VP Bank AG

Our Sustainability Board supports the implementation of the Sustainability Plan 2026 and ensures consistency across the Bank. It is chaired by the Chief Investment Officer and includes senior representatives from various departments. The board meets to review progress, discuss any issues and develop suggestions for further improvements.

The implementation of these measures, both carbon-specific and the general VPSS, is continuously monitored by the first and second lines of defence and for our own investments reported to the Risk Committee of the Bank's Supervisory Board as part of the quarterly risk report.

Group Sustainability is responsible for setting strategic priorities, developing and implementing the Sustainability Plan 2026 and monitoring progress. This includes supporting different departments with relevant sustainability topics and raising awareness among all employees. The topic of sustainability is firmly anchored in our core business, with the Head of Group Sustainability reporting directly to the Chief Investment Officer (CIO), who in turn reports to the Chief Executive Officer (CEO). Updates are provided regularly to the GEM and annually to the Strategy & Digitalisation Committee of the BoD. [...] The Board of Directors (BoD) has ultimate oversight of climate-related risks and opportunities. The BoD, which is responsible for the ultimate management, supervision and control of VP Bank Group, bears overall responsibility for risk management, including ESG risks and climate-related financial risks. This includes, among other things, the establishment and maintenance of suitable organizational and operational structure as well as an internal control system for risk management to ensure the long-term risk-bearing capacity of VP Bank. This is reflected in VP Bank's risk policy. Group Executive Management (GEM) is responsible for the implementation of and compliance with the risk policy (framework and risk strategies) approved by the BoD.

Efficient and effective sustainability governance is essential to ensuring that we continue to embed sustainability into our business, stay on track with our sustainability goals and recognise potential opportunities and challenges at an early stage. As such, we have put into place a straightforward governance structure and a comprehensive support mechanism by way of our Sustainability Board. The integration of sustainability into the investment and advisory processes is governed by relevant Group policy frameworks, including our investment policy and related compliance and monitoring systems. GEM members are informed on the status and progress of sustainability measures. [...] The Group Sustainability department is responsible for setting strategic priorities, developing and implementing the Sustainability Plan 2026 and monitoring progress. This includes supporting different departments with relevant sustainability topics and raising awareness among all employees. The topic of sustainability is firmly anchored in our core business, with the Head of Group Sustainability reporting directly to the Chief Investment Officer (CIO), who in turn reports to the Chief Executive Officer (CEO). Regular updates are provided to the GEM and annually to the Strategy & Digitalisation Committee of the BoD. [...] The Sustainability Board supports the implementation of the 2026 Sustainability Plan and ensures a consistent approach across VP Bank. It is chaired by the Chief Investment Officer. The Sustainability Board also includes representatives from various departments (see  Figure 8). The Sustainability Board meets as needed to review progress, discuss any issues and develop further suggestions for improvement. Meetings are organised by the Head of Group Sustainability. Our sustainability governance has been instrumental in setting our strategy, monitoring progress and addressing potential challenges in achieving our goals, including meeting our voluntary commitments. [...] Monitoring of climate-related risks and opportunities by the Board of Directors The Board of Directors (BoD) has ultimate oversight of climate-related risks and opportunities. The BoD, which is responsible for the ultimate management, supervision and control of VP Bank Group, bears overall responsibility for risk management, including ESG risks and climate-related financial risks. This includes, among other things, the establishment and maintenance of a suitable organisational and operational structure as well as an internal control system for risk management in order to ensure the long-term risk-bearing capacity of VP Bank. This is reflected in VP Bank's risk policy. [...] The role of management in assessing and managing climate-related risks and opportunities The GEM is responsible for the implementation of and compliance with the risk policy (framework and risk strategies) approved by the BoD and has the following responsibilities: - Operationalising and monitoring compliance with the "Risk Appetite Statement" approved by the BoD - Ensuring the operational functionality of the risk management process and internal control systems - Establishing committees for effective risk management and defining roles, competencies and responsibilities - Periodic review of the risk policy, risk framework and risk strategies [...] The Chief Risk Officer (CRO) heads up the risk management function and is responsible within GEM for the independent risk oversight of VP Bank and the individual Group companies. The working group formed in the previous year, comprising experts from various disciplines, deals with the necessary implementation of change processes in the risk framework and continuously reviews any necessary adjustments.

Governance

The integration of sustainability criteria into the investment and advisory processes are governed by the relevant VP Bank Group's policy frameworks and integrates it in its overall monitoring and compliance systems and processes. This includes various committees that are re-sponsible for developing and approving the approach to sustainable investing, the eligibility criteria, and strategies: Investment Strategy Committee, Investment Tactics Committee, and Product & Pricing Committee.

The relevant investment, compliance, internal audit function, management body and senior management are re-sponsible to implement aspects of this sustainability policy according to their respective duties.

Efficient and effective sustainability governance is essential in ensuring that we continue to embed sustainability into our business, stay on track with our sustainability goals and recognise potential opportunities and challenges at an early stage. As such, we have put into place a straightforward governance structure and a comprehensive support mechanism by way of our Sustainability Board. The integration of sustainability into the investment and advisory processes is governed by relevant Group policy frameworks, including our investment policy and related compliance and monitoring systems. [...] The Group Sustainability department is responsible for setting strategic priorities, developing and implementing the Sustainability Plan 2026 and monitoring progress. This includes supporting different departments with relevant sustainability topics and raising awareness among all employees. The topic of sustainability is firmly anchored in our core business, with the Head of Group Sustainability reporting directly to the Chief Investment Officer (CIO), who in turn reports to the Chief Executive Officer (CEO). Regular updates are provided to the GEM and annually to the Strategy & Digitalisation Committee of the BoD. [...] The Sustainability Board supports the implementation of the Sustainability Plan 2026 and ensures consistency across the Bank. It is chaired by the CIO and includes senior representatives from various departments (see  figure 8). The Sustainability Board meets three times per year to review progress, discuss any issues and develop suggestions for further improvements. The meetings are organised by the Head of Group Sustainability.

Efficient and effective sustainability governance is essential in ensuring that we continue to embed sustainability into our business, stay on track with our sustainability goals and recognise potential opportunities and challenges at an early stage. As such, we have put into place a straightforward governance structure and a comprehensive support mechanism by way of our Sustainability Board. The integration of sustainability into the investment and advisory processes is governed by relevant Group policy frameworks, including our investment policy and related compliance and monitoring systems. [...] The Group Sustainability department is responsible for setting strategic priorities, developing and implementing the Sustainability Plan and monitoring progress. This includes supporting different departments with relevant sustainability topics, as well as raising awareness among all employees. The topic of sustainability is firmly anchored in our core business, with the Head of Group Sustainability reporting directly to the Chief Investment Officer (CIO), who in turn reports to the Chief Executive Officer (CEO). Regular updates are provided to the Group Executive Management (GEM) and annually to the Strategy & Digitalisation Committee of the Board of Directors. [...] The Sustainability Board supports the implementation of the Sustainability Plan 2026 and ensures consistency across the Bank. It is chaired by the Chief Investment Officer and includes senior representatives from various departments. The Sustainability Board meets three times per year to review progress, discuss any issues and develop suggestions for further improvements. The meetings are organised by the Head of Group Sustainability.

Governance

The integration of sustainability criteria into the investment and advisory processes are governed by the relevant VP Bank Group's policy frameworks and integrates it in its overall monitoring and compliance systems and processes. This includes various committees that are re-sponsible for developing and approving the approach to sustainable investing, the eligibility criteria, and strategies: Investment Strategy Committee, Investment Tactics Committee, and Product & Pricing Committee.

The relevant investment, compliance, internal audit function, management body and senior management are re-sponsible to implement aspects of this sustainability policy according to their respective duties.

## 3.8. Governance

The investment process is headed by the CIO. The advisory process is headed by the Head of CII. The portfolio management process is headed by the Head of IIM. The integration of responsible investment criteria into the investment and advisory processes are governed according to the relevant VP Bank policy frameworks and integrated in its overall monitoring and compliance systems and processes. Roles and responsibilities for this group standard are the same as defined in the framework directive \"Group Investment Policy\" (FD-09-2104, Annex 1). The relevant investment, compliance, internal audit function, management body and senior management are responsible to implement aspects of this group standard according to their respective duties. [...] ## 3.9. Compliance and monitoring

Products that do not meet VP Banks's responsible investment criteria are in general not eligible for discretionary portfolio management and advisory mandates. These criteria are implemented into relevant investment, portfolio management and advisory systems and processes where VP Bank makes investment decisions and recommendations. Recommendations are continuously monitored to ensure criteria are met. Should an investment become ineligible, it will no longer be recommended and in cases where clients have holdings in these assets, we will notify clients and offer alternative solutions. In the case of in-scope portfolio or fund management mandates, ineligible financial instruments are reviewed for sale. [...] Compliance and monitoring are conducted in accordance with the relevant policies and procedures in the Group Policy Framework. These mechanisms ensure that this group standard is applied consistently.

The Group Executive Management (GEM) and the Strategy & Digitalisation Committee of the Board of Directors (BOD) participated in dedicated workshops to define the role of sustainability in the overall Group Strategy and VP Bank's ambition based on the results of the consultations. The Sustainability Plan 2026 was formulated and approved accordingly. [...] Three sustainability key performance indicators (KPIs) are included in the regular monitoring of the overall Group strategy roadmap to inform the GEM of the status and progress made. This ensures that our sustainability targets are included in the regular review of our Group Strategy 2026. The three KPIs are: CO2-neutral operations, net positive impact through our offering and external ESG ratings. [...] Clear accountability and ownership of goals have been established and Head of Sustainability has the role to oversee the progress. [...] The Group Sustainability department is responsible for setting strategic priorities, developing and implementing the Sustainability Plan 2026 and monitoring progress. This includes supporting different departments with relevant sustainability topics and raising awareness among all employees. The topic of sustainability is firmly anchored in our core business, with the Head of Group Sustainability reporting directly to the Chief Investment Officer (CIO), who in turn reports to the Chief Executive Officer (CEO). Regular updates are provided to the GEM and annually to the Strategy & Digitalisation Committee of the BoD. [...] Management's role in assessing and managing climate-related risks and opportunities: Group Executive Management (GEM) is responsible for the implementation and observance of the Risk Policy approved by the Board of Directors (BoD). It operationalises the BoD's risk appetite and ensures compliance monitoring. It also monitors VP Bank's progress towards targets. The Chief Risk Officer (CRO), as a member of the GEM, is responsible for independent risk monitoring.