Amundi SaEURONEXT: AMUN

23 - Amundi’s commitments – Sustainability statement

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AMUNDI'S COMMITMENTS



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▌ COMMITMENTS

▌ AMBITION

▌ SUSTAINABILITY STATEMENT (CERTIFIED)

▌ 3.1 GENERAL DISCLOSURES (ESRS 2)

▌ 3.2 CLIMATE CHANGE (ESRS E1)

▌ 3.3 RESPONSIBLE EMPLOYER (ESRS S1)

▌ 3.4 CLIENTS AND END-USERS (ESRS S4)

▌ 3.5 BUSINESS CONDUCT (ESRS G1)

▌ SUSTAINABILITY STATEMENT ANNEXES

▌ 3.6 CERTIFICATION REPORT ON SUSTAINABILITY AND TAXONOMY INFORMATION

▌ 3.7 UPDATE ON RESPONSIBLE INVESTMENT REPORTING

(2024 FORMAT, NON-CERTIFIED)

▌ 3.8 AMUNDI'S CLIMATE STRATEGY (NON-CERTIFIED)

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AMUNDI'S COMMITMENTS

Commitments

‌Commitments

1. ACT AS A RESPONSIBLE FINANCIAL INSTITUTION

€1,048bn

RESPONSIBLE INVESTMENT ASSETS

17,204

NUMBER OF ISSUERS COVERED

BY AMUNDI'S PROPRIETARY ESG RATING(1)

83%

AMUNDI RECOMMENDATION SCORE (2)

21.6

AVERAGE NUMBER OF TRAINING HOURS PER EMPLOYEE

39.1%

NUMBER OF WOMEN

ON THE EXECUTIVE COMMITTEE

2. ACTING AS A RESPONSIBLE EMPLOYER

0.34 Teq CO2/FTE

ENERGY-RELATED EMISSIONS (3)

0.73 Teq CO2/FTE

TRAVEL-RELATED EMISSIONS (4)

€0.6m

PURCHASES FROM

SHELTERED SECTOR COMPANIES (5)

3. ACTING RESPONSIBLY FOR THE ENVIRONMENT

Amundi's non-financial ratings

B+

RATED "PRIME",

ONE OF THE THREE INDUSTRY LEADERS (SOURCE: ISS ESG) (6)

19.5

CLASSIFIED BY SUSTAINALYTICS AS "LOW CSR RISK" (7)

AA

RATED BY MSCI

RANKED AMONG "ESG LEADERS" (8)

  1. The reduction in covered issuers versus 2024 results from a refined definition of issuer scope to enhance consistency and reliability.

  2. Rate of positive replies to the statement "I would recommend my company to my friends and relations as a good employer" in the annual survey of all employees conducted by Willis Towers Watson in December 2025.

  3. Scope 1 and 2, excluding refrigerants.

  4. Business travel by airplane and train.

  5. In France.

  6. Last updated on 13/03/2026.

  7. Last updated on 23/09/2025.

  8. Last updated on 27/01/2026.

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    AMUNDI'S COMMITMENTS

    Ambition

    ‌Ambition

    Amundi's purpose is to work every day in the interests of its clients and society. Societal engagement is thus one of the four founding pillars of the company. It is based on three convictions:

    • economic and financial players bear a social responsibility;

    • incorporating ESG criteria into investment choices provides a source of long-term performance;

    • accelerating our ESG commitments will be an important growth driver around the world.

      Amundi's 2028 Strategic Plan

      On 18 November 2025, Amundi unveiled its 2028 Medium Term Plan entitled "Invest for the future"(1). This plan reaffirms Amundi's four distinctive characteristics - notably its recognized and sustained commitment to responsible investment, as well as its global leadership, European identity and technological expertise and innovation capacity. The plan prioritizes growth, diversification, innovation, efficiency and selective investments to create attractive value for shareholders while providing clients with high-quality products and excellent service.

      ESG issues and CSR are fully integrated into Amundi's 2028 Medium Term Plan, which is structured around six priorities. One of these is to continue investing to develop products and solutions that serve our clients. In the area of Responsible Investment, Amundi intends to maintain its global leadership by offering its clients the broadest range of responsible products on the market and by innovating in distinctive areas such as blended finance, climate, and solutions related to biodiversity and the preservation of natural capital. Amundi will also continue to strengthen its engagement and voting activities, which benefit all of our active and passive funds. This cross-cutting approach likewise places exemplary conduct at the heart of Amundi's objectives.

      This Strategic Plan follows on from the ESG Ambitions 2025 plan (details in insert). The latter, which ended in late 2025, had set three objectives for the Group:

    • increase the level of ambition of its investment solutions in terms of Responsible Investment;

    • engage with as many companies as possible to define credible strategies for aligning with the Net Zero 2050 objective;

    • align its employees and shareholders with its ambitions.

      To meet these objectives and in line with the Crédit Agricole group's social project, Amundi is committed to:

    • acting as a responsible financial institution;

    • acting in the interest of clients;

    • acting as a responsible employer;

    • and acting as an environmentally responsible citizen.

      Amundi has a dedicated governance to manage its strategy as a responsible investor and responsible company. This governance operates at two levels:

    • supervision by the Board of Directors: the Board of Directors relies primarily on the work of the Strategy and CSR Committee. Composed of two-thirds independent board members, including the Chairman, it formulates an opinion on the company's climate strategy and its policy on social and environmental responsibility and, at least annually, it reviews the actions taken by the Group in this area and the results achieved;

    • monitoring and management by General Management: Amundi has committees dedicated to Responsible Investment and CSR chaired by Amundi's Chief Executive Officer:

      • the ESG and Climate Strategy Committee (described in section 3. 2. 1. 1). This Committee meets monthly to define and guide Responsible Investment actions,

      • the CSR Committee: this Committee, which meets every half year, defines and guides Amundi's responsible actions for its own operations.

        1. The 2028 Medium Term Plan is presented in Chapter 4 Review of Financial Position and Results in 2025.

          3

          AMUNDI'S COMMITMENTS

          Ambition

          ESG Ambitions 2025 plan

          Regarding its o$ering of savings or technology solutions,

          Amundi committed by 2025 to:

          1. introducing a new environmental transition rating into its open-ended funds under active management, which represent €400 billion(1). The aim of this rating will be to assess companies' decarbonisation efforts and the development of their sustainable activities. To encourage them to undertake this transformation, these portfolios invest

            in greater proportions in those making the most effort in their energy transition than in others;

          2. offering open-ended funds in all asset classes with a binding Net Zero 2050 investment objective;

          1. reaching €20bn in assets in impact funds that invest in companies seeking positive environmental or social performance. This impact is measured and reported annually;

          2. ensuring that 40% of its range of passive funds is made up of ESG funds;

          5. developing, within Amundi Technology, ALTO*

          (2)

          Sustainability, a technology analysis solution designed to support investors in decision-making regarding the environmental and social impact of their portfolio.

          1. Scope of activity of open-ended funds for which a environmental transition rating method is applicable.

          2. ALTO: Amundi Leading Technologies & Operations.

          In terms of voting & engagement with companies, Amundi committed to:

          6. working with 1,000 additional companies to define credible 7. from 2022, excluding from its portfolios companies that strategies for reducing their greenhouse gas emissions, to generate over 30% of their activity from unconventional oil vote at their annual General Shareholders' Meetings and for and gas production.

          management remuneration packages to be linked to these

          strategies;

To align its employees and shareholders with this ambition, Amundi decided to:

  1. take into account the level of achievement of these investment objectives (weight 20% of total criteria) in the KPIs calculation of performance shares for its 200 senior executives. It also set ESG targets for all investment managers and sales representatives;

  2. reduce its own direct greenhouse gas emissions by approximately 30% (vs. 2018) per employee in 2025;

  3. present its climate strategy to its shareholders at its Annual General Shareholders' Meeting in 2022.

This Chapter 3 begins with our Sustainability Statement, in compliance with the requirements of the CSRD (Corporate Sustainability Reporting Directive). It is followed by the presentation of Responsible Investment at Amundi, updated to ensure continuity with previous years.

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AMUNDI'S COMMITMENTS

Sustainability Statement (Certified)

‌Sustainability Statement (Certified)‌
  1. General disclosures (ESRS 2)
    1. Basis for preparing disclosures
      1. General basis for preparing sustainability disclosures

        Amundi, a large group as defined in Article L. 230-2 of the French Commercial Code (Code de commerce), has prepared this sustainability statement on a consolidated basis.

        The scope of sustainability information on a consolidated basis is the same as that used for the consolidated financial statements (1).

        Amundi's own operations are defined as those involving the parent company and its subsidiaries over which it exercises direct or indirect control. This statement does not include the upstream and downstream value chains associated with the own operations of Amundi's clients. Each party is responsible for publishing information on its own value chain.

        Subsidiaries not included in the scope of consolidation because they are not material from a financial perspective were subject to an additional analysis to assess the materiality of impact and whether or not it was necessary to include them in the consolidated Sustainability Statement. Following this analysis it was decided that the thresholds applied to the financial scope could be retained for the Sustainability Statement.

        The table below shows the list, as at 31 December 2025, of companies controlled by Amundi that were exempted from making a sustainability disclosure on an individual or consolidated basis in their own management report.

        Subsidiaries exempt from publishing their own report

        Companies exempt from preparing a Sustainability Statement

        because they are included in Amundi's consolidated report (2) Places of business

        AMUNDI FINANCE France

        AMUNDI FINANCE EMISSIONS France

        LCL EMISSIONS France

      2. Disclosures in relation to specific circumstances

        Context

        This report has been prepared in accordance with the obligations set by the transposition into French law of the European directive on the publication of sustainability information (known as the "CSRD" Directive 2022/2464/EU) and the European regulation 2020/ 852 of 18 June 2020 (known as the "Taxonomy" regulation). The preparation of sustainability information was again carried out, for the second consecutive year, in a context of persistent uncertainty regarding the interpretation of the texts for financial sector players in general, and asset management for third parties in particular.

        Regarding more specifically a second publication in implementing the CSRD Directive, the Amundi Group faced the absence of established frameworks, the unavailability of data, and the lack of specific sectoral standards for its sector.

        Furthermore, regarding investments for third parties and in light of recent legislative developments associated with the CSRD, this section (Certified Sustainability Statement) focuses on material issues. All other aspects of Amundi's Responsible Investment policy are described, as last year, in section 3.7 of this Universal Registration Document (URD) to ensure the continuous dissemination of information regardless of regulatory changes.

        On 26 February 2025, the European Commission presented a legislative package called "Omnibus I", aimed in particular at reducing the scope of application of the CSRD Directive, simplifying reporting related to the environmental taxonomy and initiating work to simplify ESRS standards.

        1. The scope of consolidation and changes to it as at 31 December 2025 are presented in detail in the consolidated financial statements in Note 9.3 of this Universal Registration Document (notes to the consolidated financial statements).

        2. The European CSRD Directive and the European Sustainability Reporting Standards (ESRS) could have applied from 1 January 2024, to these three companies, as public interest entities.

        Pending the negotiation and entry into force of this package, two measures were adopted in 2025. Directive 2025/794, known as "Stop the clock", which came into force on 17 April 2025 and was transposed during the year, postponed by two years the application of sustainability reporting for companies in waves 2 and 3. Delegated Regulation 2025/1416, known as "Quick fix", published in November 2025, deferred the initial ramp-up of certain requirements for wave 1 companies under the ESRS, freezing for the 2025 financial year the exemptions and data points at the level of the first reporting on 2024.

        In this package, the simplification of reporting related to the environmental taxonomy was adopted (delegated regulation 2026/73); it applies to reports published from 1 January 2026 -

        i.e. reports for the year ended 31 December 2025. This regulation simplifies, particularly for financial institutions, the rules for calculating and presenting taxonomy data (1).

        Negotiations to reduce sustainability reporting obligations -including the scope of the companies concerned - have been completed. However, at the date of preparation of this report, the full transposition of these measures into French law remains pending; the current framework (Order 2023-1142 and Decree 2023-1394) therefore still applies.

        In this context, the Amundi Group has endeavoured to comply with the requirements of the ESRS (2) in effect at the date of the establishment of the Sustainability Statement.

    2. Sustainability governance
      1. Board of Directors

        Composition and diversity of the Board of Directors

        As at 31 December 2025, the Board of Directors is composed of

        13 directors, 6 women and 7 men, including 5 independent directors and 1 director elected by employees.

        The Board of Directors ensures the collective balance and diversity of the members comprising it, in view of the challenges Amundi faces. It also ensures that everyone adheres to the company's fundamental values. These principles govern its diversity policy based in particular on multiple skills, cultures and a principle of diversity.

        • Plurality of cultures: the Board of Directors' diversity policy seeks, through the profile of each of its members, to ensure a diversity of cultures, in line with the needs of the company.

          Double materiality analysis

          Regarding the double materiality analysis, and more specifically that related to the value chain (3), the Amundi Group faced limitations related to data availability, the maturity level of assessment methodologies and their ability to cover its activities. When assumptions, projections, or approximations were used, they are specified in the relevant sections of the report. This analysis will continue to be subject to revaluation in future exercises, depending on the evolution of the framework (methodology, other regulatory developments impacting value chain actors).

          Information disclosed in the report

          For all the information disclosed in this report, the Amundi Group has adopted applicable approaches, methodologies and estimates for several categories of data, including those related to the value chain, such as the calculation of greenhouse gas emissions for its own operations. When an estimate has been used, a specific mention clarifies this in the paragraph where the data is published. For example, regarding greenhouse gas emissions, the information needed to understand the data can be found in section 3.2.4.3 Metrics, following the table "Carbon intensity scopes 1, 2, 3 and total per FTE (E1-6-AR-48-T1)". When the measurement of the indicator is validated by an external body other than the guarantor, the information is mentioned in the relevant paragraph.

          Commitment to Energy Transition

          The information regarding the specific publication conditions related to Amundi's commitment to energy transition is presented in section 3.2.2. ESG Ambitions 2025 plan for climate change mitigation and adaptation.

          Although all members are French nationals, some have a real international culture and/or professional experience, especially in Asia and Europe, as well as in North America, which is perfectly aligned with Amundi's development strategy. For example, Virginie Cayatte is Chief Financial Officer of a top-tier listed Chinese player, BlueStar Adisseo Company Ltd. Jean-Christophe Mieszala, Nathalie Wright and Pierre Cambefort have either worked for US companies, or developed skills specific to this region, in line with their personal background, thereby strengthening the Board's international culture. Gérald Grégoire has international experience, particularly in Italy, where he was Deputy Chief Executive Officer of Crédit Agricole FriulAdria, in charge of support functions.

          1. Amundi has adopted the new Taxonomy model for the production of the information presented in this report.

          2. European Sustainability Reporting Standards.

          3. European reporting standards (ESRS) define the value chain as all activities, resources and relationships related to the company's business model and the external environment in which it operates. The value chain includes stakeholders located upstream and downstream of the company. Amundi's value chain is defined in section 3.1.3.1 Strategy, business model and value chain.

            The four directors come from the Crédit Agricole regional banks, add a local and regional culture.

            • Diversity policy: the Board has set the objective of achieving, or maintaining, a gender balance, at least in accordance with the minimum proportions stipulated in the French Commercial Code. Since May 2025, the Board of Directors has been composed of 50% women and 50% men, excluding the board member elected by employees (1).

          There were more women than men on the Board's specialised committees (62.5% at both end-2024 and end-2025).

          At the time of the changes that took place in 2025, the Board of Directors, on the recommendation of its Appointments Committee, endeavoured to appoint a long-standing member of each committee as Chair. All the Committees are currently chaired by a woman.

          The desire for balanced representation of women and men is also reflected in the Group's internal organisation (see section 2.3.4 - The Group's Management Bodies). The gender equality policy, and specifically the objectives of this policy, the methods of implementation and the results achieved during the past financial year, are discussed each year by the Board of Directors when reviewing the Report on Professional Equality, after an in-depth analysis conducted by the Compensation Committee.

          Competence of the Board of Directors

          The prerequisites for the competence of the Board of Directors, its annual assessment, its training and additional information on the corporate officers (composition of the Board of Directors as at 31 December 2025 and terms of office and functions performed by the corporate officers) are described in Chapter 2 of this document, "Corporate Governance".

          The members of the Board of Directors have skills and experience acquired during their previous professional experience in the financial services industry. They are aware of the sector, services or client expectations as well as the regional specifics of the countries in which Amundi operates.

          In 2025, the Appointments Committee ensured that the new appointments that took place during the year were made in line with the skills needed by the Board.

          As a result, at 31 December 2025, all skills were maintained or strengthened within the Board, in particular strategic planning, sales/marketing, risk management/compliance/internal audit and ESG.

          With regard more specifically to environmental, social and governance issues, it should be noted that since 2023 and in line with the commitments made through its "Say On Climate" initiative, a majority of the members of the Board of Directors have strengthened their skills in this area. As a result, 92.31% of board members considered ESG to be one of their areas of expertise at the end of 2025.

          For each of the E, S and G themes that this expertise covers:

          • environmental expertise was consolidated in 2025. The board members continued to develop their expertise in climate issues during the year, in line with the commitments made as part of the Say on Climate initiative. For example, in 2025, they took part in a training session on the issues and challenges related to biodiversity and natural capital. They also received an update on European regulatory developments, including those related to sustainable finance. Drawing on its expertise, the Board was able to conduct discussions on responsible investment, contributing to the 2028 Medium Term Plan "Invest for the future", during its seminar on strategy;

          • expertise in social matters remains widely represented, in particular through the Board members who also have an executive role, and the board member elected by the employees;

          • governance remains the most represented area of expertise, particularly due to its significance in terms of culture in the banking sector.

            Each board member carries out a self-assessment of their own competencies. In addition, in accordance with banking regulations, each board member is subject to a thorough review of their profile by the European Central Bank (ECB) upon appointment. The good repute, availability and skills are therefore carefully analysed beforehand by the Appointments Committee, so that the individual skills of the selected candidate correspond to the collective need of the Board.

            To identify the expertise that the Board needs to function properly, the Appointments Committee first brought in the knowledge and experience recommended by the European banking authorities, and has added an ongoing requirement for skills in the fields of asset management and social and environmental issues. It has therefore defined a target matrix in line with its needs.

            The Appointments Committee strives to preserve this overall balance as it analyses and recommends candidates to the Board. To this end, it ensures that each of the themes in the skills matrix retains a satisfactory level of representation. It ensures that the skills of board members are strengthened while in post by ensuring that appropriate training sessions are organised by the Group.

            The addition, in 2024, of Nathalie Wright to the Audit Committee, who has taken on new duties arising from the CSRD, further strengthened the Committee's sustainability expertise.

            1. In accordance with Article L. 225-27 of the French Commercial Code (Code de commerce), the board member elected by the employees is not taken into account in the calculation of the gender representation percentage required under Article L. 225-18-1 of the French Commercial Code (Code de commerce). If this board member were taken into account in this calculation, the percentage of women on the Board would be 46.15%.

              Role of the Board of Directors in monitoring impacts, risks and opportunities

              The integration of sustainability issues within the Board of Directors and its specialised committees, as well as the activity of the Board of Directors and its specialised committees, are described in Chapter 2 of this document, "Corporate Governance".

              It is recalled that the Board of Directors relies in particular on the in-depth work carried out by its specialised committees to take social and environmental issues into account. Each Committee incorporates this dimension into its specific tasks:

              • the Strategy and CSR Committee issues recommendations on the company's strategy in the area of responsible investment and CSR;

              • the Appointments Committee ensures that the Board has a good level of collegial expertise in ESG matters;

      2. Executive governance

        • the Compensation Committee ensures that non-financial elements are taken into account in the compensation policy;

        • the Risk Management Committee monitors and controls risk indicators relating to social and environmental commitments;

        • the Audit Committee, which has been monitoring the analysis of non-financial indicators reported to the market since 2022, was entrusted, in 2024, with most of the new tasks specific to the CSRD.

        In this context, and on the basis of the work carried out by the Audit Committee, which supervised the process for preparing sustainability information, as well as that implemented to determine the information to be published, the Board of Directors validated the principles proposed for the preparation of this Sustainability Statement, which it definitively approved in March 2026.

        The Board continued to monitor the progress of the indicators related to its Climate Strategy on a quarterly basis and initiated discussions aimed at defining the future areas for its development when its Plan expires.

        For internal governance, the Amundi Group's senior managers rely on the General Management Committee to implement the strategic guidelines defined by the Board of Directors. To carry out its tasks of managing, controlling and monitoring impacts, risks and opportunities, the General Management Committee delegates these responsibilities to the committees already in place in each business line, which have been entrusted with additional tasks and roles in order to meet the requirements of the CSRD.

        In addition, the General Management Committee is represented, within each business line, by a specialised committee responsible for monitoring and validating the impacts, risks and opportunities within its scope, as well as supervising the resulting policies, action plans and objectives. These committees have decision-making authority within their business line. The main committees of the business lines concerned are as follows:

        • CSR Committee: this Committee, which meets every half year, defines and guides Amundi's responsible actions for its own operations.

        • ESG & Climate Strategy Committee: this monthly committee, chaired by the Chief Executive Officer, defines and validates the ESG and climate policy thus applicable to investments, as well as Amundi Group's strategic guidelines in this area.

        • HR Executive Committee (EXCO): this committee has responsibility for all human resources issues and defines and oversees priority projects.

        • Compliance Committee: chaired by the Deputy Chief Executive Officer; it meets at least once a quarter. It defines the Group's principles for financial security, market integrity and business compliance and supervises compliance risks.

        • Group Risk Committee (GRC): also chaired by the Deputy Chief Executive Officer; it meets monthly. It defines risk limits for all activities and oversees risk monitoring.

      3. Indicators related to the Board of Directors and Executive Committee

        Parity within the administrative, management and supervisory bodies

        With regard to the Board of Directors, in accordance with Article L. 225-27 of the French Commercial Code (Code de commerce), the board member elected by the employees is not taken into account in the calculation of the gender representation percentage required under Article L. 225-18-1 of the French Commercial Code (Code de commerce).

        Members of the Board of Directors

        Number

        2025

        Percentage

        2024

        Number

        Percentage

        Women

        6

        50.0%

        7

        58.3%

        Men

        6

        50.0%

        5

        41.7%

        Members of the Executive Committee

        Women

        18

        39.1%

        19

        38.8%

        Men

        28

        60.9%

        30

        61.2%

        Average ratio of women to men

        0.71

        0.74

        Proportion of independent board members

        2025

        2024

        Number of independent board members

        5

        5

        Proportion of independent board members (%)

        41.7%

        41.7%

      4. Integration of sustainability-related performance in compensation schemes

        The implementation of Amundi's Climate Strategy can only be done by raising awareness among all its stakeholders. This means aligning the employee compensation policy with Amundi's ESG and climate strategy. This decision is implemented as follows:

        • in 2025, the performance evaluation of the Chief Executive Officer and the Deputy Chief Executive Officer took into account the achievement of ESG (including climate commitments(1)) and CSR objectives (reflecting the criteria relating to the finalisation of the implementation of Amundi's ESG Ambitions 2025 plan, accounting for 12.5%, and the Social and Environmental Responsibility of Crédit Agricole group, accounting for 7.5%), making up 20% of the overall evaluation;

      5. Statement on due diligence

        The French law relating to parent companies' and ordering companies' duty of vigilance applies to Crédit Agricole S.A. group.

        As a parent company, Crédit Agricole S.A., a corporate entity, has chosen to draw up a vigilance action plan and to report on the effective implementation of this plan for Crédit Agricole S.A. group. In accordance with the law, this vigilance plan includes specific reasonable measures to identify the risks and to prevent

        • the implementation of Amundi's commitments in the area of ESG and CSR (which includes climate commitments) accounts for 20% of the criteria underpinning the performance shares plan applicable in 2025 to Amundi's more than 200 senior executives;

        • since 2022, Amundi has integrated ESG objectives into the evaluation of the performance of the sales and portfolio management teams, so that these objectives are taken into account in their variable compensation.

        serious infringements of human rights and fundamental freedoms, or the health and safety of persons and the environment, which could potentially result from the activity of Crédit Agricole S.A., including Amundi.

        Details of the Crédit Agricole S.A. Group's vigilance plan are included in its 2025 Universal Registration Document.

        (1) The detailed objectives of the Chief Executive Officer and the Deputy Chief Executive Officer are presented in Section 2.4.3.

        Alignment between Amundi's Sustainability Report and due diligence

        Essential elements of due

        diligence Paragraphs in the Sustainability Statement

        1. Embedding due diligence ESRS 2 GOV 2:

          in governance, strategy and 3.1.2.2 Executive governance

          business model

        2. Engaging with affected stakeholders in all key steps of the due diligence

        3. Identifying and assessing adverse impacts

          ESRS 2 GOV 3:

          3.1.2.4 Integration of sustainability-related performance in compensation schemes

          SBM-3:

          3.1.3.3 Material impacts, risks and opportunities and their relationship to the strategy and business model

          ESRS 2 GOV 2:

          3.1.2.2 Executive governance

          SBM-2:

          3.1.3.2 Interests and perspectives of stakeholders

          IRO-1:

          3.1.4.1 Description of procedures for identifying and assessing material impacts, risks and opportunities

          SBM-3:

          3.1.3.3 Material impacts, risks and opportunities and their relationship to the strategy and business model

          IRO-1:

          3.1.4.1 Description of procedures for identifying and assessing material impacts, risks and opportunities

        4. Taking actions to address ESRS 2 MDR A / Thematic ESRS:

          those adverse impacts

        5. Tracking the effectiveness of these efforts and communicating

        3.2.2 ESG Ambitions 2025 plan for climate change mitigation and adaptation

        3.2.3.1 Strategy

        3.4.1.6 Framework and references

        3.4.3.2 Action plans

        3.4.4.2 Action plans

        3.5.2.7 Combating corruption

        3.5.3.4 Action Plans

        ESRS 2 MDR M / MDR T / Thematic ESRS:

        3.2.3.1 Strategy

        3.2.3.3 Metrics

        3.2.4.3 Metrics

        3.4.3.3 Measures and controls

        3.5.2.7 Combating corruption

        3.5.3.5 Metrics and targets

      6. Risk management and internal controls over sustainability reporting

        Integration of sustainability information production risks into the internal control system

        Amundi has integrated the risks related to the production of sustainable information into its internal control system. This control system is based on both risk measurement, monitoring and control systems and a first-level permanent control system carried out by the operational units, with second-level permanent control being carried out by the Risk, Compliance and Security functions, and periodic control being carried out by Internal Audit.

    3. Sustainability strategy
      1. Strategy, business model and value chain

        Amundi's strategy and business model

        Amundi's purpose is to work every day in the interests of its clients and society. Societal commitment lies at the heart of the company's concerns. The business model is evolving to adapt to new needs, in particular by enhancing the range of solutions tailored to each client, supported by technology to improve accessibility, performance and the suitability of our offerings, and to continue serving the creation of sustainable value for all our stakeholders.

        Our business lines, embodied by the Group's 5,329 employees, are evolving to make an increasingly rich range of offerings accessible to all our clients, whatever their profile, in order to meet new needs, particularly in digital:

        • a comprehensive range of investment solutions covering all asset classes and management styles:

          • active management (equities, bonds, diversified, money market),

          • ETFs and passive management (index ETFs, active ETFs, index management, equities and bonds),

          • Private assets (real estate, private debt, private equity, infrastructure),

          • Structured solutions (protected management, formula funds, strategy funds, structured notes, employee shareholding funds),

          • Responsible investment (ESG integration, Net Zero solutions, impact investing, shareholder engagement);

        • technology services and solutions across the entire investment value chain:

          • Amundi Technology (technological solutions for all players in the savings value chain, a software offering around the ALTO range(1)),

          • Fund Channel (a platform connecting asset management companies and distributors),

          • sub-advisory solution (an open-architecture multi-manager platform, providing access to the best expertise of external management companies, at lower cost and with tighter risk control);

        • multi-dimensional research to understand the economic and financial environment and appreciate societal and environmental challenges:

          • Amundi Investment Institute (60 experts dedicated to research and strategic analysis),

          • financial analysis (190 economists and analysts in major financial centres),

          • extra-financial analysis (40 ESG and corporate governance analysts).

            On 18 November 2025, Amundi unveiled its 2028 Medium Term Plan entitled "Invest for the future"(2). This plan prioritises growth, diversification, innovation, efficiency and selective investments to create attractive shareholder value while providing clients with excellent service. ESG and CSR issues are fully integrated into this Plan.

            This Strategic Plan follows on from the ESG Ambitions 2025 plan. The latter, which ended in late 2025, had set three objectives:

            • increase the level of ambition of its investment solutions in terms of Responsible Investment;

            • engage with as many companies as possible to define credible strategies for aligning with the Net Zero 2050 objective;

            • align its employees and shareholders with its new ambitions.

              To meet these objectives and in line with the Crédit Agricole group's social project, Amundi is committed, around these four commitments, to:

            • acting as a responsible financial institution;

            • acting in the interest of clients;

            • acting as a responsible employer;

            • and acting as an environmentally responsible citizen.

            Regarding its offering of savings or technological solutions, Amundi committed by the end of 2025 to:

            1. introducing a new environmental transition rating that assesses companies' efforts in decarbonising their operations and the development of their sustainable activities, covering

              €400 bn (3) of actively managed open-ended active funds. This note aims to assess companies on their decarbonisation efforts and the development of their green activities. To encourage them to undertake this transformation, these portfolios invest in greater proportions in those making the most effort in their energy transition than in others;

            2. offering open-ended funds in all asset classes with a binding

              Net Zero 2050 investment objective;

            3. reaching €20bn in assets in impact funds that invest in companies seeking positive environmental or social performance. This impact is measured and reported annually;

            4. ensuring that 40% of its range of passive funds is made up of ESG funds;

            5. developing, within Amundi Technology, ALTO* Sustainability, a technology analysis solution designed to support investors in decision-making regarding the environmental and social impact of their portfolio.

              In terms of voting and engagement with companies, Amundi committed to:

            6. working with 1,000 additional companies to define credible strategies for reducing their greenhouse gas emissions, to vote at their annual General Shareholders' Meetings and for management remuneration packages to be linked to these strategies;

            7. from 2022, excluding from its portfolios companies that generate over 30% of their activity from unconventional oil and gas production.

              1. Amundi Leading Technologies & Operations

              2. The 2028 Medium Term Plan is presented in Chapter 4 Review of Financial Position and Results in 2025.

              3. Scope of activity of open-ended funds for which a transition rating method is applicable.

                To align its employees and shareholders with this new ambition, Amundi had decided to:

            8. take into account the level of achievement of these investment objectives (weight 20% of total criteria) in the KPIs calculation of performance shares for its 200 senior executives. It also set ESG targets for all investment managers and sales representatives;

              Essential intangible resources

              In order to comply with regulations (1), Amundi defines essential intangible resources as resources without physical substance on which the company's business model depends, and which constitute a source of value creation for the company. Amundi addresses this subject in particular from the perspective of the added value created by its employees amplified by its organisation:

              • Value added by employees: Amundi believes that the added value of its employees is based on the depth of their expertise, the variety of their experiences and behavioural skills (interactions with clients and colleagues) and the responsibility exercised. As such, Amundi invests to ensure their continuous development. For more information on this subject, see the Human Capital Development Policy in section 3.3.2.1. of this report;

              Amundi value chain

            9. reduce its own direct greenhouse gas emissions by approximately 30% (vs. 2018) per employee in 2025;

            10. present its climate strategy to its shareholders at its Annual General Shareholders' Meeting in 2022.

            • Amundi's added value lies in its ability to mobilise the collective to accelerate the managerial and cultural transformation centred on responsibility: through programmes such as Amundi Management Spirit, Amundi Tomorrow and Amundi Care, Amundi strengthens skills, cooperation and initiative at all levels. This collective model concretely improves Amundi's usefulness for its clients and for society, while at the same time realising its purpose: "to be a trusted partner acting every day in your interest and that of society".

              Amundi operates both in the management of its own operations and investment activities on behalf of third parties. This covers all products or services, from the design of solutions, as well as marketing and distribution. These two dimensions constitute its value chain.

              Value chain

              Regulators

              Civil society

              General public

              Non-governmental organisations (NGOs)

              Media

              Individual investors, Wealth and asset managers,

              Institutional investors

              invested

              (in our investment products)

              Clients

Corporates

Downstream

Our own operations

Our human capital

Suppliers

Shareholders

Upstream



Ecosystem

The upstream and downstream value chains of our clients' own operations are excluded. Each party is responsible for publishing the information about its own value chain.

(1) Article L232-1 amended by Order No. 2023-1142 of 6 December 2023 - Art. 8.

    1. Interests and perspectives of stakeholders

      Amundi's main stakeholders are clients, employees, social partners, shareholders, suppliers, supervisory and regulatory authorities, NGOs (non-governmental organisations) and rating agencies.

      Amundi acts in the interest of its clients while taking into account the expectations of other stakeholders as best as possible. Interactions with its stakeholders allow Amundi to become aware of and understand their respective priorities, and to integrate their expectations into its strategic reflections and its sustainable development strategy:

      • regular consultations with clients (particularly through surveys) and economic agents (through participation in national or international round tables or working groups);

      • exchanges with representatives of Amundi's employees aimed at understanding their expectations regarding accountability, meaning in their work, the work environment and conditions, as well as employee engagement;

      • regular meetings with civil society bodies (associations, NGOs);

      • discussions with its shareholders, represented in particular by their financial and ESG analysts through meetings with the General Management;

      • interaction with non-financial rating agencies, particularly during the annual review exercise;

      • dialogue with supervisory authorities;

      • relationships with Amundi's suppliers within the framework of sustainable partnerships.

        In accordance with the sixth paragraph of Article L. 2312-17 of the French Labour Code (Code du travail), the Social and Economic Committee (CSE) was consulted in February 2026.

        Amundi participates, directly or through sector organisations, in work and consultations on national, European and international regulatory projects aimed at developing sustainable finance and seeks to incorporate and disseminate best practices.

        Cooperate with associations and stakeholders

        Amundi welcomes regulatory initiatives aimed at building and strengthening the solidity and transparency of the Responsible Investment market. Sustainability issues are strategic, particularly in Europe where a regulatory framework for sustainable finance has been developed in response to the objectives of the "Green Deal".

        The Amundi Group strives to reconcile the effectiveness of markets and of its asset management business with the promotion of a more Responsible Investment model. It adapts its strategies, marketing, information systems and organisation to best serve its clients in a more demanding and complex regulatory environment. To this end, Amundi seeks to share its vision and experience with various international, European and national bodies and institutions on sustainable finance regulations, both upstream and downstream of future regulations, in terms of application and best practices.

        Amundi is also a member of professional associations or groups (1). In France, the Chief Executive Officer of Amundi chairs the Collège des Investisseurs de Paris-Europlace and a member of General Management is part of the executive board of the Institute of Sustainable Finance (IFD). Whether generalist or specialised, these organisations contribute to discussions on the regulatory framework for sustainable finance.

        Amundi represents its positions to these organisations, to sector authorities and publicly. These positions reflect the company's priorities, including Responsible Investment, and its commitments, in particular by contributing to the consistency and clarity of the sustainable finance framework, in order to establish its effectiveness with regard to public policy objectives for the development of Responsible Investment and client expectations.

        In order to develop and support these positions, the following governance structure has been put in place:

        • an ESG Regulatory Strategy team, responsible for sustainable finance regulatory issues within the Responsible Investment Department;

        • a Governance and Public Affairs Department, reporting to the Deputy Chief Executive Officer, which coordinates a committee that validates Amundi's positions with the involved business lines.

        Positions are thus developed and disseminated to support Amundi's development by anticipating the impacts of future sustainable finance regulations on the company and on its products intended for clients, and to contribute to the work of the financial sector on the continued strengthening of the regulatory framework for sustainable finance.

        Thus, in 2025, Amundi continued its active engagement in public consultations and regulatory work relating to sustainable finance, in particular around regulatory developments on Responsible Investment products (SFDR), corporate sustainability reporting (CSRD) and related standards (ESRS). In a context where the European Commission launched several simplification initiatives in early 2025, Amundi stresses the need to further harmonise the various texts of the sustainable finance framework (CSRD, Taxonomy, SFDR, etc.) to strengthen coherence and improve readability for investors.

        Building long-term partnerships

        Amundi seeks to play its part in creating products and services that best meet the needs of investors. In particular, it interacts with major public bodies, federations, trade unions and associations.

        To develop solutions to finance the energy transition and inclusive growth, Amundi has forged innovative partnerships with major public bodies: the World Bank's International Finance Corporation (IFC), the European Investment Bank (EIB) and the Latin American Reserve Fund (FLAR) or a coalition of British higher education institutions, conducted by the University of Cambridge.

        1. See paragraph below "Participation in collective initiatives"

          For instance, Amundi has developed the following strategies:

          • with IFC, in 2018, a first green bond fund was launched on emerging markets, followed in 2023 by a second social bond fund, also issued on emerging markets;

          • with FLAR, in June 2024, in close collaboration with central banks and several official institutions across Latin America, an ETF that aims to offer central banks and public institutions a responsible way to manage their reserves;

          • with the University of Cambridge and 78 other British higher-education institutions, an innovative money market fund that excludes issuers contributing to the expansion of fossil fuels.

        As part of its employee savings and retirement activities, Amundi collaborates with federations, trade unions and associations to address value-sharing issues in the interest of employee savers.

        Amundi offers a comprehensive range of multi-company funds for responsible, solidarity-based, or thematic investment, certified by the CIES (1), affirming its commitment to providing Responsible Investment solutions to all employees of client companies.

        Participation in collective initiatives

        Amundi is a member or signatory of numerous national and international initiatives aimed at addressing environmental, social and good governance issues. The main objective of these investor coalitions is to urge governments to adopt incentives and encourage companies to improve their sustainable development practices. These initiatives contribute, in particular, to the development of tools and methodologies that facilitate the integration of ESG issues within corporate governance and asset management.

        Initiatives (non-exhaustive list)

        RESPONSIBLE INVESTMENT

        Initiatives (non-exhaustive list)

        ENVIRONMENT

        2003

        United Nations Global Compact (UNGC)

        2003

        Institutional Investors Group on Climate Change (IIGCC)

        2006

        Principles for Responsible Investment (PRI)

        2004

        Disclosure Insight Action (CDP)

        2009

        Spain Sustainable Investment Forum (SPAINSIF)

        2016

        Science-Based Targets initiative (SBTi)

        2010

        Responsible Investment Forum (French SIF)

        2017

        Task Force on Climate-related Financial Disclosures (TCFD)

        2010

        French Financial Management Association (AFG)

        2012

        Observatory for Sustainable Real Estate (OID)

        2013

        European Fund and Asset Management Association (EFAMA)

        2016

        Swiss Sustainable Finance Association (SSF)

        2017

        Climate Action 100+ (CA 100+)

        2017

        CDP Non-Disclosure Campaign

        2021

        Net Zero Asset Managers (NZAM)

        2017

        Institute for Sustainable Finance (IFD, formerly Finance for

        2021

        Powering Past Coal Alliance (PPCA)

        Tomorrow)

        2021

        Finance for Biodiversity

        2017

        International Capital Market Association (ICMA)

        2021

        Asia Investor Group On Climate Change (AIGCC)

        2019

        One Planet Summit Sovereign Wealth Fund Asset Managers

        2023

        Nature Action 100 (NA 100)

        (OPAM)

        2019

        Operating Principles for Impact Management (OPIM)

        2020

        French Association of Real Estate Investment Companies

        SOCIAL

        2022

        Global Investors for Sustainable Development Alliance (GISD)

        2023

        China-Singapore Green Finance Taskforce (GISD)

        2023

        Global Impact Investment Network (GIIN) Amundi Immobilier also supports

        2023

        Responsible Investment Association (RIA) along with the integration of non-fin

        particular the Biodiversity Impulsion

        2023

        European Sustainable Investment Forum (EUROSIF) Sustainability Real Estate Initiative(3).

        2017 Workforce Disclosure Initiative (WDI)

        (ASPIM)

        2018

        Platform Living Wage Financials (PLWF)

        2020

        Italian Sustainable Investment Forum (ITASIF)

        2020

        Tobacco-Free Finance Pledge

        2021

        UK Stewardship Code

        2021

        The 30% Club France Investor Group

        2021

        World Benchmarking Alliance (WBA)

        2022

        The 30% Club Japan Investor Group

        2021

        2021

        France Invest

        Sweden's Forum for Sustainable Investments (SWESIF)

        2023

        GOVERN

        The 30% Club Germany Investor Group

        ANCE

        2013

        International Corporate Governance Network (ICGN)

        2022

        Council of Institutional Investors (CII)

        several biodiversity initiatives ancial issues in real estate, in Group(2) and the European

        2024

        2024

        Capacity-building Alliance of Sustainable Investment (CASI)

        Singapore Sustainable Finance Association (SSFA)

        In addition, as an active member of the ASPIM Commission, Amundi Immobilier is participating in the development of the

        2025

        London Coalition on Sustainable Sovereign Debt (LC)

        second version of the SRI Label for real estate funds in France.

        1. CIES: Comité Intersyndical de l'Epargne Salariale (Inter-union Committee on Employee Savings).

        2. The Biodiversity Impulsion Group (BIG) aims to create a common framework of indicators and measurement tools to define and improve the biodiversity footprint of property projects.

        3. The European Sustainability Real Estate Initiative (ESREI) aims, within the Observatory for Sustainable Real Estate (OID), to broaden the scope of its research to the European level, by reinforcing technical and regulatory monitoring in the countries of the European Union and at the level of the European Commission, creating a network of European sustainable property players.

    2. Material impacts, risks and opportunities and their relationship to the strategy and business model

      Presentation of impacts, risks and opportunities

      The ESRS (European Sustainability Reporting Standards) break down impacts, risks and opportunities into two parts:

      • the positive and negative sustainability impacts of a company's activities, which can be actual or potential. This corresponds to the materiality of the impacts;

      • the company's financial risks and opportunities generated by its economic, social and natural environment. This relates to financial materiality.

        Double materiality is a concept aimed at combining financial materiality with impact materiality, as part of the assessment of a company's performance.

        The list of material impacts, risks and opportunities, grouped into themes, is presented below. In addition, similar tables providing details on their nature (positive or negative impact, risk, opportunity) and their positioning in the value chain are presented in the thematic sections of the report.

        The determination of material risks under the CSRD directive does not follow the same approach as that used for the Risk Factors presented in chapter 5 of this document. These two regulatory systems have different purposes. This may result in differences in identified risks between the Sustainability Statement and the Risk Factors.

        In addition, the way in which the material impacts listed below affect the Society and the environment is specified in the description of each impact.

        For this second Sustainability Report, the process for identifying and assessing material impacts, risks and opportunities has not been modified. However, the presentation of Amundi's offering, which was originally attached to ESRS S4 Clients and End Users, has been moved to ESRS 2 General Information, resulting in the removal of the IROs associated with the offering. This change in presentation does not affect the materiality methodology or the conclusions reached and had no impact on the content of Amundi's Sustainability Report.

        ESRS

        Theme

        List of IROs

        Position in the value chain

        Reference

        in the report

        ENVIRONMENT

        ESRS E1

        Climate change Positive impact on climate change by supporting the decarbonisation of companies through the Net Zero product offering

        Indirect negative impact on climate change though investment activities in companies that have not implemented a transition plan

        Risk on portfolio performance due to lack of or inaccurate assessment of climate change risk factors

        Reputational and regulatory risks related to the company's activities that impact climate change

        Opportunity to support our clients wishing to invest in investment solutions contributing to the climate transition

        Opportunity to engage in active and constructive dialogue with investee companies to accelerate their climate transition and thus improve their long-term financial performance

        Investments 3.2.3 Climate investment strategy

        Investments

        Investments

        Investments

        Investments

        Investments

        Environmental Negative impact of operating footprint on the climate Own operations 3.2.4 Environmental

        footprint of operations

        Negative impacts of greenhouse gas emissions and the consumption of natural resources in our own operations (mitigated through the development of programmes to reduce our emissions)

        Own operations

        footprint

        ESRS

        Theme

        List of IROs

        Position in the value chain

        Reference

        in the report

        SOCIAL

        Employer attractiveness,

        Opportunity to improve attractiveness through proactive and innovative ESG practices

        Own operations 3.3.2.1 Development

        of human capital

        talent retention and employee

        engagement

        3.3.2.2 Performance and remuneration

        3.3.2.3 Working

        Environment / Quality

        of Life and Working

        Conditions (QVCT)

        3.3.2.4 Equity,

        diversity and inclusion

        3.3.2.5 Social dialogue

        and employee

        engagement

        Opportunity to enhance overall performance and employee

        Own operations

        3.3.2.1 Development

        retention, thanks to career support and skills development

        of human capital

        policies

        Opportunity to increase employee engagement thanks to

        Own operations

        3.3.2.5 Social dialogue

        significant confidence in the Group's governance

        and employee

        engagement

        Risks associated with not knowing the characteristics of

        Own operations

        3.3.2.2 Performance

        employees, leading to inefficient human resources

        and remuneration

        management and difficulties in meeting regulatory

        reporting obligations

        Social dialogue

        Reputational risk or the risk of a decrease in the group's

        Own operations

        3.3.2.5 Social dialogue

        overall performance due to a deterioration in social

        and employee

        dialogue/environment

        engagement

        Diversity and

        Reputational risk in the event of a danger to the health and

        Own operations

        3.3.2.4 Equity,

        inclusion

        safety of employees or a failure to respect human rights

        diversity and inclusion

        Personal data

        Risk to internal and external reputation due to inadequate

        Own operations

        3.3.2.1 Development

        diversity, equity and inclusion practices

        of human capital

        Human rights and

        Positive impact on employee health/safety through

        Own operations

        3.3.2.3 Working

        health and safety

        voluntary workplace well-being initiatives

        Environment / Quality

        of Life and Working

        Conditions (QVCT)

        Positive impact on employees' rights to freedom of

        Own operations

        3.3.2.3 Working

        association and collective bargaining where virtuous

        Environment / Quality

        practices are in place

        of Life and Working

        Conditions (QVCT)

        3.3.2.5 Social dialogue

        and employee

        engagement

        Positive impact on employees where social protection

        Own operations

        3.3.2.3 Working

        practices are better than the legal minimum

        Environment / Quality

        of Life and Working

        Conditions (QVCT)

        Risks to employer attractiveness, staff retention and

        Own operations

        3.3.2.3 Working

        employee engagement related to pay and benefits

        Environment / Quality

        of Life and Working

        Conditions (QVCT)

        Skills

        Positive impact on employees through good talent

        Own operations

        3.3.2.1 Development

        management

        management and ambitious skills development initiatives

        of human capital

        ESRS S1

        ESRS

        Theme

        List of IROs

        Position in the value chain

        Reference

        in the report

        Personal data

        Reputational risk in the event of data breaches, theft or improper use of personal data

        Own operations

        3.4.4 Protecting personal data (GDPR)

        ESRS S4

        Client protection

        Positive impact on Society in terms of the adaptation of products and services to the client profile (product governance, transparent information, complaints management)

        Own operations

        3.4.2 Protect clients

        GOVERNANCE

        Responsible purchasing

        Negative impact on suppliers in the event of non-responsible purchasing practices by the Group, particularly in terms of payment deadlines

        Own operations

        3.5.3. Supplier relationships and payment practices

        Reputational risk and regulatory risk in the event of non-responsible purchasing practices by the Group to its suppliers, particularly with regard to payment deadlines

        Own operations

        (G1-2 and G1-6)

        Supplier duty of care

        Reputational risk and regulatory risk in the event that the Group is held liable for an environmental, social or ethical breach - particularly in terms of corruption - on the part of its suppliers

        Own operations

        3.5.3. Supplier relationships and payment practices (G1-2 and G1-6)

        ESRS G1 Business ethics

        and the fight against

        Positive impact on the company of the implementation of a whistleblower system for reporting unethical internal practices in France and abroad

        Own operations

        3.5.2.8 Protection of whistleblowers

        corruption

        Negative impacts on services or stakeholders of unethical practices (e.g. corruption)

        Own operations

        3.5.2.5 Promoting an ethical culture

        3.5.2.7 Combating corruption

        The fight against financial crime

        Regulatory risk in the event of non-compliance with financial crime obligations

        Own operations

        3.5.2.9 The fight against financial crime

        SPECIFIC

        Market abuse (market integrity)

        Regulatory risk in the event of insufficient detection of market abuse (market integrity)

        Own operations

        3.5.2.10 Prevention of market abuse

        Conflicts of interest

        Negative impacts in the event of insufficient detection of conflicts of interest

        Own operations

        3.5.2.6 Preventing conflicts of interest

        Cybersecurity

        Negative impact on services in the event of a cyber attack

        Own operations

        3.4.3 Preventing cyber attacks

        Financial risk following inability to provide essential services and associated operational cost of remediation

        Own operations

        3.4.3 Preventing cyber attacks

        Positioning in the value chain and activities

        The double materiality analysis exercise was conducted across the entire value chain.

        Amundi distinguishes in its value chain the management of its own operations (upstream) and third-party investments (downstream).

        Regarding third-party investments, Amundi has adopted the following principles in order to include a theme in this Sustainability Statement:

      • Amundi has the ability to steer the evolution of indicators related to the selected themes;

      • Amundi can justify explicit demand from its clients for this steering.

        For this reason, based on these principles and the analysis of double materiality, and in the absence of specific sectoral standards, it was decided to include in this Sustainability Statement:

      • for environmental themes: climate change (ESRS E1), both for third-party investments and for own operations;

      • for social themes focus on own operations, for issues related to the workforce (ESRS S1) as well as clients and end users (ESRS S4);

      • finally, the impacts, risks and opportunities related to governance are positioned upstream in the value chain, both for issues related to procurement and compliance matters (ESRS G1).

        Effects on the business model, value chain, strategy and decision-making process

        The material impacts, risks and opportunities identified influence the structure of the business model and the decision-making processes. Amundi has been incorporating ESG criteria into its investment processes and its decisions, supported by specific policies (climate, diversityand inclusion, ethics, anti-corruption, sustainableprocurement, etc.). This integration, regularly reassessed,makes it possible to anticipate market trends and respond tostakeholder expectations while strengthening the resilience of the Amundi Group.

        Strategic actions or plans to manage impacts, risks and opportunities

        On material themes, Amundi has established internal policies for several years, which cover:

        • the environmental aspect, with a focus on the transition;

        • the social aspect: HR policies and actions (human capital development, social dialogue, diversity, working environment, performance and remuneration) promote inclusion, well-being and the development of human capital;

        • the governance aspect: policies and actions - ethics, anti-corruption, data protection, financial crime, market abuse and conflict of interest management - ensure rigorous compliance. Furthermore, in the context of procurement, the Group has responsible management of supplier relationships and payment practices.

          These policies are reviewed and reassessed as necessary.

          Current financial effects of risks and opportunities

          The financial materiality analyses conducted on the effects of physical and transition risks did not identify any risks as material with regard to the criteria used in the Sustainability Statement. At this stage, the cost-of-risk effects of these factors are therefore not significant and do not require action.

          Resilience of the strategy and business model

          As a responsible asset manager, Amundi believes that its fiduciary responsibility consists of contributing, in the interests of its clients and society, to addressing major socio-economic and environmental challenges. Amundi's strategy is based on the widespread integration of ESG criteria in actively managed open-ended funds, in order to offer investment solutions that reconcile financial performance, non-financial objectives and client risk levels.

          Since its inception, Amundi has been able to adapt to a constantly evolving environment, particularly to new regulatory and climate constraints by taking sustainability factors into account. This consideration draws on a structured ESG analysis, based on a best-in-class approach combining:

        • non-financial data from third-party suppliers;

        • qualitative sector and thematic analyses carried out by Amundi analysts;

        • a quantitative assessment expressed on a scale from A to G, positioning each issuer in relation to the sector average. Grated companies are excluded from the investment universe when the exclusion policy applies(1).

          For material issues, policies and action plans, detailed in the following sections, allow us to adapt to events and demonstrate resilience.

          1. The exclusion policy applies to actively managed portfolios and passive ESG portfolios, unless otherwise requested by the client, and always in compliance with applicable laws and regulations.

  1. Managing impacts, risks and opportunities
    1. Description of procedures for identifying and assessing material impacts, risks and opportunities

      General description

      In accordance with the European Sustainability Reporting Standards (ESRS), the double materiality exercise determines the information to be published in the Sustainability Statement by identifying the impacts, risks and opportunities (IRO) deemed material. The analysis covers Amundi's own operations (consolidated scope) as well as the value chain (upstream/ downstream). The analysis focuses on two dimensions: impact materiality (how Amundi's activities impact its stakeholders or the environment) and financial materiality (how sustainability issues affect Amundi and its financial performance). An IRO is material when at least one of the two dimensions is material.

      Amundi's materiality analysis methodology is the responsibility of the CSR Department, in line with the Crédit Agricole group's analysis methodology, for the company's own operations. The "third-party investments" section, which presents specific features in relation to the Group's own-account financing or investment activities, was reviewed with Amundi's Risk, Responsible Investment and CSR departments.

      The list of impacts, risks and opportunities (IRO) has been defined and is reviewed each year by the CSR Department in collaboration with teams from Compliance, Risk, Human Resources, Responsible Investment, Purchasing, etc. and by capitalising on the internal processes already in place within Amundi (mapping of operational risks, Human Resources risks, etc.) and taking into account investment activities, Amundi's value chain and the regulatory context in which Amundi operates. The IRO list covers the current ESRS and the specific themes identified by Amundi, and may be subject to change in order to reflect any changes in the environment, regulations or scope that may arise in the coming years.

      The ESRS sets the criteria for the materiality assessment. Our rating methodology is as follows:

      • Negative impacts are rated on two criteria:

        • the likelihood (for potential impacts only),

        • the severity: magnitude, extent and irremediable character.

        • Positive impacts are rated on two criteria:

          • the likelihood (for potential impacts only),

          • the severity: extent, breadth.

        • Risks and opportunities are rated on two criteria:

          • the likelihood,

          • the potential magnitude of the financial effects.

        The ESRS do not impose particular rating scales. In addition, human rights IROs are considered material, regardless of their likelihood, when severity is assessed at the highest level. Thus, at the time of the rating, the severity of the impact criterion prevails over the likelihood criterion.

        When the rating of each of the criteria of an impact, risk or opportunity is finalised, a materiality score is calculated for each IRO (1) and compared to Amundi's materiality threshold. Materiality threshold (2) means the rating at which the impacts, risks and opportunities become material. Note that IROs are not ranked in an order of priority other than material/non-material.

        In operational terms, Amundi rates the IROs for its scope by referring as far as possible to the existing internal processes (operational risk mapping, etc.) or by using external studies and consulting internal experts. The 2025 rating exercise was also based on the results of surveys conducted by Amundi with its clients and investors. These studies, carried out with the assistance of Kantar (research and data analysis institute), Greenwich (investment research and advisory firm/financial institutions) and, for France, Amadeis (a company specialising in opinion analysis and client studies), are used to gather clients' expectations and perceptions on the various ESG dimensions. The lessons learnt from these surveys reinforced Amundi's analysis of the themes considered to be the most material for its stakeholders. The results of the double materiality analysis are centralised by the CSR Department, then validated by Amundi's governance.

        In accordance with the regulation, material impacts, risks and opportunities are subject to regular review in order to take into account any subsequent changes in context, regulation or scope.

        The stakeholder consultation procedures will be reviewed regularly.

        Climate risks

        Regarding its investments, Amundi has relied on its expertise in climate change, particularly through the "Environment" pillar of its proprietary ESG rating. This ESG rating allows for the integration of physical climate risks - which result from damage caused by extreme weather and climate phenomena such as wildfires, cold waves, heat waves, water stress, coastal flooding, hurricanes, flooding and droughts, etc. - as well as transition risks, in the short, medium and long term.

        1. Each rating criterion is assessed on a scale of 1 to 4 and then a score is determined as follows: for risks, the likelihood score is multiplied by the potential magnitude score of the financial effects, thus giving a maximum score of 16; for impacts, the likelihood score is multiplied by the severity score, defined as the maximum of the scale (magnitude), scope (extent) and irremediability scores. The maximum for this score is also 16.

        2. Details of the materiality threshold: the materiality threshold is set at half the maximum score of 8 (i.e. 8 or higher).

          Furthermore, concerning its own operations, Amundi does not own any buildings, which significantly reduces its exposure to physical risk. In the absence of real estate assets, the Group is not directly affected by environmental events such as floods or storms. Additionally, as part of its Business Continuity Plan (BCP), Amundi has been able to conduct an analysis to identify, assess and manage potential threats.

          Methodological framework for alignment with international climate change mitigation goals set by the Paris Agreement

          Two frameworks allow for the evaluation of Net Zero trajectories of the assets on which Amundi has made commitments:

          • the Amundi Net Zero reference framework, in line with the PAII Net Zero Investment Framework, is used by default for our open-ended funds in corporate bonds and listed equities asset classes. This framework is also used for certain management mandates;

          • the Net Zero Target Setting Protocol of the Net Zero Asset Owner Alliance is used for certain management mandates.

            Time horizons

            Three time horizons have been selected for the analyses conducted. These time horizons are chosen not only to align with current operational and budgetary cycles but also to ensure consistency with longer-term strategic objectives and overall climate commitments:

          • the short-term horizon is set for one year, in alignment with the current budgetary horizon;

          • the medium term is set for between one and five years, in line with Amundi's strategic ambition (1);

          • the long-term horizon is set for beyond five years to capture the long-term share of exposures, particularly 2050 for climate commitments.

        Pollution (E2), Water (E3), Biodiversity (E4) and Resource use and circular economy (E5) themes

        Observation

        Amundi notes that the ESRS standards require indicators relating to the Pollution (E2), Water (E3), Biodiversity (E4) and Resource use and circular economy (E5) themes. However, there is not yet a market method for interpreting these metrics at the portfolio level, which limits their operational use. For the Biodiversity and Ecosystems theme (E4), the challenge is twofold: the available indicators are still not very developed and the evaluation methodologies have yet to be developed.

        Lack of a sector-specific methodology on materiality

        Unlike the Climate theme, the financial sector - and particularly asset managers - does not have a recognised method for measuring the impact of their activities on nature, making comparisons between different stakeholders difficult. Furthermore, although the CSRD regulation defines the actors in the value chain, it does not specify how asset managers must assess the impacts on Nature related to their investments made on behalf of third parties. Although there are indicators relating to the Pollution, Water and

        Resource use and circular economy themes (e.g. volumes withdrawn, pollutant emissions, recycling rates), Amundi notes that the absence of common thresholds and benchmarks prevents the levels of these metrics from being properly assessed. In the absence of a robust and widely agreed methodology at consolidated level, Amundi cannot assess the impacts of its investments on Nature.

        Consideration of stakeholder views

        Amundi continues to take into account the views of stakeholders (rating agencies, investors and analysts, clients, etc.) through different channels (questionnaires, calls for tenders, surveys, etc.). Although it is changing, Amundi observes overall that interest in Nature-related themes is lower than that expressed for climate. This observation illustrates a gradual approach to a subject that is particularly complex to understand.

        In this context, Amundi considers that it is not yet in a position to conclude, for the 2025 financial year, on the double materiality analysis of Nature-related themes. Amundi is continuing its work and also in the context of market groups, with the aim of establishing a sufficiently robust and measurable methodology, making it possible in particular to determine the themes that could be considered material or non-material.

        Details on Amundi's work and strategy

        Amundi carried out exploratory work using data from the ENCORE nature database (exploring natural capital opportunities, risks and exposure), in order to deepen its understanding of the methods that could, in the future, be used to measure Nature-related impacts, risks and opportunities.

        • As a company, Amundi has analysed the Nature-related impacts of asset management companies, as identified by ENCORE. This involves assessing how economic activities affect ecosystem services (pollination, water purification or climate regulation) and ecosystem components such as species, habitats and soil quality. The direct impact of asset managers is generally limited and presents a low risk ("Very Low/Low materiality rating").

        • As a third-party asset manager, Amundi has deepened the analysis by studying the impact of the companies held in the portfolio. By cross-referencing the data from the ENCORE database with the companies' business sectors, Amundi was able to estimate the potential impacts and dependencies of investee companies in relation to Nature. The main objective is to verify the relevance of Amundi's shareholder engagement with these companies. Amundi will continue this exploratory work to determine whether it is able, in the long term, to measure the Nature-related impacts, risks and opportunities.

          In addition, at the beginning of 2025, Amundi joined a working group with the ANC (French Accounting Standards Authority) whose objective is first to conduct an inventory of existing physical indicators and associated methodologies, then to propose recommendations to standardise and facilitate their measurement within the framework of the CSRD and the ESRS, as well as to experiment with a single ecological non-financial accounting framework. The work of this group will conclude with a report (materiality of biodiversity issues, transition plan and actions, definition of indicators, assessment of the associated financial costs).

          1. Regarding third-party investments, Amundi has developed a Net Zero investment framework based on the Net Zero Emissions by 2050 (NZE) scenario developed by the International Energy Agency (IEA) to set decarbonisation targets for 2025 and 2030 for the Net Zero alignment products.

        Conclusion

        Given the aforementioned methodological difficulties and limitations, Amundi is not, at this stage, in a position to conclusively assess the materiality of ESRS E2 (Pollution), E3 (Water and marine resources), E4 (Biodiversity and ecosystems) and E5 (Resource use and circular economy) within the CSRD framework. Amundi will continue its work with a view to reaching a conclusion on the Nature themes in its 2026 Statement. If the robustness of the data and the absence of sectoral benchmarks prevent a reliable quantitative assessment, Amundi may formulate, in accordance with the normative guidelines, a conclusion based solely on a qualitative approach.

        Description of procedures for identifying

        and assessing impacts, risks and opportunities in relation to business conduct

        As part of the double materiality methodology, the Compliance Department has defined the impacts, risks and opportunities (IRO), based on the existing body of standards, non-compliance risk maps and available quantitative indicators.

        The IROs relating to business conduct are grouped around six material themes: promoting an ethical culture, preventing conflicts of interest, protecting whistleblowers, combating corruption, combating financial crime and preventing market abuse. For the financial risk rating, Amundi used its noncompliance risk mapping, taking into account both recurring and exceptional financial risks. With regard to the ratings relating to the materiality of impact and the likelihood of occurrence, Amundi carried out the assessments while taking into account the specific characteristics of its activity. The consolidated IRO ratings have been validated by the Compliance governance bodies.

        As regards Purchasing, the IROs were identified using the AFNOR risk map, based on ISO 31000 Risk Management, ISO 20400 Sustainable Procurement and ISO 26000 Social Responsibility, as well as the internal operational risk management tool.

    2. ESRS disclosure requirements covered

      by the company's Sustainability Statement

      Coverage of publication requirements

      Data points required by other European legislation are presented in Annex 1 of this document.

      List of DRs Reference

      ESRS 2-BP-1 3. 1. 1. 1 General basis for preparing sustainability disclosures

      ESRS 2-BP-2 3. 1. 1. 2 Disclosures in relation to specific circumstances

      1. 1. 2. 1 Board of Directors

        ESRS 2-GOV-1

        ESRS 2-GOV-2

        1. 2. 2 Executive governance

      1. 1. 2. 3 Indicators related to the Board of Directors and Executive Committee

        1. 2. 1 Board of Directors

      3. 1. 2. 2 Executive governance

      ESRS 2-GOV-3 3. 1. 2. 4 Integration of sustainability-related performance in compensation schemes

      ESRS 2-GOV-4 3. 1. 2. 5 Statement on due diligence

      ESRS 2-GOV-5 3. 1. 2. 6 Risk management and internal controls over sustainability reporting

      ESRS 2-SBM-1 3. 1. 3. 1 Strategy, business model and value chain

      ESRS 2-SBM-2 3. 1. 3. 2 Interests and views of stakeholders

      ESRS 2-SBM-3 3. 1. 3. 3 Material impacts, risks and opportunities and their relationship to the strategy and business model

      ESRS 2-IRO-1 3. 1. 4. 1 Description of the processes to identify and assess material impacts, risks and opportunities

      ESRS 2-IRO-2 3. 1. 4. 2 ESRS disclosure requirements covered by the company's Sustainability Statement

      E1 - ESRS 2 - GOV-3 3. 1. 2. 4 Integration of sustainability-related performance in compensation schemes

      E1-1 3. 2. 2 ESG Ambitions 2025 plan for climate change mitigation and adaptation

      E1 - ESRS 2 - SBM-3 3. 1. 3. 3 Material impacts, risks and opportunities and their relationship to the strategy and business model

      E1 - ESRS 2 - IRO-1 3. 1. 4. 1 Description of the processes to identify and assess material impacts, risks and opportunities

      3. 2. 3 Climate investment strategy

      E1-2

      E1-3

      3. 2. 4 Environmental footprint

      3. 2. 3. 2 Action plan

      3. 2. 4. 2 Climate action plan

      E1-4 3. 2. 3. 3 Metrics

      List of DRs Reference

      E1-5 3. 2. 3. 3 Metrics

      E1-6 3. 2. 3. 3 Metrics

      E2 - ESRS 2 - IRO-1 3. 1. 4. 1 Description of the processes to identify and assess material impacts, risks and opportunities E3 - ESRS 2 - IRO-1 3. 1. 4. 1 Description of the processes to identify and assess material impacts, risks and opportunities E4 - ESRS 2 - IRO-1 3. 1. 4. 1 Description of the processes to identify and assess material impacts, risks and opportunities E5 - ESRS 2 - IRO-1 3. 1. 4. 1 Description of the processes to identify and assess material impacts, risks and opportunities S1 - ESRS 2 - SBM-2 3. 1. 3. 2 Interests and views of stakeholders

      S1 - ESRS 2 - SBM-3 3. 3. 1. 3 Managing impacts, risks and opportunities

      3. 3. 1 Strategy

      S1-1

      3. 3. 2 Policies

      S1-2 3. 3. 2. 5 Social dialogue and employee engagement

      S1-3 3. 3. 2. 3 Working environment

      S1-4 3. 3. 2 Policies

      S1-5 3. 3. 2 Policies

      S1-6 3. 3. 2. 1 Development of human capital

      S1-8 3. 3. 2. 5 Social dialogue and employee engagement

      S1-9 3. 3. 2. 4 Equality, diversity and inclusion (ED&I)

      S1-10 3. 3. 2. 2 Performance and remuneration

      S1-11 3. 3. 2. 3 Working environment

      S1-12 3. 3. 2. 4 Equality, diversity and inclusion (ED&I)

      S1-13 3. 3. 2. 1 Development of human capital

      S1-14 3. 3. 2. 3 Working environment

      S1-15 3. 3. 2. 3 Working environment

      S1-16 3. 3. 2. 2 Performance and remuneration

      S1-17 3. 3. 2. 3 Working environment

      S4 - ESRS 2 - SBM-2 3. 4. 1. 3 Interests and views of stakeholders

      S4 - ESRS 2 - SBM-3 3. 4. 1. 2 Material impacts, risks and opportunities and interactions with the business model

      S4-1 3. 4. 1. 7 Policies, governance and action plans

      S4-2 3. 4. 1. 3 Interests and views of stakeholders

      3. 4. 3. 2 Action plans

      3. 4. 4. 2 Action plans

      3. 4. 5. 2 Action plans

      S4-5 3. 4. 1. 5 Indicators and targets

      G1 - ESRS 2 - GOV-1 3. 1. 2. 1 Board of Directors

      G1 - ESRS 2 - IRO-1 3. 5. 2. 4 Policies, objectives and ambitions, impacts, risks and opportunities and their scope

      3. 5. 2. 5 Promoting an ethical culture

      3. 5. 2. 6 Preventing conflicts of interest

      3. 5. 2. 7 Combating corruption

      G1-1

      3. 5. 2. 8 Protection of whistleblowers

      3. 5. 2. 9 The fight against financial crime

      3. 5. 2. 10 Prevention of market abuse

      G1-2 3. 5. 3 Supplier relationships and payment practices (G1-2 and G1-6)

      3. 5. 2. 5 Promoting an ethical culture

      G1-3

      3. 5. 2. 7 Combating corruption

      G1-4 3. 5. 2. 7 Combating corruption

      G1-6 3. 5. 3 Supplier relationships and payment practices (G1-2 and G1-6)

  2. Presentation of Amundi's offering

    Amundi offers investors one of the widest ranges of products and services on the market in order to meet their diverse needs. This offering includes:

    • investment solutions and management delegation services;

    • a comprehensive range of Responsible Investment expertise;

    • technological solutions and associated services;

    • support, events, tools and training.

      1. Investment solutions and management delegation services

        Amundi offers a wide range of services and solutions to meet the needs of its individual investors, wealth and asset managers and institutional investors (1) integrating sustainability issues through:

        • fiduciary management services for institutional investors, from advisory services (investment universe, strategic allocation, medium-term asset allocation, etc. ) to investment delegation (overlay, tactical allocation or implementation and complete monitoring of a portfolio);

        • services to support wealth and asset managers (retail banks, private banks, insurers and asset managers) throughout the investment advice value chain;

        • investment solutions: model portfolios for advisory management or management under mandate;

        • fund selection services and offer of sub-advisory delegation: through its Fund Channel distribution platform and its multi-manager platform, Amundi allows distributors to optimise the structuring, management and monitoring of their offer in an open architecture.

          Each of these services and solutions takes into account clients' sustainability preferences, either by integrating ESG criteria directly into the offering, or by auditing the ESG policies of external managers in the event of management delegation.

          Since 2024, Amundi has offered a range of model portfolios comprised of several products focused on climate or sustainability themes.

          Regarding its fund selection and delegation services, Amundi selects external managers that meet the financial and nonfinancial criteria required by its clients, drawing on the expertise of its fund selection and Responsible Investment teams. In 2025, at the request of Amundi's distributor clients, four funds managed under delegation and classified as Article 8 under the SFDR regulation were launched.

      2. A comprehensive range of Responsible Investment expertise

        Amundi has a comprehensive and diversified offering to meet the specific needs of each investor and their sustainability preferences. It covers all types of management: active management, passive management, real assets, structured solutions and alternative investment management. It offers expertise across all geographical areas and in different legal formats.

        This management offering is available in open-ended funds or through dedicated funds and mandates. The dedicated funds and mandates are customised to align with the specific and regulatory needs of the clients.

        Amundi applies minimum standards and an exclusion (2) to actively managed portfolios and passive ESG portfolios, unless otherwise requested by the client, and always in compliance with applicable laws and regulations. The objective of these funds is to achieve a better weighted average ESG score than the average ESG score of their reference index or benchmark. Many individual products or ranges of funds also benefit from further ESG integration, through higher selectivity, a higher rating level or higher non-financial indicators, or a broader selection of themes, etc.

        Lastly, both to incorporate regulatory changes and to offer its clients enhanced transparency, Amundi has decided to structure its offering into two main categories:

    • funds that invest in all economic activities (outside the exclusion policies mentioned above);

    • funds that apply limitations on fossil fuels activities.

      Impact products

      "Impact" products are investment products aimed at generating a positive, measurable environmental and/or social impact while also delivering a financial return. Impact is measured against specific impact goals that have been defined ex-ante and are based on the intentionality of investors or, where applicable, of the companies in which they invest. Impact themes cover a wide range of areas and offer various sustainable outcomes, for example: creating jobs in high-unemployment areas; providing access to essential services for low-income populations; reducing net greenhouse gas (GHG) emissions per unit of production; etc.

      1. For more details on client segmentation, refer to section 3.4 Clients and end users (ESRS S4).

      2. Amundi's general Responsible Investment policy is available on its website.

    Amundi has developed an internal evaluation grid to assess funds on the three key aspects of impact investment: intentionality, measurability and additionality (1). To qualify as an "impact" product, the fund must achieve a minimum rating on all three aspects.

    Under the ESG Ambitions 2025 plan, Amundi has committed to expanding the range of impact investment solutions to

    €20 billion.

    At the end of 2025, assets under management (AuM) in "impact" products reached €21.8 billion, an increase of nearly €5.7 billion over the year. This increase was driven by the alignment of existing products with Amundi's "impact" investment framework and by the launch of new "impact" investment strategies, notably in listed assets (bonds and equities) and unlisted assets (private equity and infrastructure).

    Net Zero products

    The Net Zero offering is detailed in chapter 3.2.3 "Climate investment strategy".

    Replication of ESG indices

    Amundi has one of the widest ranges of Responsible Investment ETFs on the European market (2). This covers the main asset classes and geographical regions for a diversified portfolio allocation.

    In line with the ESG Ambitions 2025 plan, Amundi continued to expand this offering and achieved its target of at least 40% ESG ETFs within the ETF range by 2025: 42% of Amundi's index ETFs were ESG as at 31/12/2025, i.e. classified as Article 8 or 9 under the SFDR.

    Achieving this objective required not only the launch of new products, but also a proactive approach to transforming funds from replicating traditional indices towards incorporating ESG criteria in the indices.

    Amundi proactively continued its ESG development with the launch of new investment solutions in 2025, including the launch of an SRI Label ETF offering equity exposure to emerging markets, and two new government bond ETFs including green bonds and a range of ESG ETFs combining responsible investment and low tracking error.

    Responsible Investment structured funds

    Amundi was a pioneer in the development of a range of ESG formula funds, launching in 2021 of an impact fund that invested in equities linked to a social-theme index. Since then, Amundi has continued to innovate in structured solutions, with the launch of several ESG formula funds on environmental and climate themes.

    Other structured solutions are also offered to international investors through portfolio management funds with capital protection and investments aligned with Amundi's Responsible Investment policy.

    These launches reflect Amundi's commitment to providing investors with funds that meet their sustainability requirements and preferences, even for specific assets such as structured solutions.

    Responsible Investment Employee and Retirement Savings range

    Amundi was among the first three asset management companies to obtain the CIES (Inter-union Committee on Employee Savings) label in April 2002, thanks to its wide range of funds incorporating ESG and solidarity-based criteria. Since then, this offering has been enriched with new themes such as the energy transition, the fight against climate change, sustainable development, environmentally friendly technologies and the reduction of social inequalities. These investments benefit from Amundi's recognised expertise in Responsible Investment, notably through the know-how of its asset management subsidiary CPR Asset Management, which specialises in thematic management.

    More than 85% of Amundi's employee and retirement savings assets under management are classified as Article 8 and Article 9 under the SFDR in France (excluding employee share ownership) and represent over 45% of total employee and retirement savings assets under management in the country.

    In addition, Société Générale Gestion, a wholly-owned subsidiary of Amundi, helped Société Générale build a new Employee and Retirement Savings offer called "Palissandre". This new offering, which is part of the bank's CSR approach, adds to the range of responsible savings funds created for its retail clients.

    Société Générale wanted to provide employees of its corporate clients with a 100% SRI Employee and Retirement Savings scheme built around seven funds, thus offering greater clarity in structuring their savings.

    At the end of October 2025, four funds had obtained the ISR France label, while the other three are in the process of being labelled for 2026.

    1. The additionality of impact products is reflected in the financing and support of projects that would not have been feasible under current market conditions, through the mobilisation of complementary capital and the provision of operational expertise ensuring the measurability and sustainability of the impact.

    2. ETFGI Global ESG ETFs Industry Insights Report, December 2025. Amundi is the world's second-largest provider of ESG ETFs by number of products and assets under management.

      Responsible Investment Expertise of Amundi Real and Alternative Assets (ARA)

      Amundi ARA offers a range of responsible and impact investment solutions in the areas of real estate, private debt, private equity, multi-management and infrastructure.

      "Impact" practices are being developed within these areas of expertise.

      Real estate

      During the year, Amundi Immobilier continued its responsible commitments by implementing an ESG policy for assets under direct management.

      Thus, each of the real estate assets has an assessment of its nonfinancial performance based on an assessment grid composed of

      14 key themes (energy, carbon, biodiversity, mobility and transport) and nearly 50 criteria.

      This rating is systematically accompanied by the definition of an action plan to improve the non-financial assessment over time. Through this approach, we are pursuing our objectives of transparency on the non-financial strategy of the funds by obtaining and renewing the ISR France label for six real estate funds, representing nearly 300 properties located in several European countries.

      Private debt

      Consideration of ESG issues and impact practices continued this year. Amundi Private Debt is committed, in particular, to sharing its analyses of non-financial results and areas for improvement with the issuers that we finance. We continue to participate in working groups aimed at defining:

      • impact criteria for private debt, with the "Impact" Commission of the Sustainable Finance Institute;

      • the impact of indicators in the Sustainability Linked-Loans structuring framework, with France Invest's "Impact SLL" Commission;

      • the structure and organisation of biodiversity webinars for issuers and portfolio companies with France Invest's "Biodiversity" working group; and

      • common approaches to finance and natural capital in the Paris financial centre, with the "Biodiversity" Commission of the Sustainable Finance Institute.

    Private equity and multi-management

    Amundi Private Equity integrates ESG factors into the investment processes of its three activities (Private Equity MidCap, Funds of Funds and Impact) and throughout the holding period. The teams are committed to supporting sustainable transitions through a sustainable engagement policy and investment strategy.

    Amundi Private Equity MidCap assists the companies in its portfolio in formalising and structuring their ESG approach, as well as in defining their CSR ambition through a personalised ESG roadmap with each of them. This annual support is reflected in an improvement in the portfolio's ESG performance, notably on issues such as carbon footprint coverage (1) (+15%), review of ESG issues by the Supervisory Board (2) (+14%), implementation of a value-sharing system for employees (+9%) and linking executive remuneration to the achievement of sustainability performance objectives (+43%).

    Three Biodiversity webinars were organised this year with the Biodiversity working group of France Invest to support companies in understanding and integrating biodiversity issues and in building their expertise on the subject.

    Regarding the activities of the Amundi Alpha Associates multi-management platform, collaboration with portfolio asset managers on ESG issues is continuing and strengthening, with increased participation in the annual campaign and an increase in the collection of quantitative indicators to monitor the portfolio's ESG impacts, helping to encourage management companies to improve the non-financial performance of portfolio companies.

    For "impact" activities, see the section on "impact" products above.

    Infrastructure

    Amundi Transition Énergétique (ATE) promotes a robust and sustainable energy model in the face of challenges related to energy supply, rising prices, natural resource depletion and environmental protection.

    This year, ATE strengthened its position as a key player in the energy transition in Europe. All Alba II funds are now classified as impact funds. This programme invests in projects with high potential for expansion that address energy transition challenges (energy production, hydrogen, charging stations).

    1. Scopes 1 and 2 or scopes 1, 2 and 3.

    2. For funds launched after 2020.

    1. Technological solutions and associated services

      Through Amundi Technology, Amundi offers a comprehensive range of tools and services to help clients transform their operating model and thus focus on their core business line.

      These specialised 100% cloud solutions support clients' advanced needs to cover the entire investment life cycle.

      Amundi Technology has strengthened its support for Responsible Investment and sustainable finance with the launch of ALTO(1)* Sustainability, a technological analysis and decision-making solution for investors on environmental and societal issues. The development of this platform is one of the ten key objectives of Amundi's ESG Ambitions 2025 plan.

      Innovative and modular, the ALTO* Sustainability solution provides additional flexibility to clients and helps them align investment decisions with their ESG and climate objectives. It enables users to:

      • integrate their own ESG data and analytics into ALTO* Investment;

      • integrate third-party ESG data and benefit from a quality control service for this data provided by the Amundi's teams;

      • build customised scores at the issuer and/or portfolio level;

      • use ESG, climate, biodiversity and SFDR data throughout the asset management value chain: portfolio analysis, simulation, pre-trade and post-trade controls of investment rules, production of reports;

      • track the Net Zero pathway of portfolios with ALTO* Dashboard.

        ALTO* Sustainability facilitates the implementation of regulatory reporting obligations, allowing investment professionals to effectively execute ESG investment strategies.

        Depending on business models and client objectives, BPO(2) services complement these technological solutions for dealing, middle office, reference data management and reporting.

        Amundi Technology also has an innovation lab, the Innovation Lab. The team consists of experts including data scientists, investment managers and developers. This lab supports client activities and seeks to leverage fintech inclusion and innovation, which are key differentiators for all its clients. To continue improving the client experience, Amundi is gradually integrating artificial intelligence into its tools where relevant. With this lab, Amundi is committed to using AI (artificial intelligence) ethically and transparently while protecting client data security.

        In 2025, Amundi Technology added the ALTO* Climate module developed by the Innovation Lab to the ALTO* Sustainability suite, making it possible to quantify the impact of climate stress tests on portfolios.

        Development of responsible AI

        Amundi ensures that artificial intelligence (AI) is used and developed within an ethical governance framework to ensure that social and environmental issues are taken into account. The use of AI is governed by an AI charter and mandatory training, notably to improve employees' skills on the subject and to raise their awareness of the ethical biases of AI. In addition, a steering committee at General Management level oversees compliance with the European regulatory framework on artificial intelligence (EU AI Act), audits, the traceability of use cases and the promotion of a responsible AI culture. In this context, Amundi has, for example, developed its own internal AI platform, Alto Studio, taking into account, from its design, data security issues, particularly with regard to the GDPR and independence from LLMs (large language models), which require specific controls (data security, anonymisation, traceability and human validation).

    2. Support, videos, tools and training

      Amundi assists its clients with the selection of investment solutions and services and offers videos, tools and training.

      Support and facilitation tools for wealth managers

      Amundi supports its distributors with the marketing of products and services through major (mainly digital) information and communication systems: videos for savers and advisors, thematic articles, infographics, sales pitches, educational guides, thematic web conferences, etc.

      Amundi also provides digital tools to assist advisors in finding suitable solutions that take into account clients' sustainability preferences.

      In 2025, for example, Amundi:

      • organised customised sessions with experts, workshops, etc. on the regulatory aspects of sustainable finance;

      • offered turnkey events for distributors and their clients to deepen their knowledge of Responsible Investment, raise their awareness of sustainability issues - such as climate - and give them the opportunity to act through appropriate investment solutions;

      • increased the clarity of its range of funds in terms of Responsible Investment by renaming its funds.

        1. ALTO*: Amundi Leading Technologies & Operations.

        2. BPO: Business Process Outsourcing.

          Support for companies and institutions with dedicated client services

          To offer its clients a personalised, responsive service in their language and time zone, Amundi has dedicated Client Service teams in the majority of the Amundi Group entities in France and internationally. These teams are also specialised by client segment (Distribution, Institutional, Corporate) to account for end clients' specific characteristics and needs.

          Client Service plays a key role in service quality, responsiveness and the fulfilment of commitments made to clients. As the primary point of contact and coordinator, it relies on all Amundi experts to respond to clients accurately and as quickly as possible.

          The importance placed on the internal control function and, in particular, on second-level control and permanent control systems related to the services provided to clients, is reflected in particular in the attainment of ISAE 3402 certification. This certification, held by Amundi for several years (international standard for assessing risk management policies), is an additional guarantee of compliance with procedures and the proper functional coverage of subjects.

          Active when entering into a relationship with the client and during the life cycle of the products marketed for them, Client Service participates in numerous projects, particularly regulatory projects such as Fund Naming, as well as in the constant improvement of Amundi's internal tools and processes, in order to continually improve quality of service.

          Training at all levels in the value chain

          To act in the interest of its clients, Amundi seeks to enhance the expertise of all stakeholders in the value chain: Amundi employees and executives, advisers at distributors, retail clients as well as employees of prospects and institutional investors or corporate clients. The Group has comprehensive training content, which can be used "à la carte" according to each profile or profession.

          In-house training

          Amundi provides training for its employees to raise their awareness of sustainability issues in general, improve their understanding of sustainable finance regulations and Amundi's role as a Responsible Investor, and train them in ethics and the prevention of unfair commercial practices.

          In 2025, Amundi continued to develop its employees' skills and improved knowledge sharing by making two e-learning courses on marketing documentation and the engagement and voting policy mandatory for certain targeted business lines.

          Amundi's training policy is detailed in Chapter 3.3.2.1 and the training courses aimed at preventing unfair practices are described in Chapter 3.5.2.6.

          Financial education and training for distributors and their clients

          Amundi offers distributors' advisers training solutions on financial markets, regulations and services to improve their financial and non-financial knowledge.

          Among these solutions, the Amundi Academy digital platform includes varied and engaging educational pathways, accessible in several languages.

          In 2025, Amundi Academy offered over 100 modules across three levels (fundamental, expert and chartered financial analyst) and had thousands of users in around ten countries.

          Amundi also offers financial education programmes accessible on its websites for its distributors and their retail clients, in the form of educational videos, TV programmes and learning pathways. The aim is to facilitate understanding of key concepts, particularly sustainable finance.

          In 2025, several initiatives illustrated this commitment:

      • educational videos were created for the general public, covering topics such as investment fundamentals, behavioural biases and considerations for retirement;

      • the adoption of a training platform combining an interactive learning approach and the possibilities of artificial intelligence, with effective statistical monitoring;

      • the creation of an ETF module.

      Training for institutional investors and corporate clients

      Amundi offers an increasing number of training courses on sustainable finance (knowledge transfer) for its institutional investors and corporate clients.

      These courses are primarily aimed at central banks, sovereign wealth funds and pension funds, and they seek to impart knowledge to their employees, from newcomers through the in-house training program to senior executives and managers via the Executive Programs.

      The "Executive Program 2025", held in Paris over two days in June 2025, brought together CIOs (Chief Investment Officer) and CRIOs (Chief Responsible Investment Officer) from Asia, Europe and Latin America. The event was dedicated to deepening understanding of ESG issues and sharing best practices, including presentations and discussions on Amundi's commitments, Net Zero strategies, ESG data quality, biodiversity, blended finance solutions and the role of AI in ESG.

      3

      AMUNDI'S COMMITMENTS

      General disclosures (ESRS 2)

      Our ESG Ambitions plan

      Amundi put in place an ESG Ambitions 2025 plan, particularly for climate change mitigation and adaptation.

      A new Climate Strategy is planned for 2026.

      • Positive impacts through the Net Zero product offering

      • Own operations: negative impact of the operating footprint on the climate (emissions and resource consumption)

      • Investments: indirect negative impacts by investing in

      companies without a transition plan

      Sustainability governance

      The Climate Strategy is steered by the Board and Management, supported by dedicated committees and business teams (Responsible Investment, CSR).

      • Own operations: risks related to activities that affect climate change

      • Investments: portfolio performance risk linked to a poor

      assessment of climate transition risk.

      • Opportunity to support clients towards transition

      investments and engage investee companies

      ESRS E1 Climate change

      OPPORTUNITIES

RISKS

NEGATIVE IMPACT

POSITIVE IMPACT



POLICIES AND ACTIONS



Investments for third parties

  • Net Zero range

  • Thermal coal and unconventional hydrocarbons

    exclusion policy

  • Active climate engagement policy

  • Rigorous climate voting policy

    Own operations

  • Greening of electricity and energy efficiency

  • Travel policy reducing CO2 emissions

  • Decarbonisation of purchases

  • Awareness of employees

KEY RESULTS



Own operations:

-66%

CO2 EMISSIONS RELATED

TO ENERGY (SCOPES 1 AND 2) COMPARED TO THE END OF 2018

Net Zero portfolios:

100%

PORTFOLIOS IN THE NET ZERO

RANGE HAVE ACHIEVED A 30% REDUCTION IN CARBON INTENSITY, OR AN EQUIVALENT TARGET, BY THE END OF 2025 COMPARED TO A 2019 BASELINE

-65%

Own operations:

-30%

REDUCTION BY THE END OF 2025 IN ENERGY (SCOPES 1 AND 2) AND BUSINESS TRAVEL COMPARED TO THE END OF 2018

-41%

-50%

REDUCTION BY THE END REDUCTION BY THE END

OF 2028 IN ENERGY (SCOPES 1 AND 2) AND BUSINESS TRAVEL COMPARED TO THE END OF 2019

OF 2030 IN ENERGY (SCOPES 1 AND 2) AND BUSINESS TRAVEL COMPARED TO THE END OF 2019

Net Zero portfolios:

compared to a 2019 baseline

-30% -60%

REDUCTION BY 2025 REDUCTION BY 2030

TARGETS



CO2 EMISSIONS RELATED TO BUSINESS TRAVEL COMPARED TO THE END OF 2018

€332bn

ASSETS UNDER MANAGEMENT IN THE NET ZERO RANGE, +33%, COMPARED TO THE END OF 2024

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3

AMUNDI'S COMMITMENTS

Climate change (ESRS E1)

  1. ‌Climate change (ESRS E1)
    1. Governance

      Because acting as a responsible financial institution is an essential part of Amundi's strategy, its governance structure integrates sustainability challenges in general, and Climate challenges in particular.

      1. Supervision and monitoring of the Climate strategy

        by the Board of Directors and the General Management

        Role of the Board of Directors

        The missions of the Board of Directors relate to the definition of the strategic orientations of Amundi's activity, while ensuring their operational implementation by General Management. The Climate Strategy is therefore fully integrated within the scope of its deliberations and decisions. This role is explicitly described in Article 2 of its Internal Rules since it "regularly reviews, in connection with the strategy it has defined, the opportunities and risks such as financial, legal, operational, social and environmental risks as well as the measures taken as a result".

        The Board of Directors thus ensures that Amundi fulfils its role as a responsible financial player. In 2022, it determined that the Amundi Group, as a pioneer in Responsible Investment and a committed player on climate issues, should participate in the transparency movement concerning climate strategies, in line with its expectations towards the companies in which it invests.

        In accordance with the commitments made as part of the Climate Strategy, the Board members participate in an annual training session on the climate theme, which took place at the end of 2025. The directors also received an update on European regulatory developments, notably those related to sustainable finance.

        The Board of Directors relies in particular on the in-depth work carried out by its specialised committees, including the Strategy and CSR Committee described below. The other specialised board committees (Audit, Risk, etc.) also each contribute within their scope.

        Role of the Strategy and CSR Committee for Climate

        With regard to the Climate Strategy, the Board of Directors relies primarily on the work of the Strategy and CSR Committee. Under Article 5.3 of the Internal Rules of the Board of Directors, the latter's mission is "to deepen the Group's strategic thinking in its various business lines, in France and internationally, as well as in terms of social and environmental responsibility". Chaired by an independent director and now comprising four members, it formulates an opinion on the company's climate strategy and examines, at least annually, the actions taken by the Group in this area and the results obtained.

        At the request of the Committee, the Chief Executive Officer and the Deputy Chief Executive Officer also Head of the Strategy, Finance and Control division, systematically participate in the meetings of the Strategy and CSR Committee. Other occasional speakers may also be called upon to present on specific topics, at the express request of the Committee.

        The work and opinions of the Strategy and CSR Committee are reported to the Board of Directors by the Chairman of the Committee or by a member of the Committee appointed by the latter.

        In addition, other internal committees, supervised by General Management, help steer the commitments made, notably regarding Climate Strategy.

        CSR Committee

        This half-yearly committee, chaired by the Chief Executive Officer, sets the Amundi Group's strategic guidelines in terms of CSR, in particular by defining and guiding actions on the environmental footprint of internal operations.

        The purpose of this committee is to define and steer Amundi's actions related to its own operations:

        • develop the CSR strategy and its narrative;

        • define CSR indicators, objectives and pathways;

        • prioritise CSR initiatives and monitor the implementation of strategic projects.

          ESG & Climate Strategy Committee

          This committee, which meets monthly and is chaired by the Chief Executive Officer, sets the Amundi Group's strategic guidelines on climate issues.

          It determines and approves the climate policy applicable to investments. The purpose of this committee is to:

        • manage, validate and monitor Amundi's Climate Strategy and validate the main strategic orientations of the General Responsible Investment Policy (sector policy, exclusion policy, voting policy, engagement policy);

        • monitor key strategic projects.

          3

          AMUNDI'S COMMITMENTS

          Climate change (ESRS E1)

      2. Teams dedicated to Climate Strategy

        (own operations and third-party investment)

        A business line dedicated to Responsible Investment

        The Responsible Investment business line defines and implements Amundi's climate strategy (1), in conjunction with all of the Group's major business lines. It works for the various management platforms and departments and provides them with all the elements necessary to integrate climate criteria into their activities: Analysis and rating of issuers on the Environment pillar, climate-related engagement and voting, design of climate-related investment solutions and participation in industry projects and initiatives.

        A "Corporate Social Responsibility (CSR)" team

        The CSR team reports to the Sustainable Transformation and Organisation Department. It works closely with the business lines, in particular with the Responsible Investment, Compliance, Risk and Human Resources teams.

        The main missions of the Amundi CSR team are:

        • structuring the CSR strategy, defining priorities in close collaboration with the relevant business lines as well as the Climate Strategy for its own operations;

        • developing and managing the company's non-financial reporting;

        • managing Amundi's carbon footprint.

    2. ESG Ambitions 2025 plan for climate change mitigation and adaptation

This year, Amundi is continuing the implementation of its ESG Ambitions 2025 plan, defined within the framework of its medium-term strategic plan for 2025, and is reporting on the progress made towards achieving its objectives. Amundi's ESG Ambitions 2025 plan was developed prior to the definition of the ESRS.

The 2025 plan, as well as the identification of the IROs, is aligned with a pathway aimed at limiting global warming to 1.5°C and covers own operations and third-party investments, for its Net Zero range:

  • Regarding its own operations, Amundi has committed to reducing its direct greenhouse gas emissions by nearly 30% per full-time equivalent (FTE) by the end of 2025, compared to 2018. This target is in line with the recommendations of the Intergovernmental Panel on Climate Change (IPCC). For Amundi, this reduction target translates into a goal of decreasing CO2 emissions by 30% per FTE related to energy consumption (scopes 1 and 2) and business travel (scope 3), compared to the reference year 2018.

  • Regarding third-party investments, Amundi has developed a Net Zero investment framework based on the Net Zero Emissions by 2050 (NZE) scenario developed by the International Energy Agency (IEA) to set decarbonization targets for 2025 and 2030 for the Net Zero products, as described in the following section.

The members of the Board of Directors monitor the progress of the Climate Strategy.

In line with the ESG Ambitions 2025 plan, on 18 November 2025 Amundi unveiled its 2028 Medium Term Plan entitled "Invest for the future". Regarding climate-related targets, Amundi has defined targets for 2030, in line with the requirements of the European Sustainability Reporting Standards (ESRS).

  • Regarding own operations, Amundi is committed to reducing its direct greenhouse gas emissions by 50% per FTE by 2030, compared to the year 2019(2). This reduction objective is in line with international standards, while taking into account Amundi's development objectives.

  • For investments on behalf of third parties, Amundi maintains the decarbonisation targets detailed in the section below.

    Furthermore, Amundi is not excluded from climate indices aligned with the Paris Agreement, namely, CTB (Climate Transition Benchmark) and PAB (Paris-Aligned Benchmark). Indeed, as an asset manager, Amundi is not subject to the specific exclusions of these indices.

    1. Amundi's Climate Strategy is presented in chapter 3.8.

    2. To ensure consistency, on the one hand, with the reference year of the objectives for investments on behalf of third parties and, on the other hand, with market practices, Amundi defines 2019 as the new reference year for the objectives set for its own operations as part of the 2028 Medium Term Plan.

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