UBS Group AG

As embedded in the Organization Regulations of UBS Group AG, the Board of Directors' (BoD) Corporate Culture and Responsibility Committee (CCRC) oversees our climate strategy. Within the parameters set by the CCRC, the Group Executive Board ensures firm-wide execution of the climate strategy, including the firm's net zero commitment, and sets our firm's climate-related risk appetite. In joint meetings, the CCRC and the BoD's Risk Committee regularly and critically review the assessments and steps taken by these management bodies towards executing our climate strategy. The CCRC approves UBS's annual climate-related objectives and oversees the progressive alignment of our climate disclosure with the TCFD recommendations. These annual plans and objectives are managed as part of our ISO 14001-certified environmental management system (EMS) with defined management accountabilities across the firm. The EMS helps us to systematically reduce environmental risks, seize market opportunities and continuously improve our environmental and climate performance and resource efficiency. The CCRC supports the UBS Board of Directors in its duties to safeguard and advance the Group's reputation for responsible and sustainable conduct. This includes ensuring that the Board's oversight of climate-related issues is consistently implemented. The CCRC It approves and monitors UBS's overall sustainability and impact strategy and annual objectives, reviews that the pertinent constitutional document is relevant and up to date, and oversees the annual management review.

The management of SCR is steered at the GEB level. Reporting to the Group CEO, the Group Chief Risk Officer is responsible for the development and implementation of control principles and an appropriate independent control framework for SCR within UBS, and its integration into the firm's overall risk management and risk appetite frameworks. The Chief Risk Officer (the CRO) for Sustainability supports the GEB by providing leadership on sustainability in collaboration with business divisions and Group Functions. [...] Clients, transactions or suppliers potentially in breach of our standards, or otherwise subject to significant climate, environmental and human rights controversies, are referred to our SCR unit, which approves or rejects the cases after assessing their compliance with the firm's risk appetite standards. Advanced data analytics on companies associated with such risks is integrated into the web-based compliance tool used by our staff before they enter into a client or supplier relationship, or a transaction. The systematic nature of this tool significantly enhances our ability to identify potential risk.

Our voting decisions are coordinated and managed by our Stewardship team. The Team work closely with our fundamental analysts and portfolio managers in our investment teams to decide how to vote, based on the principles in our voting policy and considering any insights from engagement we may have undertaken, as well as our knowledge of the company. [...] Our voting activities are overseen by our Stewardship Committee, which is chaired by the Head of Investments. In cases where the analyst proposes that our vote should be cast differently to the recommendation provided, the Stewardship Committee will review and consider the reasons for this. A majority of committee members must approve the proposed vote. All voting actions reviewed by the committee are recorded, tracked and used to inform our future policy reviews. This additional governance strengthens our decision-making process, consistency, and aligns votes to our principles. [...] Proposed changes to our voting principles are drafted by our stewardship team and shared with our investment teams for comment and feedback. All final proposed updates are reviewed and approved by our Stewardship Committee. Any changes are also provided to the appropriate boards of our internally managed mutual funds for acceptance decision.

##### 4.2 Public policy engagement

Financial market stability is largely dependent on the overall economic, regulatory, and political environment, and the conduct of firms within the sector. UBS actively participates in political discussions to share our expertise on proposed regulatory and supervisory changes. UBS also actively engages in discussions relating to corporate responsibility and sustainability. Sustainability and sustainable finance continue to remain key focus topics in our interactions with our financial regulators and supervisors. These are subject to ongoing oversight and control by the second and third lines of defense.

We continue to see a greater focus on, and demand for, transparency and disclosure around climate and decarbonization, and we participate in dialogue with industry and regulators on these topics.

Globally, our firm is a member of several associations where the aforementioned topics are addressed and further considered, including for European entities. At the specific level of UBS Europe SE this includes: the Green and Sustainable Finance Cluster Germany; the Association of German Banks (Bundesverband deutscher Banken e.V.); the sustainable finance industry working groups of the European Bank Federation (EBF) and of the Association for Financial Markets in Europe (AFME); and the International Sustainability Standards Board (ISSB). [...] UBS engagement policies and processes are reviewed on an ongoing basis, enhanced, monitored, and adapted when insufficient progress is identified, and also in order to incorporate additional PAI indicators and to ensure the key environmental, socials and governance topics are taken into consideration.

Our climate strategy is overseen by UBS Group AG's Corporate Culture and Responsibility Committee (CCRC), a Board of Directors committee chaired by the Chairman of UBS Group AG. Climate matters, notably climate risk, are considered jointly by the CCRC and the BoD's Risk Committee (RC). The CCRC is chaired by the Chairman of UBS Group AG and also consists of four additional BoD board members, including the Chair of the RC. The responsibility of the CCRC for the climate strategy is embedded in its mandate in the Organization Regulations of UBS. The Chair of the CCRC brings the topics considered and decided by the CCRC, including climate, to the attention of the full Board of UBS Group AG. As part of its annual approval of UBS's sustainability and impact objectives, the CCRC considers our firm's climate-related objectives as set by the GEB. The committee also reviews the alignment of our climate disclosures with the recommendations of the TCFD. The CCRC is the firm's highest governance body for the firm's sustainability and impact strategy and activities. The annual objectives are managed as part of our ISO 14001-certified environmental management system (EMS), with defined management accountabilities across the firm. The EMS helps us to systematically reduce environmental risks, seize climate change (CC) /environment-related market opportunities and to continuously improve UBS's CC/environmental performance and resource efficiencies and is established according to the ISO14001 standard and codified in the UBS ISO14001 manual. This certificate attests that UBS's EMS is an appropriate tool for evaluating compliance with the relevant environmental regulations, achieving self-defined environmental objectives, and maintaining continual improvement of environmental performance. The EMS, structured in an annual cycle consisting of planning, implementation, controlling and review including corrective actions, applies world-wide to all transactions, services and activities involving CC/environmental issues entered into by or on behalf of UBS, with regular monitoring and reporting to the relevant committees. All types of material risks and opportunities are in-scope (including regulatory, customer behavior changes, reputational and weather-related). In the context of the EMS, Sustainability and Climate Risk (SCR) unit regularly coordinates a systematic materiality assessment in line with the ISO14001 standard covering all business divisions (BD) and products and services within the divisions, to assess if and where products/services may have an impact on the climate (and/or environment) and/or pose a risk (financial, reputational, etc.) to UBS (rated on severity and frequency, where frequent and/or severe SCR is defined as having a substantive impact). We prioritize risks and opportunities by focusing on the impact of CC and on our exposure to the risk, considering factors such as the product, service, client base, etc. Each BD assesses and rates the potential for risks/opportunities arising in the products and services offered according to a step-by-step procedure of identification and ranking, review and approval, and documentation. Items rated as having a substantive impact are further referred for management. We manage CR in our own operations, balance sheet, client assets and value chain. In March 2020, UBS launched the Group Risk Control Climate Risk Program to further integrate CR in the firm's risk management framework. The program follows a multi-year roadmap to address current and emerging regulations and is engaging with stakeholders and experts both internally and externally to further develop climate risk methodologies, deliver on climate stress test exercises, and build capacity to respond to climate risk management expectations. To protect our clients' and our own assets from climate-related risks, in 2021 we continued to drive the integration of climate-related risk into our standard risk management framework. Case studies on how UBS identifies and assesses climate-related risks: Transition risk: UBS, as a global financial services firm active in AM, WM and IB, can be affected by new carbon pricing regulation (reg.) and energy transition policies. Companies in carbon intensive sectors that are unprepared for reg. changes could face increasing costs and/or significant decline in demand for their goods and services with a negative impact on revenues and financial stability. We are (indirectly) exposed to fossil fuel intensive businesses in investment/ loan portfolios which may affect our own and our clients' assets. This may have a devaluating effect on the assets that UBS holds in its portfolio (lending portfolio and securities). Therefore routinely assess the impact of current and emerging reg., either directly affecting our operations or indirectly affecting those sectors where we have clients. Assessments and gap analysis exercises are conducted several times a year following a standardized identification process defined by the climate risk program. Additionally, reg. developments are assessed for impacts via quarterly monitoring. Other potential risks emerging in the short term:1)Reputation: CC related methodologies and standards will continue to change in the coming years. Our reputation may be adversely affected if our CC related actions and methods are not perceived as meeting existing or future industry standards and best practice. Example of this would be allegations related to greenwashing or inadequate action on CC. Increased reputational risks could lead to loss of business and may result in changes in regulations, which in turn could impact UBS's business model. 2)Market & sentiment: We have made protecting our clients' assets a strategic pillar in our firm's climate approach. We address this potential risk through our comprehensive sustainability and climate-focused product and service offering. Physical risk: UBS manages physical (acute & chronic) CR within its in-house operations (as part of the EMS described above). More frequent extreme weather conditions (Typhoons, Hurricanes) may have an adverse impact on vulnerable UBS locations). UBS plans for potential disruptions to its business, from adverse weather events, with its Business Continuity Management (BCM) unit. Critical locations get an annual Threat and Vulnerability Assessment (TVA) to identify such threats based on relative severity and likelihood. E.g., due diligence processes on any new vendor would routinely include a Threat and Vulnerability Analysis. It is essential that vendors performing critical activities on behalf of UBS have appropriate BCM arrangements in place for addressing the risks associated with the locations in which they operate, and for internal UBS departments to understand these critical dependencies.

###### SECTION 9 #### Our governance and oversight \n\nWe have established a clear structure for planning and execution of our sustainability approach and stewardship responsibilities. The Stewardship Committee oversees and coordinates our stewardship responsibilities and supports our executive team on all topics related to stewardship matters.\n\nThe Stewardship Committee is chaired by the head of investments. It also comprises of the head of sustainable investing, head of active equities, head of fixed income, head of institutional client coverage and head of portfolio execution and trading.\n\n###### Stewardship Committee oversight \n\nOur voting activities are overseen by our Stewardship Committee, which is chaired by the head of investments. In cases where our proposed final intended voting action differs from our policy guidelines, the Stewardship Committee will review and consider the supporting reason for this.\n\nA majority of committee members must approve any diversion from the recommendation prescribed by our voting policy. All voting actions reviewed by the Committee are recorded, tracked, and used to inform our future policy reviews. This additional governance step adds additional structure to our decision-making process with the goal that votes remain aligned to our principles and take a consistent approach.\n\nThe Committee also oversees the engagement progress for issuers with severe ESG risk and makes the ultimate decision regarding whether an issuer's engagement progress is sufficient to justify maintaining a holding in any issuer flagged for severe ESG risks.\n\nThe Committee is the executive forum for all relevant legal entities of the traditional business of UBS-AM globally. The Committee meets quarterly with ad-hoc meetings at the discretion of the chair should matters arise that warrant Committee review. The Committee can also perform duties on ad-hoc basis via email, as required, in respect to voting approvals that are required to be escalated for committee review.\n\nThe core committee responsibilities and duties are outlined in the table below.\n\n**Global Stewardship Approach** **Proxy Voting Policy**\n\n**Stewardship Committee**\n\n– Head of Investments (Chair)\n– Head of Active Equities\n– Head of Fixed Income\n– Head of Portfolio Execution and Trading\n– Head of Institutional Client Coverage\n– Head of Sustainable Investing\n\n**Category** **Responsibility**\n\n**ESG Integration/**\n**Stewardship**\n\n– Oversees engagement progress for issuers with severe ESG risk and approves related\n\nexclusion where necessary\n– Approves investments in companies identified as breaching global norms, where credible\n\ncorrective actions have been evidenced\n– Reviews and approves membership of any organization or collaborative efforts with other\n\ninvestors in relation to ESG/stewardship\n\n**Engagement** – Ensures alignment of our engagement activities with our Stewardship Policy across strategies\n– Reviews and approves requests to escalate our engagement activities through letters to the\n\nboard, AGM statements and/or public communications\n\n**Proxy voting** – Reviews and approves our Proxy Voting policy, including updates as required and/or scope\n\nchanges of country coverage\n– Approves all proposed proxy voting decisions which deviate from UBS Proxy Voting Policy\n\nguidelines, including where we vote upon shares held in UBS Group on behalf of client\n\nportfolios\n– Reviews and determines voting decisions where a consensus has not been reached among\n\nour sustainable investing team and portfolio management teams\n\n**Others** – Supports our efforts to send a clear message to companies based on all our holdings across\n\nindex and active strategies\n– Reviews and approves requests to participate in the filing of a shareholder resolution

Our management of sustainability and climate risk (SCR) is steered at the Group Executive Board (GEB) level. Our GEB Lead for Sustainability and Impact manages the Group Sustainability and Impact (GSI) organization and, together with our Chief Sustainability Officer (the CSO), co-chairs the Sustainability and Climate Task Force (the SCTF).

Regarding the stability of the financial system, UBS advocates for an internationally aligned regulatory framework, including capital and liquidity rules, anti-money laundering and digital regulation. Moreover, in the wake of the Credit Suisse rescue, we advocate for targeted and balanced amendments to the too-big-to-fail (TBTF) framework to address the lessons learned from the recent crisis. We also actively engage in discussions relating to corporate responsibility and sustainability. Sustainability and sustainable finance continue to remain key focus topics in our interactions with our financial regulators and supervisors. These are subject to ongoing oversight and control by the second and third lines of defense. [...] In Switzerland, they must be aligned with the general political engagement approach defined by the Political Board Swiss Chapter. In the US, our lobbying priorities are presented to and approved by the Region Americas' top management group at the beginning of each year.

The Chairman of the BoD, together with the Group CEO, takes responsibility for UBS's reputation and is closely involved in, and responsible for, ensuring effective communication with shareholders and stakeholders, including government officials, regulators and public organizations. [...] The CCRC oversees our Group-wide sustainability and impact strategy and key activities across environmental and social topics. This includes climate, nature, and human rights. Annually, it considers and approves our firm's sustainability (including climate) and impact objectives. As part of this process, it also considers the impact and financial materiality of climate-related risks and opportunities on UBS's business and strategy. [...] The GEB Lead for Sustainability and Impact also manages the Group Sustainability and Impact (GSI) organization and, together with the Chief Sustainability Officer (the CSO), co-chairs the Sustainability and Climate Task Force (the SCTF). Both the GEB Lead for Sustainability and Impact and the CSO attend the CCRC meetings. [...] The SCTF is the cross-divisional and cross-functional authority for sustainability and climate governance, as well as the Group's sustainability and climate governance body. Its role includes agreeing on the actions required to achieve UBS's sustainability and impact strategy, monitoring progress against that strategy and providing assurances to the GEB that UBS is managing sustainability and climate risks and opportunities in an appropriate manner. [...] The SCTF relies on the Sustainability and Climate Implementation Group to ensure cross-divisional, cross-functional and cross-regional (if needed) alignment of sustainability and climate activities. It oversees the following crossdivisional and cross-functional workstreams: Net Zero, Corporate Disclosures and Reporting, Regulatory and Market, Financial Risk Management, Non-Financial Risk, Investment Product Regulations, Commercial Opportunities, Data and Methodology, and Educate workstreams. [...] Linking our climate engagement with voting action is key to ensuring a continued clear alignment across our active ownership approach. To support this, we have aligned our voting policy with our climate engagement efforts and objectives in our policy framework and clarified our climate and net-zero expectations of companies. We have a clearly defined set of criteria which we use to evaluate companies' say-on-climate proposals. [...] We will further evaluate climate proposals against the following six key factors: climate governance, net-zero ambition and targets, quality of decarbonization strategy, net-zero performance alignment, lobbying and policy engagement, and use of offsets."
"The management of sustainability and climate risk is steered at the GEB level. Reporting to the Group CEO, the Group Chief Risk Officer is responsible for the development and implementation of control principles and an appropriate independent control framework for sustainability and climate risk within UBS, and its integration into the firm's overall risk management and risk appetite frameworks. The Chief Risk Officer (the CRO) for Sustainability supports the GEB by providing leadership on sustainability in collaboration with the business divisions and Group Functions. [...] Clients, transactions or suppliers potentially in breach of our standards, or otherwise subject to significant climate, environmental and human rights controversies, are referred to our Sustainability and Climate Risk unit, which approves or rejects the cases after assessing their compliance with the firm's risk appetite standards. Advanced data analytics on companies associated with such risks is integrated into the web-based compliance tool used by our staff before they enter into a client or supplier relationship, or a transaction. The systematic nature of this tool significantly enhances our ability to identify potential risk. In 2023, 3,297 referrals were assessed by our Sustainability and Climate Risk unit, of which 251 were rejected or not pursued, 356 were approved with certain qualifications and 419 were pending. The overall number of SCR referrals increased by 16% compared with 2022."
"The members of the UBS Europe SE's Management Board are ultimately responsible for adequate risk management and for establishing an integrated and institution-wide risk culture. This includes determining the firm's risk principles, risk appetite, major portfolio limits and their allocation to the business divisions and Treasury. The Management Board implements the risk framework, oversees the entity's risk profile and approves key UBS Europe SE risk policies. The oversight and controls include all business conducted in the entity including its branches, the risks associated with the branch business, and ensuring compliance with local legal and regulatory requirements. Notwithstanding the joint responsibility of the Management Board, each member of the Management Board is responsible for establishing adequate controls and monitoring processes in their respective area of responsibility. [...] UBS Europe SE's Supervisory Board is responsible for overseeing and challenging the Management Board, which informs the Supervisory Board about risk-relevant topics, including risk strategy and risk appetite. The Supervisory Board has established a Supervisory Board Risk Committee, which monitors and oversees the firm's risk profile and the implementation of the risk framework as approved by the Management Board, as well as reviewing the firm's key risk measurement methodologies, including sustainability and climate risk. [...] Regarding the governance of sustainability and climate risk, in addition to the UBS Group structure, UBS Europe SE has established its own organization. Since 2021 UBS Europe SE has had in place a Sustainability and SCR Steering Forum. It meets monthly, with Management Board representation including CEO and four additional members, and oversees the strategy and the implementation of plans to address regulatory expectations concerning the impact of climate-related and environmental risk on the legal entity. Furthermore, to ensure sustainability is handled as a key priority, in 2022 the UBS Europe SE Chief Risk Officer formally became the Management Board Member responsible for Sustainability Risks for UBS Europe SE, while the CFO UBS Europe SE became responsible for sustainability in January 2024, with responsibility previously under the Head Global Wealth Management Luxembourg & Nordics and Head Asset Management. Both co-chair the Sustainability and SCR Steering Forum. In 2022 the role of UBS Europe SE SCR Lead was established (2nd LoD), part of Group Risk Control, as well as the role of UBS Europe SE Sustainability Lead (1st LoD), part of the Group's Chief Sustainability Office. [...] In 2023, enhancements were made to the Sustainability and SCR Steering Forum and the formal reporting to the Management Board, providing quarterly, and when required bespoke updates. This allows sustainability to be addressed and monitored at the highest level in the entity. Also, a new ESG GCRG Monthly Forum has been established. Additionally, a new semi-annual report to the Management and Supervisory Boards on progress against the net-zero commitment was implemented in 2023.

Embedding our approach to climate The Corporate Culture and Responsibility Committee (the CCRC) of UBS Group AG's Board of Directors (the BoD) oversees UBS's climate strategy. This is set by our firm's Group Executive Board (the GEB), and includes our appetite for climate-related risks. In its six annual meetings, the CCRC regularly reviews the GEB's activities in executing UBS's climate strategy and, jointly with the BoD's Risk Committee, evaluates the progress of the firm's climate risk program. As part of its annual approval of UBS's sustainability and impact objectives, the CCRC considers our firm's climate-related objectives, as set by the GEB. The committee also reviews the alignment of our climate disclosures with the recommendations of the TCFD. We manage these annual plans and goals through our ISO 14001-certified environmental management system (the EMS) and management accountabilities across UBS Group AG. The EMS helps us reduce environmental risks, seize market opportunities and continually improve our environmental, climate and resource-efficiency performance. [...] Sustainability and climate risk management Our management of sustainability and climate risks (SCR) is steered at the GEB level. Reporting to the Group CEO, the Group Chief Risk Officer (GCRO) is responsible for the development and implementation of control principles and an appropriate independent control framework for SCR within UBS, and its integration into the firm's overall risk management and risk appetite frameworks. Under the leadership of the GCRO, the Chief Risk Officer for Sustainability oversees sustainability activities in Group Risk Control (GRC), including the climate risk program, and supports the GEB by providing leadership on sustainability in collaboration with the business divisions and Group Functions.

The Committee also oversees and reviews, at least annually, the company's public policy agenda, its position on significant public policy matters, political contributions and lobbying activities. [...] The North America Operating Unit Vice President of Public Policy, Federal Government Relations & Political Engagement is responsible for management of our public policy agenda and political engagement...

Sustainability activities, including sustainable finance, are overseen at the highest level of UBS, by the Board of Directors (the BoD) and the Group Executive Board (the GEB), and are grounded in our Code of Conduct and Ethics (the Code). [...] The BoD's Corporate Culture and Responsibility Committee (the CCRC) is the UBS body primarily responsible for corporate culture, responsibility and sustainability. The CCRC oversees our sustainability and impact strategy and activities and approves Group-wide sustainability and impact objectives. The Group CEO has delegated to the GEB lead for sustainability and impact, Suni Harford, the responsibility for setting the firm's sustainability and impact strategy, in agreement with fellow GEB members. [...] Group Risk Control is responsible for the development and implementation of principles and an appropriate independent control framework for sustainability and climate risks within UBS, and the integration of the principles and the framework into the firm's overall risk management and risk appetite frameworks."
"As part of its annual approval of our sustainability and impact objectives, the CCRC also oversees UBS's climate strategy, as set by the GEB. During its six meetings throughout the course of the year, the CCRC reviews the GEB's activities in executing our climate strategy and, jointly with the BoD's Risk Committee, evaluates the progress of our climate risk program. The committee also reviews the alignment of our climate disclosures with the recommendations of the Task Force on Climate-related Financial Disclosures (the TCFD). We manage these annual plans and goals through our ISO 14001-certified environmental management system (the EMS), with management accountabilities across our firm. The EMS helps us reduce environmental risks, seize market opportunities, and continually improve our environmental, climate and resource-efficiency performance. In May 2021, we established a net-zero task force to help progress toward our ambition of reaching net zero by 2050. The GEB lead for sustainability and impact chairs the task force. Senior representatives from across our firm, including from the business, risk and finance, attend the task force's monthly meetings.

#### Our Group-wide sustainability governance

###### − All BoD committees have specific responsibilities pertaining to ESG matters

− The BoD's Corporate Culture and Responsibility Committee (the CCRC) is the body primarily responsible for corporate culture, responsibility, and sustainability

− GEB Lead for sustainability and impact responsible for setting the sustainability and impact strategy and developing Group-wide sustainability and impact objectives

− Certain CS sustainability governance bodies have been retired in 2023 and our aim is to achieve full integration of the relevant bodies, together with their associated procedures and policies, into the overall UBS Group sustainability governance during 2024

Our governance framework on sustainability supports the creation of long-term value. Sustainability activities, including sustainable finance, are overseen at the highest level of UBS (the Board of Directors (BoD) and Group Executive Board (GEB)) and are grounded in our Code of Conduct and Ethics. In 2021, the Group Sustainability and Impact (GSI) organization was created to support the GEB lead for sustainability and impact with carrying out her responsibilities. GSI comprises of the Chief Sustainability and Social Impact offices, headed by the Chief Sustainability Officer (CSO) and the Head Social Impact. The CSO is responsible for driving the implementation of the Group-wide sustainability and impact strategy, including reporting on our progress toward net zero, and the execution thereof by the business divisions and Group Functions. The Head Social Impact is responsible for driving and implementing our social impact strategy, including community impact, philanthropy services, and UBS Global Visionaries. Progress against the strategy and associated targets is reviewed at least annually by the GEB and Corporate Culture and Responsibility Committee (the CCRC). [...] Our firm's sustainability and corporate culture activities are overseen at the highest level of our firm and are founded in our Principles and Behaviors. The Board of Directors (the BoD) of UBS Group AG decides on the strategy of the Group, upon recommendation by the Group Chief Executive Officer (the Group CEO), and has ultimate oversight for the overall direction, supervision and control of the Group and its management, as well as for supervising compliance with applicable laws, rules and regulations. Progress made in implementing Group Sustainability and Impact objectives are reported as part of UBS's annual reporting. This reporting is reviewed and assured externally according to the requirements of the Global Reporting Initiative's (GRI) Sustainability Reporting Guideline. The CCRC also reviews the alignment of our climate disclosures with the recommendations of the TCFD. We manage these annual plans and goals through our ISO 14001-certified environmental management system (the EMS) and management accountabilities across UBS Group AG. The EMS helps us reduce environmental risks, seize market opportunities and continually improve our environmental, climate and resource-efficiency performance. [...] Sustainability activities, including sustainable finance, are overseen at the highest level of UBS, by the Board of Directors (BoD) and the Group Executive Board (GEB), and are grounded in our Code of Conduct and Ethics (the Code). It is our goal to be the financial provider of choice for clients wishing to mobilize capital toward the SDGs and the orderly transition to a low-carbon economy. The Group Sustainability and Impact (GSI) governance and framework defines the high-level principles and responsibilities, and our corporate purpose supports further promotion of this commitment systematically across all relevant businesses and for implementing the ethical standards defined in the Code that governs UBS's interactions with society and the environment. Our sustainability and climate risk (SCR) policy framework is embedded in the firm's culture, and applies firm-wide to relevant activities, including client and supplier relationships; is integrated in management practices and control principles and overseen by senior management; and supports transition towards a net-zero future. [...] UBS's sustainability and impact activities are overseen at the highest level of our firm and are founded in our Principles and Behaviors, as captured in the Code. The BoD of UBS Group AG has ultimate oversight for the overall direction, supervision and control of the Group and its management, as well as for supervising compliance with applicable laws, rules and regulations. The BoD's Corporate Culture and Responsibility Committee (the CCRC) is primarily charged with oversight of our sustainability and impact strategy and activities, and approves Group-wide sustainability and impact objectives. The Group Executive Board (the GEB) develops the strategy for the Group, as outlined in the Organization Regulations of UBS Group AG. The Group CEO has delegated to the GEB lead for sustainability and impact the responsibility for setting the sustainability and impact strategy, and developing Group-wide sustainability and impact objectives, in agreement with fellow GEB members.

### 4. Governance«

The Board of Directors of UBS BB ("Board") is responsible for: I - approving and reviewing the PRSAC, with the help of CRO LatAm; II - ensure the adherence of the institution to PRSAC and to the actions implemented; III - ensure the compatibility and integration of PRSAC with other policies established by the institution; IV - ensure the timely correction of deficiencies related to PRSAC; V - ensure that the remuneration structure does not encourage behavior incompatible with PRSAC; and VI - promote the internal dissemination of PRSAC and the actions implemented.

The Executive Board of UBS BB is responsible for complying with this Policy and for executing the business in accordance with its principles.

The Risk and Capital Committee of UBS BB ("CORIS") assists the Board in the exercise of its responsibilities with respect to risk and capital management, including social, environmental and climate risk, by issuing non-binding recommendations to support the decisions of the Board. In addition, other topics related to social, environmental and climate risks are also reported to the Risk and Control Committee of UBS BB ("RCC") on a monthly basis.

**Executive Boards of the respective regulated entities are responsible for: approve PRSAC within the framework of their** respective governance, propose recommendations to the Board of directors on the establishment and review of PRSAC and evaluating the degree of adherence of the actions implemented to PRSAC, proposing recommendations for improvement, when necessary.

The Chief Risk Officer of América Latina ("CRO LatAm") is responsible for: assisting the Board of Directors, by providing support and participating in the decision-making process related to the establishment and review of PRSAC, ensuring the implementation of actions linked to PRSAC's effectiveness; monitor and evaluate the actions implemented, indicating improvements when any deficiency is identified, and disseminate reliable information, according to article 10 of CMN Resolution 4,945/21.

**All employees of the 1st and/or 2nd Lines of Defense or Group Functions have responsibilities in relation to the principles** established in this Policy, among others, when onboarding customers, performing continuous customer coverage and periodic review, approving transactions, performing controls or selecting or engaging with suppliers. Each principle of this Policy has its control and metrics defined by the respective area responsible for it.

The **Sustainability and Climate Risk Team ("SCR Team") is responsible for implementing e monitoring SCR Framework,** according to defined risk appetite, monitoring emerging topics related to environmental, social and climate risk exposure, ensuring that the pattern of sustainability and climate risks are incorporated into the culture, management and principles of UBS BB entities, and carrying out sustainability and climate analysis of transactions, customers and suppliers.

**Corporate lobbying** In general, we will support resolutions seeking greater transparency on company lobbying, except where covered by existing legislation and where the company meets such regulation, unless there is a direct reputational risk. We will not support resolutions where the company's current reporting meets industry and regional standards. We will generally support shareholder proposals seeking greater transparency on the company's industry association participation. For UK listed companies we may support proposals put forward by companies to make contributions to industry associations that fall under the technical scope of EU legislation, provided that a defined materiality threshold and limit has been disclosed, in line with market practice.

Reviewed by the UBS Group BoD' Corporate Culture and Responsibility Committee (the CCRC), UBS's GRI-based materiality assessment process is managed by our MAT. The MAT consists of a group of employees who deal with stakeholder expectations and concerns in their respective roles. Their regular engagement with clients, employees, investors, suppliers, regulators and governments, communities, and civil society ensures that the views of these stakeholders are adequately considered. The MAT is responsible for delivering the outcome of the materiality assessment to the CCRC and permanent guests on an annual basis and oversees the aggregation process, following three principles. – Completeness: the MAT reviews the long and short lists and their aggregation into a prioritized list. – Accuracy: the MAT challenges the approach, provides access to relevant resources, and helps to overcome hurdles throughout the process. – Relevance: the MAT reviews all decisions in terms of relevance for the stakeholders they represent." [...] "The UBS Sustainability and Climate Risk Framework, defined in the Supplement "Managing sustainability and climate risks" to the UBS Group Sustainability Report 2023, is also embedded in the UBS Europe SE risk control framework. The sustainability and climate risk initiative follows a multi-year roadmap across our firm's business divisions and legal entities, and hence also covers UBS Europe SE. It is designed to integrate sustainability and climate risk considerations into our firm's various traditional financial risk management frameworks, and related policies and processes. This is necessary to meet expectations regarding the management of sustainability and climate risks and to deliver on climate stress-test exercises. There will be continuous enhancement of the sustainability and climate risk management framework as additional capabilities and enhanced data become available. › Refer to the "Managing sustainability and climate risks" section of the UBS Group Sustainability Report 2023, available at ubs.com/sustainability-reporting and in particular to the "Sustainability and climate risk framework" section for further details on the implementation plans to integrate sustainability and climate risk into other risk categories as well as progress to date.

SCR framework UBS annually performs a sustainability and climate risk materiality assessment of its products, services and supply chain (in accordance with the ISO 14001 standard and UBS's Risk Control Self-Assessment). Products, services and activities deemed as having high risk are subject to the following framework. **(1) Risk identification and measurement: the materiality of** sustainability and climate risks to which UBS is exposed to are assessed using the firm's risk identification framework as part of the risk inventory process. Climate risks are identified with heatmaps that rate cross-sectoral credit risk exposure to climate sensitivity, from high to low, through a risk segmentation process. In addition, climate risks are assessed by using climate scenario analysis and stress tests exercises to understand the short-, medium- and long-term financial risks to the business model stemming from climate change. **(2) Risk monitoring and appetite setting: UBS's exposures to** high- and medium-risk sectors, changes in regulations, and emerging sustainability risks are monitored, and the Group Executive Board reviews and adjusts the risk appetite standards when it sees fit. **(3) Risk management and control: standard financial and non-** financial risk processes ensure that material sustainability and climate risks are identified, assessed, approved and escalated in a timely manner. These processes are applied in client onboarding, transaction due diligence, product development and supply chain management. **(4) Risk reporting: key sustainability and climate risk** considerations are included in periodic risk reporting at legal entity, divisional and Group levels. Standard financial and non-financial risk processes ensure that material sustainability and climate risks are identified, assessed, approved and escalated in a timely manner. These include controls during client onboarding, transaction due diligence and product development and as part of the investment decision processes, own operations, supply chain management, and portfolio reviews _Governance_ In view of the many sustainability and climate-related challenges globally, these topics will continue to increase in relevance for banks. These developments therefore require regular and critical assessment of our policies and practices, based on an accurate monitoring and analysis of societal topics of potential relevance to UBS. The management of SCR is steered at the GEB level. Reporting to the Group CEO, the Group Chief Risk Officer is responsible for the development and implementation of control principles and an appropriate independent control framework for SCR within UBS, and its integration into the firm's overall risk management and risk appetite frameworks. The Chief Risk Officer (the CRO) for Sustainability supports the GEB by providing leadership on sustainability in collaboration with business divisions and Group Functions. _Integration in financial and non-financial processes_ – _Client onboarding:_ Potential clients are assessed for sustainability and climate risks associated with their business activities as part of UBS's Know-your-client processes. – _Transaction due diligence:_ Sustainability and climate risks are identified and assessed as part of standard transaction due diligence and decision-making processes. – _Product development and investment decision processes:_ New financial products and services are reviewed before their launch in order to assess their compatibility and consistency with UBS's environmental and human rights standards. Sustainability and climate risks are also considered where relevant as part of the firm's overall ESG approach to investment decision processes and when exercising ownership rights, such as proxy voting, and engagement with the management of investee entities. – _Own operations:_ Our operational activities and employees, and contractors working on UBS's premises, are assessed for compliance with relevant environmental, health and safety, and labor rights regulations. – _Supply chain management:_ Sustainability and climate risks are assessed when selecting and dealing with suppliers. UBS also evaluates goods and services that pose potential environmental, labor and human rights risks during life cycle (production, usage and disposal) as part of its purchasing processes. – _Portfolio review:_ At the portfolio level, we regularly review sensitive sectors and activities prone to bearing sustainability and climate-related risks. We assess client exposure and revenue in such sectors and attempt to benchmark the portfolio quality against regional and / or sector averages. Such portfolio reviews give us an accurate aggregated exposure profile and an enhanced insight into our transaction and client onboarding processes. Based on the outcome of these reviews, we can explore ways to improve the future portfolio profile along a range of risk parameters. Clients, transactions or suppliers potentially in breach of our standards, or otherwise subject to significant climate, environmental and human rights controversies, are referred to our SCR unit, which approves or rejects the cases after assessing their compliance with the firm's risk appetite standards. Advanced data analytics on companies associated with such risks is integrated into the web-based compliance tool used by our staff before they enter into a client or supplier relationship, or a transaction. The systematic nature of this tool significantly enhances our ability to identify potential risk. In 2021, 2,919 referrals were assessed by our SCR unit, of which 100 were rejected or not pursued, 384 were approved with qualifications and 72 were pending. The overall number of SCR referrals increased by 35% compared with 2020, primarily driven by portfolio reviews conducted in the context of UBS net-zero commitment.

#### Our Group-wide sustainability governance

###### − All BoD committees have specific responsibilities pertaining to ESG matters

− The BoD's Corporate Culture and Responsibility Committee (the CCRC) is the body primarily responsible for corporate culture, responsibility, and sustainability

− GEB Lead for sustainability and impact responsible for setting the sustainability and impact strategy and developing Group-wide sustainability and impact objectives

− Certain CS sustainability governance bodies have been retired in 2023 and our aim is to achieve full integration of the relevant bodies, together with their associated procedures and policies, into the overall UBS Group sustainability governance during 2024

Our climate strategy is overseen by UBS Group AG's Corporate Culture and Responsibility Committee (CCRC), a Board of Directors committee chaired by the Chairman of UBS Group AG. Climate matters, notably climate risk, are considered jointly by the CCRC and the BoD's Risk Committee (RC). The CCRC is chaired by the Chairman of UBS Group AG and also consists of four additional BoD board members, including the Chair of the RC. The responsibility of the CCRC for the climate strategy is embedded in its mandate in the Organization Regulations of UBS. The Chair of the CCRC brings the topics considered and decided by the CCRC, including climate, to the attention of the full Board of UBS Group AG. As part of its annual approval of UBS's sustainability and impact objectives, the CCRC considers our firm's climate-related objectives as set by the GEB. The committee also reviews the alignment of our climate disclosures with the recommendations of the TCFD. The CCRC is the firm's highest governance body for the firm's sustainability and impact strategy and activities. The annual objectives are managed as part of our ISO 14001-certified environmental management system (EMS), with defined management accountabilities across the firm. The EMS helps us to systematically reduce environmental risks, seize climate change (CC) /environment-related market opportunities and to continuously improve UBS's CC/environmental performance and resource efficiencies and is established according to the ISO14001 standard and codified in the UBS ISO14001 manual. This certificate attests that UBS's EMS is an appropriate tool for evaluating compliance with the relevant environmental regulations, achieving self-defined environmental objectives, and maintaining continual improvement of environmental performance. The EMS, structured in an annual cycle consisting of planning, implementation, controlling and review including corrective actions, applies world-wide to all transactions, services and activities involving CC/environmental issues entered into by or on behalf of UBS, with regular monitoring and reporting to the relevant committees. All types of material risks and opportunities are in-scope (including regulatory, customer behavior changes, reputational and weather-related). In the context of the EMS, Sustainability and Climate Risk (SCR) unit regularly coordinates a systematic materiality assessment in line with the ISO14001 standard covering all business divisions (BD) and products and services within the divisions, to assess if and where products/services may have an impact on the climate (and/or environment) and/or pose a risk (financial, reputational, etc.) to UBS (rated on severity and frequency, where frequent and/or severe SCR is defined as having a substantive impact). We prioritize risks and opportunities by focusing on the impact of CC and on our exposure to the risk, considering factors such as the product, service, client base, etc. Each BD assesses and rates the potential for risks/opportunities arising in the products and services offered according to a step-by-step procedure of identification and ranking, review and approval, and documentation. Items rated as having a substantive impact are further referred for management. We manage CR in our own operations, balance sheet, client assets and value chain. In March 2020, UBS launched the Group Risk Control Climate Risk Program to further integrate CR in the firm's risk management framework. The program follows a multi-year roadmap to address current and emerging regulations and is engaging with stakeholders and experts both internally and externally to further develop climate risk methodologies, deliver on climate stress test exercises, and build capacity to respond to climate risk management expectations. To protect our clients' and our own assets from climate-related risks, in 2021 we continued to drive the integration of climate-related risk into our standard risk management framework.

Embedding our approach to climate The Corporate Culture and Responsibility Committee (the CCRC) of UBS Group AG's Board of Directors (the BoD) oversees UBS's climate strategy. This is set by our firm's Group Executive Board (the GEB), and includes our appetite for climate-related risks. In its six annual meetings, the CCRC regularly reviews the GEB's activities in executing UBS's climate strategy and, jointly with the BoD's Risk Committee, evaluates the progress of the firm's climate risk program. As part of its annual approval of UBS's sustainability and impact objectives, the CCRC considers our firm's climate-related objectives, as set by the GEB. The committee also reviews the alignment of our climate disclosures with the recommendations of the TCFD. We manage these annual plans and goals through our ISO 14001-certified environmental management system (the EMS) and management accountabilities across UBS Group AG. The EMS helps us reduce environmental risks, seize market opportunities and continually improve our environmental, climate and resource-efficiency performance. [...] In 2021, we established a net-zero task force to help ensure we become a net-zero firm by 2050. The GEB lead for sustainability and impact chairs the task force. Senior stakeholders from across our business attend the task force's monthly meetings, including senior leaders from risk and finance.

Our BoD's Corporate Culture and Responsibility Committee (the CCRC) is the body primarily responsible for corporate culture, responsibility and sustainability. The CCRC oversees our Groupwide sustainability and impact strategy (including PRB implementation) and key activities across environmental and social topics, including climate, nature and human rights. Annually, it considers and approves our firm's sustainability and impact objectives, meeting 6 times within the year. [...] Our GEB Lead for Sustainability and Impact manages the Group Sustainability and Impact (GSI) organization and, together with our Chief Sustainability Officer (the CSO), co-chairs the Sustainability and Climate Task Force (the SCTF). Both our GEB Lead for Sustainability and Impact and our CSO are also permanent guests of the CCRC.

Our BoD's Corporate Culture and Responsibility Committee (the CCRC) is the body primarily responsible for corporate culture, responsibility and sustainability. The CCRC oversees our Groupwide sustainability and impact strategy (including PRB implementation) and key activities across environmental and social topics, including climate, nature and human rights. Annually, it considers and approves our firm's sustainability and impact objectives, meeting 6 times within the year. As part of this process, it also considers the impact and financial materiality of climate-related risks and opportunities on UBS's business and strategy. [...] The Group Executive Board (the GEB) develops the strategy for the Group. It is responsible for managing our assets and liabilities in line with the Group's strategy, regulatory commitments and the interests of our stakeholders. As determined by the BoD's Risk Committee, the GEB manages the risk profile of the Group as a whole. It has overall responsibility for establishing and implementing risk management and control. The Group CEO has delegated responsibility for setting the sustainability and impact strategy and developing Group-wide sustainability and impact objectives, in agreement with fellow GEB members, to the GEB Lead for Sustainability and Impact. Progress against the strategy and associated targets are reviewed at least once a year by the GEB and the CCRC. [...] The GEB Lead for Sustainability and Impact also manages the Group Sustainability and Impact (GSI) organization and, together with the Chief Sustainability Officer (the CSO), co-chairs the Sustainability and Climate Task Force (the SCTF). Both the GEB Lead for Sustainability and Impact and the CSO attend the CCRC meetings.

Our BoD's Corporate Culture and Responsibility Committee (the CCRC) is the body primarily responsible for corporate culture, responsibility and sustainability. The CCRC oversees our Group-wide sustainability and impact strategy and key activities across environmental and social topics, including climate, nature and human rights. Annually, it considers and approves our firm's sustainability and impact objectives. [...] The responsibility for setting the sustainability and impact strategy and developing Group-wide sustainability and impact objectives, in agreement with fellow GEB members, has been delegated to the GEB Lead for Sustainability and Impact by the Group chief executive officer (the Group CEO). Progress against strategy and the associated targets are reviewed at least once a year by the GEB and the CCRC. [...] Our GEB Lead for Sustainability and Impact manages the Group Sustainability and Impact (GSI) organization and, together with our Chief Sustainability Officer (the CSO), co-chairs the Sustainability and Climate Task Force (the SCTF). Both our GEB Lead for Sustainability and Impact and our CSO are also permanent guests of the CCRC. [...] The Sustainability and Climate Task Force (the SCTF) is the authority for divisional and functional sustainability and climate governance, as well as the Group's sustainability and climate governance. The SCTF's role includes the approval of the actions required to achieve our firm's climate strategy, monitoring progress against that strategy and providing assurances to the GEB that UBS manages climate risk and opportunities in a proper manner.

Our BoD's Corporate Culture and Responsibility Committee (the CCRC) is the body primarily responsible for corporate culture, responsibility and sustainability. The CCRC oversees our Group-wide sustainability and impact strategy and key activities across environmental and social topics, including climate, nature and human rights. Annually, it considers and approves our firm's sustainability and impact objectives. [...] The responsibility for setting the sustainability and impact strategy and developing Group-wide sustainability and impact objectives, in agreement with fellow GEB members, has been delegated to the GEB Lead for Sustainability and Impact by the Group chief executive officer (the Group CEO). Progress against strategy and the associated targets are reviewed at least once a year by the GEB and the CCRC. [...] The Sustainability and Climate Task Force (the SCTF) is the authority for divisional and functional sustainability and climate governance, as well as the Group's sustainability and climate governance. The SCTF's role includes the approval of the actions required to achieve our firm's climate strategy, monitoring progress against that strategy and providing assurances to the GEB that UBS manages climate risk and opportunities in a proper manner. [...] Our Group Compliance, Regulatory & Governance (GCRG) function is responsible for the ongoing monitoring of the adequacy of our control environment for non-financial risks (NFR) and sets out requirements for the design and operation of 1st LoD (Line of Defense) and 2nd LoD controls across Operational Risk, Compliance and Financial Crime Prevention. GCRG is actively engaged across UBS's Risk Committee structure and supervisory board governance. It drives the review and, where necessary, the required adaptations to our NFR frameworks to align the independent control and oversight capabilities with existing and new regulations and changes across business activities. [...] In 2022, GCRG established the Sustainability Expert Group (the SEG, with senior representatives from across the divisional, regional and functional GCRG units, supported by senior experts across Group Legal, Group Risk Control, Sustainability CFO and Group Sustainability and Impact. In 2022, we focused our activities on initiating a range of enhancements to our ESG NFR risk assessment and process control coverage whilst undertaking appropriate reviews of the integration of ESG factors into the NFR control framework. This included considerations relevant to the consistent assessment, monitoring and escalation of high inherent reputational risk – incorporating ESG factors.

**Corporate lobbying** In general, we will support resolutions seeking greater transparency on company lobbying, except where covered by existing legislation and where the company meets such regulation, unless there is a direct reputational risk. We will not support resolutions where the company's current reporting meets industry and regional standards. We will generally support shareholder proposals seeking greater transparency on the company's industry association participation. For UK listed companies we may support proposals put forward by companies to make contributions to industry associations that fall under the technical scope of EU legislation, provided that a defined materiality threshold and limit has been disclosed, in line with market practice.

The Board of Directors of UBS Group AG (the BoD) has ultimate responsibility for the success of the Group and for delivering sustainable shareholder value within a framework of prudent and effective controls. It decides on the Group's strategy and the necessary financial and human resources, on the recommendation of the Group Chief Executive Officer (the Group CEO). The BoD also sets the Group's values and standards to ensure its obligations to shareholders and other stakeholders are met. It also supervises compliance with applicable laws, rules and regulations. Five committees support the Board of Directors of UBS Group AG (the BoD) in fulfilling its duty through the respective responsibilities and authority given to them. All BoD committees have specific responsibilities pertaining to environmental, social and governance (ESG) matters: the Compensation Committee is responsible for ESG-related compensation topics, the Risk Committee supervises the integration of ESG in risk management and the Audit Committee has oversight of the control framework underpinning ESG metrics. Our BoD's Corporate Culture and Responsibility Committee (the CCRC) is the body primarily responsible for corporate culture, responsibility and sustainability. The CCRC oversees our Groupwide sustainability and impact strategy (including PRB implementation) and key activities across environmental and social topics, including climate, nature and human rights. Annually, it considers and approves our firm's sustainability and impact objectives, meeting 6 times within the year. As part of this process, it also considers the impact and financial materiality of climate-related risks and opportunities on UBS's business and strategy. The Group Executive Board (the GEB) develops the strategy for the Group. It is responsible for managing our assets and liabilities in line with the Group's strategy, regulatory commitments and the interests of our stakeholders. As determined by the BoD's Risk Committee, the GEB manages the risk profile of the Group as a whole. It has overall responsibility for establishing and implementing risk management and control. The Group CEO has delegated responsibility for setting the sustainability and impact strategy and developing Group-wide sustainability and impact objectives, in agreement with fellow GEB members, to the GEB Lead for Sustainability and Impact. Progress against the strategy and associated targets are reviewed at least once a year by the GEB and the CCRC. The GEB Lead for Sustainability and Impact also manages the Group Sustainability and Impact (GSI) organization and, together with the Chief Sustainability Officer (the CSO), co-chairs the Sustainability and Climate Task Force (the SCTF). Both the GEB Lead for Sustainability and Impact and the CSO attend the CCRC meetings. Furthermore, our compensation determination process considers environmental, social and governance (ESG) objectives in objective setting, performance award pool funding, performance evaluation and individual compensation decisions. ESG-related objectives have been embedded in our Pillars and Principles since they were established in 2011. In 2021, we introduced explicit sustainability objectives in the non-financial goal category of the Group CEO and GEB performance scorecards. In 2023, we further enhanced the GEB performance scorecard framework by establishing separate Environmental & Sustainability and People & Governance categories.

Regarding the stability of the financial system, UBS advocates for an internationally aligned regulatory framework, including capital and liquidity rules, anti-money laundering and digital regulation. Moreover, in the wake of the Credit Suisse rescue, we advocate for targeted and balanced amendments to the too-big-to-fail (TBTF) framework to address the lessons learned from the recent crisis. We also actively engage in discussions relating to corporate responsibility and sustainability. Sustainability and sustainable finance continue to remain key focus topics in our interactions with our financial regulators and supervisors. These are subject to ongoing oversight and control by the second and third lines of defense. [...] In Switzerland, they must be aligned with the general political engagement approach defined by the Political Board Swiss Chapter. In the US, our lobbying priorities are presented to and approved by the Region Americas' top management group at the beginning of each year.

Our sustainability governance [...] The CCRC oversees our Group-wide sustainability and impact strategy and key activities across environmental and social topics. This includes climate, nature, and human rights. Annually, it considers and approves our firm's sustainability (including climate) and impact objectives. As part of this process, it also considers the impact and financial materiality of climate-related risks and opportunities on UBS's business and strategy. [...] The GEB Lead for Sustainability and Impact also manages the Group Sustainability and Impact (GSI) organization and, together with the Chief Sustainability Officer (the CSO), co-chairs the Sustainability and Climate Task Force (the SCTF). Both the GEB Lead for Sustainability and Impact and the CSO attend the CCRC meetings. [...] The SCTF is the cross-divisional and cross-functional authority for sustainability and climate governance, as well as the Group's sustainability and climate governance body. Its role includes agreeing on the actions required to achieve UBS's sustainability and impact strategy, monitoring progress against that strategy and providing assurances to the GEB that UBS is managing sustainability and climate risks and opportunities in an appropriate manner. [...] The SCTF relies on the Sustainability and Climate Implementation Group to ensure cross-divisional, cross-functional and cross-regional (if needed) alignment of sustainability and climate activities. It oversees the following cross-divisional and cross-functional workstreams: Net Zero, Corporate Disclosures and Reporting, Regulatory and Market, Financial Risk Management, Non-Financial Risk, Investment Product Regulations, Commercial Opportunities, Data and Methodology, and Educate workstreams.

The management of sustainability and climate risk is steered at the GEB level. Reporting to the Group CEO, the Group Chief Risk Officer is responsible for the development and implementation of control principles and an appropriate independent control framework for sustainability and climate risk within UBS, and its integration into the firm's overall risk management and risk appetite frameworks. The Chief Risk Officer (CRO) for Sustainability oversees sustainability and climate risk activities in Group Risk Control, including the Sustainability and Climate Risk Initiative. [...] Clients, transactions or suppliers potentially in breach of our standards, or otherwise subject to significant climate, environmental and human rights controversies, are referred to our SCR unit, which approves or rejects the cases after assessing their compliance with the firm's risk appetite standards. Advanced data analytics on companies associated with such risks is integrated into the web-based compliance tool used by our staff before they enter into a client or supplier relationship or a transaction. The systematic nature of this tool significantly enhances our ability to identify potential risk.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]UBS' governance of sustainability ensures that relevant functions, up to and including the highest governance level, are informed about and involved in the decision-making on and evolution of UBS' climate change strategy. UBS Group AG's Board of Directors' Corporate Culture and Responsibility Committee (CCRC), chaired by the UBS Chairman (=Board Chair), and with the Group CEO, the GEB Lead for Sustainability and Impact, the Group Chief Risk Officer and the Chief Sustainability Officer as permanent guests, meets six times a year. The CCRC regularly considers UBS' strategy on climate change, including also external engagements & positions and relevant regulatory developments. Discussions on climate risk take place as joint CCRC and RC (Risk Committee) meetings. The UBS Group Executive Board, led by the Group CEO, regularly discusses and considers UBS' climate strategy, including the implementation of the firm's Net Zero commitment. The Chief Sustainability Office ensures that relevant aspects are communicated to and discussed with the BoD and the GEB and relevant functions within the firm. Internal communication of the climate change strategy ensures all employees are informed and educated about the firm's climate change strategy. For example, regular intranet articles inform employees about our CC strategy and the economic impact of CC on the economy and the financial sector. Both the Chairman and Group CEO of UBS are directly involved in initiatives that influence policy consistent with our firm's climate change strategy (including e.g. via GFANZ and the WEF Alliance of CEO Climate Leaders). In addition: UBS contributes to pertinent external discussions and consultations on climate-related matters. The Head External Engagement chairs the IIF's Sustainable Finance Working Group. UBS is represented in the Swiss Banker's Association and is a member of the FSB's TCFD and TNFD. Headquartered in Switzerland, UBS representatives regularly interact with government officials, including on climate-related matters. The UBS Chief Sustainability Officer serves on the Board of Swiss Sustainable Finance. The Head Corporate Responsibility chairs the joint CSR working group of major Swiss trade associations economiesuisse and SwissHoldings, which consider sustainability topics, including climate change. It is also a member of economiesuisse's working group on energy, which also considers climate change, including how it pertains to policy-making in Switzerland.

Attach commitment or position statement(s)[…]We engage with stakeholders on a regular basis and on a wide range of topics. This engagement yields important information about their goals, expectations and concerns. It makes a critical contribution to our understanding and management of issues that have a potential impact (whether positive or negative) on our firm and on our stakeholders. Please find more information on our engagement with stakeholders on pp. 156-157 of our Sustainability Report.

Additionally, UBS' (climate) commitments to the NZBA and the PRB translate into our engagement activities with stakeholders including via our direct engagements and trade associations as publicly outlined in our sustainability report pp. 80-81:

"It is our firm belief that by taking action – both on our own and in partnership with other large investors, standard setters, our clients and our peers, as well as our communities and our own employees – we can achieve a real impact on a truly global scale. This is why partnerships are integral to our sustainability approach. Sustainability reporting is a clear case in point. We recognize that currently there is a lack of standardization, with gaps that in some cases can only be fixed by standardization of disclosure requirements. However, this will not be accomplished by the financial industry alone: it will require a concerted effort on the part of regulators, governmental organizations, non-profit organizations and many others. We therefore regularly work with other financial firms and organizations outside our industry, including standard setters, to address this challenge".

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes