advances | 1,783 | 606 | 312 | 0 | 0 | 112 |  | 2 | 1 | 0 | 0 |  | 608 | 312 | 0 | 0 | 112
10 | Debt securities, including UoP | 59 | 5 | 1 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 5 | 1 | 0 | 0 | 0
11 | Equity instruments | 0 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
12 | of which management companies | 110 | 3 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 3 | 0 | 0 | 0 | 0
13 | Loans and advances | 108 | 3 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 3 | 0 | 0 | 0 | 0
14 | Debt securities, including UoP | 0 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
15 | Equity instruments | 2 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
16 | of which insurance undertakings | 2,496 | 190 | 16 | 0 | 1 | 2 |  | 0 | 0 | 0 | 0 |  | 190 | 16 | 0 | 1 | 2
17 | Loans and advances | 2,049 | 183 | 12 | 0 | 1 | 0 |  | 0 | 0 | 0 | 0 |  | 184 | 12 | 0 | 1 | 0
18 | Debt securities, including UoP | 328 | 6 | 5 | 0 | 0 | 1 |  | 0 | 0 | 0 | 0 |  | 6 | 5 | 0 | 0 | 1
19 | Equity instruments | 119 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
20 | Non-financial undertakings | 27,473 | 8,504 | 3,968 | 0 | 91 | 1,706 |  | 62 | 30 | 0 | 20 |  | 8,566 | 3,998 | 0 | 91 | 1,727
21 | Loans and advances | 25,611 | 7,865 | 3,517 | 0 | 89 | 1,646 |  | 49 | 18 | 0 | 9 |  | 7,914 | 3,534 | 0 | 89 | 1,655
22 | Debt securities, including UoP | 1,843 | 636 | 451 | 0 | 2 | 60 |  | 11 | 10 | 0 | 10 |  | 648 | 461 | 0 | 2 | 70
23 | Equity instruments | 19 | 3 | 1 |  | 0 | 1 |  | 1 | 1 |  | 1 |  | 4 | 2 |  | 0 | 2
24 | Households | 582,241 | 410,097 | 40,112 | 40,112 | 11,990 | 0 |  | 0 | 0 | 0 | 0 |  | 410,097 | 40,112 | 40,112 | 11,990 | 0
25 | of which loans collateralised by residential immovable property | 343,443 | 316,028 | 28,123 | 28,123 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 316,028 | 28,123 | 28,123 | 0 | 0

Annual report 2025 138

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
26 | of which building renovation loans | 1,286 | 1,286 | 3 | 3 | 3 | 0 |  | 0 | 0 | 0 | 0 |  | 1,286 | 3 | 3 | 3 | 0
27 | of which motor vehicle loans | 92,783 | 92,783 | 11,987 | 11,987 | 11,987 | 0 |  |  |  |  |  |  | 92,783 | 11,987 | 11,987 | 11,987 | 0

Annual report 2025 139

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 4,202 | 1,946 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 1,946 | 0 | 0 | 0 | 0
29 | Housing financing | 144 | 140 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 140 | 0 | 0 | 0 | 0
30 | Other local government financing | 4,058 | 1,806 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 1,806 | 0 | 0 | 0 | 0
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 4,505 | 49 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 49 | 0 | 0 | 0 | 0
32 | Assets excluded from the numerator for GAR calculation (covered in the denominator) | 714,794 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
33 | Financial and Non-financial undertakings | 450,321 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
34 | SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations | 120,681 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
35 | Loans and advances | 118,610 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
36 | of which loans collateralised by commercial immovable property | 15,237 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
37 | of which building renovation loans | 1,586 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
38 | Debt securities | 1,719 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
39 | Equity instruments | 352 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
40 | Non-EU country counterparties not subject to NFRD disclosure obligations | 329,640 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
41 | Loans and advances | 290,038 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
42 | Debt securities | 35,079 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
43 | Equity instruments | 4,523 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
44 | Derivatives | 4,030 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
45 | On demand interbank loans | 9,650 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
46 | Cash and cash-related assets | 7,344 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
47 | Other categories of assets (e.g. Goodwill, commodities etc.) | 243,449 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
48 | Total GAR assets | 1,359,362 | 425,416 | 45,540 | 40,112 | 12,135 | 2,212 |  | 72 | 33 | 0 | 21 |  | 425,488 | 45,573 | 40,112 | 12,135 | 2,233
49 | Assets not covered for GAR calculation | 558,430 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
50 | Central governments and Supranational issuers | 149,320 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
51 | Central banks exposure | 156,831 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |

107 The assets under management taken into account in this template covers the whole Group.
Annual report 2025 140

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
52 | Trading book | 252,279 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
53 | Total assets | 1,917,792 | 425,416 | 45,540 | 40,112 | 12,135 | 2,212 |  | 72 | 33 | 0 | 21 |  | 425,488 | 45,573 | 40,112 | 12,135 | 2,233
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 | Financial guarantees | 17,728 | 1,323 | 610 | 0 | 50 | 407 |  | 21 | 1 | 0 | 1 |  | 1,344 | 611 | 0 | 50 | 407
55 | Assets under management 107 | 184,693 | 18,080 | 4,946 | 0 | 260 | 2,123 |  | 154 | 131 | 0 | 4 |  | 18,234 | 5,077 | 0 | 260 | 2,127
56 | Of which debt securities | 73,146 | 12,031 | 2,703 | 0 | 131 | 1,363 |  | 120 | 108 | 0 | 3 |  | 12,150 | 2,811 | 0 | 131 | 1,366
57 | Of which equity instruments | 77,939 | 6,050 | 2,243 | 0 | 129 | 760 |  | 34 | 23 | 0 | 1 |  | 6,084 | 2,266 | 0 | 129 | 761

108 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 141

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

1. Assets for the calculation of GAR (Turnover) - 2025 108

Million EUR | 2025
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 640,063 | 423,342 | 43,105 | 40,112 | 12,095 | 1,460 |  | 377 | 44 | 0 | 43 |  | 423,720 | 43,150 | 40,112 | 12,095 | 1,502
2 | Financial undertakings | 26,147 | 4,529 | 944 | 0 | 32 | 367 |  | 330 | 35 | 0 | 33 |  | 4,859 | 979 | 0 | 32 | 400
3 | Credit institutions | 17,570 | 2,964 | 498 | 0 | 20 | 129 |  | 49 | 30 | 0 | 29 |  | 3,014 | 528 | 0 | 20 | 158
4 | Loans and advances | 16,746 | 2,835 | 450 | 0 | 19 | 129 |  | 49 | 30 | 0 | 29 |  | 2,885 | 480 | 0 | 19 | 157
5 | Debt securities, including UoP | 824 | 129 | 47 | 0 | 1 | 1 |  | 0 | 0 | 0 | 0 |  | 129 | 47 | 0 | 1 | 1
6 | Equity instruments | 0 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
7 | Other financial corporations | 8,578 | 1,565 | 447 | 0 | 12 | 237 |  | 281 | 5 | 0 | 5 |  | 1,846 | 452 | 0 | 12 | 242
8 | of which investment firms | 1,842 | 157 | 70 | 0 | 0 | 47 |  | 1 | 0 | 0 | 0 |  | 157 | 70 | 0 | 0 | 47
9 | Loans and advances | 1,783 | 140 | 69 | 0 | 0 | 47 |  | 1 | 0 | 0 | 0 |  | 140 | 69 | 0 | 0 | 47
10 | Debt securities, including UoP | 59 | 17 | 1 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 17 | 1 | 0 | 0 | 0
11 | Equity instruments | 0 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
12 | of which management companies | 110 | 54 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 54 | 0 | 0 | 0 | 0
13 | Loans and advances | 108 | 54 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 54 | 0 | 0 | 0 | 0
14 | Debt securities, including UoP | 0 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
15 | Equity instruments | 2 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
16 | of which insurance undertakings | 2,496 | 185 | 11 | 0 | 1 | 2 |  | 279 | 4 | 0 | 4 |  | 464 | 15 | 0 | 1 | 6
17 | Loans and advances | 2,049 | 180 | 9 | 0 | 1 | 0 |  | 40 | 1 | 0 | 1 |  | 220 | 10 | 0 | 1 | 1
18 | Debt securities, including UoP | 328 | 4 | 2 | 0 | 0 | 1 |  | 239 | 3 | 0 | 3 |  | 244 | 6 | 0 | 0 | 5
19 | Equity instruments | 119 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
20 | Non-financial undertakings | 27,473 | 6,771 | 2,049 | 0 | 74 | 1,093 |  | 47 | 9 | 0 | 9 |  | 6,818 | 2,058 | 0 | 74 | 1,102
21 | Loans and advances | 25,611 | 6,444 | 1,812 | 0 | 74 | 1,055 |  | 39 | 6 | 0 | 6 |  | 6,484 | 1,818 | 0 | 74 | 1,061
22 | Debt securities, including UoP | 1,843 | 326 | 236 | 0 | 0 | 38 |  | 4 | 0 | 0 | 0 |  | 330 | 236 | 0 | 0 | 38
23 | Equity instruments | 19 | 1 | 0 |  | 0 | 0 |  | 3 | 3 |  | 3 |  | 4 | 4 |  | 0 | 4
24 | Households | 582,241 | 410,097 | 40,112 | 40,112 | 11,990 | 0 |  | 0 | 0 | 0 | 0 |  | 410,097 | 40,112 | 40,112 | 11,990 | 0
25 | of which loans collateralised by residential immovable property | 343,443 | 316,028 | 28,123 | 28,123 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 316,028 | 28,123 | 28,123 | 0 | 0
26 | of which building renovation loans | 1,286 | 1,286 | 3 | 3 | 3 | 0 |  | 0 | 0 | 0 | 0 |  | 1,286 | 3 | 3 | 3 | 0

Annual report 2025 142

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Million EUR | 2025
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
27 | of which motor vehicle loans | 92,783 | 92,783 | 11,987 | 11,987 | 11,987 | 0 |  |  |  |  |  |  | 92,783 | 11,987 | 11,987 | 11,987 | 0
28 | Local governments financing | 4,202 | 1,946 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 1,946 | 0 | 0 | 0 | 0
29 | Housing financing | 144 | 140 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 140 | 0 | 0 | 0 | 0
30 | Other local government financing | 4,058 | 1,806 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 1,806 | 0 | 0 | 0 | 0
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 4,505 | 49 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 49 | 0 | 0 | 0 | 0
32 | Assets excluded from the numerator for GAR calculation (covered in the denominator) | 714,794 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
33 | Financial and Non-financial undertakings | 450,321 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
34 | SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations | 120,681 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
35 | Loans and advances | 118,610 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
36 | of which loans collateralised by commercial immovable property | 15,237 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
37 | of which building renovation loans | 1,586 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
38 | Debt securities | 1,719 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
39 | Equity instruments | 352 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
40 | Non-EU country counterparties not subject to NFRD disclosure obligations | 329,640 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
41 | Loans and advances | 290,038 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
42 | Debt securities | 35,079 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
43 | Equity instruments | 4,523 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
44 | Derivatives | 4,030 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
45 | On demand interbank loans | 9,650 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
46 | Cash and cash-related assets | 7,344 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
47 | Other categories of assets (e.g. Goodwill, commodities etc.) | 243,449 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
48 | Total GAR assets | 1,359,362 | 423,391 | 43,105 | 40,112 | 12,095 | 1,460 |  | 377 | 44 | 0 | 43 |  | 423,768 | 43,150 | 40,112 | 12,095 | 1,502
49 | Assets not covered for GAR calculation | 558,430 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
50 | Central governments and Supranational issuers | 149,320 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |

109 The assets under management taken into account in this template covers the whole Group.
Annual report 2025 143

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Million EUR | 2025
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
51 | Central banks exposure | 156,831 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
52 | Trading book | 252,279 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
53 | Total assets | 1,917,792 | 423,391 | 43,105 | 40,112 | 12,095 | 1,460 |  | 377 | 44 | 0 | 43 |  | 423,768 | 43,150 | 40,112 | 12,095 | 1,502
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 | Financial guarantees | 17,728 | 968 | 292 | 0 | 19 | 212 |  | 31 | 5 | 0 | 5 |  | 999 | 296 | 0 | 19 | 217
55 | Assets under management 109 | 184,693 | 17,619 | 3,495 | 0 | 122 | 1,547 |  | 818 | 38 | 0 | 37 |  | 18,437 | 3,533 | 0 | 122 | 1,583
56 | Of which debt securities | 73,146 | 10,923 | 1,647 | 0 | 49 | 809 |  | 321 | 20 | 0 | 20 |  | 11,243 | 1,667 | 0 | 49 | 828
57 | Of which equity instruments | 77,939 | 6,696 | 1,848 | 0 | 73 | 738 |  | 497 | 18 | 0 | 17 |  | 7,194 | 1,866 | 0 | 73 | 755

Annual report 2025 144

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

1. Assets for the calculation of GAR (Capex) - 2024

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 664,610 | 447,158 | 42,818 | 36,969 | 9,508 | 2,202 |  | 101 | 17 | 0 | 3 |  | 447,259 | 42,834 | 36,969 | 9,508 | 2,206
2 | Financial undertakings | 25,544 | 5,704 | 1,600 | 0 | 28 | 432 |  | 27 | 2 | 0 | 0 |  | 5,732 | 1,602 | 0 | 28 | 432
3 | Credit institutions | 18,208 | 3,332 | 312 | 0 | 1 | 12 |  | 24 | 2 | 0 | 0 |  | 3,356 | 314 | 0 | 1 | 12
4 | Loans and advances | 16,848 | 3,097 | 293 | 0 | 1 | 12 |  | 11 | 2 | 0 | 0 |  | 3,108 | 295 | 0 | 1 | 12
5 | Debt securities, including UoP (Use of Proceeds) | 1,360 | 235 | 19 | 0 | 0 | 0 |  | 13 | 0 | 0 | 0 |  | 248 | 19 | 0 | 0 | 0
6 | Equity instruments | 0 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
7 | Other financial corporations | 7,336 | 2,372 | 1,288 | 0 | 28 | 420 |  | 4 | 0 | 0 | 0 |  | 2,376 | 1,289 | 0 | 28 | 420
8 | of which investment firms | 2,300 | 975 | 878 | 0 | 0 | 233 |  | 0 | 0 | 0 | 0 |  | 975 | 878 | 0 | 0 | 233
9 | Loans and advances | 1,778 | 528 | 439 | 0 | 0 | 136 |  | 0 | 0 | 0 | 0 |  | 528 | 439 | 0 | 0 | 136
10 | Debt securities, including UoP | 523 | 447 | 439 | 0 | 0 | 98 |  | 0 | 0 | 0 | 0 |  | 447 | 439 | 0 | 0 | 98
11 | Equity instruments | 0 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
12 | of which management companies | 258 | 101 | 8 | 0 | 0 | 5 |  | 0 | 0 | 0 | 0 |  | 102 | 8 | 0 | 0 | 5
13 | Loans and advances | 176 | 61 | 3 | 0 | 0 | 3 |  | 0 | 0 | 0 | 0 |  | 61 | 3 | 0 | 0 | 3
14 | Debt securities, including UoP | 80 | 41 | 5 | 0 | 0 | 2 |  | 0 | 0 | 0 | 0 |  | 41 | 5 | 0 | 0 | 2
15 | Equity instruments | 2 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
16 | of which insurance undertakings | 2,050 | 246 | 9 | 0 | 0 | 0 |  | 2 | 0 | 0 | 0 |  | 247 | 9 | 0 | 0 | 0
17 | Loans and advances | 1,931 | 246 | 9 | 0 | 0 | 0 |  | 2 | 0 | 0 | 0 |  | 247 | 9 | 0 | 0 | 0
18 | Debt securities, including UoP | 0 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
19 | Equity instruments | 119 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
20 | Non-financial undertakings | 28,232 | 11,539 | 4,248 | 0 | 648 | 1,771 |  | 73 | 15 | 0 | 3 |  | 11,612 | 4,263 | 0 | 648 | 1,774
21 | Loans and advances | 26,333 | 10,918 | 3,827 | 0 | 646 | 1,508 |  | 65 | 6 | 0 | 3 |  | 10,983 | 3,833 | 0 | 646 | 1,511
22 | Debt securities, including UoP | 1,891 | 620 | 420 | 0 | 1 | 262 |  | 8 | 8 | 0 | 1 |  | 628 | 428 | 0 | 1 | 263
23 | Equity instruments | 8 | 1 | 1 |  | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 1 | 1 |  | 0 | 0
24 | Households | 609,668 | 428,942 | 36,969 | 36,969 | 8,832 | 0 |  | 0 | 0 | 0 | 0 |  | 428,942 | 36,969 | 36,969 | 8,832 | 0
25 | of which loans collateralised by residential immovable property | 362,813 | 331,277 | 28,137 | 28,137 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 331,277 | 28,137 | 28,137 | 0 | 0
26 | of which building renovation loans | 1,189 | 1,189 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 1,189 | 0 | 0 | 0 | 0
27 | of which motor vehicle loans | 96,477 | 96,477 | 8,832 | 8,832 | 8,832 | 0 |  |  |  |  |  |  | 96,477 | 8,832 | 8,832 | 8,832 | 0

Annual report 2025 145

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 1,166 | 973 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 973 | 0 | 0 | 0 | 0
29 | Housing financing | 155 | 153 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 153 | 0 | 0 | 0 | 0
30 | Other local government financing | 1,012 | 819 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 819 | 0 | 0 | 0 | 0
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 4,825 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
32 | Assets excluded from the numerator for GAR calculation (covered in the denominator) | 637,106 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
33 | Financial and Non-financial undertakings | 438,149 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
34 | SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations | 134,206 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
35 | Loans and advances | 132,387 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
36 | of which loans collateralised by commercial immovable property | 23,620 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
37 | of which building renovation loans | 1,704 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
38 | Debt securities | 1,575 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
39 | Equity instruments | 244 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
40 | Non-EU country counterparties not subject to NFRD disclosure obligations | 303,944 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
41 | Loans and advances | 276,247 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
42 | Debt securities | 24,306 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
43 | Equity instruments | 3,391 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
44 | Derivatives | 5,772 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
45 | On demand interbank loans | 12,146 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
46 | Cash and cash-related assets | 9,252 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
47 | Other categories of assets (e.g. Goodwill, commodities etc.) | 171,788 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
48 | Total GAR assets | 1,306,542 | 447,158 | 42,818 | 36,969 | 9,508 | 2,202 |  | 101 | 17 | 0 | 3 |  | 447,259 | 42,834 | 36,969 | 9,508 | 2,206
49 | Assets not covered for GAR calculation | 565,848 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
50 | Central governments and Supranational issuers | 142,309 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
51 | Central banks exposure | 193,354 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |

110 The assets under management taken into account in this template covers the whole Group.
Annual report 2025 146

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
52 | Trading book | 230,185 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
53 | Total assets | 1,872,390 | 447,158 | 42,818 | 36,969 | 9,508 | 2,202 |  | 101 | 17 | 0 | 3 |  | 447,259 | 42,834 | 36,969 | 9,508 | 2,206
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 | Financial guarantees | 16,898 | 1,282 | 570 | 0 | 47 | 387 |  | 39 | 15 | 0 | 4 |  | 1,320 | 585 | 0 | 47 | 390
55 | Assets under management 110 | 156,908 | 13,238 | 3,345 | 0 | 184 | 1,419 |  | 348 | 15 | 0 | 1 |  | 13,586 | 3,360 | 0 | 184 | 1,420
56 | Of which debt securities | 71,062 | 8,288 | 1,665 | 0 | 96 | 752 |  | 292 | 2 | 0 | 0 |  | 8,580 | 1,668 | 0 | 96 | 752
57 | Of which equity instruments | 63,320 | 4,744 | 1,616 | 0 | 86 | 642 |  | 54 | 12 | 0 | 1 |  | 4,798 | 1,628 | 0 | 86 | 643

Annual report 2025 147

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

1. Assets for the calculation of GAR (Turnover) - 2024

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 664,610 | 444,137 | 39,615 | 36,969 | 8,952 | 1,412 |  | 365 | 41 | 0 | 18 |  | 444,503 | 39,656 | 36,969 | 8,952 | 1,431
2 | Financial undertakings | 25,544 | 4,921 | 776 | 0 | 3 | 280 |  | 289 | 21 | 0 | 2 |  | 5,210 | 798 | 0 | 3 | 281
3 | Credit institutions | 18,208 | 3,265 | 280 | 0 | 0 | 5 |  | 25 | 2 | 0 | 0 |  | 3,290 | 281 | 0 | 0 | 5
4 | Loans and advances | 16,848 | 3,028 | 260 | 0 | 0 | 5 |  | 12 | 2 | 0 | 0 |  | 3,040 | 262 | 0 | 0 | 5
5 | Debt securities, including UoP | 1,360 | 237 | 19 | 0 | 0 | 0 |  | 13 | 0 | 0 | 0 |  | 250 | 19 | 0 | 0 | 0
6 | Equity instruments | 0 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
7 | Other financial corporations | 7,336 | 1,656 | 497 | 0 | 2 | 274 |  | 264 | 20 | 0 | 2 |  | 1,919 | 516 | 0 | 2 | 276
8 | of which investment firms | 2,300 | 392 | 263 | 0 | 0 | 141 |  | 43 | 4 | 0 | 2 |  | 435 | 268 | 0 | 0 | 143
9 | Loans and advances | 1,778 | 174 | 68 | 0 | 0 | 47 |  | 43 | 4 | 0 | 2 |  | 217 | 72 | 0 | 0 | 49
10 | Debt securities, including UoP | 523 | 218 | 196 | 0 | 0 | 94 |  | 0 | 0 | 0 | 0 |  | 218 | 196 | 0 | 0 | 94
11 | Equity instruments | 0 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
12 | of which management companies | 258 | 122 | 6 | 0 | 0 | 4 |  | 0 | 0 | 0 | 0 |  | 122 | 6 | 0 | 0 | 4
13 | Loans and advances | 176 | 120 | 6 | 0 | 0 | 4 |  | 0 | 0 | 0 | 0 |  | 121 | 6 | 0 | 0 | 4
14 | Debt securities, including UoP | 80 | 1 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 1 | 0 | 0 | 0 | 0
15 | Equity instruments | 2 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
16 | of which insurance undertakings | 2,050 | 244 | 7 | 0 | 0 | 0 |  | 219 | 15 | 0 | 0 |  | 462 | 22 | 0 | 0 | 0
17 | Loans and advances | 1,931 | 244 | 7 | 0 | 0 | 0 |  | 219 | 15 | 0 | 0 |  | 462 | 22 | 0 | 0 | 0
18 | Debt securities, including UoP | 0 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
19 | Equity instruments | 119 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
20 | Non-financial undertakings | 28,232 | 9,302 | 1,869 | 0 | 117 | 1,133 |  | 76 | 20 | 0 | 17 |  | 9,378 | 1,889 | 0 | 117 | 1,149
21 | Loans and advances | 26,333 | 9,014 | 1,648 | 0 | 117 | 936 |  | 70 | 16 | 0 | 16 |  | 9,084 | 1,664 | 0 | 117 | 952
22 | Debt securities, including UoP | 1,891 | 288 | 221 | 0 | 0 | 197 |  | 7 | 3 | 0 | 0 |  | 294 | 224 | 0 | 0 | 197
23 | Equity instruments | 8 | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 |  | 0 | 0 |  | 0 | 0
24 | Households | 609,668 | 428,942 | 36,969 | 36,969 | 8,832 | 0 |  | 0 | 0 | 0 | 0 |  | 428,942 | 36,969 | 36,969 | 8,832 | 0
25 | of which loans collateralised by residential immovable property | 362,813 | 331,277 | 28,137 | 28,137 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 331,277 | 28,137 | 28,137 | 0 | 0
26 | of which building renovation loans | 1,189 | 1,189 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 1,189 | 0 | 0 | 0 | 0
27 | of which motor vehicle loans | 96,477 | 96,477 | 8,832 | 8,832 | 8,832 | 0 |  |  |  |  |  |  | 96,477 | 8,832 | 8,832 | 8,832 | 0
28 | Local governments financing | 1,166 | 973 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 973 | 0 | 0 | 0 | 0
29 | Housing financing | 155 | 153 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 153 | 0 | 0 | 0 | 0
30 | Other local government financing | 1,012 | 819 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 819 | 0 | 0 | 0 | 0

111 The assets under management taken into account in this template covers the whole Group.
Annual report 2025 148

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 4,825 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
32 | Assets excluded from the numerator for GAR calculation (covered in the denominator) | 637,106 | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0
33 | Financial and Non-financial undertakings | 438,149 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
34 | SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations | 134,206 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
35 | Loans and advances | 132,387 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
36 | of which loans collateralised by commercial immovable property | 23,620 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
37 | of which building renovation loans | 1,704 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
38 | Debt securities | 1,575 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
39 | Equity instruments | 244 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
40 | Non-EU country counterparties not subject to NFRD disclosure obligations | 303,944 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
41 | Loans and advances | 276,247 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
42 | Debt securities | 24,306 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
43 | Equity instruments | 3,391 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
44 | Derivatives | 5,772 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
45 | On demand interbank loans | 12,146 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
46 | Cash and cash-related assets | 9,252 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
47 | Other categories of assets (e.g. Goodwill, commodities etc.) | 171,788 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
48 | Total GAR assets | 1,306,542 | 444,137 | 39,615 | 36,969 | 8,952 | 1,412 |  | 365 | 41 | 0 | 18 |  | 444,503 | 39,656 | 36,969 | 8,952 | 1,431
49 | Assets not covered for GAR calculation | 565,848 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
50 | Central governments and Supranational issuers | 142,309 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
51 | Central banks exposure | 193,354 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
52 | Trading book | 230,185 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
53 | Total assets | 1,872,390 | 444,137 | 39,615 | 36,969 | 8,952 | 1,412 |  | 365 | 41 | 0 | 18 |  | 444,503 | 39,656 | 36,969 | 8,952 | 1,431
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 | Financial guarantees | 16,898 | 809 | 218 | 0 | 1 | 166 |  | 67 | 31 | 0 | 31 |  | 876 | 249 | 0 | 1 | 197
55 | Assets under management 111 | 156,908 | 12,858 | 1,994 | 0 | 78 | 844 |  | 861 | 53 | 0 | 19 |  | 13,719 | 2,047 | 0 | 78 | 863

Annual report 2025 149

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Million EUR | 2024
| Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Total [gross] carrying amount | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible)
| Of which environmentally sustainable (Taxonomy- aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy- aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
56 | Of which debt securities | 71,062 | 8,627 | 912 | 0 | 37 | 367 |  | 520 | 20 | 0 | 11 |  | 9,147 | 931 | 0 | 37 | 378
57 | Of which equity instruments | 63,320 | 4,061 | 1,040 | 0 | 40 | 462 |  | 328 | 32 | 0 | 8 |  | 4,389 | 1,072 | 0 | 40 | 470

112 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 150

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2. GAR sector information (Capex) - 2025 112

Breakdown by sector - NACE 4 digits level (code and label) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
1 | A Agriculture, forestry and fishing | 23 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 23 | 0 |  |  |
2 | B910 - Support activities for petroleum and natural gas extraction | 73 | 57 |  |  |  |  | 1 | 1 |  |  |  |  | 74 | 58 |  |  |
3 | B Mining and quarrying | 314 | 235 |  |  |  |  | 2 | 2 |  |  |  |  | 316 | 237 |  |  |
4 | C2059 - Manufacture of other chemical products n.e.c. | 60 | 38 |  |  |  |  | 0 | 0 |  |  |  |  | 60 | 39 |  |  |
5 | C2410 - Manufacture of basic iron and steel and of ferro- alloys | 98 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 98 | 0 |  |  |
6 | C2511 - Manufacture of metal structures and parts of structures | 48 | 46 |  |  |  |  | 15 | 15 |  |  |  |  | 62 | 60 |  |  |
7 | C2733 - Manufacture of wiring devices | 66 | 21 |  |  |  |  | 0 | 0 |  |  |  |  | 66 | 21 |  |  |
8 | C2910 - Manufacture of motor vehicles | 75 | 5 |  |  |  |  | 0 | 0 |  |  |  |  | 75 | 5 |  |  |
9 | C3020 - Manufacture of railway locomotives and rolling stock | 68 | 60 |  |  |  |  | 0 | 0 |  |  |  |  | 68 | 60 |  |  |
10 | C3030 - Manufacture of air and spacecraft and related machinery | 559 | 181 |  |  |  |  | 0 | 0 |  |  |  |  | 559 | 181 |  |  |
11 | C Manufacturing | 138 | 23 |  |  |  |  | 0 | 0 |  |  |  |  | 138 | 23 |  |  |
12 | D3511 - Production of electricity | 444 | 113 |  |  |  |  | 0 | 0 |  |  |  |  | 445 | 114 |  |  |
13 | D3512 - Transmission of electricity | 1,048 | 918 |  |  |  |  | 2 | 2 |  |  |  |  | 1,050 | 919 |  |  |
14 | D3513 - Distribution of electricity | 86 | 83 |  |  |  |  | 0 | 0 |  |  |  |  | 86 | 83 |  |  |
15 | D3514 - Trade of electricity | 578 | 479 |  |  |  |  | 2 | 2 |  |  |  |  | 580 | 481 |  |  |
16 | D Electricity, gas, steam and air conditioning supply | 801 | 670 |  |  |  |  | 0 | 0 |  |  |  |  | 801 | 670 |  |  |
17 | E Water supply | 56 | 46 |  |  |  |  | 0 | 0 |  |  |  |  | 56 | 46 |  |  |
18 | F4110 - Development of building projects | 17 | 16 |  |  |  |  | 0 | 0 |  |  |  |  | 17 | 16 |  |  |

Annual report 2025 151

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Breakdown by sector - NACE 4 digits level (code and label) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
19 | F4211 - Construction of roads and motorways | 6 | 2 |  |  |  |  | 0 | 0 |  |  |  |  | 6 | 2 |  |  |
20 | F4299 - Construction of other civil engineering projects n.e.c. | 69 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 69 | 1 |  |  |
21 | F4312 - Site preparation | 150 | 34 |  |  |  |  | 0 | 0 |  |  |  |  | 150 | 34 |  |  |
22 | F4321 - Electrical installation | 102 | 29 |  |  |  |  | 6 | 3 |  |  |  |  | 108 | 32 |  |  |
23 | F Construction | 229 | 80 |  |  |  |  | 0 | 0 |  |  |  |  | 229 | 80 |  |  |
24 | G4511 - Sale of cars and light motor vehicles | 50 | 2 |  |  |  |  | 0 | 0 |  |  |  |  | 50 | 2 |  |  |
25 | G4614 - Agents involved in the sale of machinery, industrial equipment, ships and aircraft | 62 | 47 |  |  |  |  | 0 | 0 |  |  |  |  | 63 | 47 |  |  |
26 | G Wholesale and retail trade | 125 | 9 |  |  |  |  | 0 | 0 |  |  |  |  | 125 | 9 |  |  |
27 | H4910 - Passenger rail transport, interurban | 66 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 66 | 1 |  |  |
28 | H5221 - Service activities incidental to land transportation | 239 | 27 |  |  |  |  | 0 | 0 |  |  |  |  | 239 | 27 |  |  |
29 | H Transport and storage | 57 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 57 | 1 |  |  |
30 | I5510 - Hotels and similar accommodation | 210 | 52 |  |  |  |  | 0 | 0 |  |  |  |  | 210 | 52 |  |  |
31 | I Accommodation and food service activities | 92 | 40 |  |  |  |  | 0 | 0 |  |  |  |  | 92 | 40 |  |  |
32 | J6120 - Wireless telecommunications activities | 189 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 189 | 0 |  |  |
33 | J6399 - Other information service activities n.e.c. | 77 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 77 | 0 |  |  |
34 | J Information and communication | 62 | 20 |  |  |  |  | 25 | 1 |  |  |  |  | 88 | 21 |  |  |
35 | L6810 - Buying and selling of own real estate | 433 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 433 | 0 |  |  |
36 | L6820 - Renting and operating of own or leased real estate | 65 | 7 |  |  |  |  | 3 | 1 |  |  |  |  | 69 | 8 |  |  |
37 | L6832 - Management of real estate on a fee or contract basis | 83 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 83 | 0 |  |  |
38 | L Real estate activities | 55 | 3 |  |  |  |  | 0 | 0 |  |  |  |  | 55 | 3 |  |  |
39 | M7010 - Activities of head offices | 58 | 50 |  |  |  |  | 0 | 0 |  |  |  |  | 58 | 50 |  |  |
40 | M7021 - Public relations and communication activities | 459 | 303 |  |  |  |  | 1 | 0 |  |  |  |  | 460 | 303 |  |  |

Annual report 2025 152

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Breakdown by sector - NACE 4 digits level (code and label) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
41 | M7022 - Business and other management consultancy activities | 61 | 17 |  |  |  |  | 0 | 0 |  |  |  |  | 61 | 17 |  |  |
42 | M7112 - Engineering activities and related technical consultancy | 55 | 4 |  |  |  |  | 0 | 0 |  |  |  |  | 55 | 4 |  |  |
43 | M7490 - Other professional, scientific and technical activities n.e.c. | 77 | 24 |  |  |  |  | 0 | 0 |  |  |  |  | 77 | 24 |  |  |
44 | M Professional, scientific and technical activities | 225 | 59 |  |  |  |  | 1 | 0 |  |  |  |  | 226 | 59 |  |  |
45 | N7711 - Renting and leasing of cars and light motor vehicles | 3 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 3 | 1 |  |  |
46 | N8010 - Private security activities | 43 | 3 |  |  |  |  | 0 | 0 |  |  |  |  | 43 | 3 |  |  |
47 | N8211 - Combined office administrative service activities | 62 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 62 | 1 |  |  |
48 | N8299 - Other business support service activities n.e.c. | 125 | 52 |  |  |  |  | 0 | 0 |  |  |  |  | 125 | 52 |  |  |
49 | N Administrative and support service activities | 32 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 32 | 1 |  |  |
50 | O Public administration and defence, compulsory social security | 0 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 0 | 0 |  |  |
51 | P Education | 16 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 16 | 0 |  |  |
52 | Q Human health services and social work activities | 9 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 9 | 1 |  |  |
53 | R Arts, entertainment and recreation | 4 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 4 | 0 |  |  |
54 | S Other services | 299 | 107 |  |  |  |  | 1 | 1 |  |  |  |  | 301 | 108 |  |  |

1. Exposures in the banking book towards those sectors covered by the Taxonomy (NACE sectors 4 levels of detail), using the relevant NACE Codes on the basis of the principal activity of the counterparty. A threshold above 0.5% of the eligible exposure has been set for reporting NACE at level 4. All other NACEs outside this threshold are reported at level 1.

113 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 153

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2. GAR sector information (Turnover) - 2025 113

Breakdown by sector - NACE 4 digits level (code and label) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
1 | A Agriculture, forestry and fishing | 23 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 23 | 0 |  |  |
2 | B910 - Support activities for petroleum and natural gas extraction | 118 | 28 |  |  |  |  | 0 | 0 |  |  |  |  | 118 | 28 |  |  |
3 | B Mining and quarrying | 42 | 16 |  |  |  |  | 0 | 0 |  |  |  |  | 42 | 16 |  |  |
4 | C2059 - Manufacture of other chemical products n.e.c. | 40 | 4 |  |  |  |  | 0 | 0 |  |  |  |  | 40 | 4 |  |  |
5 | C2410 - Manufacture of basic iron and steel and of ferro- alloys | 45 | 10 |  |  |  |  | 0 | 0 |  |  |  |  | 45 | 10 |  |  |
6 | C2511 - Manufacture of metal structures and parts of structures | 93 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 93 | 0 |  |  |
7 | C2733 - Manufacture of wiring devices | 44 | 28 |  |  |  |  | 0 | 0 |  |  |  |  | 44 | 28 |  |  |
8 | C2910 - Manufacture of motor vehicles | 581 | 52 |  |  |  |  | 0 | 0 |  |  |  |  | 581 | 52 |  |  |
9 | C3020 - Manufacture of railway locomotives and rolling stock | 100 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 100 | 0 |  |  |
10 | C3030 - Manufacture of air and spacecraft and related machinery | 42 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 42 | 0 |  |  |
11 | C Manufacturing | 260 | 47 |  |  |  |  | 0 | 0 |  |  |  |  | 260 | 47 |  |  |
12 | D3511 - Production of electricity | 708 | 466 |  |  |  |  | 4 | 2 |  |  |  |  | 711 | 468 |  |  |
13 | D3512 - Transmission of electricity | 53 | 47 |  |  |  |  | 0 | 0 |  |  |  |  | 53 | 47 |  |  |
14 | D3513 - Distribution of electricity | 414 | 312 |  |  |  |  | 1 | 1 |  |  |  |  | 415 | 313 |  |  |
15 | D3514 - Trade of electricity | 499 | 348 |  |  |  |  | 0 | 0 |  |  |  |  | 499 | 348 |  |  |
16 | D Electricity, gas, steam and air conditioning supply | 26 | 12 |  |  |  |  | 0 | 0 |  |  |  |  | 26 | 12 |  |  |
17 | E Water supply | 22 | 4 |  |  |  |  | 1 | 0 |  |  |  |  | 23 | 4 |  |  |
18 | F4110 - Development of building projects | 70 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 70 | 1 |  |  |

Annual report 2025 154

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Breakdown by sector - NACE 4 digits level (code and label) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
19 | F4211 - Construction of roads and motorways | 90 | 16 |  |  |  |  | 3 | 0 |  |  |  |  | 92 | 16 |  |  |
20 | F4299 - Construction of other civil engineering projects n.e.c. | 93 | 16 |  |  |  |  | 2 | 0 |  |  |  |  | 95 | 16 |  |  |
21 | F4312 - Site preparation | 114 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 114 | 0 |  |  |
22 | F4321 - Electrical installation | 59 | 5 |  |  |  |  | 0 | 0 |  |  |  |  | 59 | 5 |  |  |
23 | F Construction | 40 | 17 |  |  |  |  | 2 | 0 |  |  |  |  | 42 | 17 |  |  |
24 | G4511 - Sale of cars and light motor vehicles | 318 | 38 |  |  |  |  | 0 | 0 |  |  |  |  | 318 | 38 |  |  |
25 | G4614 - Agents involved in the sale of machinery, industrial equipment, ships and aircraft | 47 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 47 | 0 |  |  |
26 | G Wholesale and retail trade | 83 | 14 |  |  |  |  | 0 | 0 |  |  |  |  | 84 | 14 |  |  |
27 | H4910 - Passenger rail transport, interurban | 47 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 47 | 0 |  |  |
28 | H5221 - Service activities incidental to land transportation | 206 | 56 |  |  |  |  | 0 | 0 |  |  |  |  | 206 | 56 |  |  |
29 | H Transport and storage | 69 | 14 |  |  |  |  | 0 | 0 |  |  |  |  | 69 | 14 |  |  |
30 | I5510 - Hotels and similar accommodation | 189 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 189 | 0 |  |  |
31 | I Accommodation and food service activities | 76 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 76 | 0 |  |  |
32 | J6120 - Wireless telecommunications activities | 140 | 53 |  |  |  |  | 13 | 1 |  |  |  |  | 153 | 54 |  |  |
33 | J6399 - Other information service activities n.e.c. | 433 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 433 | 0 |  |  |
34 | J Information and communication | 50 | 4 |  |  |  |  | 13 | 4 |  |  |  |  | 64 | 8 |  |  |
35 | L6810 - Buying and selling of own real estate | 125 | 75 |  |  |  |  | 0 | 0 |  |  |  |  | 125 | 75 |  |  |
36 | L6820 - Renting and operating of own or leased real estate | 87 | 0 |  |  |  |  | 1 | 0 |  |  |  |  | 88 | 1 |  |  |
37 | L6832 - Management of real estate on a fee or contract basis | 44 | 3 |  |  |  |  | 0 | 0 |  |  |  |  | 44 | 3 |  |  |
38 | L Real estate activities | 2 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 2 | 0 |  |  |
39 | M7010 - Activities of head offices | 285 | 172 |  |  |  |  | 2 | 0 |  |  |  |  | 288 | 172 |  |  |
40 | M7021 - Public relations and communication activities | 57 | 5 |  |  |  |  | 0 | 0 |  |  |  |  | 57 | 5 |  |  |

Annual report 2025 155

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Breakdown by sector - NACE 4 digits level (code and label) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
41 | M7022 - Business and other management consultancy activities | 58 | 6 |  |  |  |  | 0 | 0 |  |  |  |  | 58 | 6 |  |  |
42 | M7112 - Engineering activities and related technical consultancy | 70 | 10 |  |  |  |  | 0 | 0 |  |  |  |  | 70 | 10 |  |  |
43 | M7490 - Other professional, scientific and technical activities n.e.c. | 203 | 45 |  |  |  |  | 3 | 0 |  |  |  |  | 205 | 45 |  |  |
44 | M Professional, scientific and technical activities | 34 | 23 |  |  |  |  | 0 | 0 |  |  |  |  | 34 | 23 |  |  |
45 | N7711 - Renting and leasing of cars and light motor vehicles | 135 | 16 |  |  |  |  | 0 | 0 |  |  |  |  | 135 | 16 |  |  |
46 | N8010 - Private security activities | 36 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 36 | 0 |  |  |
47 | N8211 - Combined office administrative service activities | 61 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 61 | 0 |  |  |
48 | N8299 - Other business support service activities n.e.c. | 71 | 32 |  |  |  |  | 0 | 0 |  |  |  |  | 71 | 32 |  |  |
49 | N Administrative and support service activities | 18 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 18 | 1 |  |  |
50 | O Public administration and defence, compulsory social security | 0 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 0 | 0 |  |  |
51 | P Education | 16 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 16 | 0 |  |  |
52 | Q Human health services and social work activities | 9 | 3 |  |  |  |  | 0 | 0 |  |  |  |  | 10 | 3 |  |  |
53 | R Arts, entertainment and recreation | 0 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 0 | 0 |  |  |
54 | S Other services | 228 | 48 |  |  |  |  | 1 | 0 |  |  |  |  | 229 | 49 |  |  |

1. Exposures in the banking book towards those sectors covered by the Taxonomy (NACE sectors 4 levels of detail), using the relevant NACE Codes on the basis of the principal activity of the counterparty. A threshold above 0.5% of the eligible exposure has been set for reporting NACE at level 4. All other NACEs outside this threshold are reported at level 1.

Annual report 2025 156

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2. GAR sector information (Capex) - 2024

Breakdown by sector - NACE 4 digits level (code and label) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
1 | A Agriculture, forestry and fishing | 25 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 25 | 0 |  |  |
2 | B610 - Extraction of crude petroleum | 67 | 53 |  |  |  |  | 0 | 0 |  |  |  |  | 67 | 53 |  |  |
3 | B910 - Support activities for petroleum and natural gas extraction | 354 | 261 |  |  |  |  | 1 | 0 |  |  |  |  | 354 | 261 |  |  |
4 | B Mining and quarrying | 50 | 4 |  |  |  |  | 0 | 0 |  |  |  |  | 51 | 4 |  |  |
5 | C2410 - Manufacture of basic iron and steel and of ferro- alloys | 61 | 55 |  |  |  |  | 0 | 0 |  |  |  |  | 61 | 55 |  |  |
6 | C2511 - Manufacture of metal structures and parts of structures | 121 | 120 |  |  |  |  | 0 | 0 |  |  |  |  | 121 | 120 |  |  |
7 | C2732 - Manufacture of other electronic and electric wires and cables | 129 | 98 |  |  |  |  | 0 | 0 |  |  |  |  | 129 | 98 |  |  |
8 | C2733 - Manufacture of wiring devices | 66 | 55 |  |  |  |  | 0 | 0 |  |  |  |  | 66 | 55 |  |  |
9 | C2910 - Manufacture of motor vehicles | 443 | 147 |  |  |  |  | 0 | 0 |  |  |  |  | 443 | 147 |  |  |
10 | C3020 - Manufacture of railway locomotives and rolling stock | 134 | 34 |  |  |  |  | 0 | 0 |  |  |  |  | 134 | 34 |  |  |
11 | C3030 - Manufacture of air and spacecraft and related machinery | 60 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 60 | 0 |  |  |
12 | C Manufacturing | 622 | 278 |  |  |  |  | 3 | 3 |  |  |  |  | 625 | 281 |  |  |
13 | D3511 - Production of electricity | 971 | 726 |  |  |  |  | 0 | 0 |  |  |  |  | 972 | 726 |  |  |
14 | D3513 - Distribution of electricity | 400 | 362 |  |  |  |  | 0 | 0 |  |  |  |  | 400 | 362 |  |  |
15 | D3514 - Trade of electricity | 471 | 328 |  |  |  |  | 0 | 0 |  |  |  |  | 471 | 328 |  |  |
16 | D3521 - Manufacture of gas | 136 | 46 |  |  |  |  | 0 | 0 |  |  |  |  | 136 | 46 |  |  |
17 | D Electricity, gas, steam and air conditioning supply | 92 | 38 |  |  |  |  | 0 | 0 |  |  |  |  | 92 | 38 |  |  |
18 | E Water supply | 78 | 3 |  |  |  |  | 0 | 0 |  |  |  |  | 78 | 3 |  |  |
19 | F4110 - Development of building projects | 80 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 80 | 1 |  |  |
20 | F4211 - Construction of roads and motorways | 149 | 35 |  |  |  |  | 3 | 0 |  |  |  |  | 152 | 35 |  |  |

Annual report 2025 157

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Breakdown by sector - NACE 4 digits level (code and label) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
21 | F4299 - Construction of other civil engineering projects n.e.c. | 88 | 10 |  |  |  |  | 2 | 0 |  |  |  |  | 90 | 10 |  |  |
22 | F4312 - Site preparation | 390 | 2 |  |  |  |  | 0 | 0 |  |  |  |  | 390 | 2 |  |  |
23 | F Construction | 162 | 38 |  |  |  |  | 1 | 0 |  |  |  |  | 164 | 38 |  |  |
24 | G4511 - Sale of cars and light motor vehicles | 551 | 81 |  |  |  |  | 0 | 0 |  |  |  |  | 552 | 81 |  |  |
25 | G4519 - Sale of other motor vehicles | 101 | 23 |  |  |  |  | 0 | 0 |  |  |  |  | 101 | 23 |  |  |
26 | G4641 - Wholesale of textiles | 58 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 58 | 0 |  |  |
27 | G4711 - Retail sale in non- specialised stores with food, beverages or tobacco predominating | 132 | 11 |  |  |  |  | 0 | 0 |  |  |  |  | 132 | 11 |  |  |
28 | G4778 - Other retail sale of new goods in specialised stores | 103 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 103 | 1 |  |  |
29 | G Wholesale and retail trade | 403 | 69 |  |  |  |  | 8 | 0 |  |  |  |  | 412 | 69 |  |  |
30 | H4950 - Transport via pipeline | 148 | 134 |  |  |  |  | 0 | 0 |  |  |  |  | 148 | 134 |  |  |
31 | H5210 - Warehousing and storage | 83 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 83 | 0 |  |  |
32 | H5221 - Service activities incidental to land transportation | 267 | 7 |  |  |  |  | 0 | 0 |  |  |  |  | 267 | 7 |  |  |
33 | H Transport and storage | 158 | 30 |  |  |  |  | 0 | 0 |  |  |  |  | 159 | 30 |  |  |
34 | I5510 - Hotels and similar accommodation | 182 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 182 | 0 |  |  |
35 | I Accommodation and food service activities | 50 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 50 | 0 |  |  |
36 | J6120 - Wireless telecommunications activities | 348 | 30 |  |  |  |  | 31 | 1 |  |  |  |  | 379 | 31 |  |  |
37 | J6399 - Other information service activities n.e.c. | 472 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 472 | 0 |  |  |
38 | J Information and communication | 160 | 12 |  |  |  |  | 2 | 2 |  |  |  |  | 163 | 14 |  |  |
39 | L6810 - Buying and selling of own real estate | 140 | 73 |  |  |  |  | 7 | 0 |  |  |  |  | 148 | 73 |  |  |
40 | L6820 - Renting and operating of own or leased real estate | 175 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 175 | 1 |  |  |
41 | L Real estate activities | 22 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 22 | 0 |  |  |
42 | M7010 - Activities of head offices | 929 | 554 |  |  |  |  | 8 | 8 |  |  |  |  | 937 | 562 |  |  |

Annual report 2025 158

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Breakdown by sector - NACE 4 digits level (code and label) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
43 | M7490 - Other professional, scientific and technical activities n.e.c. | 196 | 88 |  |  |  |  | 3 | 0 |  |  |  |  | 199 | 88 |  |  |
44 | M Professional, scientific and technical activities | 156 | 69 |  |  |  |  | 1 | 0 |  |  |  |  | 157 | 69 |  |  |
45 | N7711 - Renting and leasing of cars and light motor vehicles | 723 | 119 |  |  |  |  | 0 | 0 |  |  |  |  | 723 | 119 |  |  |
46 | N8211 - Combined office administrative service activities | 84 | 30 |  |  |  |  | 0 | 0 |  |  |  |  | 84 | 30 |  |  |
47 | N8299 - Other business support service activities n.e.c. | 230 | 90 |  |  |  |  | 0 | 0 |  |  |  |  | 230 | 90 |  |  |
48 | N Administrative and support service activities | 105 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 105 | 0 |  |  |
49 | O Public administration and defence, compulsory social security | 0 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 0 | 0 |  |  |
50 | P Education | 18 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 18 | 0 |  |  |
51 | Q Human health services and social work activities | 14 | 2 |  |  |  |  | 0 | 0 |  |  |  |  | 14 | 2 |  |  |
52 | R Arts, entertainment and recreation | 20 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 20 | 0 |  |  |
53 | S9609 - Other personal service activities n.e.c. | 83 | 19 |  |  |  |  | 0 | 0 |  |  |  |  | 83 | 19 |  |  |
54 | S Other services | 275 | 111 |  |  |  |  | 1 | 0 |  |  |  |  | 276 | 111 |  |  |

1. Exposures in the banking book towards those sectors covered by the Taxonomy (NACE sectors 4 levels of detail), using the relevant NACE Codes on the basis of the principal activity of the counterparty. A threshold above 0.5% of the eligible exposure has been set for reporting NACE at level 4. All other NACEs outside this threshold are reported at level 1.

Annual report 2025 159

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

2. GAR sector information (Turnover) - 2024

Breakdown by sector - NACE 4 digits level (code and label) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
1 | A Agriculture, forestry and fishing | 25 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 25 | 0 |  |  |
2 | B910 - Support activities for petroleum and natural gas extraction | 186 | 76 |  |  |  |  | 1 | 0 |  |  |  |  | 187 | 76 |  |  |
3 | B Mining and quarrying | 46 | 6 |  |  |  |  | 0 | 0 |  |  |  |  | 46 | 6 |  |  |
4 | C2351 - Manufacture of cement | 67 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 67 | 1 |  |  |
5 | C2410 - Manufacture of basic iron and steel and of ferro- alloys | 88 | 3 |  |  |  |  | 0 | 0 |  |  |  |  | 88 | 3 |  |  |
6 | C2442 - Aluminium production | 138 | 35 |  |  |  |  | 0 | 0 |  |  |  |  | 138 | 35 |  |  |
7 | C2511 - Manufacture of metal structures and parts of structures | 150 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 150 | 0 |  |  |
8 | C2732 - Manufacture of other electronic and electric wires and cables | 100 | 44 |  |  |  |  | 0 | 0 |  |  |  |  | 100 | 44 |  |  |
9 | C2910 - Manufacture of motor vehicles | 432 | 36 |  |  |  |  | 0 | 0 |  |  |  |  | 432 | 36 |  |  |
10 | C3011 - Building of ships and floating structures | 68 | 16 |  |  |  |  | 0 | 0 |  |  |  |  | 68 | 16 |  |  |
11 | C3020 - Manufacture of railway locomotives and rolling stock | 134 | 37 |  |  |  |  | 0 | 0 |  |  |  |  | 134 | 37 |  |  |
12 | C3030 - Manufacture of air and spacecraft and related machinery | 73 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 73 | 0 |  |  |
13 | C3313 - Repair of electronic and optical equipment | 49 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 49 | 0 |  |  |
14 | C Manufacturing | 318 | 60 |  |  |  |  | 0 | 0 |  |  |  |  | 318 | 60 |  |  |
15 | D3511 - Production of electricity | 613 | 348 |  |  |  |  | 2 | 0 |  |  |  |  | 615 | 348 |  |  |
16 | D3513 - Distribution of electricity | 236 | 165 |  |  |  |  | 0 | 0 |  |  |  |  | 236 | 165 |  |  |
17 | D3514 - Trade of electricity | 235 | 163 |  |  |  |  | 0 | 0 |  |  |  |  | 235 | 163 |  |  |
18 | D3521 - Manufacture of gas | 99 | 5 |  |  |  |  | 0 | 0 |  |  |  |  | 99 | 5 |  |  |
19 | D Electricity, gas, steam and air conditioning supply | 52 | 19 |  |  |  |  | 0 | 0 |  |  |  |  | 52 | 19 |  |  |
20 | E3600 - Water collection, treatment and supply | 51 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 51 | 0 |  |  |

Annual report 2025 160

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Breakdown by sector - NACE 4 digits level (code and label) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
21 | E Water supply | 28 | 4 |  |  |  |  | 1 | 0 |  |  |  |  | 29 | 4 |  |  |
22 | F4110 - Development of building projects | 81 | 2 |  |  |  |  | 0 | 0 |  |  |  |  | 81 | 2 |  |  |
23 | F4120 - Construction of residential and non-residential buildings | 51 | 11 |  |  |  |  | 0 | 0 |  |  |  |  | 51 | 11 |  |  |
24 | F4211 - Construction of roads and motorways | 175 | 71 |  |  |  |  | 8 | 0 |  |  |  |  | 183 | 71 |  |  |
25 | F4299 - Construction of other civil engineering projects n.e.c. | 93 | 19 |  |  |  |  | 4 | 0 |  |  |  |  | 97 | 19 |  |  |
26 | F4312 - Site preparation | 374 | 0 |  |  |  |  | 1 | 0 |  |  |  |  | 374 | 0 |  |  |
27 | F Construction | 111 | 33 |  |  |  |  | 6 | 0 |  |  |  |  | 117 | 33 |  |  |
28 | G4511 - Sale of cars and light motor vehicles | 272 | 24 |  |  |  |  | 0 | 0 |  |  |  |  | 272 | 24 |  |  |
29 | G4519 - Sale of other motor vehicles | 99 | 11 |  |  |  |  | 0 | 0 |  |  |  |  | 99 | 11 |  |  |
30 | G4614 - Agents involved in the sale of machinery, industrial equipment, ships and aircraft | 63 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 63 | 0 |  |  |
31 | G Wholesale and retail trade | 174 | 16 |  |  |  |  | 0 | 0 |  |  |  |  | 174 | 16 |  |  |
32 | H4950 - Transport via pipeline | 50 | 36 |  |  |  |  | 0 | 0 |  |  |  |  | 50 | 36 |  |  |
33 | H5210 - Warehousing and storage | 83 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 83 | 0 |  |  |
34 | H5221 - Service activities incidental to land transportation | 265 | 10 |  |  |  |  | 0 | 0 |  |  |  |  | 265 | 10 |  |  |
35 | H Transport and storage | 124 | 7 |  |  |  |  | 0 | 0 |  |  |  |  | 124 | 7 |  |  |
36 | I5510 - Hotels and similar accommodation | 167 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 167 | 0 |  |  |
37 | I Accommodation and food service activities | 41 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 41 | 0 |  |  |
38 | J6120 - Wireless telecommunications activities | 453 | 90 |  |  |  |  | 20 | 3 |  |  |  |  | 473 | 93 |  |  |
39 | J6399 - Other information service activities n.e.c. | 472 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 472 | 0 |  |  |
40 | J Information and communication | 138 | 3 |  |  |  |  | 12 | 3 |  |  |  |  | 150 | 7 |  |  |
41 | L6810 - Buying and selling of own real estate | 158 | 61 |  |  |  |  | 0 | 0 |  |  |  |  | 158 | 61 |  |  |
42 | L6820 - Renting and operating of own or leased real estate | 185 | 0 |  |  |  |  | 4 | 4 |  |  |  |  | 189 | 4 |  |  |
43 | L Real estate activities | 22 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 22 | 0 |  |  |

Annual report 2025 161

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Breakdown by sector - NACE 4 digits level (code and label) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD |  | Non-Financial corporates (Subject to NFRD) |  | SMEs and other NFC not subject to NFRD
[Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount |  | [Gross] carrying amount
Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCM) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA) |  | Mn EUR | Of which environmentally sustainable (CCM+CCA)
44 | M7010 - Activities of head offices | 767 | 179 |  |  |  |  | 4 | 3 |  |  |  |  | 772 | 183 |  |  |
45 | M7112 - Engineering activities and related technical consultancy | 67 | 29 |  |  |  |  | 1 | 0 |  |  |  |  | 68 | 29 |  |  |
46 | M7490 - Other professional, scientific and technical activities n.e.c. | 145 | 62 |  |  |  |  | 4 | 0 |  |  |  |  | 149 | 62 |  |  |
47 | M Professional, scientific and technical activities | 59 | 27 |  |  |  |  | 6 | 4 |  |  |  |  | 65 | 31 |  |  |
48 | N7711 - Renting and leasing of cars and light motor vehicles | 716 | 41 |  |  |  |  | 0 | 0 |  |  |  |  | 716 | 41 |  |  |
49 | N7712 - Renting and leasing of trucks | 49 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 49 | 0 |  |  |
50 | N8211 - Combined office administrative service activities | 58 | 4 |  |  |  |  | 0 | 0 |  |  |  |  | 58 | 4 |  |  |
51 | N8299 - Other business support service activities n.e.c. | 196 | 65 |  |  |  |  | 0 | 0 |  |  |  |  | 196 | 65 |  |  |
52 | N Administrative and support service activities | 79 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 79 | 0 |  |  |
53 | O Public administration and defence, compulsory social security | 0 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 0 | 0 |  |  |
54 | P Education | 18 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 18 | 0 |  |  |
55 | Q Human health services and social work activities | 13 | 1 |  |  |  |  | 0 | 0 |  |  |  |  | 13 | 1 |  |  |
56 | R Arts, entertainment and recreation | 15 | 0 |  |  |  |  | 0 | 0 |  |  |  |  | 15 | 0 |  |  |
57 | S9609 - Other personal service activities n.e.c. | 70 | 3 |  |  |  |  | 0 | 0 |  |  |  |  | 70 | 3 |  |  |
58 | S Other services | 210 | 44 |  |  |  |  | 2 | 2 |  |  |  |  | 212 | 46 |  |  |

114 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 162

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3. GAR KPI stock (Capex) - 2025 114

% (compared to total covered assets in the denominator) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 66.5% | 7.1% | 6.3% | 1.9% | 0.3% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 66.5% | 7.1% | 6.3% | 1.9% | 0.3% | 33.4%
2 | Financial undertakings | 18.4% | 5.6% | 0.0% | 0.2% | 1.9% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 18.5% | 5.6% | 0.0% | 0.2% | 1.9% | 1.4%
3 | Credit institutions | 14.7% | 1.6% | 0.0% | 0.1% | 0.2% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 14.7% | 1.6% | 0.0% | 0.1% | 0.2% | 0.9%
4 | Loans and advances | 14.6% | 1.5% | 0.0% | 0.1% | 0.2% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 14.6% | 1.5% | 0.0% | 0.1% | 0.2% | 0.9%
5 | Debt securities, including UoP | 16.3% | 3.2% | 0.0% | 0.1% | 0.1% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 16.3% | 3.2% | 0.0% | 0.1% | 0.1% | 0.0%
6 | Equity instruments | 29.9% | 1.7% |  | 0.1% | 0.2% |  | 0.2% | 0.1% |  | 0.0% |  | 30.1% | 1.9% |  | 0.1% | 0.2% | 0.0%
7 | Other financial corporations | 26.1% | 13.7% | 0.0% | 0.4% | 5.6% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 26.2% | 13.7% | 0.0% | 0.4% | 5.6% | 0.4%
8 | of which investment firms | 33.2% | 17.0% | 0.0% | 0.0% | 6.1% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 33.3% | 17.0% | 0.0% | 0.0% | 6.1% | 0.1%
9 | Loans and advances | 34.0% | 17.5% | 0.0% | 0.0% | 6.3% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 34.1% | 17.5% | 0.0% | 0.0% | 6.3% | 0.1%
10 | Debt securities, including UoP | 7.9% | 1.5% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 7.9% | 1.5% | 0.0% | 0.0% | 0.0% | 0.0%
11 | Equity instruments | 26.3% | 0.8% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 26.3% | 0.8% |  | 0.0% | 0.0% | 0.0%
12 | of which management companies | 3.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 3.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
13 | Loans and advances | 3.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 3.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
14 | Debt securities, including UoP | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
15 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
16 | of which insurance undertakings | 7.6% | 0.7% | 0.0% | 0.0% | 0.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 7.6% | 0.7% | 0.0% | 0.0% | 0.1% | 0.1%
17 | Loans and advances | 8.9% | 0.6% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 9.0% | 0.6% | 0.0% | 0.0% | 0.0% | 0.1%
18 | Debt securities, including UoP | 1.9% | 1.5% | 0.0% | 0.0% | 0.4% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 1.9% | 1.5% | 0.0% | 0.0% | 0.4% | 0.0%
19 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
20 | Non-financial undertakings | 31.0% | 14.4% | 0.0% | 0.3% | 6.2% |  | 0.2% | 0.1% | 0.0% | 0.0% |  | 31.2% | 14.6% | 0.0% | 0.3% | 6.3% | 1.4%
21 | Loans and advances | 30.7% | 13.7% | 0.0% | 0.3% | 6.4% |  | 0.2% | 0.1% | 0.0% | 0.0% |  | 30.9% | 13.8% | 0.0% | 0.3% | 6.5% | 1.3%
22 | Debt securities, including UoP | 34.5% | 24.5% | 0.0% | 0.1% | 3.2% |  | 0.6% | 0.6% | 0.0% | 0.0% |  | 35.2% | 25.0% | 0.0% | 0.1% | 3.8% | 0.1%
23 | Equity instruments | 14.3% | 4.6% |  | 0.0% | 2.9% |  | 6.9% | 6.9% |  | 0.0% |  | 21.2% | 11.5% |  | 0.0% | 9.8% | 0.0%
24 | Households | 70.4% | 6.9% | 6.9% | 2.1% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 70.4% | 6.9% | 6.9% | 2.1% | 0.0% | 30.4%
25 | of which loans collateralised by residential immovable property | 92.0% | 8.2% | 8.2% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 92.0% | 8.2% | 8.2% | 0.0% | 0.0% | 17.9%
26 | of which building renovation loans | 100.0% | 0.2% | 0.2% | 0.2% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 100.0% | 0.2% | 0.2% | 0.2% | 0.0% | 0.1%
27 | of which motor vehicle loans | 100.0% | 12.9% | 12.9% | 12.9% | 0.0% |  |  |  |  |  |  |  |  |  |  |  |

Annual report 2025 163

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

% (compared to total covered assets in the denominator) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 46.3% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 46.3% | 0.0% | 0.0% | 0.0% | 0.0% | 0.2%
29 | Housing financing | 96.6% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 96.6% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
30 | Other local government financing | 44.5% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 44.5% | 0.0% | 0.0% | 0.0% | 0.0% | 0.2%
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 1.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 1.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.2%
32 | Total GAR assets | 31.3% | 3.4% | 3.0% | 0.9% | 0.2% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 31.3% | 3.4% | 3.0% | 0.9% | 0.2% | 70.9%

115 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 164

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3. GAR KPI stock (Turnover) - 2025 115

% (compared to total covered assets in the denominator) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 66.1% | 6.7% | 6.3% | 1.9% | 0.2% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 66.2% | 6.7% | 6.3% | 1.9% | 0.2% | 33.4%
2 | Financial undertakings | 17.3% | 3.6% | 0.0% | 0.1% | 1.4% |  | 1.3% | 0.1% | 0.0% | 0.1% |  | 18.6% | 3.7% | 0.0% | 0.1% | 1.5% | 1.4%
3 | Credit institutions | 16.9% | 2.8% | 0.0% | 0.1% | 0.7% |  | 0.3% | 0.2% | 0.0% | 0.2% |  | 17.2% | 3.0% | 0.0% | 0.1% | 0.9% | 0.9%
4 | Loans and advances | 16.9% | 2.7% | 0.0% | 0.1% | 0.8% |  | 0.3% | 0.2% | 0.0% | 0.2% |  | 17.2% | 2.9% | 0.0% | 0.1% | 0.9% | 0.9%
5 | Debt securities, including UoP | 15.6% | 5.8% | 0.0% | 0.1% | 0.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 15.7% | 5.8% | 0.0% | 0.1% | 0.1% | 0.0%
6 | Equity instruments | 29.9% | 1.5% |  | 0.1% | 0.6% |  | 0.2% | 0.1% |  | 0.1% |  | 30.1% | 1.7% |  | 0.1% | 0.7% | 0.0%
7 | Other financial corporations | 18.2% | 5.2% | 0.0% | 0.1% | 2.8% |  | 3.3% | 0.1% | 0.0% | 0.1% |  | 21.5% | 5.3% | 0.0% | 0.1% | 2.8% | 0.4%
8 | of which investment firms | 8.5% | 3.8% | 0.0% | 0.0% | 2.5% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 8.5% | 3.8% | 0.0% | 0.0% | 2.5% | 0.1%
9 | Loans and advances | 7.8% | 3.9% | 0.0% | 0.0% | 2.6% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 7.9% | 3.9% | 0.0% | 0.0% | 2.6% | 0.1%
10 | Debt securities, including UoP | 29.1% | 1.3% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 29.1% | 1.3% | 0.0% | 0.0% | 0.0% | 0.0%
11 | Equity instruments | 26.0% | 0.6% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 26.0% | 0.6% |  | 0.0% | 0.0% | 0.0%
12 | of which management companies | 49.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 49.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
13 | Loans and advances | 50.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 50.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
14 | Debt securities, including UoP | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
15 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
16 | of which insurance undertakings | 7.4% | 0.4% | 0.0% | 0.0% | 0.1% |  | 11.2% | 0.2% | 0.0% | 0.2% |  | 18.6% | 0.6% | 0.0% | 0.0% | 0.2% | 0.1%
17 | Loans and advances | 8.8% | 0.4% | 0.0% | 0.0% | 0.0% |  | 1.9% | 0.0% | 0.0% | 0.0% |  | 10.7% | 0.5% | 0.0% | 0.0% | 0.1% | 0.1%
18 | Debt securities, including UoP | 1.3% | 0.7% | 0.0% | 0.0% | 0.4% |  | 73.1% | 1.0% | 0.0% | 1.0% |  | 74.3% | 1.8% | 0.0% | 0.0% | 1.4% | 0.0%
19 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
20 | Non-financial undertakings | 24.6% | 7.5% | 0.0% | 0.3% | 4.0% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 24.8% | 7.5% | 0.0% | 0.3% | 4.0% | 1.4%
21 | Loans and advances | 25.2% | 7.1% | 0.0% | 0.3% | 4.1% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 25.3% | 7.1% | 0.0% | 0.3% | 4.1% | 1.3%
22 | Debt securities, including UoP | 17.7% | 12.8% | 0.0% | 0.0% | 2.1% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 17.9% | 12.8% | 0.0% | 0.0% | 2.1% | 0.1%
23 | Equity instruments | 3.0% | 2.5% |  | 0.0% | 1.8% |  | 18.2% | 18.2% |  | 18.2% |  | 21.2% | 20.8% |  | 0.0% | 20.1% | 0.0%
24 | Households | 70.4% | 6.9% | 6.9% | 2.1% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 70.4% | 6.9% | 6.9% | 2.1% | 0.0% | 30.4%
25 | of which loans collateralised by residential immovable property | 92.0% | 8.2% | 8.2% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 92.0% | 8.2% | 8.2% | 0.0% | 0.0% | 17.9%
26 | of which building renovation loans | 100.0% | 0.2% | 0.2% | 0.2% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 100.0% | 0.2% | 0.2% | 0.2% | 0.0% | 0.1%
27 | of which motor vehicle loans | 100.0% | 12.9% | 12.9% | 12.9% | 0.0% |  |  |  |  |  |  |  |  |  |  |  |

Annual report 2025 165

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

% (compared to total covered assets in the denominator) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 46.3% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 46.3% | 0.0% | 0.0% | 0.0% | 0.0% | 0.2%
29 | Housing financing | 96.6% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 96.6% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
30 | Other local government financing | 44.5% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 44.5% | 0.0% | 0.0% | 0.0% | 0.0% | 0.2%
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 1.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 1.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.2%
32 | Total GAR assets | 31.1% | 3.2% | 3.0% | 0.9% | 0.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 31.2% | 3.2% | 3.0% | 0.9% | 0.1% | 70.9%

Annual report 2025 166

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3. GAR KPI stock (Capex) - 2024

% (compared to total covered assets in the denominator) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 67.3% | 6.4% | 5.6% | 1.4% | 0.3% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 67.3% | 6.4% | 5.6% | 1.4% | 0.3% | 35.5%
2 | Financial undertakings | 22.3% | 6.3% | 0.0% | 0.1% | 1.7% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 22.4% | 6.3% | 0.0% | 0.1% | 1.7% | 1.4%
3 | Credit institutions | 18.3% | 1.7% | 0.0% | 0.0% | 0.1% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 18.4% | 1.7% | 0.0% | 0.0% | 0.1% | 1.0%
4 | Loans and advances | 18.4% | 1.7% | 0.0% | 0.0% | 0.1% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 18.4% | 1.7% | 0.0% | 0.0% | 0.1% | 0.9%
5 | Debt securities, including UoP | 17.3% | 1.4% | 0.0% | 0.0% | 0.0% |  | 1.0% | 0.0% | 0.0% | 0.0% |  | 18.2% | 1.4% | 0.0% | 0.0% | 0.0% | 0.1%
6 | Equity instruments | 30.9% | 3.4% |  | 0.0% | 0.0% |  | 0.1% | 0.0% |  | 0.0% |  | 31.0% | 3.5% |  | 0.0% | 0.0% | 0.0%
7 | Other financial corporations | 32.3% | 17.6% | 0.0% | 0.4% | 5.7% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 32.4% | 17.6% | 0.0% | 0.4% | 5.7% | 0.4%
8 | of which investment firms | 42.4% | 38.2% | 0.0% | 0.0% | 10.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 42.4% | 38.2% | 0.0% | 0.0% | 10.1% | 0.1%
9 | Loans and advances | 29.7% | 24.7% | 0.0% | 0.0% | 7.6% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 29.7% | 24.7% | 0.0% | 0.0% | 7.6% | 0.1%
10 | Debt securities, including UoP | 85.5% | 84.0% | 0.0% | 0.0% | 18.7% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 85.5% | 84.0% | 0.0% | 0.0% | 18.7% | 0.0%
11 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
12 | of which management companies | 39.3% | 3.0% | 0.0% | 0.0% | 1.9% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 39.3% | 3.0% | 0.0% | 0.0% | 1.9% | 0.0%
13 | Loans and advances | 34.6% | 1.7% | 0.0% | 0.0% | 1.6% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 34.6% | 1.7% | 0.0% | 0.0% | 1.6% | 0.0%
14 | Debt securities, including UoP | 50.7% | 5.7% | 0.0% | 0.0% | 2.6% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 50.7% | 5.7% | 0.0% | 0.0% | 2.6% | 0.0%
15 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
16 | of which insurance undertakings | 12.0% | 0.5% | 0.0% | 0.0% | 0.0% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 12.1% | 0.5% | 0.0% | 0.0% | 0.0% | 0.1%
17 | Loans and advances | 12.7% | 0.5% | 0.0% | 0.0% | 0.0% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 12.8% | 0.5% | 0.0% | 0.0% | 0.0% | 0.1%
18 | Debt securities, including UoP | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
19 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
20 | Non-financial undertakings | 40.9% | 15.0% | 0.0% | 2.3% | 6.3% |  | 0.3% | 0.1% | 0.0% | 0.0% |  | 41.1% | 15.1% | 0.0% | 2.3% | 6.3% | 1.5%
21 | Loans and advances | 41.5% | 14.5% | 0.0% | 2.5% | 5.7% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 41.7% | 14.6% | 0.0% | 2.5% | 5.7% | 1.4%
22 | Debt securities, including UoP | 32.8% | 22.2% | 0.0% | 0.1% | 13.9% |  | 0.4% | 0.4% | 0.0% | 0.0% |  | 33.2% | 22.7% | 0.0% | 0.1% | 13.9% | 0.1%
23 | Equity instruments | 9.6% | 9.5% |  | 0.0% | 4.6% |  | 0.0% | 0.0% |  | 0.0% |  | 9.6% | 9.5% |  | 0.0% | 4.6% | 0.0%
24 | Households | 70.4% | 6.1% | 6.1% | 1.4% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 70.4% | 6.1% | 6.1% | 1.4% | 0.0% | 32.6%
25 | of which loans collateralised by residential immovable property | 91.3% | 7.8% | 7.8% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 91.3% | 7.8% | 7.8% | 0.0% | 0.0% | 19.4%
26 | of which building renovation loans | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.1%
27 | of which motor vehicle loans | 100.0% | 9.2% | 9.2% | 9.2% | 0.0% |  |  |  |  |  |  |  |  |  |  |  |

Annual report 2025 167

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

% (compared to total covered assets in the denominator) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 83.4% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 83.4% | 0.0% | 0.0% | 0.0% | 0.0% | 0.1%
29 | Housing financing | 99.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 99.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
30 | Other local government financing | 81.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 81.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.1%
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.3%
32 | Total GAR assets | 34.2% | 3.3% | 2.8% | 0.7% | 0.2% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 34.2% | 3.3% | 2.8% | 0.7% | 0.2% | 69.8%

Annual report 2025 168

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

3. GAR KPI stock (Turnover) - 2024

% (compared to total covered assets in the denominator) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportio n of total assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 66.8% | 6.0% | 5.6% | 1.3% | 0.2% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 66.9% | 6.0% | 5.6% | 1.3% | 0.2% | 35.5%
2 | Financial undertakings | 19.3% | 3.0% | 0.0% | 0.0% | 1.1% |  | 1.1% | 0.1% | 0.0% | 0.0% |  | 20.4% | 3.1% | 0.0% | 0.0% | 1.1% | 1.4%
3 | Credit institutions | 17.9% | 1.5% | 0.0% | 0.0% | 0.0% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 18.1% | 1.5% | 0.0% | 0.0% | 0.0% | 1.0%
4 | Loans and advances | 18.0% | 1.5% | 0.0% | 0.0% | 0.0% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 18.0% | 1.6% | 0.0% | 0.0% | 0.0% | 0.9%
5 | Debt securities, including UoP | 17.4% | 1.4% | 0.0% | 0.0% | 0.0% |  | 1.0% | 0.0% | 0.0% | 0.0% |  | 18.4% | 1.4% | 0.0% | 0.0% | 0.0% | 0.1%
6 | Equity instruments | 31.0% | 3.2% |  | 0.0% | 0.0% |  | 0.1% | 0.0% |  | 0.0% |  | 31.1% | 3.3% |  | 0.0% | 0.0% | 0.0%
7 | Other financial corporations | 22.6% | 6.8% | 0.0% | 0.0% | 3.7% |  | 3.6% | 0.3% | 0.0% | 0.0% |  | 26.2% | 7.0% | 0.0% | 0.0% | 3.8% | 0.4%
8 | of which investment firms | 17.1% | 11.4% | 0.0% | 0.0% | 6.1% |  | 1.9% | 0.2% | 0.0% | 0.1% |  | 18.9% | 11.6% | 0.0% | 0.0% | 6.2% | 0.1%
9 | Loans and advances | 9.8% | 3.8% | 0.0% | 0.0% | 2.7% |  | 2.4% | 0.3% | 0.0% | 0.1% |  | 12.2% | 4.1% | 0.0% | 0.0% | 2.7% | 0.1%
10 | Debt securities, including UoP | 41.7% | 37.4% | 0.0% | 0.0% | 18.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 41.7% | 37.4% | 0.0% | 0.0% | 18.0% | 0.0%
11 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
12 | of which management companies | 47.1% | 2.4% | 0.0% | 0.0% | 1.5% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 47.3% | 2.4% | 0.0% | 0.0% | 1.5% | 0.0%
13 | Loans and advances | 68.4% | 3.4% | 0.0% | 0.0% | 2.1% |  | 0.3% | 0.0% | 0.0% | 0.0% |  | 68.7% | 3.4% | 0.0% | 0.0% | 2.1% | 0.0%
14 | Debt securities, including UoP | 1.5% | 0.2% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 1.5% | 0.2% | 0.0% | 0.0% | 0.0% | 0.0%
15 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
16 | of which insurance undertakings | 11.9% | 0.3% | 0.0% | 0.0% | 0.0% |  | 10.7% | 0.7% | 0.0% | 0.0% |  | 22.6% | 1.1% | 0.0% | 0.0% | 0.0% | 0.1%
17 | Loans and advances | 12.6% | 0.4% | 0.0% | 0.0% | 0.0% |  | 11.3% | 0.8% | 0.0% | 0.0% |  | 23.9% | 1.1% | 0.0% | 0.0% | 0.0% | 0.1%
18 | Debt securities, including UoP | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
19 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
20 | Non-financial undertakings | 32.9% | 6.6% | 0.0% | 0.4% | 4.0% |  | 0.3% | 0.1% | 0.0% | 0.1% |  | 33.2% | 6.7% | 0.0% | 0.4% | 4.1% | 1.5%
21 | Loans and advances | 34.2% | 6.3% | 0.0% | 0.4% | 3.6% |  | 0.3% | 0.1% | 0.0% | 0.1% |  | 34.5% | 6.3% | 0.0% | 0.4% | 3.6% | 1.4%
22 | Debt securities, including UoP | 15.2% | 11.7% | 0.0% | 0.0% | 10.4% |  | 0.3% | 0.2% | 0.0% | 0.0% |  | 15.6% | 11.9% | 0.0% | 0.0% | 10.4% | 0.1%
23 | Equity instruments | 6.0% | 4.3% |  | 0.0% | 3.0% |  | 0.0% | 0.0% |  | 0.0% |  | 6.0% | 4.3% |  | 0.0% | 3.0% | 0.0%
24 | Households | 70.4% | 6.1% | 6.1% | 1.4% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 70.4% | 6.1% | 6.1% | 1.4% | 0.0% | 32.6%
25 | of which loans collateralised by residential immovable property | 91.3% | 7.8% | 7.8% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 91.3% | 7.8% | 7.8% | 0.0% | 0.0% | 19.4%
26 | of which building renovation loans | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.1%
27 | of which motor vehicle loans | 100.0% | 9.2% | 9.2% | 9.2% | 0.0% |  |  |  |  |  |  |  |  |  |  |  |

Annual report 2025 169

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

% (compared to total covered assets in the denominator) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportio n of total assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 83.4% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 83.4% | 0.0% | 0.0% | 0.0% | 0.0% | 0.1%
29 | Housing financing | 99.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 99.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
30 | Other local government financing | 81.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 81.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.1%
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.3%
32 | Total GAR assets | 34.0% | 3.0% | 2.8% | 0.7% | 0.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 34.0% | 3.0% | 2.8% | 0.7% | 0.1% | 69.8%

116 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 170

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

4. GAR KPI flow (Capex) - 2025 116

% (compared to total covered assets in the denominator) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total new assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 63.9% | 9.9% | 7.0% | 4.0% | 1.2% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 64.0% | 9.9% | 7.0% | 4.0% | 1.2% | 26.0%
2 | Financial undertakings | 16.0% | 5.9% | 0.0% | 0.2% | 2.2% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 16.0% | 5.9% | 0.0% | 0.2% | 2.2% | 3.0%
3 | Credit institutions | 10.6% | 1.3% | 0.0% | 0.1% | 0.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 10.6% | 1.3% | 0.0% | 0.1% | 0.1% | 2.0%
4 | Loans and advances | 10.6% | 1.2% | 0.0% | 0.1% | 0.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 10.7% | 1.2% | 0.0% | 0.1% | 0.1% | 2.0%
5 | Debt securities, including UoP | 10.1% | 3.9% | 0.0% | 0.1% | 0.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 10.1% | 3.9% | 0.0% | 0.1% | 0.1% | 0.0%
6 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
7 | Other financial corporations | 33.9% | 21.3% | 0.0% | 0.4% | 9.1% |  | 0.1% | 0.1% | 0.0% | 0.0% |  | 34.0% | 21.3% | 0.0% | 0.4% | 9.1% | 1.0%
8 | of which investment firms | 15.6% | 7.6% | 0.0% | 0.0% | 2.3% |  | 0.3% | 0.1% | 0.0% | 0.0% |  | 15.9% | 7.7% | 0.0% | 0.0% | 2.3% | 0.0%
9 | Loans and advances | 15.1% | 7.7% | 0.0% | 0.0% | 2.4% |  | 0.3% | 0.1% | 0.0% | 0.0% |  | 15.4% | 7.8% | 0.0% | 0.0% | 2.4% | 0.0%
10 | Debt securities, including UoP | 37.9% | 4.2% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 37.9% | 4.2% | 0.0% | 0.0% | 0.0% | 0.0%
11 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
12 | of which management companies | 14.4% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 14.4% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
13 | Loans and advances | 14.4% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 14.4% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
14 | Debt securities, including UoP | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
15 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
16 | of which insurance undertakings | 1.9% | 1.5% | 0.0% | 0.0% | 0.4% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 1.9% | 1.5% | 0.0% | 0.0% | 0.4% | 0.0%
17 | Loans and advances | 5.2% | 0.3% | 0.0% | 0.0% | 0.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 5.2% | 0.3% | 0.0% | 0.0% | 0.1% | 0.0%
18 | Debt securities, including UoP | 1.9% | 1.5% | 0.0% | 0.0% | 0.4% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 1.9% | 1.5% | 0.0% | 0.0% | 0.4% | 0.0%
19 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
20 | Non-financial undertakings | 32.8% | 19.6% | 0.0% | 0.4% | 8.1% |  | 0.2% | 0.1% | 0.0% | 0.1% |  | 33.0% | 19.8% | 0.0% | 0.4% | 8.2% | 3.0%
21 | Loans and advances | 32.7% | 18.9% | 0.0% | 0.5% | 8.6% |  | 0.2% | 0.1% | 0.0% | 0.0% |  | 32.9% | 19.0% | 0.0% | 0.5% | 8.7% | 3.0%
22 | Debt securities, including UoP | 34.0% | 28.0% | 0.0% | 0.0% | 1.5% |  | 0.9% | 0.8% | 0.0% | 0.8% |  | 34.9% | 28.9% | 0.0% | 0.0% | 2.3% | 0.0%
23 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
24 | Households | 75.4% | 9.1% | 9.1% | 5.1% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 75.4% | 9.1% | 9.1% | 5.1% | 0.0% | 20.0%
25 | of which loans collateralised by residential immovable property | 96.6% | 9.2% | 9.2% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 96.6% | 9.2% | 9.2% | 0.0% | 0.0% | 9.0%
26 | of which building renovation loans | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
27 | of which motor vehicle loans | 100.0% | 15.3% | 15.3% | 15.3% | 0.0% |  |  |  |  |  |  | 100.0% | 15.3% | 15.3% | 15.3% | 0.0% | 7.0%

Annual report 2025 171

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

% (compared to total covered assets in the denominator) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total new assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 40.6% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 40.6% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
29 | Housing financing | 67.4% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 67.4% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
30 | Other local government financing | 40.5% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 40.5% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
32 | Total GAR assets | 24.8% | 3.8% | 2.7% | 1.6% | 0.5% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 24.8% | 3.8% | 2.7% | 1.6% | 0.5% | 67.8%

117 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 172

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

4. GAR KPI flow (Turnover) - 2025 117

% (compared to total covered assets in the denominator) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total new assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 62.9% | 8.5% | 7.0% | 4.0% | 0.8% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 63.1% | 8.5% | 7.0% | 4.0% | 0.8% | 26.0%
2 | Financial undertakings | 18.4% | 4.2% | 0.0% | 0.1% | 1.9% |  | 2.0% | 0.2% | 0.0% | 0.2% |  | 20.4% | 4.4% | 0.0% | 0.1% | 2.1% | 3.0%
3 | Credit institutions | 16.5% | 2.6% | 0.0% | 0.1% | 1.1% |  | 0.4% | 0.3% | 0.0% | 0.3% |  | 17.0% | 2.9% | 0.0% | 0.1% | 1.3% | 2.0%
4 | Loans and advances | 16.7% | 2.6% | 0.0% | 0.1% | 1.1% |  | 0.4% | 0.3% | 0.0% | 0.3% |  | 17.1% | 2.9% | 0.0% | 0.1% | 1.3% | 2.0%
5 | Debt securities, including UoP | 9.9% | 3.7% | 0.0% | 0.1% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 9.9% | 3.7% | 0.0% | 0.1% | 0.0% | 0.0%
6 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
7 | Other financial corporations | 24.6% | 9.4% | 0.0% | 0.1% | 4.5% |  | 7.3% | 0.1% | 0.0% | 0.1% |  | 31.9% | 9.5% | 0.0% | 0.1% | 4.6% | 1.0%
8 | of which investment firms | 4.5% | 1.6% | 0.0% | 0.1% | 0.9% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 4.5% | 1.6% | 0.0% | 0.1% | 0.9% | 0.0%
9 | Loans and advances | 3.7% | 1.5% | 0.0% | 0.1% | 0.9% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 3.7% | 1.5% | 0.0% | 0.1% | 0.9% | 0.0%
10 | Debt securities, including UoP | 37.7% | 4.1% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 37.7% | 4.1% | 0.0% | 0.0% | 0.0% | 0.0%
11 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
12 | of which management companies | 0.3% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.3% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
13 | Loans and advances | 0.3% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.3% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
14 | Debt securities, including UoP | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
15 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
16 | of which insurance undertakings | 1.3% | 0.7% | 0.0% | 0.0% | 0.4% |  | 73.0% | 1.0% | 0.0% | 1.0% |  | 74.2% | 1.8% | 0.0% | 0.0% | 1.4% | 0.0%
17 | Loans and advances | 5.1% | 0.2% | 0.0% | 0.0% | 0.0% |  | 14.6% | 0.3% | 0.0% | 0.2% |  | 19.7% | 0.5% | 0.0% | 0.0% | 0.3% | 0.0%
18 | Debt securities, including UoP | 1.3% | 0.7% | 0.0% | 0.0% | 0.4% |  | 73.1% | 1.0% | 0.0% | 1.0% |  | 74.3% | 1.8% | 0.0% | 0.0% | 1.4% | 0.0%
19 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
20 | Non-financial undertakings | 22.0% | 8.8% | 0.0% | 0.3% | 4.9% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 22.1% | 8.8% | 0.0% | 0.3% | 4.9% | 3.0%
21 | Loans and advances | 22.5% | 8.3% | 0.0% | 0.4% | 5.2% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 22.6% | 8.3% | 0.0% | 0.4% | 5.3% | 3.0%
22 | Debt securities, including UoP | 15.6% | 14.5% | 0.0% | 0.0% | 0.3% |  | 0.4% | 0.0% | 0.0% | 0.0% |  | 16.0% | 14.5% | 0.0% | 0.0% | 0.3% | 0.0%
23 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
24 | Households | 75.4% | 9.1% | 9.1% | 5.1% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 75.4% | 9.1% | 9.1% | 5.1% | 0.0% | 20.0%
25 | of which loans collateralised by residential immovable property | 96.6% | 9.2% | 9.2% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 96.6% | 9.2% | 9.2% | 0.0% | 0.0% | 9.0%
26 | of which building renovation loans | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
27 | of which motor vehicle loans | 100.0% | 15.3% | 15.3% | 15.3% | 0.0% |  |  |  |  |  |  | 100.0% | 15.3% | 15.3% | 15.3% | 0.0% | 7.0%

Annual report 2025 173

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

% (compared to total covered assets in the denominator) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total new assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 40.6% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 40.6% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
29 | Housing financing | 67.4% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 67.4% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
30 | Other local government financing | 40.5% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 40.5% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
32 | Total GAR assets | 24.4% | 3.3% | 2.7% | 1.5% | 0.3% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 24.5% | 3.3% | 2.7% | 1.5% | 0.3% | 67.8%

Annual report 2025 174

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

4. GAR KPI flow (Capex) - 2024

% (compared to total covered assets in the denominator) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total new assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 58.1% | 8.8% | 5.5% | 4.2% | 1.3% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 58.2% | 8.8% | 5.5% | 4.2% | 1.3% | 25.0%
2 | Financial undertakings | 25.5% | 10.2% | 0.0% | 0.2% | 2.6% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 25.7% | 10.2% | 0.0% | 0.2% | 2.6% | 2.0%
3 | Credit institutions | 17.8% | 1.8% | 0.0% | 0.0% | 0.1% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 18.0% | 1.8% | 0.0% | 0.0% | 0.1% | 2.0%
4 | Loans and advances | 17.5% | 1.8% | 0.0% | 0.0% | 0.1% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 17.5% | 1.8% | 0.0% | 0.0% | 0.1% | 2.0%
5 | Debt securities, including UoP | 27.2% | 2.5% | 0.0% | 0.0% | 0.0% |  | 5.3% | 0.0% | 0.0% | 0.0% |  | 32.5% | 2.5% | 0.0% | 0.0% | 0.0% | 0.0%
6 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
7 | Other financial corporations | 57.3% | 44.6% | 0.0% | 1.2% | 13.2% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 57.3% | 44.6% | 0.0% | 1.2% | 13.2% | 0.0%
8 | of which investment firms | 92.7% | 91.2% | 0.0% | 0.0% | 21.2% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 92.7% | 91.2% | 0.0% | 0.0% | 21.2% | 0.0%
9 | Loans and advances | 71.1% | 66.5% | 0.0% | 0.0% | 20.3% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 71.1% | 66.5% | 0.0% | 0.0% | 20.3% | 0.0%
10 | Debt securities, including UoP | 97.3% | 96.4% | 0.0% | 0.0% | 21.4% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 97.3% | 96.4% | 0.0% | 0.0% | 21.4% | 0.0%
11 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
12 | of which management companies | 54.5% | 7.7% | 0.0% | 0.0% | 4.9% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 54.5% | 7.7% | 0.0% | 0.0% | 4.9% | 0.0%
13 | Loans and advances | 70.3% | 15.7% | 0.0% | 0.0% | 14.1% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 70.4% | 15.7% | 0.0% | 0.0% | 14.1% | 0.0%
14 | Debt securities, including UoP | 50.7% | 5.7% | 0.0% | 0.0% | 2.6% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 50.7% | 5.7% | 0.0% | 0.0% | 2.6% | 0.0%
15 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
16 | of which insurance undertakings | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
17 | Loans and advances | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
18 | Debt securities, including UoP | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
19 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
20 | Non-financial undertakings | 37.9% | 20.5% | 0.0% | 3.9% | 9.0% |  | 0.2% | 0.1% | 0.0% | 0.0% |  | 38.1% | 20.6% | 0.0% | 3.9% | 9.1% | 3.0%
21 | Loans and advances | 38.2% | 19.8% | 0.0% | 4.3% | 8.2% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 38.4% | 19.9% | 0.0% | 4.3% | 8.2% | 3.0%
22 | Debt securities, including UoP | 35.3% | 26.9% | 0.0% | 0.0% | 17.2% |  | 0.6% | 0.6% | 0.0% | 0.1% |  | 36.0% | 27.5% | 0.0% | 0.0% | 17.3% | 0.0%
23 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
24 | Households | 64.4% | 6.9% | 6.9% | 4.7% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 64.4% | 6.9% | 6.9% | 4.7% | 0.0% | 20.0%
25 | of which loans collateralised by residential immovable property | 93.1% | 6.1% | 6.1% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 93.1% | 6.1% | 6.1% | 0.0% | 0.0% | 7.0%
26 | of which building renovation loans | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
27 | of which motor vehicle loans | 100.0% | 15.4% | 15.4% | 15.4% | 0.0% |  |  |  |  |  |  | 100.0% | 15.4% | 15.4% | 15.4% | 0.0% | 6.0%

Annual report 2025 175

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

% (compared to total covered assets in the denominator) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total new assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 97.7% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 97.7% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
29 | Housing financing | 94.4% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 94.4% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
30 | Other local government financing | 98.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 98.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
32 | Total GAR assets | 22.2% | 3.3% | 2.1% | 1.6% | 0.5% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 22.2% | 3.3% | 2.1% | 1.6% | 0.5% | 65.9%

Annual report 2025 176

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

4. GAR KPI flow (Turnover) - 2024

% (compared to total covered assets in the denominator) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total new assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
| GAR - Covered assets in both numerator and denominator |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
1 | Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation | 56.6% | 6.9% | 5.5% | 3.8% | 0.8% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 56.7% | 6.9% | 5.5% | 3.8% | 0.8% | 25.0%
2 | Financial undertakings | 21.2% | 5.3% | 0.0% | 0.0% | 2.1% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 21.4% | 5.3% | 0.0% | 0.0% | 2.1% | 2.0%
3 | Credit institutions | 18.4% | 2.0% | 0.0% | 0.0% | 0.0% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 18.6% | 2.0% | 0.0% | 0.0% | 0.0% | 2.0%
4 | Loans and advances | 18.1% | 1.9% | 0.0% | 0.0% | 0.0% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 18.1% | 2.0% | 0.0% | 0.0% | 0.0% | 2.0%
5 | Debt securities, including UoP | 27.2% | 2.5% | 0.0% | 0.0% | 0.0% |  | 5.3% | 0.0% | 0.0% | 0.0% |  | 32.5% | 2.5% | 0.0% | 0.0% | 0.0% | 0.0%
6 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
7 | Other financial corporations | 33.0% | 18.9% | 0.0% | 0.1% | 10.6% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 33.1% | 18.9% | 0.0% | 0.1% | 10.6% | 0.0%
8 | of which investment firms | 42.5% | 37.2% | 0.0% | 0.0% | 18.3% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 42.5% | 37.2% | 0.0% | 0.0% | 18.3% | 0.0%
9 | Loans and advances | 20.8% | 10.0% | 0.0% | 0.0% | 7.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 20.8% | 10.0% | 0.0% | 0.0% | 7.0% | 0.0%
10 | Debt securities, including UoP | 47.1% | 43.0% | 0.0% | 0.0% | 20.7% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 47.1% | 43.0% | 0.0% | 0.0% | 20.7% | 0.0%
11 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
12 | of which management companies | 18.0% | 6.1% | 0.0% | 0.0% | 3.8% |  | 0.5% | 0.0% | 0.0% | 0.0% |  | 18.5% | 6.1% | 0.0% | 0.0% | 3.8% | 0.0%
13 | Loans and advances | 85.3% | 30.1% | 0.0% | 0.2% | 19.2% |  | 2.4% | 0.0% | 0.0% | 0.0% |  | 87.6% | 30.1% | 0.0% | 0.2% | 19.2% | 0.0%
14 | Debt securities, including UoP | 1.5% | 0.2% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 1.5% | 0.2% | 0.0% | 0.0% | 0.0% | 0.0%
15 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
16 | of which insurance undertakings | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 0.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
17 | Loans and advances | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 0.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
18 | Debt securities, including UoP | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
19 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
20 | Non-financial undertakings | 28.2% | 8.1% | 0.0% | 0.6% | 5.1% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 28.5% | 8.1% | 0.0% | 0.6% | 5.1% | 3.0%
21 | Loans and advances | 29.7% | 7.6% | 0.0% | 0.7% | 4.3% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 30.0% | 7.6% | 0.0% | 0.7% | 4.3% | 3.0%
22 | Debt securities, including UoP | 14.0% | 13.0% | 0.0% | 0.0% | 12.3% |  | 0.5% | 0.3% | 0.0% | 0.0% |  | 14.5% | 13.2% | 0.0% | 0.0% | 12.3% | 0.0%
23 | Equity instruments | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% |  | 0.0% |  | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0%
24 | Households | 64.4% | 6.9% | 6.9% | 4.7% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 64.4% | 6.9% | 6.9% | 4.7% | 0.0% | 20.0%
25 | of which loans collateralised by residential immovable property | 93.1% | 6.1% | 6.1% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 93.1% | 6.1% | 6.1% | 0.0% | 0.0% | 7.0%
26 | of which building renovation loans | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 100.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
27 | of which motor vehicle loans | 100.0% | 15.4% | 15.4% | 15.4% | 0.0% |  |  |  |  |  |  | 100.0% | 15.4% | 15.4% | 15.4% | 0.0% | 6.0%

Annual report 2025 177

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

% (compared to total covered assets in the denominator) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA) |
Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) |  | Of which towards taxonomy relevant sectors (Taxonomy-eligible) | Proportion of total new assets covered
| Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned) |  |  | Of which environmentally sustainable (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
28 | Local governments financing | 97.7% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 97.7% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
29 | Housing financing | 94.4% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 94.4% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
30 | Other local government financing | 98.1% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 98.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
31 | Collateral obtained by taking possession: residential and commercial immovable properties | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0%
32 | Total GAR assets | 21.6% | 2.6% | 2.1% | 1.5% | 0.3% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 21.6% | 2.6% | 2.1% | 1.5% | 0.3% | 65.9%

118 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 178

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

5. KPI off-balance sheet exposures (Capex stock) - 2025 118

% (compared to total eligible off-balance sheet assets) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
| Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
1 | Financial guarantees (FinGuar KPI) | 7.5% | 3.4% | 0.0% | 0.3% | 2.3% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 7.6% | 3.4% | 0.0% | 0.3% | 2.3%
2 | Assets under management (AuM KPI) | 9.8% | 2.7% | 0.0% | 0.1% | 1.1% |  | 0.1% | 0.1% | 0.0% | 0.0% |  | 9.9% | 2.7% | 0.0% | 0.1% | 1.2%

5. KPI off-balance sheet exposures (Turnover stock) - 2025 119

% (compared to total eligible off-balance sheet assets) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
| Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
1 | Financial guarantees (FinGuar KPI) | 5.5% | 1.6% | 0.0% | 0.1% | 1.2% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 5.6% | 1.7% | 0.0% | 0.1% | 1.2%
2 | Assets under management (AuM KPI) | 11.4% | 1.9% | 0.0% | 0.1% | 0.8% |  | 0.6% | 0.0% | 0.0% | 0.0% |  | 11.9% | 1.9% | 0.0% | 0.1% | 0.9%

119 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 0.03% and alignment below 0.007% in all cases).
Annual report 2025 179

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

5. KPI off-balance sheet exposures (Capex flow) - 2025 119

% (compared to total eligible off-balance sheet assets) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
| Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
1 | Financial guarantees (FinGuar KPI) | 11.3% | 4.7% | 0.0% | 0.0% | 3.9% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 11.5% | 4.7% | 0.0% | 0.0% | 3.9%
2 | Assets under management (AuM KPI) | 16.7% | 4.2% | 0.0% | 0.2% | 1.9% |  | 0.1% | 0.1% | 0.0% | 0.0% |  | 16.9% | 4.3% | 0.0% | 0.2% | 1.9%

5. KPI off-balance sheet exposures (Turnover flow) - 2025 120

% (compared to total eligible off-balance sheet assets) | 2025
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
| Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
1 | Financial guarantees (FinGuar KPI) | 8.4% | 1.7% | 0.0% | 0.0% | 1.5% |  | 0.0% | 0.0% | 0.0% | 0.0% |  | 8.4% | 1.7% | 0.0% | 0.0% | 1.5%
2 | Assets under management (AuM KPI) | 17.6% | 2.9% | 0.0% | 0.1% | 1.3% |  | 0.7% | 0.0% | 0.0% | 0.0% |  | 18.4% | 2.9% | 0.0% | 0.1% | 1.3%

Annual report 2025 180

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

5. KPI off-balance sheet exposures (Capex stock) - 2024

% (compared to total eligible off-balance sheet assets) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
| Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
1 | Financial guarantees (FinGuar KPI) | 7.6% | 3.4% | 0.0% | 0.3% | 2.3% |  | 0.2% | 0.1% | 0.0% | 0.0% |  | 7.8% | 3.5% | 0.0% | 0.3% | 2.3%
2 | Assets under management (AuM KPI) | 8.4% | 2.1% | 0.0% | 0.1% | 0.9% |  | 0.2% | 0.0% | 0.0% | 0.0% |  | 8.7% | 2.1% | 0.0% | 0.1% | 0.9%

5. KPI off-balance sheet exposures (Turnover stock) - 2024

% (compared to total eligible off-balance sheet assets) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
| Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
1 | Financial guarantees (FinGuar KPI) | 4.8% | 1.3% | 0.0% | 0.0% | 1.0% |  | 0.4% | 0.2% | 0.0% | 0.2% |  | 5.2% | 1.5% | 0.0% | 0.0% | 1.2%
2 | Assets under management (AuM KPI) | 8.2% | 1.3% | 0.0% | 0.0% | 0.5% |  | 0.5% | 0.0% | 0.0% | 0.0% |  | 8.7% | 1.3% | 0.0% | 0.0% | 0.5%

Annual report 2025 181

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

5. KPI off-balance sheet exposures (Capex flow) - 2024

% (compared to total eligible off-balance sheet assets) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
| Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
1 | Financial guarantees (FinGuar KPI) | 13.4% | 5.5% | 0.0% | 1.0% | 4.0% |  | 0.7% | 0.3% | 0.0% | 0.0% |  | 14.1% | 5.8% | 0.0% | 1.0% | 4.0%
2 | Assets under management (AuM KPI) | 9.7% | 2.1% | 0.0% | 0.1% | 0.9% |  | 0.4% | 0.0% | 0.0% | 0.0% |  | 10.0% | 2.1% | 0.0% | 0.1% | 0.9%

5. KPI off-balance sheet exposures (Turnover flow) - 2024

% (compared to total eligible off-balance sheet assets) | 2024
Climate Change Mitigation (CCM) |  | Climate Change Adaptation (CCA) |  | TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
| Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) |  |  | Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned)
|  | Of which Use of Proceeds | Of which transitional | Of which enabling |  |  |  | Of which Use of Proceeds | Of which enabling |  |  |  | Of which Use of Proceeds | Of which transitional | Of which enabling
1 | Financial guarantees (FinGuar KPI) | 7.0% | 2.5% | 0.0% | 0.0% | 2.0% |  | 0.1% | 0.0% | 0.0% | 0.0% |  | 7.1% | 2.5% | 0.0% | 0.0% | 2.0%
2 | Assets under management (AuM KPI) | 9.1% | 1.2% | 0.0% | 0.1% | 0.5% |  | 0.6% | 0.0% | 0.0% | 0.0% |  | 9.7% | 1.3% | 0.0% | 0.1% | 0.5%

120 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as
they are not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 1.7% and alignment below 0.07% in all cases).
Annual report 2025 182

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

6. The proportion of the insurance or reinsurance undertaking’s investments that are directed at funding, or are associated with, Taxonomy-aligned in relation to total investments -
2025 120

The weighted average value of all the investments of insurance or reinsurance undertakings that are directed at funding, or are associated with Taxonomy-aligned economic activities relative to the value of total assets covered by the KPI, with following weights for investments in undertakings per below: |  | The weighted average value of all the investments of insurance or reinsurance undertakings that are directed at funding, or are associated with Taxonomy-aligned economic activities, with following weights for investments in undertakings per below:
Turnover-based: % | 1.7% |  | Turnover-based: [EUR million] | 142
CapEx—based: % | 2.1% |  | CapEx-based: [EUR million] | 175
The percentage of assets covered by the KPI relative to total investments of insurance or reinsurance undertakings (total AuM). Excluding investments in sovereign entities. |  | The monetary value of assets covered by the KPI. Excluding investments in sovereign entities.
Coverage ratio: % | 35.9% |  | Coverage: [EUR million] | 8,388
Additional, complementary disclosures: breakdown of denominator of the KPI
The percentage of derivatives relative to total assets covered by the KPI. |  | The value in EUR millions of derivatives:.
X % | 0.4% |  | [EUR million] | 31
The proportion of exposures to financial and non-financial undertakings not subject to Articles 19a and 29a of Directive 2013/34/ EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings not subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 2.2% |  | For non-financial undertakings: [EUR million] | 181
For financial undertakings: | 32.2% |  | For financial undertakings: [EUR million] | 2,701
The proportion of exposures to financial and non-financial undertakings from non-EU countries not subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings from non-EU countries not subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 1.9% |  | For non-financial undertakings: [EUR million] | 155
For financial undertakings: | 3.3% |  | For financial undertakings: [EUR million] | 274
The proportion of exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 2.8% |  | For non-financial undertakings: [EUR million] | 231
For financial undertakings: | 33.7% |  | For financial undertakings: [EUR million] | 2,828
The proportion of exposures to other counterparties over total assets covered by the KPI: |  | Value of exposures to other counterparties:
X % | 23.7% |  | [EUR million] | 1,986
The proportion of the insurance or reinsurance undertaking’s investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders, that are directed at funding, or are associated with, Taxonomy-aligned economic activities: X % |  | The proportion of the insurance or reinsurance undertaking’s investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders, that are directed at funding, or are associated with, Taxonomy-aligned economic activities:
X % | 80.7% |  | [EUR million] | 6,772
The value of all the investments that are funding economic activities that are not Taxonomy-eligible relative to the value of total assets covered by the KPI: |  | Value of all the investments that are funding economic activities that are not Taxonomy-eligible:
X % | 92.1% |  | [EUR million] | 7,723
The value of all the investments that are funding taxonomy-eligible economic activities, but not taxonomy- aligned relative to the value of total assets covered by the KPI: |  | Value of all the investments that are funding Taxonomy- eligible economic activities, but not taxonomy- aligned:
X % | 6.2% |  | [EUR million] | 522

Annual report 2025 183

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Additional, complementary disclosures: breakdown of numerator of the KPI
The proportion of Taxonomy-aligned exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of Taxonomy-aligned exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: |  | For non-financial undertakings:
Turnover-based: % | 0.3% |  | Turnover-based: [EUR million] | 25
Capital expenditures-based: % | 0.5% |  | Capital expenditures-based: [EUR million] | 42
For financial undertakings: |  | For financial undertakings:
Turnover-based: % | 1.4% |  | Turnover-based: [EUR million] | 117
Capital expenditures-based: % | 1.6% |  | Capital expenditures-based: [EUR million] | 133
The proportion of the insurance or reinsurance undertaking’s investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders, that are directed at funding, or are associated with, Taxonomy-aligned: |  | Value of insurance or reinsurance undertaking’s investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders, that are directed at funding, or are associated with, Taxonomy-aligned:
Turnover-based: % | 1% |  | Turnover-based: [EUR million] | 106
Capital expenditures-based: % | 2% |  | Capital expenditures-based: [EUR million] | 130
The proportion of exposures to other counterparties and assets over total assets covered by the KPI: |  | Value of taxonomy-aligned exposures to other counterparties:
Turnover-based: % | 0% |  | Turnover-based: [EUR million] | 0
Capital expenditures-based: % | 0% |  | Capital expenditures-based: [EUR million] | 0
Breakdown of the numerator of the KPI per environmental objective
Taxonomy-aligned activities –:
(1) Climate change mitigation | Turnover: 1.7% |  | Transitional activities turnover: A% | 0.0%
| Transitional activities capex: A% | 0.1%
CapEx: 2.1% |  | Enabling activities turnover: B% | 0.9%
| Enabling activities capex: B% | 0.6%
(2) Climate change adaptation | Turnover: —% |  | Enabling activities turnover: A% | 0.0%
CapEx: —% |  | Enabling activities capex: B% | 0.0%

Annual report 2025 184

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

6. The proportion of the insurance or reinsurance undertaking’s investments that are directed at funding, or are associated with, Taxonomy-aligned in relation to total investments -
2024

The weighted average value of all the investments of insurance or reinsurance undertakings that are directed at funding, or are associated with Taxonomy-aligned economic activities relative to the value of total assets covered by the KPI, with following weights for investments in undertakings per below: |  | The weighted average value of all the investments of insurance or reinsurance undertakings that are directed at funding, or are associated with Taxonomy-aligned economic activities, with following weights for investments in undertakings per below:
Turnover-based: % | 1.4% |  | Turnover-based: [EUR million] | 125
CapEx—based: % | 2.1% |  | CapEx-based: [EUR million] | 177
The percentage of assets covered by the KPI relative to total investments of insurance or reinsurance undertakings (total AuM). Excluding investments in sovereign entities. |  | The monetary value of assets covered by the KPI. Excluding investments in sovereign entities.
Coverage ratio: % | 38.9% |  | Coverage: [EUR million] | 8,654
Additional, complementary disclosures: breakdown of denominator of the KPI
The percentage of derivatives relative to total assets covered by the KPI. |  | The value in EUR millions of derivatives:.
X % | 0.7% |  | [EUR million] | 61
The proportion of exposures to financial and non-financial undertakings not subject to Articles 19a and 29a of Directive 2013/34/ EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings not subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 1.4% |  | For non-financial undertakings: [EUR million] | 122
For financial undertakings: | 26.0% |  | For financial undertakings: [EUR million] | 2,249
The proportion of exposures to financial and non-financial undertakings from non-EU countries not subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings from non-EU countries not subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 1.7% |  | For non-financial undertakings: [EUR million] | 145
For financial undertakings: | 1.4% |  | For financial undertakings: [EUR million] | 121
The proportion of exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 4.6% |  | For non-financial undertakings: [EUR million] | 394
For financial undertakings: | 17.4% |  | For financial undertakings: [EUR million] | 1,502
The proportion of exposures to other counterparties over total assets covered by the KPI: |  | Value of exposures to other counterparties:
X % | 46.9% |  | [EUR million] | 4,060
The proportion of the insurance or reinsurance undertaking’s investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders, that are directed at funding, or are associated with, Taxonomy-aligned economic activities: X % |  | The proportion of the insurance or reinsurance undertaking’s investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders, that are directed at funding, or are associated with, Taxonomy-aligned economic activities:
X % | 80.9% |  | [EUR million] | 6,999
The value of all the investments that are funding economic activities that are not Taxonomy-eligible relative to the value of total assets covered by the KPI: |  | Value of all the investments that are funding economic activities that are not Taxonomy-eligible:
X % | 88.3% |  | [EUR million] | 7,639
The value of all the investments that are funding taxonomy-eligible economic activities, but not taxonomy- aligned relative to the value of total assets covered by the KPI: |  | Value of all the investments that are funding Taxonomy- eligible economic activities, but not taxonomy- aligned:
X % | 10.3% |  | [EUR million] | 890

Annual report 2025 185

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Additional, complementary disclosures: breakdown of numerator of the KPI
The proportion of Taxonomy-aligned exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of Taxonomy-aligned exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: |  | For non-financial undertakings:
Turnover-based: % | 0.5% |  | Turnover-based: [EUR million] | 47
Capital expenditures-based: % | 0.9% |  | Capital expenditures-based: [EUR million] | 74
For financial undertakings: |  | For financial undertakings:
Turnover-based: % | 0.9% |  | Turnover-based: [EUR million] | 78
Capital expenditures-based: % | 1.2% |  | Capital expenditures-based: [EUR million] | 103
The proportion of the insurance or reinsurance undertaking’s investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders, that are directed at funding, or are associated with, Taxonomy-aligned: |  | Value of insurance or reinsurance undertaking’s investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders, that are directed at funding, or are associated with, Taxonomy-aligned:
Turnover-based: % | * |  | Turnover-based: [EUR million] | *
Capital expenditures-based: % | * |  | Capital expenditures-based: [EUR million] | *
The proportion of exposures to other counterparties and assets over total assets covered by the KPI: |  | Value of taxonomy-aligned exposures to other counterparties:
Turnover-based: % | 0% |  | Turnover-based: [EUR million] | 0%
Capital expenditures-based: % | 0% |  | Capital expenditures-based: [EUR million] | 0%
Breakdown of the numerator of the KPI per environmental objective
Taxonomy-aligned activities –:
(1) Climate change mitigation | Turnover: 1.4% |  | Transitional activities turnover: A% | 0.0%
| Transitional activities capex: A% | 0.1%
CapEx: 2.0% |  | Enabling activities turnover: B% | 0.7%
| Enabling activities capex: B% | 0.7%
(2) Climate change adaptation | Turnover: —% |  | Enabling activities turnover: A% | 0.0%
CapEx: —% |  | Enabling activities capex: B% | 0.0%

* The value of these investments is 89M€ (1%) turnover-based and 125€ (1,4%) CapEx based. The calculation is based on the proportion of these investments with respect to the total portfolio.
121 Only assets under management from asset managers are included.
122 For presentation purposes, the breakdowns relating to the degree of portfolio alignment with the objectives of Biodiversity, Circular Economy, Pollution Prevention and Control, and Water and Marine Resources are not included in these templates, as they are
not material in the context of the Taxonomy disclosures, given that their impact on the GAR ratio is residual (eligibility below 1.30% and alignment below 0.02% in all cases).
Annual report 2025 186

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

7. Template: KPI for Asset Managers. 121 - 2025 122

Standard template for the disclosure required under Article 8 of Regulation (EU) 2020/852 (asset managers)
The weighted average value of all the investments that are directed at funding, or are associated with Taxonomy-aligned economic activities relative to the value of total assets covered by the KPI, with following weights for investments in undertakings per below: |  | The weighted average value of all the investments that are directed at funding, or are associated with taxonomy-aligned economic activities, with following weights for investments in undertakings per below:
Turnover-based: % | 2.4% |  | Turnover-based: [EUR million] | 3,466
CapEx—based: % | 3.5% |  | CapEx-based: [EUR million] | 4,954
The percentage of assets covered by the KPI relative to total investments (total AuM). Excluding investments in sovereign entities. |  | The monetary value of assets covered by the KPI. Excluding investments in sovereign entities.
Coverage ratio: % | 65.00% |  | Coverage: [EUR million] | 142,164
Additional, complementary disclosures: breakdown of denominator of the KPI
The percentage of derivatives relative to total assets covered by the KPI. |  | The value in EUR millions of derivatives:.
X % | 0.90% |  | [EUR million] | 1,336
The proportion of exposures to financial and non-financial undertakings not subject to Articles 19a and 29a of Directive 2013/34/ EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings not subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 9.3% |  | For non-financial undertakings: [EUR million] | 13,247
For financial undertakings: | 15.2% |  | For financial undertakings: [EUR million] | 21,664
The proportion of exposures to financial and non-financial undertakings from non-EU countries not subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings from non-EU countries not subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 16.4% |  | For non-financial undertakings: [EUR million] | 23,314
For financial undertakings: | 13.6% |  | For financial undertakings: [EUR million] | 19,393
The proportion of exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 11.2% |  | For non-financial undertakings: [EUR million] | 15,930
For financial undertakings: | 33.3% |  | For financial undertakings: [EUR million] | 47,278
The proportion of exposures to other counterparties over total assets covered by the KPI: |  | Value of exposures to other counterparties:
X % | 0.0% |  | [EUR million] | 0
The value of all the investments that are funding economic activities that are not Taxonomy-eligible relative to the value of total assets covered by the KPI: |  | Value of all the investments that are funding economic activities that are not Taxonomy-eligible:
X % | 87.3% |  | [EUR million] | 124,068
The value of all the investments that are funding taxonomy-eligible economic activities, but not taxonomy- aligned relative to the value of total assets covered by the KPI: |  | Value of all the investments that are funding Taxonomy- eligible economic activities, but not taxonomy- aligned:
X % | 10.3% |  | [EUR million] | 14,630

Annual report 2025 187

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Additional, complementary disclosures: breakdown of numerator of the KPI
The proportion of Taxonomy-aligned exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of Taxonomy-aligned exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: |  | For non-financial undertakings:
Turnover-based: % | 1.0% |  | Turnover-based: [EUR million] | 1,468
Capital expenditures-based: % | 1.9% |  | Capital expenditures-based: [EUR million] | 2,665
For financial undertakings: |  | For financial undertakings:
Turnover-based: % | 1.4% |  | Turnover-based: [EUR million] | 1,998
Capital expenditures-based: % | 1.6% |  | Capital expenditures-based: [EUR million] | 2,289
The proportion of exposures to other counterparties and assets over total assets covered by the KPI: |  | Value of taxonomy-aligned exposures to other counterparties:
Turnover-based: % | 0.0% |  | Turnover-based: [EUR million] | 0
Capital expenditures-based: % | 0.0% |  | Capital expenditures-based: [EUR million] | 0
Breakdown of the numerator of the KPI per environmental objective
Taxonomy-aligned activities –:
(1) Climate change mitigation | Turnover: 2.4% |  | Transitional activities turnover: A% | 0.10%
| Transitional activities capex: A% | 0.20%
CapEx: 3.4% |  | Enabling activities turnover: B% | 1.10%
| Enabling activities capex: B% | 1.50%
(2) Climate change adaptation | Turnover: —% |  | Enabling activities turnover: A% | 0.00%
CapEx: 0,1% |  | Enabling activities capex: B% | 0.00%

123 Only assets under management from asset managers are included.
Annual report 2025 188

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

7. Template: KPI for Asset Managers 123. - 2024

Standard template for the disclosure required under Article 8 of Regulation (EU) 2020/852 (asset managers)
The weighted average value of all the investments that are directed at funding, or are associated with Taxonomy-aligned economic activities relative to the value of total assets covered by the KPI, with following weights for investments in undertakings per below: |  | The weighted average value of all the investments that are directed at funding, or are associated with taxonomy-aligned economic activities, with following weights for investments in undertakings per below:
Turnover-based: % | 1.6% |  | Turnover-based: [EUR million] | 2,003
CapEx—based: % | 2.6% |  | CapEx-based: [EUR million] | 3,278
The percentage of assets covered by the KPI relative to total investments (total AuM). Excluding investments in sovereign entities. |  | The monetary value of assets covered by the KPI. Excluding investments in sovereign entities.
Coverage ratio: % | 62.10% |  | Coverage: [EUR million] | 125,892
Additional, complementary disclosures: breakdown of denominator of the KPI
The percentage of derivatives relative to total assets covered by the KPI. |  | The value in EUR millions of derivatives:.
X % | 0.00% |  | [EUR million] | 37
The proportion of exposures to financial and non-financial undertakings not subject to Articles 19a and 29a of Directive 2013/34/ EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings not subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 15.8% |  | For non-financial undertakings: [EUR million] | 19,863
For financial undertakings: | 18.7% |  | For financial undertakings: [EUR million] | 23,489
The proportion of exposures to financial and non-financial undertakings from non-EU countries not subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings from non-EU countries not subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 9.4% |  | For non-financial undertakings: [EUR million] | 11,776
For financial undertakings: | 17.7% |  | For financial undertakings: [EUR million] | 22,301
The proportion of exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: | 9.2% |  | For non-financial undertakings: [EUR million] | 11,637
For financial undertakings: | 29.1% |  | For financial undertakings: [EUR million] | 36,665
The proportion of exposures to other counterparties over total assets covered by the KPI: |  | Value of exposures to other counterparties:
X % | 0.1% |  | [EUR million] | 124
The value of all the investments that are funding economic activities that are not Taxonomy-eligible relative to the value of total assets covered by the KPI: |  | Value of all the investments that are funding economic activities that are not Taxonomy-eligible:
X % | 89.3% |  | [EUR million] | 112,424
The value of all the investments that are funding taxonomy-eligible economic activities, but not taxonomy- aligned relative to the value of total assets covered by the KPI: |  | Value of all the investments that are funding Taxonomy- eligible economic activities, but not taxonomy- aligned:
X % | 9.1% |  | [EUR million] | 11,465

Annual report 2025 189

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Additional, complementary disclosures: breakdown of numerator of the KPI
The proportion of Taxonomy-aligned exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI: |  | Value of Taxonomy-aligned exposures to financial and non-financial undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: |  | For non-financial undertakings:
Turnover-based: % | 0.8% |  | Turnover-based: [EUR million] | 959
Capital expenditures-based: % | 2.9% |  | Capital expenditures-based: [EUR million] | 3,609
For financial undertakings: |  | For financial undertakings:
Turnover-based: % | 0.8% |  | Turnover-based: [EUR million] | 1,044
Capital expenditures-based: % | 2.3% |  | Capital expenditures-based: [EUR million] | 2,947
The proportion of exposures to other counterparties and assets over total assets covered by the KPI: |  | Value of taxonomy-aligned exposures to other counterparties:
Turnover-based: % | 0.0% |  | Turnover-based: [EUR million] | 5
Capital expenditures-based: % | 0.0% |  | Capital expenditures-based: [EUR million] | 5
Breakdown of the numerator of the KPI per environmental objective
Taxonomy-aligned activities –:
(1) Climate change mitigation | Turnover: 1.5% |  | Transitional activities turnover: A% | 0.10%
| Transitional activities capex: A% | 0.70%
CapEx: 2.6% |  | Enabling activities turnover: B% | 0.10%
| Enabling activities capex: B% | 1.00%
(2) Climate change adaptation | Turnover: —% |  | Enabling activities turnover: A% | 0.00%
CapEx: —% |  | Enabling activities capex: B% | 0.00%

Annual report 2025 190

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

8. Consolidated KPI - 2025

|  |  | KPI per Business segment
| Revenue | Proportion of total group revenue | KPI turnover based | KPI CapEx based | KPI turnover based weighted | KPI CapEx based weighted
Asset management | 1,309 | 2.2% | 2.4% | 3.5% | 0.1% | 0.1%
Banking activities | 57,894 | 95.7% | 3.2% | 3.4% | 3.0% | 3.2%
Investment firms | 685 | 1.1% | 0.0% | 0.0% | 0.0% | 0.0%
Insurance undertakings | 638 | 1.1% | 1.7% | 2.1% | 0.0% | 0.0%
Total | 60,527 | 100.0% |  |  |  |
Average KPI |  |  |  |  | 3.1% | 3.3%

8. Consolidated KPI - 2024

|  |  | KPI per Business segment
| Revenue | Proportion of total group revenue | KPI turnover based | KPI CapEx based | KPI turnover based weighted | KPI CapEx based weighted
Asset management | 1,258 | 2.1% | 1.6% | 2.6% | 0.0% | 0.1%
Banking activities | 57,526 | 97.0% | 3.0% | 3.3% | 2.9% | 3.2%
Investment firms | 111 | 0.2% | 0.0% | 0.0% | 0.0% | 0.0%
Insurance undertakings | 440 | 0.7% | 1.4% | 2.1% | 0.0% | 0.0%
Total | 59,335 | 100.0% |  |  |  |
Average KPI |  |  |  |  | 3.0% | 3.2%

Annual report 2025 191

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities - 2025 (credit institution)

| Nuclear energy related activities |
1 | The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle. | YES
2 | The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies. | YES
3 | The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades. | YES
| Fossil gas related activities |
4 | The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels. | YES
5 | The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels. | YES
6 | The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels. | YES

Annual report 2025 192

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Capex - 2025

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 20 | 0.0% | 20 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 59 | 0.0% | 59 | 0.0% | 0 | 0.0%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 45,492 | 3.3% | 45,459 | 3.3% | 33 | 0.0%
8 | Total applicable KPI | 45,573 | 3.4% | 45,540 | 3.4% | 33 | 0.0%

Note 1: The denominator of the applicable KPI is 1.359.362.227.454 euros

9. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Turnover - 2025

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 88 | 0.0% | 88 | 0.0% | 0 | 0.0%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 43,039 | 3.2% | 42,995 | 3.2% | 44 | 0.0%
8 | Total applicable KPI | 43,129 | 3.2% | 43,085 | 3.2% | 44 | 0.0%

Note 1: The denominator of the applicable KPI is 1.359.362.227.454 euros

Annual report 2025 193

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Capex - 2025

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 20 | 0.0% | 20 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 59 | 0.1% | 59 | 0.1% | 0 | 0.0%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 45,492 | 99.8% | 45,459 | 99.8% | 33 | 0.1%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 45,573 | 100.0% | 45,540 | 99.9% | 33 | 0.1%

9. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Turnover - 2025

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 88 | 0.2% | 88 | 0.2% | 0 | 0.0%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 43,039 | 99.8% | 42,995 | 99.7% | 44 | 0.1%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 43,129 | 100.0% | 43,085 | 99.9% | 44 | 0.1%

Annual report 2025 194

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Capex- 2025

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 126 | 0.0% | 126 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 16 | 0.0% | 16 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 379,724 | 27.9% | 379685 | 27.9% | 39 | 0.0%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 379,866 | 27.9% | 379827 | 27.9% | 39 | 0.0%

9. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities -Turnover- 2025

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 69 | 0.0% | 69 | 0.0% | 0 | 0.0%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 480 | 0.0% | 480 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 32 | 0.0% | 32 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 380,009 | 28.0% | 379,676 | 27.9% | 333 | 0.0%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 380,591 | 28.0% | 380,258 | 28.0% | 333 | 0.0%

Annual report 2025 195

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Capex- 2025

|  | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 933,923 | 68.7%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 933,923 | 68.7%

9. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Turnover- 2025

|  | Amount | %
1 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
2 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
3 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
4 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
5 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
6 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
7 | Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 935,643 | 68.8%
8 | Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI | 935,643 | 68.8%

Annual report 2025 196

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities - 2024 (credit institution)

| Nuclear energy related activities |
1 | The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle. | YES
2 | The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies. | YES
3 | The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades. | YES
| Fossil gas related activities |
4 | The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels. | YES
5 | The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels. | YES
6 | The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels. | YES

Annual report 2025 197

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Capex - 2024

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 4 | 0.0% | 4 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 28 | 0.0% | 28 | 0.0% | 0 | 0.0%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 42,800 | 3.3% | 42,784 | 3.3% | 17 | 0.0%
8 | Total applicable KPI | 42,834 | 3.3% | 42,818 | 3.3% | 17 | 0.0%

Note 1: The denominator of the applicable KPI is 1.306.541.919.505 euros

9. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Turnover - 2024

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 36 | 0.0% | 36 | 0.0% | 0 | 0.0%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 39,620 | 3.0% | 39,578 | 3.0% | 41 | 0.0%
8 | Total applicable KPI | 39,656 | 3.0% | 39,615 | 3.0% | 41 | 0.0%

Note 1: The denominator of the applicable KPI is 1.306.541.919.505 euros

Annual report 2025 198

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Capex - 2024

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 4 | 0.0% | 4 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 28 | 0.1% | 28 | 0.1% | 0 | 0.0%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 42,800 | 99.9% | 42,784 | 99.9% | 17 | 0.0%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 42,834 | 100.0% | 42,818 | 100.0% | 17 | 0.0%

9. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Turnover - 2024

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 36 | 0.1% | 36 | 0.1% | 0 | 0.0%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 39,620 | 99.9% | 39,578 | 99.8% | 41 | 0.1%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 39,656 | 100.0% | 39,615 | 99.9% | 41 | 0.1%

Annual report 2025 199

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Capex- 2024

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 17 | 0.0% | 17 | 0.0% | 0 | 0.0%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 80 | 0.0% | 80 | 0.0% | 0 | 0.0%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 23 | 0.0% | 23 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 404,304 | 30.9% | 404220 | 30.9% | 84 | 0.0%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 404,424 | 31.0% | 404340 | 30.9% | 84 | 0.0%

9. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities -Turnover- 2024

|  | CCM+CCA | CCM | CCA
| Nuclear energy related activities | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1 | 0.0% | 1 | 0.0% | 0 | 0.0%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 70 | 0.0% | 70 | 0.0% | 0 | 0.0%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 833 | 0.1% | 833 | 0.1% | 0 | 0.0%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 41 | 0.0% | 41 | 0.0% | 0 | 0.0%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0% | 0 | 0.0% | 0 | 0.0%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 403,901 | 30.9% | 403,577 | 30.9% | 324 | 0.0%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 404,846 | 31.0% | 404,523 | 31.0% | 324 | 0.0%

Annual report 2025 200

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

9. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Capex- 2024

|  | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 859,283 | 65.8%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 859,283 | 65.8%

9. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Turnover- 2024

|  | Amount | %
1 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
2 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
3 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
4 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
5 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
6 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0.0%
7 | Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 862,039 | 66.0%
8 | Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI | 862,039 | 66.0%

Annual report 2025 201

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

10. Nuclear and fossil gas related activities - 2025 (insurance)

| Nuclear energy related activities |
1 | The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle. | NO
2 | The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies. | NO
3 | The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades. | NO
| Fossil gas related activities |
4 | The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels. | YES
5 | The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels. | YES
6 | The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels. | NO

10. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Capex- 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 175.5 | 2.09% | 173.6 | 2.07% | 1.9 | 0.02%
8 | Total applicable KPI | 175.5 | 2.09% | 173.6 | 2.07% | 1.9 | 0.02%

Note 1: The denominator of the applicable KPI is 8,388 million euros.
10. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Turnover- 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 142.4 | 1.70% | 141.6 | 1.69% | 0.8 | 0.01%
8 | Total applicable KPI | 142.4 | 1.70% | 141.6 | 1.69% | 0.8 | 0.01%

Note 1: The denominator of the applicable KPI is 8,388 million euros.
Annual report 2025 202

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

10. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Capex- 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 175.5 | 100.00% | 173.6 | 98.91% | 1.9 | 1.09%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 175.5 | 100.00% | 173.6 | 98.91% | 1.9 | 1.09%

10. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Turnover- 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 142.4 | 100.00% | 141.6 | 99.45% | 0.8 | 0.55%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 142.4 | 100.00% | 141.6 | 99.45% | 0.8 | 0.55%

Annual report 2025 203

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

10. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Capex - 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 442.2 | 5.27% | 441.1 | 5.26% | 1.1 | 0.01%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 442.2 | 5.27% | 441.1 | 5.26% | 1.1 | 0.01%

10. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Turnover-2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.1 | 0.00% | 0.1 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 521.0 | 6.21% | 494.0 | 5.89% | 27.0 | 0.32%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 521.1 | 6.21% | 494.1 | 5.89% | 27.0 | 0.32%

Annual report 2025 204

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

10. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Capex- 2025

| Nuclear energy related activities | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI |  | 0
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI |  | 0
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI |  | 0
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI |  | 0
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI |  | 0
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI |  | 0
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 7,768.0 | 92.61%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 7,768.0 | 92.61%

10. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Turnover - 2025

| Nuclear energy related activities | Amount | %
1 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
2 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
3 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
4 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
5 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
6 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 7,723.0 | 92.08%
8 | Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI | 7,723.0 | 92.08%

Annual report 2025 205

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

10. Nuclear and fossil gas related activities - 2024 (insurance)

| Nuclear energy related activities |
1 | The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle. | NO
2 | The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies. | NO
3 | The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades. | NO
| Fossil gas related activities |
4 | The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels. | YES
5 | The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels. | YES
6 | The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels. | NO

10. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Capex- 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 177.4 | 2.05% | 177.3 | 2.05% | 0.1 | 0.00%
8 | Total applicable KPI | 177.4 | 2.05% | 177.3 | 2.05% | 0.1 | 0.00%

Note 1: The denominator of the applicable KPI is 8,654 million euros..
10. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Turnover- 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 125.2 | 1.45% | 124.3 | 1.44% | 0.8 | 0.01%
8 | Total applicable KPI | 125.2 | 1.45% | 124.3 | 1.44% | 0.8 | 0.01%

Note 1: The denominator of the applicable KPI is 8,654 million euros..
Annual report 2025 206

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

10. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Capex- 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 177.4 | 100.00% | 177.3 | 99.94% | 0.1 | 0.06%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 177.4 | 100.00% | 177.3 | 99.94% | 0.1 | 0.06%

10. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Turnover- 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 125.2 | 100.00% | 124.3 | 99.33% | 0.8 | 0.67%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 125.2 | 100.00% | 124.3 | 99.33% | 0.8 | 0.67%

Annual report 2025 207

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

10. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Capex - 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 895.8 | 10.35% | 892.8 | 10.32% | 3.0 | 0.03%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 895.9 | 10.35% | 892.8 | 10.32% | 3.0 | 0.03%

10. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Turnover-2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.1 | 0.00% | 0.1 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 889.4 | 10.28% | 870.0 | 10.05% | 19.5 | 0.22%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 889.5 | 10.28% | 870.1 | 10.05% | 19.5 | 0.22%

Annual report 2025 208

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

10. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Capex- 2024

| Nuclear energy related activities | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0 | 0
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 7,580.8 | 87.60%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 7,580.8 | 87.60%

10. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Turnover - 2024

| Nuclear energy related activities | Amount | %
1 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
2 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
3 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
4 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
5 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
6 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 7,638.6 | 88.27%
8 | Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI | 7,638.6 | 88.27%

Annual report 2025 209

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

11. Nuclear and fossil gas related activities- 2025 (asset manager)

| Nuclear energy related activities |
1 | The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle. | YES
2 | The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies. | YES
3 | The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades. | YES
| Fossil gas related activities |
4 | The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels. | YES
5 | The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels. | YES
6 | The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels. | YES

11. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Capex- 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 4.6 | 0.00% | 4.6 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1.2 | 0.00% | 1.2 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.1 | 0.00% | 0.0 | 0.00% | 0.1 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 20.4 | 0.01% | 20.4 | 0.01% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 4,927.7 | 3.47% | 4,798.6 | 3.38% | 129.0 | 0.09%
8 | Total applicable KPI | 4,953.9 | 3.48% | 4,824.8 | 3.39% | 129.1 | 0.09%

Note 1: The denominator of the applicable KPI is 142,164 million euros .
11. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Turnover- 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1.5 | 0.00% | 1.5 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 32.5 | 0.02% | 32.5 | 0.02% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.9 | 0.00% | 0.9 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.3 | 0.00% | 0.3 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 3,431.0 | 2.41% | 3,393.2 | 2.39% | 37.8 | 0.03%
8 | Total applicable KPI | 3,466.1 | 2.44% | 3,428.3 | 2.41% | 37.8 | 0.03%

Note 1: The denominator of the applicable KPI is 142,164 million euros.
Annual report 2025 210

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

11. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Capex- 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 4.6 | 0.09% | 4.6 | 0.09% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 1.2 | 0.02% | 1.2 | 0.02% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.1 | 0.00% | 0.0 | 0.00% | 0.1 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 20.4 | 0.41% | 20.4 | 0.41% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 4,927.7 | 99.47% | 4,798.6 | 96.87% | 129.0 | 2.60%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 4,953.9 | 100.00% | 4,824.8 | 97.39% | 129.1 | 2.61%

11. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Turnover- 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 1.5 | 0.04% | 1.5 | 0.04% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 32.5 | 0.94% | 32.5 | 0.94% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.9 | 0.02% | 0.9 | 0.02% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.3 | 0.01% | 0.3 | 0.01% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 3,431.0 | 98.99% | 3,393.2 | 97.90% | 37.8 | 1.09%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 3,466.1 | 100.00% | 3,428.3 | 98.91% | 37.8 | 1.09%

Annual report 2025 211

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

11. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Capex- 2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 7.0 | 0.00% | 7.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 37.0 | 0.03% | 37.0 | 0.03% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 13,399.0 | 9.42% | 13377.0 | 9.41% | 22.0 | 0.02%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 13,443.0 | 9.46% | 13421.0 | 9.44% | 23.0 | 0.02%

11. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Turnover-2025

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 34.0 | 0.02% | 34.0 | 0.02% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 102.0 | 0.07% | 102.0 | 0.07% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 6.0 | 0.00% | 6.0 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 15,044.0 | 10.58% | 14,269.0 | 10.04% | 775.0 | 0.55%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 15,187.0 | 10.68% | 14,412.0 | 10.14% | 775.0 | 0.55%

Annual report 2025 212

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

11. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Capex- 2025

|  | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 123,767.0 | 87.06%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 123,767.0 | 87.06%

11. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Capex- 2025

|  | Amount | %
1 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
2 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
3 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
4 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
5 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
6 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 123,511.0 | 86.88%
8 | Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI | 123,511.0 | 86.88%

Annual report 2025 213

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

11. Nuclear and fossil gas related activities- 2024 (asset manager)

| Nuclear energy related activities |
1 | The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle. | YES
2 | The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies. | YES
3 | The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades. | YES
| Fossil gas related activities |
4 | The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels. | YES
5 | The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels. | YES
6 | The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels. | YES

11. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Capex- 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 2.6 | 0.00% | 2.6 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 2.2 | 0.00% | 2.2 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.6 | 0.00% | 0.6 | 0.00% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.1 | 0.00% | 0.0 | 0.00% | 0.1 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 16.9 | 0.01% | 16.9 | 0.01% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 3,255.8 | 2.59% | 3,241.1 | 2.57% | 14.8 | 0.01%
8 | Total applicable KPI | 3,278.1 | 2.60% | 3,263.3 | 2.59% | 14.9 | 0.01%

Note 1: The denominator of the applicable KPI is 125,892 million euros.
11. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (denominator) - Turnover- 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.4 | 0.00% | 0.4 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 21.9 | 0.02% | 21.9 | 0.02% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.2 | 0.00% | 0.2 | 0.00% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.3 | 0.00% | 0.3 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 1,980.7 | 1.57% | 1,928.6 | 1.53% | 52.1 | 0.04%
8 | Total applicable KPI | 2,003.4 | 1.59% | 1,951.3 | 1.55% | 52.1 | 0.04%

Note 1: The denominator of the applicable KPI is 125,892 million euros.
Annual report 2025 214

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

11. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Capex- 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 2.6 | 0.08% | 2.6 | 0.08% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 2.2 | 0.07% | 2.2 | 0.07% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.6 | 0.02% | 0.6 | 0.02% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.1 | 0.00% | 0.0 | 0.00% | 0.1 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 16.9 | 0.51% | 16.9 | 0.51% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 3,255.8 | 99.32% | 3,241.1 | 98.87% | 14.8 | 0.45%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 3,278.1 | 100.00% | 3,263.3 | 99.55% | 14.9 | 0.45%

11. Nuclear and fossil gas related activities:
Taxonomy-aligned economic activities (numerator) - Turnover- 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.4 | 0.02% | 0.4 | 0.02% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 21.9 | 1.09% | 21.9 | 1.09% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.2 | 0.01% | 0.2 | 0.01% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI | 0.3 | 0.01% | 0.3 | 0.01% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI | 1,980.7 | 98.87% | 1,928.6 | 96.27% | 52.1 | 2.60%
8 | Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI | 2,003.4 | 100.00% | 1,951.3 | 97.40% | 52.1 | 2.60%

Annual report 2025 215

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

11. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Capex- 2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.1 | 0.00% | 0.1 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 4.7 | 0.00% | 4.7 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 26.1 | 0.02% | 26.1 | 0.02% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 1.1 | 0.00% | 0.0 | 0.00% | 1.1 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.6 | 0.00% | 0.6 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 10,501.2 | 8.34% | 9883.7 | 7.85% | 617.4 | 0.49%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 10,533.7 | 8.37% | 9915.2 | 7.88% | 618.5 | 0.49%

11. Nuclear and fossil gas related activities:
Taxonomy-eligible but not taxonomy-aligned economic activities - Turnover-2024

|  | CCM+CCA | CCM | CCA
|  | Amount | % | Amount | % | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00% | 0.0 | 0.00% | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 8.2 | 0.01% | 8.2 | 0.01% | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 111.5 | 0.09% | 111.5 | 0.09% | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 11.2 | 0.01% | 11.2 | 0.01% | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.4 | 0.00% | 0.4 | 0.00% | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 10,823.2 | 8.60% | 10,752.4 | 8.54% | 70.8 | 0.06%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 10,954.4 | 8.70% | 10,883.6 | 8.65% | 70.8 | 0.06%

Annual report 2025 216

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

11. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Capex- 2024

|  | Amount | %
1 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
2 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
3 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
4 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
5 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
6 | Amount and proportion of taxonomy- eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 112,080.1 | 89.03%
8 | Total amount and proportion of taxonomy eligible but not taxonomy- aligned economic activities in the denominator of the applicable KPI | 112,080.1 | 89.03%

11. Nuclear and fossil gas related activities:
Taxonomy non-eligible economic activities - Capex- 2024

|  | Amount | %
1 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
2 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
3 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
4 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
5 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
6 | Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI | 0.0 | 0.00%
7 | Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI | 112,934.2 | 89.71%
8 | Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI | 112,934.2 | 89.71%

Annual report 2025 217

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 7.3 Employees

6. Employees by region A
| Number of employees
Region | 2025 | 2024
Spain | 34,142 | 34,940
Brazil | 52,696 | 57,133
Chile | 8,868 | 9,240
Poland | 14,219 | 13,846
Argentina | 7,778 | 8,100
Mexico | 28,578 | 29,768
Portugal | 5,354 | 5,316
UK | 19,931 | 22,542
USA | 10,950 | 11,341
Others | 15,887 | 14,527
Total | 198,403 | 206,753

A.At year end, information from People, Culture & Organization global platform for harmonized
people processes groupwide. Employee data is breakdown according to geographical criteria and
cannot be compared to the figures in the 'Economic and Financial Report' chapter, which follow
management criteria. Employees refers to employees hired as described in chapter 3.1. Our
employees. Santander Polska’s employees represent 5.5% of the total workforce in 2025.

7. Employees by gender A
| Number of employees (headcount)
Gender | 2025 | 2024
Male | 95,129 | 98,377
Female | 103,213 | 108,319
Other B | 5 | 6
Not declared C | 56 | 51
Total employees | 198,403 | 206,753

A. Employees at year end. At Santander Group, we record gender as stated on employees’ identity
documents (as required by each local administration and in line with the CSRD) and we break it
down into four categories: men, women (both available in all countries), plus other and not
declared (the latter two accepted only under the regulations of some countries). Santander Polska’s
employees represent 5.5% of the total workforce in 2025.
B. Additionally, in 12 countries the regulation allows us to voluntarily report gender identity,
guaranteeing privacy and equal treatment. Among those employees who have voluntarily reported
it, 2.2% identify themselves as non-binary, trans or others.
C. ‘Not declared’ refers to employees whose gender data is unavailable in Group systems at the
reporting date due to non-disclosure or legal restrictions, in line with applicable data protection
laws and voluntary disclosure rules applicable in some jurisdictions.
Annual report 2025 218

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

8. Employees by management group and gender A
| Senior executives B
| 2025 |  | 2024
| Men | Women | Others | Not declared | Total |  | Men | Women | Others | Not declared | Total
Europe | 918 | 426 | 0 | 0 | 1,344 |  | 959 | 443 | 0 | 1 | 1,403
North America | 181 | 64 | 0 | 0 | 245 |  | 198 | 72 | 0 | 0 | 270
South America | 284 | 142 | 0 | 0 | 426 |  | 299 | 146 | 0 | 0 | 445
Group total | 1,383 | 632 | 0 | 0 | 2,015 |  | 1,456 | 661 | 0 | 1 | 2,118

| Other executives C
| 2025 |  | 2024
| Men | Women | Others | Not declared | Total |  | Men | Women | Others | Not declared | Total
Europe | 8,778 | 5,052 | 0 | 10 | 13,840 |  | 8,850 | 5,096 | 1 | 6 | 13,953
North America | 3,859 | 2,630 | 0 | 4 | 6,493 |  | 3,881 | 2,622 | 0 | 3 | 6,506
South America | 4,678 | 3,398 | 0 | 1 | 8,077 |  | 3,982 | 2,996 | 0 | 1 | 6,979
Group total | 17,315 | 11,080 | 0 | 15 | 28,410 |  | 16,713 | 10,714 | 1 | 10 | 27,438

| Other employees
| 2025 |  | 2024
| Men | Women | Others | Not declared | Total |  | Men | Women | Others | Not declared | Total
Europe | 31,404 | 37,094 | 3 | 39 | 68,540 |  | 32,654 | 39,201 | 3 | 37 | 71,895
North America | 14,555 | 18,517 | 2 | 1 | 33,075 |  | 15,047 | 19,571 | 2 | 3 | 34,623
South America | 30,472 | 35,890 | 0 | 1 | 66,363 |  | 32,507 | 38,172 | 0 | 0 | 70,679
Group total | 76,431 | 91,501 | 5 | 41 | 167,978 |  | 80,208 | 96,944 | 5 | 40 | 177,197

A. At year end. In this and other tables, the units and representative offices in Asia, totalling 425 employees, are counted under Europe.
B. Senior Executives includes: Senior Executive VP. Executive VP and VP.
C. Other Executives includes Directors, Mangers, Experts and Branch Managers.

9. Employees by age bracket A
Number and % of total
| 2025 |  | 2024
| aged < 30 |  | aged 30 - 50 |  | age over 50 |  | aged < 30 |  | aged 30 - 50 |  | age over 50
Europe | 10,765 | 12.86% |  | 51,882 | 61.97% |  | 21,077 | 25.17% |  | 11,842 | 13.57% |  | 54,262 | 62.19% |  | 21,147 | 24.24%
North America | 9,457 | 23.75% |  | 24,783 | 62.25% |  | 5,573 | 14.00% |  | 10,485 | 25.33% |  | 25,239 | 60.97% |  | 5,675 | 13.71%
South America | 19,503 | 26.05% |  | 48,107 | 64.26% |  | 7,256 | 9.69% |  | 22,372 | 28.64% |  | 49,183 | 62.97% |  | 6,548 | 8.38%
Group total | 39,725 | 20.02% |  | 124,772 | 62.89% |  | 33,906 | 17.09% |  | 44,699 | 21.62% |  | 128,684 | 62.24% |  | 33,370 | 16.14%

A.At year end.
Annual report 2025 219

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

10. Employees by employment contract A |  |  |  |  |  |
| 2025 |  | 2024
| Men | Women | Other | Not declared | Total |  | Men | Women | Other | Not declared | Total
Number of employees | 95,129 | 103,213 | 5 | 56 | 198,403 |  | 98,377 | 108,319 | 6 | 51 | 206,753
Number of permanent employees | 93,290 | 100,891 | 4 | 53 | 194,238 |  | 96,541 | 105,942 | 6 | 13 | 202,502
Number of temporary employees | 1,839 | 2,322 | 1 | 3 | 4,165 |  | 1,836 | 2,377 | 0 | 38 | 4,251
Number of full-time employees | 94,060 | 98,121 | 4 | 56 | 192,241 |  | 97,163 | 102,740 | 5 | 50 | 199,958
Number of part-time employees | 1,069 | 5,092 | 1 | 0 | 6,162 |  | 1,214 | 5,579 | 1 | 1 | 6,795
Number of non- guaranteed hours employees | 0 | 0 | 0 | 0 | 0 |  | 0 | 0 | 0 | 0 | 0

A. At year end 98% of employees in Santander have a permanent employment contract and 97% have full-time contract, as in 2024. For additional definitions see 7.
Employees by gender.

11. Collective bargaining coverage and social dialogue A
| Collective Bargaining Coverage | Social dialogue
Coverage Rate | Employees – EEA (European Economic Area) (for countries with >50 empl. representing >10% total empl) | Employees – Non-EEA (estimate for regions with >50 empl. representing >10% total empl) | Workplace representation (EEA only) (for countries with >50 empl. representing >10% total empl)
0-19% | Poland | United States |
20-39% |  | Mexico |
40-59% |  |  |
60-79% |  |  |
80-100% | Portugal and Spain | Argentina, Brazil, Chile and United Kingdom | Spain, Poland and Portugal

A. Percentage of employees covered by collective agreement, as defined by CSRD. The collective bargaining and social dialogue figures
remain as in 2024.

12. Turnover by region A,B
| 2025 |  | 2024
| Total | Turnover ratio C |  | Total | Turnover ratio
Europe | 10,326 | 12.08% |  | 10,464 | 11.77%
North America | 9,176 | 22.55% |  | 9,905 | 23.38%
South America | 20,112 | 25.86% |  | 19,726 | 25.33%
Group total | 39,614 | 19.42% |  | 40,095 | 19.17%

A. Employees who ended definitely their employment relation with Santander entities through 2025, it does not include
temporary leave or transfer between Santander companies. Information from People, Culture & Organization global
platform used harmonized people processes groupwide.
B. The total number of terminated employees was 1% below than last year, the turnover rate remained stable compared to the
previous year, 53.7% of those laid off are women, in line with the distribution of our workforce. The total number of
employees leaving Santander Polska in 2025 represents 3.7%.
C. Turnover rate is calculated over average headcount of the period.
Annual report 2025 220

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

13. Average remuneration by management group, gender, and age bracket A
| 2025 |  | 2024
| Women | Men | Other B | Not declared B | Total C |  | Women | Men | Other B | Not declared B | Total C
Gender | 45,836 | 73,357 | - | - | 58,984 |  | 41,822 | 65,625 | - | - | 53,131
| Senior executives | Other executives | Other employees |  | Total |  | Senior executives | Other executives | Other employees |  | Total
Management group | 598,760 | 144,997 | 38,933 |  | 58,984 |  | 524,748 | 129,847 | 36,834 | - | 53,131
| <30 | 30-50 | >50 |  | Total |  | <30 | 30-50 | >50 |  | Total
Age bracket | 25,179 | 59,225 | 96,488 |  | 58,984 |  | 23,329 | 53,353 | 88,044 | - | 53,131

A. It includes gross annual salary and comparable supplements, pension schemes and variable remuneration.
B. The categories requested by CSRD, by gender and age groups have been used. Groups with less than 50 employees (others, not declared) are not included because they are
not statistically relevant and to avoid statistically erroneous conclusions.
C. Our employees’ average remuneration increased by 11%. This variation is not comparable with 2024 due to staff turnover (hires, departures and promotions) and
movements in relative exchange rates. The exchange rates required by the European Central Bank for regulatory remuneration reporting are applied.

14. Remuneration ratios |
| 2025 | 2024
Hourly GPG ratio (average) | 35% | 36%
GPG ratio (median) A | 26% | 26%
EPG ratio | <1 | c. 0
Remuneration ratio B | 361.9 | 367.1

A. GPG Ratio (median) includes annual base salary and variable remuneration paid in the year.
B.Ratio of the annual remuneration of the highest-paid person performing executive functions
(salary, pension plan contributions and variable remuneration) divided by the median
annual remuneration of the remaining employees (excluding the highest-paid person).

15. Average remuneration of senior management (with variable remuneration not linked to long-term objectives)
Thousand euros | 2025 |  | 2024
| Men | Women | Total |  | Men | Women | Total
Executive directors | 9,489 | 11,977 | 10,733 |  | 9,137 | 12,127 | 10,632
Non-executive directors | 347 | 357 | 350 |  | 285 | 356 | 309
Senior management A | 4,135 | 1,917 | 3,839 |  | 3,898 | 1,380 | 3,538

A. Members of senior management at year-end. This includes the non-executive directors who served on the board
of directors during the year. Where there have been changes in its composition, both outgoing and incoming
directors have been taken into account, as well as the remuneration received by each.

16. Average remuneration of senior management linked to long-term objectives (fair value)
Thousand euros | 2025 |  | 2024
| Men | Women | Total |  | Men | Women | Total
Executive directors | 1,938 | 2,804 | 2,371 |  | 1,611 | 2,332 | 1,972
Senior management | 660 | 231 | 603 |  | 553 | 170 | 498

17. Senior management composition A
Number | 2025 |  | 2024
| Men | Women | Total |  | Men | Women | Total
Executive directors | 1 | 1 | 2 |  | 1 | 1 | 2
Non-executive directors | 8 | 5 | 13 |  | 10 | 5 | 15
Senior management | 13 | 2 | 15 |  | 12 | 2 | 14

A.This includes the non-executive directors who served on the board of directors during the year. Where there have
been changes in its composition, both outgoing and incoming directors have been taken into account. Members of
the senior management at the end of the year.
Annual report 2025 221

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

18. Training |
| 2025 | 2024
Total hours of training | 5,075,133 | 5,286,317
% employees trained A | 94.6 | 94.4
Total attendees B | 7,507,232 | 6,925,442
Hours of training per employee C | 24.9 | 25.3

A. Calculation based on year-end headcount. The total number of training hours at Santander Polska in
2025 represents 5.5%.
B. Training courses completed by our employees during 2025 (8% higher vs. 2024).
C. Calculation based on average headcount during the year. 3.3 days of learning. Women completed an average of
25.7 hours and men 23.9 hours.

19. Hours of training by gender and management group A |  |  |  |  |  |
Gender | 2025 |  | 2024
Men | Women | Others | Not declared | Total |  | Men | Women | Others | Not declared | Total
2,325,003 | 2,739,434 | 150 | 10,546 | 5,075,133 |  | 2,413,371 | 2,872,035 | 111 | 800 | 5,286,317
Management level | Senior executive | Other executive | Other employees |  | Total |  | Senior executive | Other executive | Other employees |  | Total
44,122 | 666,259 | 4,364,752 | - | 5,075,133 |  | 52,476 | 857,065 | 4,376,775 | - | 5,286,317

A. The total training hours completed by our employees were 4% lower than in 2024, although the total number of training sessions
completed was higher, driven by the digitalisation and optimisation of courses, as well as changes in our workforce. The total number of
training hours at Santander Polska in 2025 represents 5.5%.

20. Occupational health and safety A,H
| 2025 |  | 2024
| Men | Women | Total |  | Men | Women | Total
Number of fatal occupational accidents or work-related illness | 0 | 0 | 0 |  | 0 | 0 | 0
Work-related illness B | 6 | 16 | 22 |  | 1 | 2 | 3
Total number of accidents C | 166 | 467 | 633 |  | 317 | 633 | 950
Work-related accident rate (CSRD criterion, equivalent to the frequency rate of Law 11/2018) D | 0.61 | 1.58 | 1.12 |  | 1.15 | 2.08 | 1.64
Total number of days of absence due to accidents E | 6,398 | 21,360 | 27,758 |  | 12,617 | 24,094 | 36,711
Accident rate F | 0.02 | 0.05 | 0.04 |  | 0.03 | 0.06 | 0.05
Severity rate G | 0.02 | 0.07 | 0.05 |  | 0.05 | 0.08 | 0.06

A. As in the rest of this chapter, we only include information about our employees.
B. Information is reported for the entire Santander Group in line with local occupational disease regulations where these are regulated
nationally and/or for specific jobs. These events are recorded once the occupational cause has been confirmed following the relevant
specialised investigation by the occupational health experts required under each jurisdiction. In Brazil, in line with local practice, external
judicial rulings are not included.
C. We report occupational injuries that can be documented in 2025, including accidents while commuting. We standardized criteria,
processes and systems across our footprint to calculate leave on medical grounds in every market. Banco Santander only considers
occupational accidents and illnesses that, following expert review, are recognized as work-related and reported to official bodies (e.g. in
Brazil, through a comunicação de acidente de trabalho — CAT, or work-related accident notice — to the Instituto Nacional do Seguro
Social — INSS, National Social Security Institute). In Brazil, this indicator only considers absences due to occupational accident of 15 days
or more. In the occupational accident ratios, the United States is excluded because it uses a local system that is not integrated into the
Group’s platform; the number of accidents resulting in absence in the United States is not material (1% of the Group total). The total
number of accidents at Santander Bank Polska in 2025 represents 7.1%.
D. Number of occupational accidents with leave for every 1,000,000 theoretical working hours.
E. Includes days of absence due to occupational accidents or occupational diseases resulting in absence, in line with the above definitions.
F. Ratio of hours missed due to an occupational accident divided by the total number of theoretical hours worked by employees in the year.
G. Days missed due to occupational accident with leave for every 1,000 theoretical working hours. Hours worked are theoretical.
H. In addition, in all units our employees have recorded 15.3 million hours of absence due to health reasons (16.4 million hours in 2024).
Annual report 2025 222

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 7 .4 Customers

21. Group customers A
| 2025 | 2024 | var.
Europe | 47,080,494 | 46,820,826 | 1%
Spain | 15,361,751 | 15,307,491 | —%
United Kingdom | 22,719,618 | 22,541,474 | 1%
Portugal | 2,970,542 | 2,988,779 | (1)%
Poland | 6,023,727 | 5,978,671 | 1%
Others Europe B | 4,856 | 4,411 | 10%
South America | 86,303,021 | 80,404,762 | 7%
Brazil | 73,948,413 | 69,454,776 | 6%
Chile | 4,608,182 | 4,311,488 | 7%
Argentina | 5,412,475 | 5,117,205 | 6%
Others South America C | 2,333,951 | 1,521,293 | 53%
North America | 26,945,104 | 25,762,219 | 5%
United States D | 4,368,527 | 4,473,683 | (2)%
México | 22,576,577 | 21,288,536 | 6%
Digital Consumer Bank | 19,892,525 | 19,549,525 | 2%
Santander Consumer Bank E | 16,186,185 | 16,953,371 | (5)%
Santander Digital F | 3,706,340 | 2,596,154 | 43%
Total | 180,221,144 | 172,537,332 | 4%

A. Figures corresponding to total customers.
B. Includes the rest of Private Banking and other CIB Europe.
C. Includes Uruguay, Peru and Colombia. In Peru, the increase is driven by the acquisition of
CrediScotia Financiera.
D. Includes BPI Miami
E. SCF includes customers in all European countries, including the UK.
F. Increase driven by the growth of the Zinia digital platform.

22. Dialogue by channel
| 2025 | 2024 | Var .2025/2024 %.
Branches |  |  |
Number of branches A | 7,124 | 8,086 | (11.9)%
Digital banking B |  |  |
Digital customers C (millions) | 63.0 | 59.3 | 6.2%

A.Reduction in the number of branches in line with Group’s strategy. For both the 2025 and 2024 figures,
CartaSur points of sale and Argentina’s banking service points (PAB) have been included, while
operational points that do not provide customer service to clients in Colombia have been excluded.
B. Santander Consumer Finance not included.
C.Counts once for customers of both Internet and mobile banking. It excludes Openbank Mexico.
Annual report 2025 223

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

23. NPS ranking by country
| 2025 | 2024
Argentina | 1 | 2
Brazil | 2 | 5
Chile | 2 | 1
Uruguay | 2 | 1
Spain | 3 | 3
Poland | 3 | 3
Portugal | 3 | 3
UK | 5 | 4
Mexico | 3 | 3
USA | 3 | 6

NPS to measure customer satisfaction, audited by Stiga/Deloitte.
Santander position vs. competitors (Official Peer Group by countries). Key peers by country: Argentina:
Galicia, BBVA, ICBC, HSBC, Banco Macro, Banco de la Nación; Brazil: Itaú, CEF, Bradesco, Banco do Brasil,
Nubank; Chile: BCI, Banco de Chile, Itaú, Scotiabank, Banco Estado; Uruguay: Brou, Itaú, BBVA, Scotiabank;
Spain: ING, Bankinter, BBVA, Caixabank, Sabadell, Unicaja; Poland: ING, Millenium, MBank, Bank Polski,
Bank Pekao, BNP Paribas; Portugal: BPI, Millenium BCP, CGD, Novo Banco, Montepio; UK: Nationwide,
Barclays, Halifax, NatWest Gr., Lloyds, HSBC, TSB; Mexico: BBVA, Nubank, Scotiabank, Banorte, HSBC,
Banamex, Banco Azteca; US: Chase, Capital One, Bank of America, PNC, Wells Fargo, KeyBank, Citizens,
Citigroup, TD Bank, M&T Bank, Truist.

24. Total complaints A
| 2025 | 2024
Spain B | 82,650 | 156,460
Portugal | 2,857 | 3,588
United Kingdom | 32,321 | 30,778
Poland | 5,172 | 4,209
Brazil B | 285,723 | 226,976
Mexico B | 57,258 | 71,082
Chile | 11,074 | 10,458
Argentina | 5,542 | 6,351
US B | 9,102 | 6,256
SCF B | 281,081 | 165,478
Total | 772,780 | 681,636

A. Compliance metrics based on group-wide criteria, homogeneous for all geographies. Include
complaints received through formal channels such as the official complaints service (if exists), public or
private consumer organisations and agencies, senior management, customer ombudsmen (if exists),
regulator channels. 82.6% of complaints resolved in favour of the Bank.
B. Overall positive evolution of formal complaints that remain concentrated in the largest retail business:
Brazil, SCF, Spain and Mexico. Excluding the UK specific dealer commissions issue, there has been a year-
on-year decrease of 4%. Material improvements in Mexico, mainly in first contact resolution and fraud
management, and Spain, following the 2024 Supreme Court ruling on mortgage fees matter. Continued
trend of increased complaints generated by Complaints Management Companies / influencers, but with
significant majority not upheld (Brazil / USA).
SN 7.5 Financial inclusion

25. People financially included A,B
million people (Accumulated since 2023) | 2025 | 2024
Access | 2.9 | 1.9
Finance | 3.5 | 2.4
Total | 6.3 | 4.3

A. A new target for people financially included was launched in 2023, which considers access and
finance initiatives (the previous target also included financial education). The figures reflect only
the new people financially included since 2023 (unique people).
B. The figure of people financially included through Santander Polska in 2025 is 0.5 million.
Annual report 2025 224

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

26. Microfinance
million euros / people | 2025 | 2024
Total credit disbursed A | 1,258 | 1,270
Total microentrepreneurs supported | 1.8 | 1.3

A. The increase in microentrepreneurs supported is mainly due to the bank's objective to expand its
microfinance programmes in Latin America.
SN 7.6 Community support
27 . Community Support

million euros | 2025 | 2024
Support for higher education, employability, and entrepreneurship | 102.1 | 103.8
Other local initiatives | 61.7 | 62.5
Total | 163.7 | 166.4

28. People and organizations helped

28.1 Through Santander Universities A
| 2025 | 2024
Higher education B | 1,773,549 | 34,062
Employability C | 2,829,483 | 2,078,051
Entrepreneurship D | 59,569 | 52,570
Total E | 4,626,147 | 2,164,683

A. The scope of reporting on people and businesses supported has been broadened in 2025 to include
not only beneficiaries within the impact perimeter but also those outside it, in line with the
methodology for Calculating People Supported under Santander Universities, updated this year.
Universities helped are included
B. The increase in the number of people supported in education is due to Campus Digital.
C. The number of people enrolled in unlimited-access programmes to enhance their employability
continues to increase significantly.
D. In 2025, open-access training programmes (with unlimited places) were launched to support
entrepreneurship training.
E. The sum of the strategic pillars exceeds the total figure, as duplicates are removed for individuals
supported in both education and employability.

28.2 Through other local initiatives A,B
| 2025 | 2024
Education, Employability and Entrepreneurship | 707,387 |
Financial education and Vulnerable people | 3,886,777 | -
Culture and Institutional activities | 353,481 | -
Other local specific needs | 278,656 | -
Total | 5,226,301 | -

A. 2025 data is not comparable with previous years due to changes in the methodology and increase
in the scope of reporting.
B. The figure of people and organizations helped through Santander Polska in 2025 is 1.1 million.
Annual report 2025 225

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 7.7 Tax contribution
We pay taxes in the jurisdictions where we earn a profit. Thus, the
profits obtained, and the taxes accrued and paid, correspond to the
countries where we operate.
For every EUR 100 in total income, the Group pays EUR 35 in taxes,
including EUR 15 in taxes paid directly by Santander and EUR 20 in
taxes collected from third parties.
The taxes Santander pays directly (see table below) include non-
recoverable value added tax (VAT), employers' social security
contributions, charges levied on banks and financial transactions in
Spain, the UK, Poland, Portugal, Brazil and Argentina, and other
taxes.

29. Total taxes paid
EUR million
2025
Jurisdiction | Corporate income tax A | Other taxes paid | Total own taxes paid B | Third-party taxes C | Total contribution
Spain | 792 | 1,236 | 2,028 | 2,155 | 4,183
UK | 169 | 521 | 690 | 623 | 1,313
Portugal | 437 | 168 | 605 | 340 | 945
Poland | 543 | 341 | 884 | 354 | 1,238
Germany | 60 | 66 | 126 | 288 | 414
Rest of Europe | 665 | 361 | 1,026 | 339 | 1,365
Total Europe | 2,666 | 2,693 | 5,359 | 4,099 | 9,458
Brazil | 1,204 | 549 | 1,753 | 3,021 | 4,774
Mexico | 558 | 567 | 1,125 | 1,210 | 2,335
Chile | 35 | 83 | 118 | 320 | 438
Argentina | 133 | 464 | 597 | 2,825 | 3,422
Uruguay | 29 | 95 | 124 | 95 | 219
Rest of Latin America | 51 | 30 | 81 | 20 | 101
Total Latin America | 2,010 | 1,788 | 3,798 | 7,491 | 11,289
United States | 268 | 111 | 379 | 924 | 1,303
Other | 10 | 7 | 17 | 6 | 23
TOTAL | 4,954 | 4,599 | 9,553 | 12,520 | 22,073

A. The Group's income tax for the year 2024 amounted to EUR 5,880 mn
B. Total own taxes paid for all these concepts amounted to EUR 9,553 million, broken down as EUR 4,954 million in corporate income tax (including EUR 392 million in tax on
net interest income and fees in Spain), EUR 1,123 million in non-recoverable VAT and other sales taxes, EUR 1,913 million in employer-paid payroll taxes, EUR 90 million in
property taxes, EUR 392 million in bank levies and EUR 1,081 million in other taxes.
C. Total third-party taxes amounted to EUR 12,520 million, broken down as EUR 3,364 million in salary withholdings and employees' social security contributions, EUR 1,464
million in recoverable VAT, EUR 2,835 million in tax deducted at source on capital, EUR 463 million in non-resident taxes, EUR 377 million in property taxes, EUR 335 million
in stamp taxes, EUR 2,253 million in taxes related to the financial activity and EUR 1,429 million in other taxes.
Annual report 2025 226

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 8. Additional metrics to comply with Spanish Act 11/2018

1. Average employees, by contract type and gender
| 2025 |  | 2024
| Women | Men | Other | Not declared | Total |  | Women | Men | Other | Not declared | Total
Average employees | 106,539 | 97,284 | 6 | 106 | 203,936 |  | 109,762 | 99,257 | 6 | 86 | 209,112
Average permanent employees | 104,084 | 95,445 | 5 | 71 | 199,606 |  | 107,404 | 97,487 | 6 | 64 | 204,960
Average temporary employees | 2,455 | 1,839 | 1 | 35 | 4,330 |  | 2,358 | 1,771 | 0 | 22 | 4,151
Average full-time employees | 101,123 | 96,099 | 5 | 100 | 197,326 |  | 103,837 | 98,023 | 6 | 83 | 201,949
Average part-time employees | 5,417 | 1,185 | 1 | 7 | 6,609 |  | 5,925 | 1,234 | 0 | 3 | 7,163

2. Average employees, by contract type and age bracket
| 2025 |  | 2024
| Under 30 | 30-50 | Over 50 | Total |  | Under 30 | 30-50 | Over 50 | Total
Average employees | 42,540 | 127,674 | 33,722 | 203,936 |  | 46,556 | 129,728 | 32,828 | 209,112
Average permanent employees | 40,559 | 125,623 | 33,423 | 199,606 |  | 44,748 | 127,682 | 32,531 | 204,960
Average temporary employees | 1,981 | 2,051 | 299 | 4,330 |  | 1,808 | 2,046 | 297 | 4,151
Average full-time employees | 41,522 | 123,802 | 32,002 | 197,326 |  | 45,412 | 125,537 | 30,999 | 201,949
Average part-time employees | 1,018 | 3,871 | 1,720 | 6,609 |  | 1,143 | 4,191 | 1,829 | 7,163

3. Average employees, by contract type and management group.
| 2025 |  | 2024
| Senior executive | Other executive | Other employees | Total |  | Senior executive | Other executive | Other employees | Total
Average employees | 2,101 | 29,250 | 172,585 | 203,936 |  | 2,273 | 30,748 | 176,091 | 209,112
Average permanent employees | 2,087 | 29,042 | 168,477 | 199,606 |  | 2,253 | 30,291 | 172,416 | 204,960
Average temporary employees | 14 | 208 | 4,108 | 4,330 |  | 20 | 457 | 3,674 | 4,151
Average full-time employees | 2,091 | 28,968 | 166,267 | 197,326 |  | 2,263 | 30,234 | 169,452 | 201,949
Average part-time employees | 9 | 281 | 6,318 | 6,609 |  | 10 | 514 | 6,639 | 7,163

4. Dismissals, by gender, management group and age bracket |
| 2025 |  | 2024
| Women | Men | Other | Not declared | Total |  | Women | Men | Other | Not declared | Total
Gender | 7,942 | 6,595 | 1 | 8 | 14,546 |  | 7,755 | 6,599 | 2 | 29 | 14,385
| Senior executive | Other executive | Other employees |  | Total |  | Senior executive | Other executive | Other employees |  | Total
Management group | 90 | 1,571 | 12,885 |  | 14,546 |  | 114 | 1,229 | 13,042 |  | 14,385
| <30 | 30-50 | >50 |  | Total |  | <30 | 30-50 | >50 |  | Total
Age bracket | 4,122 | 8,481 | 1,943 |  | 14,546 |  | 4,495 | 7,866 | 2,024 |  | 14,385

A. Dismissal: the unilateral termination of an employment contract by decision of the company includes departures within
the framework of reorganisation processes, for individual performance reasons or disciplinary measures. It does not
include temporary absences or transfers to other Group companies.
Annual report 2025 227

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 9. Alternative performance measures (APMs)
The following are additional alternative performance measures
(APMs) to those listed in section 8 of the chapter 'Economic and
Financial Review' . The metrics we use in this report have not been
subject to further third-party verification beyond the scope of
limited assurance.
Data related to tax contribution
The profits obtained, and the taxes accrued and paid, correspond to
the countries where we operate.

Taxes paid by the Group |  | The taxes Santander pays directly are included in the cash flow statement and mainly stem from the corporate income tax paid. They also include non-recoverable value added tax (VAT), employers' social security contributions, charges levied on banks and financial transactions in the geographies were we operate, and other taxes. See data in the section SN 7.7 Tax contribution of this chapter. |  | It reflects how the Bank complies with its commitment to tax transparency in the jurisdictions where it operates.
Third-party taxes |  | These are those generated by the development of our economic activity. This is the sum of salary withholdings and employees' social security contributions, recoverable VAT, tax deduced at source on capital, non- resident taxes, property taxes, stamp taxes, taxes related to the financial activity, and others. See data in the section SN 7.7 Tax contribution of this chapter. |
Total tax contribution |  | The Group's total tax contribution includes the taxes paid by the Group as a direct cost and the taxes collected from third parties in the course of our economic activity. See data in the section SN 7.7 Tax contribution of this chapter. |

Data related to sustainable finance

Green finance raised and facilitated |  | Nominal amount of project finance, financial advisory, project bonds, green bonds (DCM), export finance, mergers and acquisitions (M&A), and equity capital markets (ECM) transactions ranked by the ESG Classification Meeting and reported in the League Tables of Infralogic, Bloomberg, Dealogic, and TXF since the beginning of the year. See data in section 2. Climate transition plan and SN 7.1 Green transition (Table 1. Green finance) in this chapter. |  | It reflects Santander's ambition and contribution to helping our customers, and society as a whole, in the transition to a low-carbon economy.
Financing volume of renewable energy projects |  | Nominal amount of renewable energy projects (greenfield and brownfield) financed since the beginning of the year and reported externally as reported in Infralogic's League Tables for project financing. See data in section Sustainability 2025 summary of this chapter. |
Financing volume of renewable electric vehicles |  | Financing volume of vehicles powered exclusively by a rechargeable electric battery (no petrol engine). See data in section Sustainability 2025 summary of this chapter. |

Credit disbursed to microentrepreneurs (EUR) |  | Total amount of credit disbursed during the year to low-income entrepreneurs with low access to banking services, or with difficulties in accessing credit, with the objective of creating and/or growing their businesses. Data includes information on microfinance programmes in Brazil, Colombia, Mexico and Peru. See data in section Sustainability 2025 summary and SN 7.5 Financial inclusion (Table 27. Microfinance) of this chapter. |  | It reflects Santander's ambition and contribution to help address financial inclusion challenges in the markets where we operate.

Annual report 2025 228

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Data related to financed emissions

Financed emissions from corporates and projects |  | For the financed emissions associated with business loans, equities, investments, bonds, and projects we calculate the emissions in accordance with the methodology established by management that is based on the Partnership for Carbon Accounting Financials (PCAF) standard for financed emissions. The financed emissions for a corporate client portfolio are calculated using the following equation: Financed emissions = Attribution Factor x Emissions The following equations are used to determine the attribution factor at company level: Attribution Factor = Outstanding amount / Total Enterprise Value In the case of corporate business loans (CIB alignment targets), Banco Santander calculates the Total Value of the Company (used to obtain the emissions attribution factor) by adding the total equity and debt of the company to avoid the high volatility in market capitalization. In the case of Project Finance, the financed emissions for a Project are calculated using the production and an emission factor. We use as data sources (non-exhaustive): annual/Sustainability Reports of our customers, Asset Impact, Capital IQ, Carbon Disclosure Project, S&P Trucost, Transition Pathway Initiative, Wood Mackenzie, IBA, JATO, Global data and PCAF database. See data in section Our transition plan in this chapter. |  | These metrics reflect Santander’s ambition and contribution to addressing the challenges of emissions measurement, supporting our customers in their objectives and aligning portfolios to progress on our ambition towards net zero emissions by 2050.
Auto – lending |  | For the auto lending portfolio for Santander Consumer Finance Europe the financed emissions are those associated with the passenger cars financed and leased (passenger cars being the most material vehicle type in the Auto portfolio). These are calculated following the PCAF methodology: Financed emissions = ∑ emissions per vehicle / ∑ attributed annual distance Emissions per vehicle = vehicle emissions × attribution factor × annual distance To determine the attribution factor of each of the loans, the following formula is used: Attribution factor = Outstanding amount / vehicle value at origination The vehicle emissions are calculated using the emissions of each specific vehicle, where available, multiplied by the annual distance estimated for each vehicle and by the attribution factor. See data in section Our transition plan in this chapter. |
Mortgages and Commercial Real Estate |  | Mortgages and commercial real estate portfolio emissions lending on residential mortgages includes Scope 1 and 2 emissions based on actual (where available) and modelled EPC's. We define this asset class as on balance sheet loans for specific consumer purposes – namely the purchase and refinance of residential property. The following calculation approach was used to arrive at the financed emissions for each of the properties in the portfolio: Financed emissions = building emissions x LTV The attribution factor is the outstanding amount of the loan as per the reporting year for each mortgage, divided by the total property value at origination for each building. See data in section Our transition plan in this chapter. |
Agriculture |  | Agriculture portfolio emissions for Santander Brazil from lending to farmers associated with primary production activities in Brazil (agriculture and livestock activities), financed through Retail mechanisms. Assessment includes Scope 1 and 2 emissions. In this sector, Santander’s financed emissions estimation is based on GHG Protocol guidance and PCAF methodology, with adaptations to accommodate data availability in retail agriculture portfolio. Land management emissions: The general equations used to calculate financed emissions of an agricultural activity are as follows: Financed emissions = ∑ quantity produced or area of production or number of animals x Emission factor Emission factor sources include the GHG Protocol Brazil Tool for the Agricultural Sector, the Reference Report from Brazil's IV National Inventory, among other specialized literature. Land Use Change (LUC) emissions: The total LUC emissions for the portfolio are calculated for each property: collecting shapefiles of farms associated with the operations financed in the retail portfolio, computing annual tree- cover loss areas (in hectares), for the last 20 years, for each property, and evaluate corresponding carbon stock loss using emission factors, applying the Linear Discounting Methodology, and calculating the attribution factor for emissions related to Santander. Sources (non-exhaustive): properties’ Rural Environmental Registry number, MapBiomas Collection 8, Brazil´s IV National Inventory Carbon Map.x See data in section Our transition plan in this chapter. |
Sovereign bonds |  | For the sovereign bonds portfolio we calculate the financed emissions following the PCAF standard recommendations, as follows: Attributed emissions = Exposure to Sovereign Bond (USD) / PPP-adjusted GDP (international USD) x Sovereign Emissions (tCO2e) See data in section Our transition plan in this chapter. |

Annual report 2025 229

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Data related to responsible investment

Socially responsible investment assets under management (SRI AUM) |  | Value corresponding to total volume of assets under management registered as article 8 - promoting ESG characteristics - and 9 - with explicit sustainability objectives - of the Sustainable Finance Disclosure Regulation (SFDR, EU Reg. 2019/2088) except for illiquid investments in Private Banking which are reported in terms of committed capital. It includes: i) assets managed or advised by Santander Asset Management (SAM) and other Group asset managers in the EU and, using equivalent criteria, in countries where SFDR does not apply; and ii) third party funds and assets under advise deemed sustainable investments according to either SFDR (Article 2.17) or internal criteria as per SFICS. See data in section 3.2.2 Responsible investment and social finance of this chapter. |  | It reflects Santander's ambition and contribution to promote responsible investment. It also allows our managers and bankers to have a more complete vision of the assets in which to invest and identify competitive advantages and mitigate risks.

Data related to community support

Support for education, employment and entrepreneurship |  | Total amount invested to support education, employment and entrepreneurship. See data in section 3.2.4 Community support and SN 7.6 Community support (table 27. Community support) of this chapter. |  | It reflects Santander's ambition and contribution to promoting (beyond our business operations) the progress and inclusive and sustainable growth of the communities where we are present.
Support for other local initiatives |  | Total amount invested through local initiatives to promote childhood education, social welfare (especially among vulnerable groups), art and culture. See data in section 3.2.4 Community support and SN 7.6 Community support (table 27. Community support) of this chapter. |
Total community support |  | Sum of investment in education, employability and entrepreneurship, plus investment in other community support programmes. See data in section 3.2.4 Community support and SN 7.6 Community support (table 27. Community support)of this chapter. |

Data related to suppliers

Payments to suppliers |  | Total amount of payments made to suppliers outside the Group. See data in section 4.4 Our suppliers of this chapter. |  | It reflects the Group's economic contribution through the purchase of products and services in its operations. It also reflects our commitment to the local economies of the geographies in which we operate.
% Turnover of locally contracted suppliers (M EUR) |  | % of the Group's total turnover made to suppliers based in the same geography where the services are purchased. Turnover from locally contracted suppliers is divided by total turnover to suppliers. See data in section 4.4 Our suppliers of this chapter. |

Annual report 2025 230

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 10. Non-financial information Act 11/2018 content index
Table of equivalences with reporting requirements under Spain's Act 11/2018

| Non-financial information to be disclosed |  | Chapter/section of the annual report |  | Correspondence with CSRD/other regulations
0. General Information | Brief description of the Group’s business model (including its business environment, organization and structure, markets, objectives and strategies, plus the main factors and trends that can affect its future performance). |  | Business model and strategy (p. 7 ). Economic and financial review (p. 409 ). 1. Sustainability at Santander (p. 21) [1.2 Materiality assessment]. SN 3. Materiality assessment - Detailed methodology (p. 114). |  | SBM-1 SBM-2 GOV-1 MDR-T E1-4 S1-5 S3-5 S4-5
A description of the Group's policies that includes due diligence procedures for identifying, assessing, preventing and mitigating risks and significant impacts, and for verifying and controlling, including the measures in which they have been adopted): |  | 1. Sustainability at Santander (p. 21 ) [1.4 Sustainability governance] [1.4.2 Human rights due diligence]. SN 2 Sustainability governance (p. 110) [Cross-cutting regulations to embed ESG standards in our business model]. 2. Climate transition plan (p. 31) [2.3 Embedding ESG in risk management]. 3. Supporting employees, communities and customers (p. 70 ) [3.2.3 Management of Environmental and social aspects]. |  | GOV-4 MDR-P E1-2 S1-1 S3-1 S4-1 G1-1
The results of these policies, including key indicators of relevant non-financial results that allow the monitoring and evaluation of progress and that favour the comparability between companies and sectors, in accordance with national, European or international frameworks of reference used for each matter. |  | 2. Climate transition plan (p. 31 ). 3. Supporting employees, communities and customers (p. 70 ). 4. Business conduct (p. 93 ). |  | MDR-M E1 S1 S3 S4 G1
SN 7. Our progress in figures (p. 129 ). |
The main risks related to these matters associated with the Group's activities (business relationships, products or services) that may have a negative effect in these areas, and how the Group manages these risks, explaining the procedures used to detect and assess them in accordance with national, European or international frameworks of reference for each matter. It must include information about the impacts that have been detected, offering a breakdown, in particular of the main risks in the short, medium and long term. |  | 1. Sustainability at Santander (p. 21 ) [1.2 Materiality assessment]. SN 3. Materiality assessment - detailed methodology (p. 114) [Information on impacts, risks and opportunities]. 2. Climate transition plan (p. 31). 3. Supporting employees, communities and customers (p. 70). 4. Business conduct (p. 93 ). |  | GOV-5 SBM-3 IRO-1 E1 S1 S3 S4 G1

Annual report 2025 231

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

| Non-financial information to be disclosed |  | Chapter/section of the annual report |  | Correspondence with CSRD/other regulations
1. Environmental Information | Detailed information on the current and foreseeable effects of the activities of the company in the environment and, where appropriate, health and safety, environmental evaluation or certification procedures; the resources dedicated to the prevention of environmental risks; the application of the principle of caution, the amount of provisions and guarantees for environmental risks. |  | 2. Climate transition plan (p. 31 ); At the end of the 2025 financial year, no significant account is presented in the Consolidated Annual Accounts of the Group that should be included in this chapter regarding environmental provisions or guarantees. |  | SBM-3 IRO-1 MDR-A MDR-M E1 SBM-3 E1 IRO-1 E1-3 E1-6 E1-7 E1-9
Contamination:
Measures to prevent, reduce or repair CO 2 emissions that seriously affect the environment, taking into account any form of air pollution, including noise and light pollution. |  | 2. Climate transition plan (p. 31 ) [2.4.5 Our environmental footprint]. |  | MDR-A E1-3 E1-7
Circular economy and waste prevention and management:
Waste prevention measures, waste recycling measures, waste reuse measures; other forms of waste recovery and reuse; actions against food waste. |  | 2. Climate transition plan (p. 31 ) [2.4.5 Our environmental footprint]. |  | E5 IRO-1
Sustainable use of resources:
Use and supply of water according to local limitations |  | 2. Climate transition plan (p. 31 ) [2.4.5 Our environmental footprint]. SN 7.1 Green transition (p. 130 ) [Table 2. Environmental footprint] |  | E3 IRO 1
Consumption of raw materials and measures taken to improve the efficiency of its use. |  | 2. Climate transition plan (p. 31 ) [2.4.5 Our environmental footprint]. SN 7.1 Green transition (p. 130 ) [Table 2. Environmental footprint] |  | E5 IRO-1
Energy: direct and indirect consumption, measures taken to improve energy efficiency, use of renewable energies |  | 2. Climate transition plan (p. 31 ) [2.4.5 Our environmental footprint]. SN 7.1 Green transition (p. 130 ) [Table 2. Environmental footprint] |  | MDR-A MDR-M E1-3 E1-5
Climate change:
Important elements of greenhouse gas emissions generated as a business activity (including goods and services produced) |  | 2. Climate transition plan (p. 31 ) [2.4.5 Our environmental footprint]. SN 7.1 Green transition (p. 130 ) [Table 2. Environmental footprint]. |  | MDR-M E1-6
Measures taken to adapt to the consequences of climate change |  | 2. Climate transition plan (p. 31 ) |  | MDR-A E1 SBM-3 E1-1 E1-3
Reduction targets voluntarily established in the medium and long term to reduce greenhouse gas emissions and means implemented for this purpose. |  | 2. Climate transition plan (p. 31 ) |  | MDR-T E1-4
Protection of biodiversity:
Measures taken to preserve or restore biodiversity |  | 2. Climate transition plan (p. 31 ) [2.3.5 Our approach to nature and biodiversity]. |  | E4 IRO-1
Impacts caused by the activities or operations of protected areas |  |

Annual report 2025 232

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

| Non-financial information to be disclosed |  | Chapter/section of the annual report |  | Correspondence with CSRD/other regulations
2. Social | Employment:
Total number and distribution of employees by gender, age, country and professional classification |  | SN 7.3 Employees (p. 217 ). |  | MDR-M S1-6 S1-9
Total number and distribution of contracts modes and annual average of undefined contracts, temporary contracts, and part-time contracts by: sex, age and professional classification. |  | SN 7.3 Employees (p. 217 ). |  | MDR-M S1-6 S1-9
Number of dismissals by: gender, age and professional classification. |  | SN 7.3 Employees (p. 217 ). |  | MDR-M S1-6
Average remuneration and its progression broken down by gender, age and professional classification |  | SN 7.3 Employees (p. 217 ). |  | MDR-M S1-16
Salary gap and remuneration of equal or average jobs in society |  | 3. Supporting employees, communities and customers (p. 70) [3.1.3 Inclusive culture]. |  | MDR-M S1-16
Average remuneration of directors and executives (including variable remuneration, allowances, compensation, payment to long-term savings forecast systems and any other payment broken down by gender) |  | SN 7.3 Employees (p. 217 ). |  | GOV-3 MDR-M S1-16
Implementation of work disconnection policies |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.2 Working conditions]. |  | MDR-P S1-1
Employees with disabilities |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.3 Inclusive culture]. |  | MDR-M S1-12
Organization of work:
Organization of work time |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.2 Working conditions]. |  | MDR-P MDR-A S1-1 S1-4
Number of absent hours |  | SN 7.3 Employees (p. 217 ). |  | MDR-M S1-14
Measures designed to facilitate work-life balance and encourage a jointly responsible use of said measures by parents |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.2 Working conditions]. |  | MDR-A S1-4
Health and safety:
Conditions of health and safety in the workplace |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.2 Working conditions]. |  | MDR-A S1-14
Occupational accidents, in particular their frequency and severity, as well as occupational illnesses. Broken down by gender. |  | SN 7.3 Employees (p. 217). |  | MDR-M S1-14
Social relations:
Organization of social dialogue (including procedures to inform and consult staff and negotiate with them) |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.2 Working conditions]. |  | MDR-A S1-2 S1-8
Percentage of employees covered by collective bargaining agreements by country |  | SN 7.3 Employees (p. 217). |  | MDR-M S1-8
Balance of the collective bargaining agreements (particularly in the field of health and safety in the workplace) |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.2 Working conditions]. SN 7.3 Employees (p. 217 ). |  | MDR-M S1-8 S1-14
Mechanisms and procedures that employers have for encouraging the involvement of workers in management of the company, in terms of information, consultation and participation |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.4 Employee feedback and experience]. 4. Business conduct (p. 93 ) [4.3 Ethical channels]. |  | MDR-A S1-2 S1-8
Training:
The policies implemented in the field of training |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.1 Talent and skills development] |  | MDR-P S1-1
Total number of hours of training by professional categories. |  | SN 7.3 Employees (p. 217 ). |  | MDR-M S1-13

Annual report 2025 233

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

| Non-financial information to be disclosed |  | Chapter/section of the annual report |  | Correspondence with CSRD/other regulations
2. Social | Accessibility:
Universal accessibility of people |  | 3. Supporting employees, communities and customers (p.70 ) [3,1.3 Inclusive culture] [3.2.4 Community support] [3.3.1 Conduct with customers]. |  | MDR-A S1-4 S1-12
Equality:
Measures taken to promote equal treatment and opportunities between women and men, Equality plans (Chapter III of Organic Law 3/2007, of 22 March, for the effective equality of women and men), measures taken to promote employment, protocols against sexual and gender- based harassment, Policy against all types of discrimination and, where appropriate, integration of protocols against sexual and gender-based harassment and protocols against all types of discrimination and, where appropriate, management of diversity |  | 3. Supporting employees, communities and customers (p.70 ) [3,1.3 Inclusive culture]. [3.2.4 Community support]. |  | MDR-P MDR-A S1-1 S1-4 S1-12
3. Human Rights | Application of due diligence procedures in the field of Human Rights |  | 1. Sustainability at Santander (p.21 ) [1.4.2 Human rights due diligence]. |  | GOV-4
Prevention of the risks of Human Rights violations and, where appropriate, measures to mitigate, manage and repair any possible abuses committed |  | 3. Supporting employees, communities and customers (p. 70). 4. Business conduct (p. 93). |  | MDR-A S1-4 S3-4 S4-4
Complaints about cases of human rights violations |  | 4. Business conduct (p. 93 ) [4.3 Ethical channels]. |  | MDR-M S1-17 S3-4 S4-4
Promotion and compliance with the provisions of the fundamental conventions of the International Labour Organization regarding respect for freedom of association and the right to collective bargaining. |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.2 Working conditions]. NS 7.3 Employees (p. 217 ) [Table 11 Collective bargaining coverage and social dialogue]. |  | MDR-P S1-1
Elimination of discrimination in respect of employment and occupation; elimination of forced or compulsory labour; and the effective abolition of child labour. |  | 3. Supporting employees, communities and customers (p.70 ) [3.1.2 Working conditions] [3.2.3 Management of environmental and social aspects]. 4. Business conduct (p. 93) [4.2 Ethical conduct] [4.3 Ethical channels] |  | MDR-P S1-1
4. Fight against corruption | Measures taken to prevent corruption and bribery |  | 4. Business conduct (p. 93) [Financial crime compliance (FCC)]. Risk management and compliance chapter: 6.2 Compliance risk management section (p. 588). |  | MDR-A G1-3
Measures to combat money laundering |  | 4. Business conduct (p. 93) [Financial crime compliance (FCC)]. Risk management and compliance chapter: 6.2 Compliance risk management section (p. 588). |  | MDR-A G1-3
Contributions to non-profit foundations and entities |  | 3. Supporting employees, communities and customers (p.70 ) [3.2.4 Community support]. |  | MDR-A S3-4

Annual report 2025 234

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

| Non-financial information to be disclosed |  | Chapter/section of the annual report |  | Correspondence with CSRD/other regulations
5. Information on the company | Commitments of the company to sustainable development:
The impact of the company’s activity on employment and local development |  | Sustainability 2025 summary 3. Supporting employees, communities and customers (p. 70 ) [3.2.1 Supporting the economic and social development of our communities] [3.2.3 Management of Environmental and social aspects] [3.2.4 Community support] [3.3.2 Financial health and inclusion]. |  | MDR-A MDR-T MDR-M S3-4 S3-5
The impact of the company’s activity on local towns and villages and in the country. |  | 3. Supporting employees, communities and customers (p. 70) [3.2.4 Community support] [3.3.2 Financial health and inclusion]. |  | MDR-A MDR-T MDR-M S3-4 S3-5
Relations maintained with the representatives of local communities and the modalities of dialogue with them. |  | 1.Sustainability at Santander (p.21 ) [1.3 Stakeholder engagement]. |  | MDR-A S3-2
Association or sponsorship actions |  | Santander participates in the sectoral associations representing financial activity in the countries in which it operates, such as the AEB (Spanish Banking Association) in the case of Spain. |  | MDR-A S3-4
Outsourcing and suppliers:
Inclusion of social, gender equality and environmental issues in the procurement policy |  | 4. Business conduct (p. 93) [4.4 Our suppliers]. |  | MDR-P G1-2
Consideration in relations with suppliers and subcontractors of their responsibility |  | 4. Business conduct (p. 93) [4.4 Our suppliers]. |  | MDR-A G1-2
Supervision and audit systems and resolution thereof |  | 4. Business conduct (p. 93) [4.4 Our suppliers]. |  | MDR-M G1-2
Consumers:
Measures for the health and safety of consumers |  | 3. Supporting employees, communities and customers (p. 70). Risk, compliance and conduct management chapter: 7.2 Compliance and conduct risk management section (p. 548). |  | MDR-A S4-4
Systems for complaints received and resolution thereof |  | 3. Supporting employees, communities and customers (p. 70). Risk, compliance and conduct management chapter: 7.2 Compliance and conduct risk management section (p. 548 ). |  | MDR-M S4-4
Tax information:
The profits obtained country by country |  | Auditor's report and 2025 annual consolidate accounts (p. 607) (Annex VI Annual banking report) and Auditor's Report and 2024 annual consolidate accounts (Annex VI Annual banking report). |  | -
Taxes on benefits paid |  | SN 7.7 Tax contribution (p. 225) |
Public grants received |  | Grupo Santander did not receive significant public subsidies in 2024 and 2025. More details see VI Annual banking report, section e)Public subsidies (p. 904). |  | -
6. Other relevant information | EU Taxonomy |  | Information related to article 8 of EU Taxonomy: 3. Supporting employees, communities and customers (p. 70 ) [3.2.2 Responsible investment and social finances]. SN 5. EU Taxonomy (p. 125). |  | EU Regulation 2020/852 and Commission Delegated Regulations 2021/2139 and 2021/2178 as amended by Delegated Regulations (EU) 2022/1214, 2023/2485, 2023/2486 and 2026/73

Annual report 2025 235

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

SN 11. Commission Delegated Regulation (EU) 2023/2772 on sustainability reporting
standards content index
Table with references to sections and subsections of the Sustainability statement that respond to the information
requirements of the Directive (EU) 2022/2464 of the European Parliament and the Commission Delegated Regulation
(EU) 2023/2772.

Commission Delegated Regulation (EU) 2023/2772 content index
ESRS 2 - General disclosures
Basis for preparation | Section | Sub-section | Sub-sub-section | Comments
BP-1 – General basis for preparation of sustainability | About this chapter (p. 18 ) Sustainability notes (p. 99) | SN 1. Introduction, basis of presentation of the consolidated sustainability statement and other information (p. 99) |  |
BP-2 – Disclosures in relation to specific circumstances | Sustainability notes (p. 99) | SN 1. Introduction, basis of presentation of the consolidated sustainability statement and other information (p. 99) |  |
Governance | Section | Sub-section | Sub-sub-section | Comments
GOV-1 – The role of the administrative, management and supervisory bodies | 1. Sustainability at Santander (p. 21 ) Sustainability notes (p. 99) | 1.4 Sustainability governance (p. 29 ) SN 2. Sustainability governance (p. 110) SN 7.3 Employees (p. 217 ) | Table 17. Senior management composition |
GOV-2 – Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies | Sustainability notes (p. 99) | SN 2. Sustainability governance (p. 110 ) |  |
GOV-3 - Integration of sustainability-related performance in incentive schemes | 1. Sustainability at Santander (p. 21 ) | 1.4 Sustainability governance (p. 29 ) | 1.4.1 Integration of sustainability-related performance in incentive schemes |
GOV-4 - Statement on due diligence | 1. Sustainability at Santander (p. 21 ) | 1.4 Sustainability governance (p. 29 ) | 1.4.2 Human rights due diligence |
GOV-5 - Risk management and internal controls over sustainability reporting | 1. Sustainability at Santander (p. 21 ) Sustainability notes (p. 99) | 1.4 Sustainability governance (p. 29 ) SN 2. Sustainability governance (p. 110) |  |

Annual report 2025 236

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Strategy | Section | Sub-section | Sub-sub-section | Comments
SBM-1 – Strategy, business model and value chain | 1. Sustainability at Santander (p. 21 ) Sustainability notes (p. 99) | 1.1 Sustainability strategy (p. 21 ) 2.2 Supporting our customers in their transition goals (p. 33 ) 3.2 Communities' sustainable development (p. 77 ) 3.3. Our customers (p. 85 ) SN 1. Introduction, basis of presentation of the consolidated sustainability statement and other information (p. 99 ) SN 7.1 Green transition (p. 130) SN 7.5 Financial inclusion (p. 223) | 3.2.2 Responsible investment and social finance (p. 77 ) 3.3.2 Financial inclusion and financial health (p. 88 ) | The percentage of revenues of concerning sectors over the Group’s total revenues is not material (1.05% over the Group’s total revenues).
SBM-2 – Interests and views of stakeholders | 1. Sustainability at Santander (p. 21 ) 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 1.3 Stakeholder engagement (p. 25) 3.1 Our employees (p. 70 ) SN 3. Materiality assessment - Detailed methodology (p. 114 ) | 3.1.4 Employee feedback and experience |
SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model | 1. Sustainability at Santander (p. 21 ) Sustainability notes (p. 99) | 1.1 Sustainability strategy (p. 21 ) 1.2 Materiality Assessment (p. 23 ) SN 3. Materiality assessment - Detailed methodology (p. 114) |  | More details on the financial impact stemming from the opportunities identified in the double materiality assessment, see: 2.2 Supporting our customers in their transition goals (volume of assets aligned with the EU Taxonomy for mortgages and automobiles in Europe). 2.2.1 Corporate and Investment Banking (Green Finance raised or facilitated) The potential financial impact of the identified risks usually comes in the form of direct financial losses from legal claims (payments to third parties, compensation, etc.) and penalties. See Note 25.d) and 25.e) of the annual accounts.
Disclosures on the materiality assessment process | Section | Sub-section | Sub-sub-section | Comments
IRO-1 - Description of the processes to identify and assess material impacts, risks and opportunities | 1. Sustainability at Santander (p. 21 ) Sustainability notes (p. 99) | 1.2 Materiality Assessment (p. 23) SN 3. Materiality assessment - Detailed methodology (p. 114 ) |  |

Annual report 2025 237

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

IRO-2 - Disclosure requirements in ESRS covered by the undertaking’s sustainability statement | Sustainability notes (p. 99) | SN 1. Introduction, basis of presentation of the consolidated sustainability statement and other information (p. 99) SN 3. Materiality assessment - Detailed methodology (p. 114 ) SN 11. Commission Delegated Regulation (EU) 2023/2772 content index |  |
Minimum Disclosure Requirement | Section | Sub-section | Sub-sub-section | Comments
MDR-P – Policies adopted to manage material sustainability matters | 2. Our climate transition plan (p. 31 ) 3. Supporting employees, communities and customers (p. 70 ) 4. Business conduct (p. 93 ) Sustainability notes (p. 99 ) | SN 1. Introduction, basis of presentation of the consolidated sustainability statement and other information (p. 99 ) SN 9. Alternative performance measures (p. 227 ) |  |
MDR-A – Actions and resources in relation to material sustainability matters |  |
MDR-M – Metrics in relation to material sustainability matters |  |
MDR-T – Tracking effectiveness of policies and actions through targets |  |
ESRS E1 - Climate change
Governance | Section | Sub-section | Sub-sub-section | Comments
ESRS 2 GOV-3 Integration of sustainability related performance in incentive schemes | 1. Sustainability at Santander (p. 21 ) 2. Our climate transition plan (p. 31) | 1.4 Sustainability Governance (p. 29 ) 2.5 Further actions and enablers (p. 68 ) | 1.4.1 Integration of sustainability-related performance in incentive schemes 2.5.2 Governance & policies |
Strategy | Section | Sub-section | Sub-sub-section | Comments
E1-1 – Transition plan for climate change mitigation | 2. Our climate transition plan (p. 31 ) Sustainability notes (p. 99) | 2.1 Strategy (p. 31) 2.2 Supporting our customers in their transition goals (p. 33 ) 2.4 Aiming to align our activity with the Paris Agreement Goals (p. 55 ) 2.5 Further actions and enablers (p. 68) SN 4. Climate transition plan- (p. 123) | 2.5.2 Governance & policies |
ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with S&BM | 2. Our climate transition plan (p. 31 ) | 2.3 Embedding ESG in risk management (p. 39) | 2.3.1 Resilience of our strategy and business model to climate change 2.3.2 Risk management cycle |
Impact, risk and opportunity management | Section | Sub-section | Sub-sub-section | Comments

Annual report 2025 238

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

ESRS 2 IRO-1 – Description of the processes to identify and assess material climate-related impacts, risks and opportunities | 2. Our climate transition plan (p. 31 ) | 2.3 Embedding ESG in risk management (p. 39 ) | 2.3.2 Risk management cycle |
E1-2 – Policies related to climate change mitigation and adaptation | 2. Our climate transition plan (p. 31 ) | 2.5 Further actions and enablers (p. 68 ) | 2.5.1 Strategy for engagement with other key stakeholders 2.5.2 Governance & policies | Further details regarding Governance and Climate Change-related policies in: section 1.4 Sustainability Governance, SN 2. Sustainability governance , SN 6. Classification system and funding framework and section 3.3 (i) Our ESCC policies
E1-3 – Actions and resources in relation to climate change policies | 2. Our climate transition plan (p. 31 ) | 2.2 Supporting our customers in their transition goals (p. 33 ) 2.4 Aiming to align our activity with the Paris Agreement Goals (p. 55) 2.5 Further actions and enablers (p. 68) |  |
Metrics and targets | Section | Sub-section | Sub-sub-section | Comments
E1-4 – Targets related to climate change mitigation and adaptation | 2. Our climate transition plan (p. 31 ) Sustainability notes (p. 99) | 2.4 Aiming to align our activity with the Paris Agreement Goals (p. 55) SN 4. Climate transition plan (p. 123 ) |  |
E1-5 – Energy consumption and mix | 2. Our climate transition plan (p. 31 ) Sustainability notes (p. 99) | 2.4 Aiming to align our activity with the Paris Agreement Goals (p. 55) SN 4. Climate transition plan (p. 123 ) SN 7.1 Supporting the green transition (p. 130 ) | 2.4.5 Our environmental footprint Table 2. Environmental footprint 2024-2025 |
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions | 2. Our climate transition plan (p. 31 ) Sustainability notes (p. 99) | 2.4 Aiming to align our activity with the Paris Agreement Goals (p. 55) SN 4. Climate transition plan (p. 123 ) SN 7.1 Green transition (p. 130 ) | 2.4.5 Our environmental footprint Table 3. Gross Scopes 1, 2, 3 and Total GHG emissions |
E1-7 – GHG removals and GHG mitigation projects financed through carbon credits | 2. Our climate transition plan (p. 31 ) Sustainability notes (p. 99) | 2.4 Aiming to align our activity with the Paris Agreement Goals (p. 55) SN 7.1 Green transition (p. 130) | 2.4.5 Our environmental footprint Table 4. GHG mitigation projects financed through carbon credits |
E1-8 - Internal carbon pricing | Sustainability notes (p. 99) | SN 4. Climate transition plan (p. 123 ) |  |
E1-9 – Anticipated financial effects from material physical and transition risks and potential climate-related opportunities | 2. Our climate transition plan (p. 31 ) | 2.3 Embedding ESG in risk management (p. 39 ) | 2.3.4 Potential financial effects | Phase-in (partially). Response to requirements 66.a), 66.c) and 67.c).
ESRS E2, E3, E4, E5. | Section | Sub-section | Sub-sub-section | Comments
ESRS 2 IRO-1 – Description of the processes to identify and assess material climate-related impacts, risks and opportunities | 2. Our climate transition plan (p. 31 ) | 2.3 Embedding ESG in risk management (p. 39 ) | 2.3.5 Our approach to nature and biodiversity |
ESRS S1 - Own Workforce

Annual report 2025 239

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Strategy | Section | Sub-section | Sub-sub-section | Comments
ESRS 2 SBM 2 - Interests and views of stakeholders | 1. Sustainability at Santander (p. 21 ) | 1.3 Stakeholder engagement (p. 25) |  |
ESRS 2 SBM 3 - Material impacts, risks and opportunities and their interaction with strategy and business model | 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 3.1 Our employees (p. 70 ) SN 3. Materiality assessment - Detailed methodology (p. 114 ) | 3.1.1 Talent and skills development |
Impact, risk and opportunity management | Section | Sub-section | Sub-sub-section | Comments
S1-1 - Policies related to own workforce | 3. Supporting employees, communities and customers (p. 70 ) | 3.1 Our employees (p. 70 ) | 3.1.1 Talent and skills development 3.1.2 Working conditions 3.1.3 Inclusive culture |
S1-2 - Processes for engaging with own workforce and workers' representatives about impacts | 1. Sustainability at Santander (p. 21 ) 3. Supporting employees, communities and customers (p. 70 ) | 1.3 Stakeholder engagement (p. 25) 3.1 Our employees (p. 70 ) | 3.1.2 Working conditions 3.1.4 Employee feedback and experience |
S1-3 – Processes to remediate negative impacts and channels for own workers to raise concerns | 3. Supporting employees, communities and customers (p. 70 ) 4. Business conduct (p. 93) | 3.1 Our employees (p. 70 ) 4.3 Ethical channels (p. 96) | 3.1.3 Inclusive culture 3.1.4 Employee feedback and experience 4.3.1 Canal abierto |
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 | 3. Supporting employees, communities and customers (p. 70 ) | 3.1 Our employees (p. 70 ) | 3.1.1 Talent and skills development 3.1.2 Working conditions 3.1.3 Inclusive culture 3.1.4 Employee feedback and experience |
Metrics and targets | Section | Sub-section | Sub-sub-section | Comments
S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | 3. Supporting employees, communities and customers (p. 70 ) | 3.1 Our employees (p. 70 ) | 3.1.1 Talent and skills development 3.1.2 Working conditions 3.1.3 Inclusive culture |
S1-6 – Characteristics of the undertaking’s employees | 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 3.1 Our employees (p. 70 ) SN 7.3 Employees (p. 217 ) | 3.1.1 Talent and skills development Table 6. Employees by region Table 7. Employees by gender Table 10. Employees by employment contract Table 12. Turnover by region |
S1-8 – Collective bargaining coverage and social dialogue | 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 3.1 Our employees (p. 70 ) SN 7.3 Employees (p. 217 ) | 3.1.2 Working conditions Table 11. Collective bargaining coverage and social dialogue |
S1-9 – Diversity metrics | 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 3.1 Our employees (p. 70 ) SN 7.3 Employees (p. 217 ) | 3.1.3 Inclusive culture Table 8. Employees by management group and gender Table 9. Employees by age bracket |
S1-10 – Adequate wages | 3. Supporting employees, communities and customers (p. 70 ) | 3.1 Our employees (p. 70 ) | 3.1.2 Working conditions |

Annual report 2025 240

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

S1-11 – Social protection | 3. Supporting employees, communities and customers (p. 70 ) | 3.1 Our employees (p. 70 ) | 3.1.2 Working conditions |
S1-12– Persons with disabilities | 3. Supporting employees, communities and customers (p. 70 ) | 3.1 Our employees (p. 70 ) | 3.1.3 Inclusive culture |
S1-13 – Training and skills development metrics | 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 3.1 Our employees (p. 70 ) SN 7.3 Employees (p. 217 ) | 3.1.1 Talent and skills development Table 18. Training Table 19. Hours of training by gender and management group |
S1-14 – Health and safety metrics | 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 3.1 Our employees (p. 70 ) SN 7.3 Employees (p. 217 ) | 3.1.2 Working conditions Table 20. Occupational health and safety | The Group relies on the phase-in established by the ESRS for specific information of non- Employees (ESRS S1, S1-14, para. 89).
S1-16 – Compensation metrics (pay gap and total compensation) | 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 3.1 Our employees (p. 70 ) SN 7.3 Employees (p. 217 ) | 3.1.2 Working conditions Table 14. Remuneration ratios |
S1-17 – Incidents, complaints and severe human rights impacts | 3. Supporting employees, communities and customers (p. 70 ) 4. Business conduct (p. 70) | 3.1 Our employees (p. 70 ) 4.3 Ethical channels (p. 96 ) | 3.1.3 Inclusive culture |
ESRS S3 - Affected communities
Strategy | Section | Sub-section | Sub-sub-section | Comments
ESRS 2 SBM-2 – Interests and views of stakeholders | 1. Sustainability at Santander (p. 21 ) | 1.3 Stakeholder engagement (p. 25) |  |
ESRS 2 SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model | 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 3.2 Communities' sustainable development (p. 77 ) SN 3. Materiality assessment - Detailed methodology (p. 114 ) | 3.2.1 Supporting the economic and social development of our communities |
Impact, risk and opportunity management | Section | Sub-section | Sub-sub-section | Comments
S3-1 – Policies related to affected communities | 3. Supporting employees, communities and customers (p. 70 ) | 3.2 Communities' sustainable development (p. 77 ) | 3.2.2 Responsible investment and social finance 3.2.3 Management of environmental and social aspects 3.2.4 Community Support | Further details on governance and other policies related to affected communities: Section 1.4 Sustainability governance and NS 2. Sustainability governance
S3-2 – Processes for engaging with affected communities about impacts | 1. Sustainability at Santander (p. 21 ) 3. Supporting employees, communities and customers (p. 70 ) | 1.3 Stakeholder engagement (p. 25) 3.2 Communities' sustainable development (p. 77) | 3.2.2 Responsible investment and social finance 3.2.3 Management of environmental and social aspects 3.2.4 Community Support |
S3-3 – Processes to remediate negative impacts and channels for affected communities to raise concerns | 3. Supporting employees, communities and customers (p. 70 ) | 3.2 Communities' sustainable development (p. 77 ) | 3.2.3 Environmental, social and climate change management |

Annual report 2025 241

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

S3-4 – Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions | 3. Supporting employees, communities and customers (p. 70 ) | 3.2 Communities' sustainable development (p. 77 ) | 3.2.2 Responsible investment and social finance 3.2.3 Management of environmental and social aspects 3.2.4 Community Support |
Metrics and targets | Section | Sub-section | Sub-sub-section | Comments
S3-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | 3. Supporting employees, communities and customers (p. 70 ) | 3.2 Communities' sustainable development (p. 77 ) | 3.2.2 Responsible investment and social finance 3.2.3 Management of environmental and social aspects 3.2.4 Community Support |
ESRS S4 - Consumers and end-users
Strategy | Section | Sub-section | Sub-sub-section | Comments
ESRS 2 SBM-2 – Interests and views of stakeholders | 1. Sustainability at Santander (p. 21 ) | 1.3 Stakeholder engagement (p. 25) |  |
ESRS 2 SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model | 3. Supporting employees, communities and customers (p. 70 ) Sustainability notes (p. 99 ) | 3.3 Our customers (p. 85 ) SN 3. Materiality assessment - Detailed methodology (p. 114 ) |  |
Impact, risk and opportunity management | Section | Sub-section | Sub-sub-section | Comments
S4-1 – Policies related to consumers and end-users | 3. Supporting employees, communities and customers (p. 70 ) | 3.3 Our customers (p. 85 ) | 3.3.1 Conduct with customers 3.3.2 Financial inclusion and financial health 3.3.3 Privacy, data protection and cybersecurity | Further details on governance and other policies related to our clients: Section 1.4 Sustainability governance and NS 2. Sustainability governance
S4-2 – Processes for engaging with consumers and end-users about impacts | 1. Sustainability at Santander (p. 21 ) 3. Supporting employees, communities and customers (p. 70 ) | 1.3 Stakeholder engagement (p. 25) 3.3 Our customers (p. 85 ) | 3.3.1 Conduct with customers 3.3.2 Financial inclusion and financial health 3.3.3 Privacy, data protection and cybersecurity |
S4-3 – Processes to remediate negative impacts and channels for consumers and end-users to raise concerns | 3. Supporting employees, communities and customers (p. 70 ) | 3.3 Our customers (p. 85 ) | 3.3.1 Conduct with customers | Further details on section 4.3 Ethical channels
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 | 3. Supporting employees, communities and customers (p. 70 ) | 3.3 Our customers (p. 85 ) | 3.3.1 Conduct with customers 3.3.2 Financial inclusion and financial health 3.3.3 Privacy, data protection and cybersecurity |
Metrics and targets | Section | Sub-section | Sub-sub-section | Comments
S4-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | 3. Supporting employees, communities and customers (p. 70 ) | 3.3 Our customers (p. 85 ) | 3.3.1 Conduct with customers 3.3.2 Financial inclusion and financial health 3.3.3 Privacy, data protection and cybersecurity |
ESRS G1 - Business Conduct
Governance | Section | Sub-section | Sub-sub-section | Comments

Annual report 2025 242

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

ESRS 2 GOV-1 – The role of the administrative, supervisory and management bodies | 1. Sustainability at Santander (p. 21 ) Sustainability notes (p. 99) | 1.4. Sustainability governance (p. 29 ) SN 2. Sustainability governance (p. 110) |  |
Impact, risk and opportunity management | Section | Sub-section | Sub-sub-section | Comments
ESRS 2 IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities | 1. Sustainability at Santander (p. 21 ) Sustainability notes (p. 99) | 1.2 Materiality assessment (p. 23) SN 3. Materiality assessment - Detailed methodology (p. 114 ) |  |
G1-1– Corporate culture and Business conduct policies and corporate culture | 4. Business Conduct (p. 93 ) | 4.1 Corporate culture (p. 93 ) 4.2 Ethical Conduct (p. 94) 4.3 Ethical channels (p. 96 ) |  |
G1-2 – Management of relationships with suppliers | 4. Business Conduct (p. 93 ) | 4.4 Our suppliers (p. 98 ) |  |
G1-3 – Prevention and detection of corruption and bribery | 4. Business Conduct (p. 93 ) | 4.2 Ethical conduct (p. 94 ) | 4.2.3 Financial Crime Compliance |
Metrics and targets | Section | Sub-section | Sub-sub-section | Comments
G1-4 – Confirmed incidents of corruption or bribery | 4. Business Conduct (p. 93 ) | 4.2 Ethical conduct (p. 94 ) | 4.2.3 Financial Crime Compliance |
G1-6 – Payment practices | 4. Business Conduct (p. 93 ) | 4.4 Our suppliers (p. 98 ) |  |

Annual report 2025 243

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Independent verification report
Annual report 2025 244

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Annual report 2025 245

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |

Annual report 2025 246

| Contents |  | Business model and strategy l |  | Sustainability statement l |  | Corporate governance l |  | Economic and financial review l |  | Risk management and compliance l |