Skandinaviska Enskilda Banken AB

###### Position on lobbying and unethical influence
SEB has strict guidelines for unethical influence, whether within business or society. All actions and decisions are to be in compliance with laws, regulations and other external rules as well as with internal instructions and policies, such as SEB's Code of Conduct. We do not support political parties through donations or otherwise. [...] ###### Sustainability governance
SEB has created a robust sustainability governance model, with clear roles and mandates on different levels, that covers our impact on the economy, environment and climate, and people, including impact on social well-being and human rights and other ethical considerations. This model determines how we set our strategy and work to implement it in practice, where Sustainable Banking is the operational unit that is responsible for coordinating as well as driving the overall corporate sustainability agenda. [...] The Board fulfils these responsibilities through the approval of the group's business plan, including the sustainability strategy considerations. The Board also approves the Corporate Sustainability Policy for the SEB Group, the Sustainability Governance Instruction for the SEB Group, which outlines the sustainability governance structure, and the thematic policies (on Climate Change, Freshwater and Biodiversity, and Social and Human Rights). The Board also approves of the entering, or cancellation, of agreements or commitments of major importance for the SEB Group in the corporate sustainability area. SEB's sector policies are approved by the Board's Risk and Capital Committee (RCC). [...] The President and Chief Executive Officer (President) is responsible for the execution of the corporate sustainability strategy and implementation of the governance structure set by the Board. The decision-making body Group Executive Sustainability Committee (GESC) is established and chaired by the President, with the purpose of executing the corporate sustainability strategy. The GESC approves the Modern Slavery Act Transparency Statement and other SEB Group instructions as well as matters that are not approved by the Board or the RCC. [...] Sustainable Banking is a first-line, operational unit that is responsible for driving and coordinating the overall corporate sustainability agenda in close collaboration with the divisions, group staff functions and group support functions. The Chief Sustainability Officer (CSO) heads Sustainable Banking and is an additional member of GEC as well as member of GESC and GRC. [...] Each Head of Division, Head of Group Support function and Head of Group Staff function is responsible for ensuring that procedures and controls are in place to implement and adhere to the corporate sustainability objectives, strategy and policies set by the Board, the President and the GESC. In each division there is a Sustainability Business Risk Committee (SBRC). These committees assess and decide upon new customers or transactions from a material sustainability risk perspective and based on SEB's strategy and policies, before bringing the onboarding or transaction for decision by the relevant decision-making body. When a proposed transaction or customer onboarding deviates from SEB's Corporate Sustainability Policy or sustainability risk appetite, the client executive (or equal) escalates the matter to a divisional SBRC.

4.3. The Bank's Supervisory Board is responsible for monitoring the timeliness of the Bank's provision (publication) of reliable information on its activities in accordance with the law, and the Bank's publication of information on the Corporate Governance Code. [...] 8.1. This Policy is approved and amended by the Supervisory Board of the Bank. [...] 8.4. This Policy shall be annually reviewed by the Bank.

**5 Governance model** This policy follows the same governance model as for all SEB's policies: - The relevant business divisions are always responsible for ensuring adherence to the policy - The CRO function is responsible for following-up and control of adherence to the commitments in the Policy. - There will be a yearly review of the credit portfolios covered by this Policy. [...] **6 Company alignment with SEB's long term strategy on fossil related activities** SEB is committed to support its customers in meeting the Paris Agreement through an orderly transition. Companies which lack a transition plan, scope 1 and 2 for power generation and scope 1,2 and 3 for extraction and refining, should over time develop such a plan. SEB expects companies to be transparent about their transition plans, that the plans include milestones for the individual company's transition plan and that companies' public and non-public policy positions do reflect those plans. A Company that does not have such a plan and does not commit to producing such a plan within a reasonable time frame represents an outlier. SEB can act as an advisor to companies developing such plans.

**Position on lobbying and unethical influence** SEB has strict guidelines for unethical influence, whether within business or society. All actions and decisions are to be in compliance with laws, regulations, and other external rules as well as with internal instructions and policies, such as SEB's Code of Conduct. We do not support political parties through donations or otherwise. In 2023, SEB established a Public Affairs function through which we aim to strengthen the knowledge of our role in the society and the conditions under which we operate. The ambition is also to describe our role and efforts in relation to broad societal issues such as the green transition, entrepreneurship, and competitiveness. Via focused and structured communication with public decisionmakers and societal stakeholders, SEB works to understand and advise when requested.

SEB Asset Management's Sustainability Oversight Committee monitors sustainability risks. [...] SEB Asset Management's Sustainable Investment Committee evaluates and decides whether investments in liquid products, shares and corporate bonds can be classified as sustainable investments under SFDR. [...] SEB Asset Management's Exclusion Committee makes decisions regarding: - Exclusions and divestments based on the Sustainability Policy. - Exceptions from the policy, such as transition companies.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Engagement is coordinated by Sustainable banking function which reports to CEO and Board that approves strategy.