Bankinter S A : 2025 Consolidated Statement of Non-Financial Information and Sustainability Information

About this update from Bankinter Sa

bankinter. Consoli ated Statement of Non-Financial Information and Sustainability Information Roberto Giménez Serrano, Deputy Branch Manager Introdu ction 3 General bases for the preparation of the Consolidated Statement of 3 Non-Financial Information and Sustainability 1.2 Double materiality e xercise 5 Inclusion of Climate Change Risk in the Credit Risk Admission Process 61 Business strategy - Transition plan 62 2.2.4 Monitoring 73 2.3 Information on Environmental Taxonomy 74 1.2.1 Contextual analysis 6 2.4. Governance of climate-related management 79 1.2.2 IRO identification and management process 7 2.5 Energy consumption and mix 80 1.2.3 Double materiality assessment 7 2.6 Emissions 81 1.2.4 List of Material Disclosure Requirements 13 2.6.1. Emissions offsetting 84 1.3 Corporate Governance 17 2.7 Targets 84 The role of the administrative, management and supervisory bodies 17 Alignment of remuneration policy with ESG objectives 22 Due diligence 23 Social Data 87 Issues relating to employees - ESRS S1 87 Characteristics of employees 87 1.4 Strategy 26 1.4.1 Business model 26 1.4.2 Plan) The Group's Commitment to Sustainability (Sustainability Policy and 28 1.4.3 Relationship with stakeholders 34 1.4.4 Integration of impacts, risks and opportunities in the strategy and 35 Risk management system and internal control related to the Sustainability information disclosure process (SCIIS) business model 24 3.1.2 Integration of IROs relating to employees into the strategy 90 Dialogue and collaboration process with the staff 93 Communication channels and employee incident management 96 Policies regarding own staff 97 Objectives and goals 100 Working conditions: Key actions and parameters. 103 Adequate salaries 103 Social protection 103 1.4.5 Policies, processes, actions, parameters and goals 36 Environmental Information - ESRS E1 37 Identification and assessment of material environmental IROs 37 Social dialogue and collective bargaining 103 Work-life balance 105 Health and safety 106 Equal treatment and opportunities: Key actions and parameters 108 2.1.1 Materiality analysis of climate change risks 39 3.1.7.1 Remuneration 108 2.1.2 Management of IROs in financing 44 3.1.7.2 Training and talent management 109 2.1.3 IRO management in investment 46 3.1.7.3 Attracting talent and promoting diversity 110 2.2 Integrating environmental factors into the Group's business 47 3.1.7.4 Measures against violence and harassment in the workplace 113 model and strategy - Climate resilience 3.2 Issues concerning consumers and end users - ESRS S4 115 2.2.1 Identification and measurement 47 3.2.1 Dialogue with stakeholders 115 2.2.1.1 Corporate book 47 3.2.1.1 Communication channels and incident management 115 2.2.1.2 Mortgage book 53 3.2.2 Incidents related to information for consumers or end users 120 2.2.2 Evaluation 58 3.2.2.1 Integration of information incidents into the strategy 120 2.2.2.1 Book alignment 59 3.2.2.2 Policies, processes and actions relating to customer relations. 122 2.2.2.2 Sensitivity analysis 59 3.2.2.3 Objectives and goals 129 2.2.2.3 Exposure method 60 3.2.3 Social inclusion of consumers 131 2.2.3 Action 61 3.2.3.1 Integration of IROs related to inclusion into the strategy 131 Policies, processes and actions 132 Objectives and goals 134 Governance Information - ESRS G1 135 Identification and evaluation of IROs related to governance 135 Business conduct 136 Ethics and conduct codes 137 The Regulatory Compliance function 138 Fight against corruption and bribery 140 Money Laundering prevention 140 Whistleblowing channels 141 Supplier relationship management 142 Payment practices 144 Annex I: Tables relating to Art. 8 of the European Taxonomy 146 Annex II: Information not required by CSRD under Law 11/2018 213 Annex III: Requirements of Law 11/2018 on non-financial information and diversity Annex IV: List of data points included in crosscutting standards and in thematic standards derived from other EU legislation. 228 237 Annex V: Independent assurance report 242 General Information ‌Introduction ‌General bases for the preparation of the Consolidated Statement of Non-Financial Information and Sustainability This document contains information on the results and trends of the non-financial indicators of Bankinter Group with respect to the impact of its activity on environmental, social and labour aspects, respect for human rights and matters related to the prevention of corruption and bribery, among others. All of the above in accordance with the provisions of Law 11/2018 of 28 December, which amended the Commercial Code, the revised text of the Spanish Companies Act approved by Royal Legislative Decree 1/2010 of 2nd July, and Law 22/2015 of 20th July on Audit, regarding non-financial information and diversity. Bankinter Group has prepared this report in voluntary compliance with Directive (EU) 2022/2464 of the European Parliament and of the Council of 14th December 2022 amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive 2006/43/ EC and Directive 2013/34/EU with regard to the reporting of sustainability information by companies (hereinafter, the CSRD), following the non-transposition of the Directive in Spain. The Directive establishes the development of a sustainability reporting framework based on the European Sustainability Reporting Standards (ESRS). This Consolidated Statement of Non-Financial Information and Sustainability is included in the Consolidated Management Report, which accompanies the Consolidated Financial Statements for the financial year 2025, as set out in Article 49.6 of the Commercial Code introduced by Law 11/2018. The report also includes a summary of the Group's business model, a description of the policies in relation to the above issues and measures adopted, the results of these policies, the main risks related to these issues linked to the Group's activities, the management of these risks and objectives and key non-financial performance indicators. Bankinter Group's 2025 information includes Bankinter and all its subsidiaries, as it did in 2024. The reporting scope of the information contained in this document is the same as that used for the purposes of the consolidated public financial reporting of the Bankinter Group, and no sensitive information has been omitted. The most significant events with an impact on the Group's consolidation scope (specific circumstances) that occurred during the current year are listed below: On 19th June 2024, the boards of directors of EVO Banco, S.A.U. and Bankinter, S.A. formulated the joint project for the merger by absorption of EVO Banco by Bankinter. Bankinter's board of directors approved the project on 26 July 2024, in accordance with Article 53 of Royal Decree-Law 5/2023. The merger was subject to authorisation from the Ministry of Economy, which was granted on 25 November 2024. The deed of merger was signed and filed with the Commercial Registry on 1st April 2025. In line with accounting regulations, the accounting effective date is 1st January 2024, retroactively applying the merger to that financial year. Bankinter's individual annual financial statements for 2025 will reflect this merger retroactively. In the third quarter of the year, the IT integration of EVO Banco took place. This operation only impacts the financial statements of the parent company Bankinter, S.A. It has no direct impact on the consolidated financial statements since EVO Banco already formed part of the consolidation perimeter of Bankinter Group. On 17th April 2024, the boards of directors of Bankinter, S.A., the parent company of Bankinter Group, and AvantCard DAC, a subsidiary company wholly owned by Bankinter, S.A., agreed to carry out a merger by absorption, thus integrating AvantCard DAC into the structure of Bankinter, S.A. and improving the Group's profitability and efficiency. On 1st April 2025, Bankinter, S.A. and Avantcard DAC were merged and a Bankinter branch was established, to which all assets, liabilities, rights, obligations and other legal relationships acquired by Bankinter, S.A. as a result of the merger were assigned. This branch operates as a permanent establishment in Ireland and has taken over the activities previously carried out by Avantcard DAC in that jurisdiction. This operation only impacts the financial statements of the parent company Bankinter, S.A. It has no direct impact on the consolidated financial statements since AvantCard DAC already formed part of the consolidation perimeter of Bankinter Group. In November 2025, Bankinter's board of directors agreed to give a new boost to the Bank's strategy in the areas of consumer lending and payment methods, integrating the differential capabilities that had previously been conducted by its wholly owned consumer subsidiary, Bankinter Consumer Finance, EFC, S.A. Once the boards of directors of Bankinter and Bankinter Consumer Finance approve the respective merger projects and the pertinent regulatory authorisations have been obtained, the teams and capabilities will be fully integrated. The merger is expected to be completed during 2026. These three significant events have no impact on non-financial and sustainability information. Regarding the information reported in relation to previous years, it should be noted that some indicators required by Law 11/2018 but not by the ESRS have been included in Annex I of this report. The 2025 Consolidated Non-Financial and Sustainability Information Statement has been prepared in accordance with the provisions of current commercial legislation, as well as EU guidelines 2017/C215/01 for reporting performance on non-financial information, and, as noted above, the ESRS approved in Commission Delegated Regulation 2023/2772. Additionally, the regulations relating to the Taxonomy Regulation (EU) 2020/852 (hereinafter, the Taxonomy Regulation), the Delegated Regulation (EU) 2021/2178 on disclosure and Delegated Acts have been taken into account for another year. The information included in this document meets the requirements of Law 11/2018 regarding non-financial information and diversity, and has been verified with a limited scope of review by PwC (PricewaterhouseCoopers Auditores, S.L.) in accordance with code 49 of the Commercial Code. This report reproduces some information that is also contained in more detail in other documents, such as the Consolidated Legal Report, the Integrated Annual Report, the Corporate Governance Report or the Remuneration Report 2025. ‌Double materiality exercise Bankinter Group has prepared this report and the information contained therein in accordance with the double materiality principles consistent with the Corporate Sustainability Reporting Directive (CSRD) and the Draft Law on Corporate Sustainability Information. This approach takes an integrated view of both the Group's impacts on society and the environment (impact materiality) and the financial risks and opportunities arising from sustainability issues (financial materiality). Prior analysis Bankinter Group periodically carries out materiality studies in order to improve the effectiveness of the channels of dialogue with social stakeholders and identify priority issues according to two parameters: the maturity of aspects related to financial activity according to sustainability analysts and the importance attributed to these aspects by the Bank's main stakeholders. The 2024-2026 Sustainability Plan was defined based on the results of the Double Materiality Analysis conducted in 2023. This study included a contextual analysis, surveys of six key stakeholder groups (customers, employees, academic experts, the media, NGOs, and suppliers, with a total of 2,732 responses), and the preliminary identification of the company's Impacts, Risks, and Opportunities (IROs). The results were validated by teams from different areas of the Group and allowed the IROs to be grouped into themes and sub-themes, establishing a double materiality matrix that served as the basis for defining the new Sustainability Plan. In 2024, the Group carried out its first double materiality analysis fully aligned with the requirements of the CSRD and with the EFRAG IG1 Materiality ffissessment methodological guidance. This exercise allowed for a review and expansion of the previous analysis, an update of the contextual analysis, and the strengthening of the identification, assessment, and prioritisation of Impacts, Risks, and Opportunities (IROs) in accordance with the criteria established by the European Sustainability Reporting Standards (ESRS), thereby consolidating the methodological framework for subsequent exercises. The process followed to carry out this analysis was as follows: Update of the materiality analysis in 2025 In 2025, Bankinter Group carried out an update of its double materiality analysis, adopting a continuous approach relative to the exercise conducted in 2024. This approach responds to the need to ensure the consistency and comparability of results over time, as well as the current context of evolving regulations and methodological guidance related to double materiality assessment within the CSRD framework. The 2025 update was carried out using the same approach, criteria, and evaluation methodology applied in 2024, pending future regulatory updates and methodological guidance that may require adjustments to the process in subsequent exercises. The exercise included reviewing the context analysis, grouping and reclassifying previously identified IROs, and surveying and evaluating new IROs where necessary, taking into account developments in the regulatory, economic, social and environmental environment, and possible changes in the Group's business model and value chain. This approach has allowed the relevance of the main previously identified material matters to be confirmed, while also incorporating, where necessary, new elements to ensure that the double materiality analysis accurately reflects the Group's current situation. The double materiality exercise, both in terms of methodology and the results and conclusions obtained, has been reviewed by both the Bank's Internal Control and Internal Audit areas, concluding that the process was appropriate and aligned with industry practices. The conclusions of the materiality analysis have been presented to the sustainability and appointments committee of the board of directors. As indicated in the standard, the materiality analysis will be reviewed annually and, in the event of relevant changes, either in the business model or in the value chain, it will be updated accordingly. ‌Contextual analysis The contextual analysis conducted in 2024 has been updated to incorporate new trends and recent developments in sustainability, taking into account the main factors of the political, economic, social, technological, environmental, and legal environment (PESTEL), as well as elements specific to Bankinter Group's business model and value chain. This update has also allowed for the review and alignment of the identified IROs with the topics, sub-topics, and sub-sub-topics defined by the European Sustainability Reporting Standards (ESRS), ensuring that the analysis is consistent with the reporting requirements established by the CSRD. The context analysis consists of an analysis of relevant internal and external information of Bankinter Group. Analysis of internal information It provides a global overview of the Group and its business model, while identifying impacts, risks and opportunities. Public documents and policies, business plan, strategy, financial statements, previous non-financial information statements, information provided to investors, results of surveys conducted in previous years, as well as risk management procedures and analysis have been included. Analysis of external information It includes public documents on sector trends, regulatory developments, reports by analysts, supervisors, shareholders and regulators, and sustainability reports by peers. In addition, documents derived from questionnaires addressed to various stakeholders, including customers, staff, suppliers, shareholders, academic experts, the media and non-governmental organisations (NGOs), have also been analysed. Bankinter Group also considers society in general (in its geographical areas of activity) and nature (as a silent stakeholder) as part of its stakeholders. To integrate the societal perspective, statistical sources and publicly available representative surveys have been reviewed, including, among others, surveys and studies produced by official reference bodies at the European level, such as Eurostat, as well as other relevant socioeconomic reports. Bankinter Group has incorporated the perspectives and opinions of its various strategic stakeholder groups, involving the different areas that maintain direct contact with them in the process. By including the opinions of stakeholders, we seek to achieve a more complete and exhaustive analysis that integrates their perspectives in a coherent manner, enriching the review of the documentation for the Bank's contextual analysis. Furthermore, Bankinter Group has identified its value chain , not only its own operations, but also all the actors involved in its supply chain, products, services and customers. It has been divided into three large groups: Upstream : Set of activities carried out by companies that form part of the initial phases of the Bank, providing products or services for the development and marketing of the Bank's own products. Own operations : This covers all the activities that Bankinter Group carries out within its organisation to manage and carry out its functions. Downstream : This refers to the offer of products and services aimed at different types of customers and users. ‌IRO identification and management process ‌When identifying IROs, the EFRAG guidelines have been taken into account when assigning each IRO to a topic, sub-topic, or sub-sub-topic included in ESRS 1. In the case of the impacts , both positive and negative ones have been identified, analysing internal and external sources of information. In addition, they have been mapped with the previous materiality analysis carried out and have been linked to the value chain at a high level, according to the stage where they impact. Finally, they are classified according to their current or potential nature, whether they are positive or negative, the time horizon when they can occur, the analysis of internal or external context and the relevant documents where they are referenced have been identified. The process of identifying, assessing, prioritising and determining impacts has not focused on specific activities, business relationships, geographic areas or other factors that give rise to a higher risk of adverse events, due to the business model and geographies where the Bank operates. The identification of impacts has considered both those caused by Bankinter Group's own operations and those to which it has contributed as a result of its business relationships throughout the value chain. To identify risks , information on risk management, as well as other relevant external documentation, has been incorporated. In addition, the negative impacts of the previous section are analysed in order to determine potential risks that could arise and dependencies between risks and impacts are established. Furthermore, to identify opportunities , internal and external documentation is also taken into account, as well as positive impacts, in order to recognise potential opportunities that could be generated, again establishing dependencies between impacts and opportunities. In the identification and assessment of IROs, Bankinter has taken an integrated approach, considering both the impacts arising from its activities and the dependencies on external factors that influence its business model and value chain. Based on the analysis of the identified impacts, the potentially associated risks and opportunities have been evaluated, establishing interrelationships between impacts, risks, and opportunities in accordance with the defined methodology. The time horizons of the IROs that reflect the expected impacts on people and/or the environment, as well as the expected financial effects, are established as follows: Up to 1 year for the short term. From 1 to 5 years for the medium term. More than 5 years for the long term. Double materiality assessment The materiality assessment identifies impacts, risks and opportunities that are material and which must therefore be reported. For these purposes, a sustainability issue is "material" when an associated IRO with that issue is assessed with a score that exceeds the established materiality threshold, as detailed below, either for impact materiality, financial materiality or both. Double materiality therefore has two dimensions: Impact materiality and financial materiality. Both dimensions are interrelated and the interdependencies between these two dimensions are considered, as can be observed with the risks and opportunities that depend on identified impacts. Impact materiality The objective criteria for assessing the materiality of current and potential impacts, whether positive or negative, are based on the severity of the impact (scale, scope, irremediable nature) and the probability of the event. Different assessments have been established for the scale, scope and irreversible nature with a scale between 1 and 4, which have allowed the classification of the various impacts identified. The probability scale has also been assessed on a scale of 1 and 4, taking into account the possible impact on human rights, with a greater weighting in the event that it does have an impact. Finally, the scale has been transformed to 1-5, taking into account a weight of 60% for severity and 40% for probability. The opinions of stakeholders have been incorporated through the scores obtained in the questionnaires carried out in the first double materiality exercise, based on the topics applicable to each impact. To obtain the final result, the adjusted result prior to consideration of the stakeholders, with a weight of 80%, is added to the result of the participation of the stakeholders, weighted at 20%. Financial materiality Bankinter Group has developed specific methodologies to assess the financial materiality of sustainability risks and opportunities. In the case of climate and environmental risks, we have taken into account the risk assessment analysis developed according to the criteria of the European Central Bank, which analyses how the different prudential risks (credit, market, liquidity, operational and reputational) are affected by climate risk factors (transition and physical for various time horizons), as well as a first assessment analysis of environmental risks. In addition, the following have been applied to assess social and corporate governance risks: The SASB (Sustainability Accounting Standards Board) methodology, an internationally accepted standard, contemplates three different levels of materiality for the financial industry, which in Bankinter Group has been mapped with each sub-subtopic of the EFRAG. The reputational risk matrix of Bankinter Group was used as a reference, leveraging the internal assessment exercise that the entity regularly conducts to evaluate these risks. Finally, the evaluation of opportunities takes into account the bank's sustainable business plan, as well as the time horizon and weighting of internal stakeholders (considering both the likelihood and the potential financial impact of each opportunity). The final determination to establish an IRO (impact, risk and opportunity) as material is set by comparing the evaluations obtained with the materiality thresholds that have been established for this purpose. Thus, all IROs that obtain an evaluation higher than 70% are considered material. The methodology and results of the double materiality analysis, the identification of the IROs that take into account the expectations of the main stakeholders and the list of IROs considered material after the analysis, have been supervised by the sustainability and appointments committee of the board of directors. This committee, as detailed below, is also responsible for approving the sustainability strategy, which takes into account these identified material IROs. Bankinter Group takes into account the materially relevant IROs in its risk analyses. In section 2.1.1 Analysis of the materiality of climate change risks, it is detailed that climate risk has been taken into account in the climate stress tests of 2022, in the internal capital adequacy assessment processes (ICAAP) where future internal capital needs are foreseen, and has been incorporated as a risk factor that can impact prudential risks. Additionally, in 2025, as explained in Note 44 of the Consolidated Financial Statements, a post-model adjustment was formalised to more directly reflect the effect of climate and environmental risks on credit risk provisions. Despite the scarcity of specific customer information and the current uncertainty regarding climate risk, based on the estimates and weightings used by the Group and active management to identify, assess and reduce such risk, a significant short-term impact on the Group's financial statements is not expected. Below is a table that presents the material impacts, risks and opportunities (IROs) identified in 2025 through the materiality analysis. It details the various IROs, including information on the ESRS standard to which they belong, the corresponding subtopic and sub-subtopic, the type of IRO (impact, risk, or opportunity), its description, whether it is current or potential, its category, and, finally, the strategic line of the ADN Plan with which it is associated. The ADN Plan is Bankinter Group's strategic sustainability plan for the 2024-2026 period, designed to integrate sustainability into the Group's strategy and operations. Further details on this plan are provided in section 1.4.2 The Group's Commitment to Sustainability. As indicated in the introductory section, in 2025 Bankinter Group carried out an update of the materiality analysis, which involved the grouping and reclassification of previously identified IROs. As a result of this exercise, the material IROs differ partially from those identified in the previous exercise, although consistency is maintained with the Group's main impacts, risks, and opportunities. The main changes are concentrated in the environmental area (E1), where it has been decided to group previously defined IROs that were more granular in nature into more general IROs, given that they responded to the same drivers and have common management mechanisms. This grouping allows for better alignment with the regulatory approach and facilitates a more cross-cutting management of climate-related risks and opportunities. In the social domain (S1), adjustments and groupings have been made to certain impacts to improve their definition and coherence, ensuring a clearer and more structured view of issues related to working conditions and employee well-being. Finally, in the governance domain (G1), one impact has been reclassified to ensure its correct placement and alignment with the nature of the identified risk and with the criteria established under the applied analysis framework. Topic Sub-topic Sub-sub-topic IRO type Description of the IRO Current/ Potential Category ADN Plan strategic line E1 Energy - Impact Positive impact of Bankinter's business arising from the promotion of customer decarbonisation, through the integration of ESG criteria into the business plan and the provision of sustainable financial products (such as green bonds, sustainable funds, or renewable energy financing) that support the transition to a low-carbon economy. Current Positive Sustainable finance E1 Climate change mitigation - Impact Increase in GHG emissions from financing and investment books due to higher volumes of assets or exposure to carbon-intensive economic activities. Current Negative Climate change E1 Climate change mitigation - Risk Delay in the transition towards climate change mitigation due to the prolongation in the implementation of effective actions by companies to reduce emissions until 2030 - Medium term Climate change E1 Climate change mitigation - Risk Operational risk arising from damage to assets and/or interruption of operations caused by physical risks - Long term Climate change E1 Climate change mitigation - Risk Business risk generated by a possible negative effect on the Bank's results due to the cessation of activities exposed to the materialisation of credit, market, operational, reputational or liquidity risks. - Medium term Climate change E1 Climate change mitigation Climate change adaptation - Risk Inefficiencies in risk management as a result of the lack of integration or inadequate integration of traditional risks (credit, operational, etc.) with ESG risks. - Medium term Climate change E1 Climate change adaptation - Risk Credit risk arising from the physical risks of climate change, which may affect customers and financed assets through direct damage, operational disruptions, or deterioration of their financial capacity. - Medium term Climate change E1 Climate change mitigation - Opportunity Reputational improvement due to increased development of sustainable products and advances in climate risk management by supervisors. - Medium term Sustainable finance E1 Climate change mitigation - Opportunity Improvement in the credit risk quality of financing books as a result of correct management of climate change risk - Medium term Climate change E1 Climate change adaptation Climate change mitigation - Opportunity Opportunity arising from the growth of sustainable financing, through the development of products such as green bonds, sustainable loans, and financing for renewable energy or energy-efficient buildings, which support the energy transition and climate change mitigation and adaptation. - Short term Sustainable finance S1 Working conditions Social dialogue Freedom of association, the existence of works councils, and workers' rights to information, consultation and participation Collective bargaining, including the proportion of workers covered by collective bargaining agreements Impact The Bank's commitment to ensure freedom of association, collective bargaining agreements and channels of social dialogue to resolve conflicts or differences between the parties and reach labour agreements Current Positive People manageme nt Topic Sub-topic Sub-sub-topic IRO type Description of the IRO Current/ Potential Category ADN Plan strategic line S1 Equal treatment and opportunities for all Gender equality and equal pay for work of equal value Impact Promotion of diversity and inclusion in the workforce and governance bodies through the encouragement of diverse profiles by age, gender, culture, and abilities Current Positive People management S1 Equal treatment and opportunities for all Training and capacity building Impact Improving the professional development of employees through training and learning activities that promote professional knowledge and skills Current Positive People management S1 Equal treatment and opportunities for all Measures against violence and harassment in the workplace Impact Promotion of employees' physical, emotional, and social well-being through health, safety, and prevention initiatives, as well as fostering a workplace free from harassment supported by operational protocols and reporting channels Current Positive People management S1 Other labour rights Privacy Impact Promoting awareness and training in Privacy and Cybersecurity for the workforce to reduce the risk of personal data security breaches Current Positive Cybersecurity S1 Equal treatment and opportunities for all Gender equality and equal pay for work of equal value Impact Fair and transparent management of the remuneration policy, promoting flexible and competitive systems that improve employees' financial conditions and contribute to pay equity. Current Positive People management S1 Working conditions Work time Work-life balance Impact Complaints from employees due to the lack of adaptation of work-life balance and welfare measures Current Negative People management S4 Incidents related to information for consumers or end users Privacy Impact Ensuring customers' right to privacy through a Privacy Governance Framework Current Positive Customer relations S4 Incidents related to information for consumers or end users Privacy Freedom of expression and access to (quality) information Impact Contribution to the communication of complaints or claims regarding operations, banking and financial services by customers thanks to the existence of Customer Services as a complaint mechanism Current Positive Customer relations S4 Social inclusion of consumers or end users Access to products and services Impact Improving accessibility to products and services for all customers by adapting to the needs of groups such as people with disabilities and the elderly Current Positive Customer relations S4 Incidents related to information for consumers or end users Social inclusion of consumers or end users Privacy Freedom of expression Access to (quality) information Non-discrimination Access to products and services Responsible marketing practices Impact Consumer dissatisfaction derived from significant issues in the overall customer experience Current Negative Customer relations S4 Incidents related to information for consumers or end users Privacy Impact Leakage of confidential/sensitive customer information Potential Negative Customer Relations / Cybersecurity Topic Sub-topic Sub-sub-topic IRO type Description of the IRO Current/ Potential Category ADN Plan strategic line S4 Social inclusion of consumers or end users Access to products and services Risk Reputational risk due to failure to meet customer expectations regarding products and services - Medium term Customer relations S4 Incidents related to information for consumers or end users Privacy Risk Security in the protection of customers' financial and/or personal data. - Short term Customer Relations / Cybersecurity S4 Social inclusion of consumers or end users Responsible marketing practices Risk Reputational risk due to lack of commercial and corporate transparency - Medium term Ethics and transparency S4 Incidents related to information for consumers or end users Privacy Risk Operational risk due to a cyberattack that compromises business continuity - Medium term Cybersecurity G1 Corporate culture - Impact Promotion of a responsible and upright corporate culture derived from good governance actions that are framed within the principles of the Sustainability Policy Current Positive Ethics and transparency G1 Management of supplier relations, including payment practices Corruption and bribery Prevention and detection, including training Cases Impact Reinforcement of the fight against corruption and improvement of integrity in the supply chain derived from the implementation of and compliance with the Supplier Code of Conduct and the incorporation of ESG criteria in its evaluation and approval Current Positive Supply chain G1 Corporate culture Corruption and bribery Prevention and detection, including training Cases Impact Strengthening the culture of transparency and integrity within the Bank through the strict enforcement of the Anti-Corruption Policy, ethics codes, etc., which includes labour and contractual sanctions for non-compliance and the possibility of mitigating liabilities Current Positive Ethics and transparency G1 Corporate culture - Impact Strengthening the capabilities of senior management through specialised ESG training that improves monitoring of ESG aspects within the organisation. Current Positive Corporate Governance ‌List of Material Disclosure Requirements Within the ESRS environmental standards, only the ESRS E1 standard on Climate Change has been identified as material. Therefore, the remaining environmental standards (ESRS E2 Pollution, ESRS E3 Water and marine resources, ESRS E4 Biodiversity and ESRS E5 Circular economy) have been classified as not significant, due to the nature of the activities of a financial institution and the information currently available on these topics. Accordingly, no information relating to these standards will be reported beyond that required by the disclosure requirements (including their data points) set out in the environmental ESRS related to the IRO-1 disclosure requirement. Regarding these specific disclosure requirements for ESRS E2, E3 and E5: Bankinter Group has not carried out an analysis of its assets by location related to pollution, water resources and use of resources and circular economy in the identification of IROs. Nor has it conducted stakeholder consultations related to the IROs identified in these standards. The Bank has conducted a top-down analysis at the company level, as no material issues related to these standards were identified due to the location of its facilities (in urban areas) and the information available at the end of the fiscal year regarding the supply chain and customer activities. Regarding the requirements for ESRS E4: Bankinter Group has not conducted an analysis of its assets by location related to the impacts and dependencies on biodiversity in the identification of IROs. Instead, it has carried out a top-down analysis at the company level, as no material issues related to these standards were identified due to the location of its facilities (in urban areas) and the information available at the end of the fiscal year regarding the supply chain and customer activities. This analysis has included the identification of risks and opportunities, which, as previously mentioned, have not been material, although no physical, transition or systemic risks have been identified. Similarly, no consultations have been conducted with stakeholders regarding these issues due to the location of our assets in urban areas, not in biodiversity-sensitive areas. Based on the analysis carried out, it has not been considered necessary to apply mitigation measures related to this area so far. Bankinter Group considers that, in future reporting periods, information relating to the value chain in connection with these environmental aspects will be progressively expanded and integrated into updates of the double materiality analysis. Additionally, within the ESRS E1 standard, requirement E1-8, related to the internal carbon price, is not applicable to Bankinter Group, since it does not currently use this type of tool. Bankinter Group also applies the transitional provision of requirement E1-9 related to the expected financial effects of climate risks and opportunities. Regarding social issues, ESRS S1 on Own Personnel and ESRS S4 on Consumers and End Users have been identified as material for the entity, given that these represent two of the main stakeholders for Bankinter Group. In contrast, ESRS S2 on Value Chain Workers and ESRS S3 on Affected Groups have been deemed non-material at this time and no information will be reported on them. Requirement S1-7, relating to non-salaried workers, will not be reported either, since Bankinter Group adheres to the time limits permitted by the regulation for the implementation of this disclosure. Finally, within the scope of the ESRS G1 governance standard, which is considered material, the disclosure requirement G1-5 on Political influence and lobbying activities has been defined as non-material in the double materiality analysis carried out in 2025. Below is a table detailing the disclosure requirements complied with in the Consolidated Non-Financial Information Statement and sustainability information: ESRS Disclosure requirement Location in the report ESRS 2 BP-1 General basis for the preparation of the sustainability report Page 3 ESRS 2 BP-2 Information regarding specific circumstances Page 3 ESRS 2 GOV-1 Role of the administrative, management and supervisory bodies Page 17 ESRS 2 GOV-2 Involvement of governing bodies Page 17 ESRS 2 GOV-3 Integrating sustainability factors into incentive systems Page 22 ESRS 2 GOV-4 Due diligence statement Page 23 ESRS 2 GOV-5 Risk management and internal controls regarding the disclosure of sustainability information Page 24 ESRS 2 SBM-1 Strategy, business model and value chain Pages 26, 28 ESRS 2 SBM-2 Interests and opinions of relevant stakeholders Page 34 ESRS 2 SBM-3 Incidents, risks and opportunities and their interaction with its strategy and business model Page 35 ESRS 2 IRO-1 Materiality assessment process Page 5 ESRS 2 IRO-2 Disclosure requirements set out in the ESRS covered by the company's sustainability report Page 13 ESRS E1 GOV-3 Integrating sustainability-related performance into incentive systems Pages 22 and 79 ESRS E1 E1-1 Transition plan for climate change mitigation Page 62 ESRS E1 SBM-3 Incidents, risks and opportunities of relative importance and their interaction with the strategy and business model Pages 44, 46 and 47 ESRS E1 IRO-1 Description of processes for determining and assessing material climate-related incidents, risks and opportunities Pages 37 and 39 ESRS E1 E1-2 Policies related to climate change mitigation and adaptation Pages 44, 46 and 62 ESRS E1 E1-3 Actions and resources related to climate change policies Page 62 ESRS E1 E1-4 Goals related to climate change mitigation and adaptation Pages 64 and 84 ESRS E1 E1-5 Energy consumption and mix Page 80 ESRS E1 E1-6 Gross scope 1, 2 and 3 GHG emissions and total GHG emissions Page 81 ESRS E1 E1-7 GHG removals and GHG mitigation projects financed by carbon credits Page 84 ESRS S1 SBM-2 Interests and opinions of relevant stakeholders Page 93 ESRS S1 SBM-3 Incidents, risks and opportunities of relative importance and their interaction with the strategy and business model Page 90 ESRS Disclosure requirement Location in the report ESRS S1 S1-1 Policies related to the Bank's personnel Page 97 ESRS S1 S1-2 Processes for collaborating with employees and their representatives on incidents Page 93 ESRS S1 S1-3 Processes for remedying negative incidents and channels for the Bank's personnel to voice their concerns Page 96 ESRS S1 S1-4 Adoption of measures related to significant incidents concerning the Bank's personnel, approaches to mitigate significant risks and take advantage of significant opportunities related to Bank's personnel, and effectiveness of such actions Pages 103 - 113 ESRS S1 S1-5 Targets related to managing material adverse incidents, driving positive events and managing material risks and opportunities Page 100 ESRS S1 S1-6 Characteristics of the company's employees Page 87 ESRS S1 S1-8 Coverage of collective bargaining and social dialogue Page 103 ESRS S1 S1-9 Diversity parameters Page 110 ESRS S1 S1-10 Adequate salaries Page 103 ESRS S1 S1-11 Social protection Page 103 ESRS S1 S1-12 People with disabilities Page 111 ESRS S1 S1-13 Training and capacity development parameters Page 109 ESRS S1 S1-14 Health and safety parameters Page 106 ESRS S1 S1-15 Work-life balance parameters Page 105 ESRS S1 S1-16 Compensation parameters (salary gap and total remuneration) Page 108 ESRS S1 S1-17 Serious incidents and complaints related to human rights Page 113 ESRS S4 SBM-2 Interests and opinions of relevant stakeholders Page 115 ESRS S4 SBM-3 Incidents, risks and opportunities of relative importance and their interaction with the strategy and business model Pages 120 and 131 ESRS S4 S4-1 Policies related to consumers and end users Pages 122 and 132 ESRS S4 S4-2 Processes for collaborating with consumers and end users regarding incidents Page 115 ESRS S4 S4-3 Processes for remedying negative incidents and channels for consumers and end users to voice their concerns Page 115 ESRS S4 S4-4 Adoption of measures related to material incidents on consumers and end users, approaches to mitigate material risks and take advantage of material opportunities related to consumers and end users and the effectiveness of such actions Pages 122 and 132 ESRS S4 S4-5 Targets related to managing material adverse incidents, driving positive events and managing material risks and opportunities Pages 129 and 134 ESRS G1 GOV-1 The role of the administrative, management and supervisory bodies Page 136 ESRS G1 IRO-1 Description of the processes for determining and assessing incidents, risks and opportunities Page 135 ESRS Disclosure requirement Location in the report ESRS G1 G1-1 Corporate culture and corporate culture and business conduct policies Pages 136, 137 and 141 ESRS G1 G1-2 Supplier relationship management Page 142 ESRS G1 G1-3 Prevention and detection of corruption and bribery Page 138 ESRS G1 G1-4 Confirmed cases of corruption or bribery Page 138 ESRS G1 G1-6 Payment practices Page 144 The list of data points included in general standards and thematic norms derived from other EU legislation is included in Annex IV of this document. ‌Corporate Governance ‌The role of the administrative, management and supervisory bodies One of the pillars of Bankinter Group (hereinafter, the "Group"), whose parent company is Bankinter, S.A. (hereinafter, "Bankinter" or the "Institution"), is its internal organisation, which is always committed to sustainability, understood as responsible performance across all areas of its activity. In the area of internal governance, this results in a robust corporate governance model underpinned by a board and Board committees with the right size and composition to ensure diversity and effectiveness; sound internal decision-making processes; and a clear corporate structure, with well-defined lines of responsibility to guarantee that risks are properly identified, assessed and managed in all of the regions in which it operates. Under the leadership and oversight of the board of directors, this model serves the essential objective of creating long-term value for all stakeholders: shareholders, customers, employees and society as a whole. Bankinter Group's board of directors, supported by its sustainability and appointments committee, is the competent body to establish and oversee compliance with the Sustainability Policy and its implementing instruments, such as strategic sustainability plans and the Transition Plan, among others. As at 31th December 2025, the composition of Bankinter's board of directors is as shown below: There is no employee representation on Bankinter's board of directors. As of 31th December 2025, the reference date of this Report, Bankinter Group's board of directors is made up of 12 directors with the following distribution by categories: In the 2025 financial year, the following changes have been made to the composition of the Board, as approved by the Annual General Meeting held in March 2025: Increase in the number of board members from 11 to 12. Appointments of Juan Antonio Zufiría Zataraín and Alfonso Villanueva Rodríguez as new independent external directors. Lastly, effective on 27th March 2025, the independent external director Álvaro Álvarez-Alonso Plaza resigned from the board. Both appointments have enhanced the composition and diversity of Bankinter's board of directors in key areas for the future of the Institution and its Group, such as technology, digitalisation, and risk management and control, particularly technological risks, as well as international experience. With regard to gender diversity, the distribution between men and women on the Board stands at 58% women (7) and 42% men (5), exceeding the targets set both by Bankinter and by national and international recommendations and best practices. Furthermore, Bankinter continues to be the only IBEX 35 company with two women in the Institution's most senior governance and executive positions (non-executive chairwoman of the board of directors and chief executive officer). The other female directors (five) are independent external directors. As regards diversity of knowledge, skills and experience, both nationally and internationally, the board of directors as a whole brings together sufficient and appropriate expertise to cover all areas of knowledge necessary to properly understand the development of the Group's activities, including its main risks, and to ensure the effective capacity of the board of directors to take decisions independently and autonomously in the best interests of the Group. This has been further strengthened, particularly in technological and digital matters, following the appointment of the two new directors: the Group's business and the main related risks, including emerging risks such as climate, environmental or geopolitical risks; each of the Institution's significant activities; relevant areas of sectoral/financial expertise, including financial and capital markets, capital adequacy and models; accounting and financial reporting; risk management, compliance and internal audit; digital, information technology and security; local and regional markets; the legal and regulatory environment; leadership skills and management experience; and strategic planning capability. It is important to note that the collective suitability of the board of directors for overall risk management, given its diversity, must be assessed using objective criteria, prioritising those risks particularly related to the core activity of the Institution and its Group. However, there are emerging risks, such as climate or geopolitical risks, which, although not specific to the activity of Bankinter Group, may, due to their cross-cutting nature, affect multiple aspects of the business. These risks require a global vision and collective capacity to understand by the board as a whole that ensures, through the diversity of perspectives and experience of the directors, that the board of directors can effectively and efficiently confront the complex and multi-faceted challenges that these universal risks present. The members of Bankinter's board of directors have experience in identifying, assessing and managing risks within their respective areas of responsibility, and collectively possess an understanding of how all types of risks may impact the operations of the Institution and its Group, its customers and the market, and are therefore in a position to understand and oversee emerging risks as well. The Annual Corporate Governance Report and the corporate website set out in detail the knowledge and experience of the members of Bankinter's board of directors, both individually and collectively, demonstrating that the composition of Bankinter's board of directors fully meets diversity objectives and maintains a completely balanced structure in all areas. Additionally, ongoing training and specialised external advice, where considered necessary, are elements that ensure the board of directors' understanding and supervisory capacity through the updating of directors' knowledge and experience in relation to the latest trends, regulatory developments and supervisory expectations, and best practices in the management of these risks, ensuring at all times that the Board oversees their integration into the business strategy, including their incorporation into decision-making processes, remuneration, and long-term planning. Given the importance of Sustainability for the Group and the regulatory developments in this area, Bankinter provided collective training to board members during the 2025 financial year on the following matters (7 sessions): Joint training session for members of the sustainability and appointments committee and the audit committee (*) On the new EBA Guide on ESG Risk Management (provided by an external expert). Joint training session for members of the risk and compliance committee and the audit committee (*) On the new ECB Guide on Internal Governance and Risk Culture (provided by an external expert). To all members of the board i) Geopolitical risks: overview and potential business implications (provided by an external party). ii) Technology: Blockchain and Cryptocurrency (provided by an independent external director of the Board). iii) Cybersecurity (provided by an external advisor). iv) Prevention of Money Laundering and Terrorist Financing. v) Update of the regulatory map that impacts Bankinter Group's activity. (*) All other board members were invited. For the 2026 financial year, and in light of the conclusions reached in the annual evaluation exercises of the Board's performance (conducted by an external expert) and the assessment of the suitability of its members, both individually and collectively, the board of directors, in accordance with its Directors' Training Policy (available on the corporate website), has scheduled training sessions comprising at least three sessions on the following topics: i) Neobanks, ii) Artificial Intelligence, and iii) the Digital Euro; in addition, training sessions planned for members of the Committees, to which all Board members are invited, focus specifically on matters relating to financial and credit risk management. Through this approach, the Board ensures that it has, at all times, the up-to-date capabilities required for the performance of its supervisory functions. With the training delivered during the 2025 financial year and that planned for 2026, the board of directors strengthens its preparedness to address the material impacts, risks and opportunities (IROs) identified in the double materiality analysis. Through a structured and continuous approach, it is ensured that directors possess the specialised knowledge necessary to effectively oversee the risks to which the Institution's activities are exposed, as well as the key strategic and regulatory aspects relevant to the activities of Bankinter Group. This training plan not only responds to the suggestions provided through the annual board performance evaluation exercises, but also aligns with the evolution of the regulatory and risk environment. The board of directors, in the exercise of its functions relating to Sustainability, is supported by its supervisory Committees, the composition and regulations of which are available on Bankinter's corporate website. All of them are made up of non-executive directors, with a majority of independent directors and chaired by one of the latter. Below is the composition of the Board committees as at the end of the 2025 financial year: Bankinter Group's Sustainability Policy, approved by the board of directors of Bankinter, establishes the framework for action under which the Group integrates responsible management values and principles into its activities in order to generate economic, social and environmental value, and is complemented by the other policies established for the Group. The Group's strategy is set out in the current Sustainability Plan. We refer to this as our ADN (Responsible Action, Differentiation and Sustainable Business - "negocio sostenible" in Spanish). This is characterised by a number of strategic approaches chosen following analysis of the sustainability challenges facing Bankinter Group. These apply across the regions in which it operates and the activities in which it is involved. They include objectives related to sustainable finance and investment and the green agenda. Further information on the ADN Plan is included in section 1.4.2 Group Commitment to Sustainability. Below are the governance bodies involved in Sustainability matters according to the functions entrusted to them, which are summarised as follows: Sustainability and appointments committee : the body responsible for reviewing the Sustainability Policy, monitoring the strategy and overseeing the performance of the Group's ESG (Environmental, Social and Governance) indicators, approving the Transition Plan, as well as monitoring dialogue with stakeholders, assessing ESG risks and ensuring the public disclosure of non-financial and diversity information. Risk and compliance committee : the body competent to exercise the powers of the Board relating to risk oversight (including sustainability risks), including, among others, advising the Board on the current and future overall risk appetite of the Institution and its Group and its strategy in this area, and assisting it in its supervision; as well as reviewing the general risk map of Bankinter and the Group and submitting the corresponding proposals to the board of directors. The committee is also responsible, without prejudice to the powers of the audit committee, for supervising the internal control and risk management systems, both financial and non-financial, so that the main risks are identified, managed and adequately disclosed. Additionally, it contributes to the establishment of rational compensation policies and practices, examining, without prejudice to the functions of the remuneration committee, as outlined below, whether the incentives provided in the compensation system take into account risk (including sustainability risks), capital, liquidity and the probability and timing of benefits. Audit committee : the body of the board of directors competent to exercise the Board's powers relating to the oversight of adequate internal control systems that ensure the proper management of the Institution's financial and non-financial risks, as well as the accuracy, objectivity, and transparency of corporate accounting, financial and non-financial information, and compliance with the legal and regulatory provisions applicable to the Group. Remuneration committee: the body of the board of directors competent to exercise the Board's powers regarding remuneration. Its responsibilities include the annual review of the remuneration policies of directors and employees whose professional activities have a significant impact on the Group's risk profile (generally, all such employees form the Identified Staff in terms of remuneration), to ensure that these policies are aligned with the Institution's short-, medium- and long-term situation and strategy, and with market conditions, and to assess whether they contribute to long-term value creation and to proper risk control and management. Likewise, there are internal bodies created within the Institution to transmit to the entire Group the principles and guidelines issued by the Board and its committees regarding sustainability, ensuring a robust, efficient, and fully coordinated management framework in this area: Sustainability committee : assumes coordination functions on sustainability within the Group, and is responsible for preparing proposals for multi-year strategic sustainability plans and promoting, within Bankinter Group, compliance with the principles contained in Bankinter Group's Sustainability Policy, approved by the board of directors, as well as the objectives of the current strategic sustainability plans. The committee is chaired by the non-executive chairwoman of the board of directors and includes the heads of the areas key to integrating ESG criteria into decision-making across the Group's value chain. The Sustainability Department is responsible for ensuring the effective performance of the actions defined in the lines and programmes of the multi-year strategic plans. It also acts as an observatory of trends and risks based on ongoing dialogue with stakeholders and promotes coordinated action among the areas to develop initiatives focused on meeting their expectations. It is also responsible for monitoring and verifying the alignment of the Bank's different divisions, subsidiaries and branches, as well as monitoring and verifying the degree of compliance with the objectives set out in the strategic plan, reporting periodically to the sustainability and appointments committee and to the sustainability committee. It also identifies areas for improvement, according to internationally recognised standards, norms, guides and ethics and sustainability indexes. It is also responsible for the preparation of the different sustainability accountability reports for the various regulators and competent bodies and other stakeholders, as well as the information required by investors and sustainability analysts. The sustainability department is committed to positioning the Bank and its group as leaders in sustainability and social responsibility. Given the Institution's and Group's activities, the sustainability department participates in units responsible for evaluating and promoting green financing and the issuance of green financial instruments. The Financial and Non-Financial Information Control division , as the second line of control integrated into the Corporate Control and Compliance division, includes control of the effectiveness of the administrative and accounting procedures for the preparation of the financial reporting communicated internally and externally. Reporting in relation to financial control is made to the audit committee. It is also necessary to emphasise the role that internal audit plays in terms of Sustainability, identifying areas for improvement in ESG practices through its recommendations, thus strengthening controls and processes and mitigating risks. At Bankinter Group, the material impacts, risks and opportunities (IROs) detected through the double materiality analysis are integrated into the strategic lines of the ADN Sustainability Plan. Details of the relationship between the different IROs and the strategic lines of the ADN Plan are provided in the table included in section 1.2.3 Double materiality assessment. In relation to the oversight of IROs by Bankinter's board of directors, Bankinter Group's Sustainability Plan, which includes the identified IROs, is presented periodically to the sustainability and appointments committee. At these meetings, information is provided on the progress of initiatives, progress in the application of due diligence and the results obtained in relation to policies, actions, parameters and goals. The IROs form part of Bankinter Group's strategy and risk management, aligning with the strategic lines of the Sustainability Plan. As detailed in the sections of this report corresponding to ESRS E1, S1, S4 and G1, their impact is analysed in the periodic sessions of the sustainability and appointments committee, where oversight is exercised on how these matters influence corporate strategy, decision-making, and the risk management process, ensuring alignment with the strategic objectives of Bankinter Group. Finally, regarding the matters addressed during the reporting period, as reflected in the Annual Activity Report of the sustainability and appointments committee, available on the Institution's corporate website, various sessions covered topics related to the material IROs included in Bankinter Group's Sustainability Plan, ensuring their proper supervision and integration into the Group's strategy. ‌Alignment of remuneration policy with ESG objectives Bankinter Group's remuneration policy is designed to be coherently aligned with ESG (Environmental, Social and Governance) objectives. This alignment seeks to incentivise behaviours and outcomes that generate long-term sustainable value, ensuring that the incentives provided for in the remuneration system adequately consider the risks related to sustainability, capital, liquidity and the timing of benefits. To ensure this alignment, Bankinter Group's remuneration policy includes variable components linked to performance on ESG criteria. This translates into the evaluation of managers and staff not only for their financial results, but also for their contribution to the achievement of the Group's environmental, social and governance objectives. In this way, a corporate culture is fostered that values and rewards responsible and sustainable practices. Furthermore, as previously indicated, the remuneration committee continuously reviews these policies to ensure they adapt to changes in the Group's strategy and market conditions, as well as to assess their effectiveness in promoting proper risk control and management. This review includes an assessment of whether the remuneration policy contributes to the creation of long-term value and whether it is aligned with international best practices in sustainability. Taken together, these measures ensure that Bankinter Group's remuneration policy not only promotes financial success but also reinforces the Group's commitment to sustainability and social responsibility, aligning incentives and remuneration practices with the ESG objectives established by the Institution. The variable remuneration of Executive Directors, as well as key personnel, is determined through the application of highly demanding indicators, fully aligned with the Group's risk profile, and which are fundamental to its long-term sustainability. To do this, the calculation of variable remuneration is carried out in three phases: First phase: achievement of the annual and multi-year goals is assessed based on the indicators established for each case. Second phase : the variable remuneration calculated based on the above indicators is adjusted by the risk appetite framework (hereinafter, "RAF") indicators aligned with metrics that adequately reflect the most significant risks, including ESG risks. These indicators affect 100% of the accrued variable remuneration and may even reduce it to zero but never increase it. Bankinter Group currently relies on six RAF indicators, two of which are related to environmental and social targets: Financed emissions (which measures the impact on decarbonising the economy through the financing granted by the bank to its customers), and the Institution's total NPS ( Net Promoter Score ) based on quality surveys (which measures the customers' willingness to recommend the Institution). Each indicator has a defined objective, tolerance and limit that are approved by the board of directors at the proposal of the risk and compliance committee. Each indicator is measured quarterly, so there are four measurements per year for each indicator. Non-compliance with the tolerance and limit levels will result in a penalty being applied to the accrued variable remuneration and may even adjust it to zero. Third phase: variable remuneration is adjusted according to ROE TTC 1 , following the scale determined by the board of directors, on the proposal of the risk and compliance committee, with the objective of creating long-term value and developing the Institution and its Group sustainably over the coming years, aligned with shareholders' interests. These three stages apply to both annual variable remuneration and multi-year variable remuneration. The second and third stages involve ex ante adjustments. Further information is available in the directors' remuneration policy and remuneration report, available on the Institution's corporate website. 1 ROE TTC (through the cycle), return on invested capital: A metric designed to evaluate the Bank's medium- to long-term profitability, isolating the cyclical component introduced into the income statement by the cost of risk, as well as other extraordinary results which, while they should be considered part of the Institution's historical profitability, constitute isolated and unique events that are not used as a reference in a forward-looking assessment of profitability. ‌Due diligence To explain the due diligence process for material IROs carried out by Bankinter Group, a table is included that links the key elements of the process with the applicable disclosure requirements and the relevant sections of the report. Essential elements of due diligence Sections of the Consolidated Statement of Non-financial Information and Sustainability Integration of due diligence into governance, strategy, and business model Section 1.3.1 The role of the administrative, management, and supervisory bodies. Page 17 Section 1.3.2 Alignment of the remuneration policy with ESG objectives. Page 22 Section 1.4.4 Integration of impacts, risks and opportunities into the strategy and business model. Page 35 Collaboration with affected stakeholders at all key stages of due diligence Section 1.3.1 The role of the administrative, management, and supervisory bodies. Page 17 Section 1.4.3 Relationship with stakeholders. Page 34 Section 1.2 Double Materiality Exercise. Page 5 Section 3.1.3 Dialogue with the staff. Page 93 Section 3.2.1 Dialogue with stakeholders. Page 115 The MDR-P (Minimum Disclosure Requirements on Policies) are met throughout the thematic standards, which detail the environmental, social and governance policies adopted to address the identified impacts, risks and opportunities. Identification and evaluation of adverse incidents Section 1.2 Double Materiality Exercise. Page 5 Section 1.4.4 Integration of impacts, risks and opportunities into the strategy and business model. Page 35 Adoption of measures to address these adverse incidents Requirements relating to the adoption of measures to address adverse incidents are addressed in a cross-cutting manner throughout the thematic standards of the regulations. In these particular requirements are addressed in E1 (Climate Change), S1 (Employees), S4 (Consumers and End Users) and G1 (Business Conduct), where the actions implemented to mitigate negative impacts and promote responsible management in environmental, social and governance matters are detailed. Monitoring the effectiveness of these efforts and communication The MDR-M (Minimum Disclosure Requirements on Metrics) are met throughout the thematic standards, providing information on the indicators used to measure environmental, social and governance performance, as well as monitoring progress on established commitments. The MDR-T (Minimum Disclosure Requirements on Targets) are disclosed in the specific sections on objectives and targets within each of the thematic standards, detailing the commitments established and monitoring their progress over time. ‌Risk management system and internal control related to the Sustainability information disclosure process (SCIIS) Characteristics and components of the sustainability information risk management and internal control system In compliance with the Corporate Sustainability Reporting Directive (CSRD) and in accordance with Technical Guide 1/2014 of the Spanish National Securities Market Commission (CNMV), Bankinter Group is implementing a Sustainability Information Internal Control System (SCIIS in Spanish) with a robust three-year risk management and internal control plan to ensure accuracy and transparency in the disclosure of sustainability information. This system is designed taking into account international regulations and standards, such as the Integrated Internal Control Framework developed by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and the ICSR Report (Internal Control Sustainability Reporting). The framework and international standards establish five components that must be the basis for the effectiveness of the internal control system: control environment, risk assessment, control activities, information and communication and monitoring activities. The components must be present and operational, so that, within the scope of the SCIIS, they are capable of preventing, detecting, correcting and mitigating material errors or fraud in information related to Sustainability. The Financial and Non-Financial Information Control department of Bankinter Group carries out an annual general evaluation of the SCIIS system based on these components. To this end, it considers in its evaluation the results of the double materiality analysis, incorporating into the control scope those issues related to the standards and sub-standards of the CSRD that have been identified as material. New disclosure requirements may be integrated into the SCIIS model on an annual basis based on the results of the review of the double materiality analysis, which may lead to a redefinition of the current scope. As part of the improvements to be made in the three-year plan, an annual SCIIS review report will be prepared, reporting on the overall assessment of the COSO-based SCIIS as well as the outcome of the monitoring of the risks and controls of the SCIIS model, as detailed in the section 'Monitoring and reporting to the management and governing bodies'. Scope of the Internal Control System for Sustainability Information The consolidation perimeter of the Consolidated Non-Financial Statement and Sustainability Information is the one used for the construction of the SCIIS, thereby ensuring that the information presented is coherent and complete, reflecting the activities of all entities within the Group. Scope, assessment and risk management and controls as part of the sustainability information disclosure process Risk identification, assessment and prioritisation methodology Bankinter Group carries out a process of identifying, assessing and prioritising nonfinancial risks, including those related to climate change and other factors, which are disclosed as part of the sustainability information. Bankinter Group's SCIIS process defines as a key risk the possibility that an event materialises due to errors in reporting information, regulatory changes or errors in information or governance systems, which affect the reliability, accuracy and integrity of the sustainability information disclosed by the Bank. The Financial and Non-Financial Information Control division has conducted an analysis of the indicators required by current regulations (CSRD Directive and Law 11/2018). Based on the analysis, the most relevant indicators that could present a higher associated risk have been identified for prioritising their review, considering variables such as potential relevance, calculation complexity, consolidation of information from subsidiaries, etc. Clear policies and procedures have also been established for the collection, verification and reporting of sustainability indicators. These policies are periodically reviewed and updated to reflect best practices and regulatory changes. Control strategy for risk mitigation Bankinter Group has narratives and flowcharts of the processes for calculating and reporting the disclosure requirements associated with the material indicators, as well as the corresponding controls defined by the first line of defence to mitigate the risks in the sustainability information disclosure process. Furthermore, as part of the three-year plan for the full implementation of the control system within the SCIIS assessment, work is being done to incorporate an annual internal certification process for the identified controls at different levels in the organisation. The result of the process is monitored by the Financial and Non-Financial Information Control division and presented to the audit committee and sustainability committee for their information. Risk and control assessment and management tool As part of its control system improvement plan, Bankinter Group is developing the incorporation of a GRC tool that incorporates SCIIS regulations, risks and controls, reducing manual tasks and allowing for traceability and consistency of the process at all times. The risks and controls of the sustainability information disclosure process will be assessed in the GRC tool in accordance with the Group's risk and control assessment methodology. Integration of risk and control assessment findings into internal functions and processes In this context, the risk and control assessment model is based on the identification and assessment of risks, the performance of self-assessments of controls by the first line, as well as on continuous and specific supervisions carried out by the second and third lines. The results (recommendations, action plans, etc.) are included in the supervisory reports that are submitted to the governance bodies. Bankinter Group also conducts ongoing training exercises for its staff on the importance of sustainability and compliance with SCIIS procedures. This ensures that all levels of the organisation are aligned with sustainability goals. Supervision and reporting to the governing bodies Bankinter Group's board of directors has the non-delegable authority to establish a risk management and control framework that takes into account all the different types of risks, both financial and non-financial, that may arise and the periodic monitoring of internal information and control systems, with a level of risk that allows: Achieve strategic objectives with controlled volatility. Ensure business stability, financial strength and reputation of the Group (stakeholders). Contribute to the achievement of the SDGs approved by the UN. Promote a culture of risk awareness. The audit committee reviews the quality, clarity, consistency, and completeness of both financial and non-financial information, and reports to the board of directors prior to its publication. The audit committee reviews the quality, clarity, consistency, and completeness of both financial and non-financial information, and reports to the board of directors prior to its publication. The Financial and Non-Financial Information Control division acts as a second line of support to the audit committee in overseeing the effectiveness of internal controls over sustainability information, reporting to both the committee and the board of directors. For its part, the internal audit department conducts periodic reviews of the SCIIS system to ensure its effectiveness and compliance with applicable regulations. The multi-year audit plan includes the review of the SCIIS and other activities related to non-financial information, including sustainability information. Audit work, as well as the periodic follow-up of recommendations, is reported to the audit committee. Internal audit function in sustainability The Internal Audit function actively participates in strengthening sustainability management within the Group. By applying a systematic and disciplined approach, Internal Audit contributes to ensuring that governance processes and risk management and internal control activities are robust and effective. This work not only supports the achievement of organisational objectives but also drives continuous improvements in sustainable management. Within the multi-year internal audit plan, processes related to sustainability have been integrated, covering the management of Environmental, Social, and Governance (ESG) risks. Furthermore, the audit function supports transparency and responsible disclosure to the market, with periodic reviews of sustainability information made available externally and of its internal control system (SCIIS). ‌Strategy ‌Business model Positioning and value proposition Bankinter is the fifth-largest Spanish bank by assets and one of the most resilient listed banks in the Eurozone, according to the European Banking Authority. The Group maintains a presence in Spain, Portugal, Ireland, and Luxembourg, with a diversified activity both across markets within the European Union and across business lines. Traditionally, the Group has maintained strong levels of profitability, operational efficiency, and asset quality. In terms of business lines, the bank stands out for a strong specialisation in Commercial Banking (for individual customers) and, within this, significant activity in Wealth Management (for high-net-worth customers or private banking) and Corporate & SME Banking. This specialisation is combined with prudent risk management, a customer service culture, and efficient capital allocation, elements that have enabled the bank to maintain good business performance, mainly supported by organic growth. Over more than 60 years of history, the bank has been a pioneer in digitalisation and financial innovation, having early on introduced mobile banking solutions, digital brokerage, robo-advisors, and fully digital investment advisory services. In this context, Bankinter develops a commercial strategy based on a business model balanced by segments and geographies, focused on profitable growth, recurring revenues, and the sustained generation of value for customers, shareholders, and other stakeholders. Structure of Activities and Business Segments The Group's business model is structured around complementary areas of activity, defined by the nature of the products offered, the needs of the customers and the distribution channels used. Commercial Banking - the core of the relationship with individual and wealth customers, integrating savings, investment, financing, and specialised advisory solutions through a multichannel and personalised service model. Corporate & SME Banking - focused on financing and financial services for large corporations, the public sector, medium-sized enterprises, and SMEs, including support in growth processes, internationalisation, and financial management. Consumer lending - delivered through credit cards, personal loans, and payment solutions, contributing to revenue diversification, strengthening relationships with individual customers, and developing payment capabilities and new business lines within the Group's commercial model. International Activity - with a consolidated banking presence in Portugal and strategic development of consumer and mortgage businesses in Ireland, progressively evolving into a broader financial franchise in products and services. Luxembourg - complements the Group's international presence through specialised financial activities, primarily related to asset and wealth management. Geographic presence and diversification Spain remains the Group's main market, concentrating the majority of commercial and customer relationship activities. However, the growth strategy has driven selective expansion into other European countries, especially Portugal and Ireland, which allows the Group to: reduce geographic concentration of risk, broaden sources of revenue generation, leverage differentiated growth dynamics within the European Union. Customers, channels, and value chain The Group provides financial services to a diversified customer base, including: individuals and households, companies and the public sector, customers with specialised wealth and investment needs. Customer relationships are managed through a multichannel model that integrates a specialised commercial network, remote channels, and digital platforms, supported by advanced technological capabilities that enhance user experience, service personalisation, and operational efficiency. The banking value chain also incorporates relationships with technology providers, financial markets, specialised partners, and other agents necessary for the comprehensive provision of financial services, within a framework of prudent risk management, regulatory compliance, and oversight. Performance and key highlights of 2025 The 2025 financial year was marked by strong financial and commercial performance, reflected in: a record net profit of 1,090 million euros (+14.4%), growth in customer business volumes and off-balance-sheet resources, maintenance of high levels of profitability, efficiency, and risk quality within the European banking sector. Bankinter's gross operating income reached 3,047 million euros in 2025, representing a 5% increase compared with 2024, when it stood at 2,902 million euros. The breakdown of gross operating income at the end of 2025 by the Group's significant business segments is presented below: Breakdown of gross operating income by segment (in thousands of euros) Alongside these results, three particularly significant strategic milestones stand out: Creation of the Consumer Banking, Payments and New Businesses Division In November 2025, Bankinter decided to integrate its consumer finance subsidiary (Bankinter Consumer Finance) into the bank and to create a Consumer Banking, Payments and New Businesses Division reporting directly to the chief executive officer. This new corporate structure aims to drive profitable growth in the consumer and payments business, accelerate the development of new value propositions, and intensify innovation in digital payments and emerging financial solutions. The integration strengthens unified management of the consumer finance business, improves operational synergies, and advances the construction of a comprehensive payments and new businesses platform, enhancing the Group's competitive position against traditional banks, neobanks, and fintech players in the digital financial ecosystem. Integration of EVO Banco: The incorporation of EVO's customers into the Group's digital organisation allowed the consolidation of a fully digital and scalable banking platform, strengthening customer acquisition through digital channels, operational efficiency, and the deployment of artificial intelligence 2025 2024 across commercial, risk, and customer service processes. Customer segments 2,730,600 2,801,717 Commercial Banking and Private Banking 1,333,718 1,329,794 During 2025, Ireland was confirmed as one of the main vectors of international Corporate & SME Banking 1,116,685 1,197,025 growth, operating under its own brand and banking licence, with dynamism in the mortgage business and progressive expansion of the product offering. The Consumer loans 280,198 274,898 development of this market, together with Portugal, increases the international contribution to the Group's revenues and strengthens its structural BK Portugal 366,708 346,214 diversification within the European Union. BK Ireland 117,598 103,138 Capital Markets 391,000 343,800 Corporate Centre Adjustment -559,037 -693,391 Total 3,046,869 2,901,477 Consolidation of the business in Ireland ‌The Group's Commitment to Sustainability (Sustainability Policy and Plan) Over the past decade, Bankinter Group has demonstrated a strong commitment to sustainability, integrating environmental, social and governance (ESG) criteria into its corporate strategy. The lines of action of this strategy are structured under sustainability plans, such as 'Noughts and Crosses' Plan (2012-2015 / 2016-2020), 3D Plan (2021-2023) and the ADN Plan (2024-2026). These plans seek to promote sustainable and inclusive development, aligning with the corporate values of agility, enthusiasm, integrity and originality. Thanks to these initiatives, Bankinter Group not only contributes to protecting the environment, but also fosters a positive impact on the society and economy of the countries where it operates. The bank has been publishing sustainability reports periodically for more than a decade (called non-financial information statements since the entry into force of Law 11/2018 on non-financial information and diversity). In this way, Bankinter Group guarantees transparency and monitoring of its progress in this area. Sustainability policy In May 2025, the board of directors approved a new update to the Group's Sustainability Policy, proposed by the sustainability and appointments committee as the body responsible for advising and making recommendations to the board on matters covered by this policy, as well as for ensuring that non-financial and diversity information is made public. The Sustainability Policy defines the framework within which Bankinter Group integrates the Bank's values - Agility, Enthusiasm, Integrity and Originality - along with the principles of responsible management into its activities to create economic, social and environmental value. This Policy is the main reference for managing the Bank's environmental, social and governance (ESG) aspects and covers the management of all IROs identified as material. It takes a comprehensive approach to ensuring the identification and management of the most relevant IROs, aligning with the requirements of the CSRD and the sub-topics outlined in this directive. Each of the principles established in the Sustainability Policy addresses, in a crosscutting manner, the different sub-topics defined in the regulatory framework, thus guaranteeing that the material IROs linked to areas such as climate change, people management, customer relations and corporate governance are reflected in the Bank's strategic guidelines. In the 2025 update, some of the principles have been redefined and structured within each of the three dimensions of sustainability (environmental, social, and governance), defining the lines of action in each of them, as well as the instruments to implement them (strategic plans, associated objectives, communication channels, and training and skills development). The Policy applies to all entities that make up Bankinter Group and reflects the commitment to align with international protocols and standards such as the United Nations 2030 Agenda Sustainable Development Goals and the Paris Agreements, among others. Bankinter is also a signatory to alliances and standards such as the United Nations Global Compact Guiding Principles, the Equator Principles, the Principles for Responsible Banking and the United Nations Environment Programme Finance Initiative. These frameworks reinforce Bankinter Group's commitment to sustainability and its integration into the corporate strategy. Bankinter Group also considers the opinions and expectations of its stakeholders as a core element in its development and implementation. To this end, the Bank carries out periodic materiality analyses, through which it identifies and prioritises the most relevant sustainability issues, integrating the perspectives of its main stakeholders. The principles of this policy are published on Bankinter Group's corporate website and are available to all stakeholders. 2024-26 ADN Sustainability Plan Sustainability plans are the instrument that the Bank implements to deploy its Sustainability Policy. For the structuring of this Plan 2024-26, the following references, among others, were considered: The Spanish Companies Act and Law 11/2018, of 28 December, on nonfinancial information and diversity. Directive (EU) 2022/2464 of the European Parliament and of the Council as regards corporate sustainability reporting (the Corporate Sustainability Reporting Directive or CSRD). Delegated Regulation (EU) 2023/2772 supplementing Directive 2013/34/ EU of the European Parliament and of the Council with regard to sustainability reporting standards (ESRS). The recommendations included in the Code of Good Governance of Listed Companies approved by the CNMV. The commitments that Bankinter Group has signed within the framework of various international initiatives, including, among others, the Guiding Principles of the United Nations Global Compact, the Equator Principles, the Principles for Responsible Banking and the initiative for the financial sector of the United Nations Environment Programme and Net-Zero Banking Alliance (NZBA). Analysis of the results of assessments by leading ESG analysts and rating agencies. International standards and frameworks relating to Sustainability management (GRI, IIRC, ISO 26000, SGE 21, etc.). Analysis of the results of satisfaction surveys completed by stakeholder groups such as customers and employees. The goals associated with the Sustainable Development Goals (SDG). Consideration of best practices from global industry leaders. Materiality analysis carried out in 2023. The ADN Sustainability Plan 2024-26 is made up of 3 pillars: "A" is for responsible action . It focuses on the Bank's ethical management and its commitment to responsible and transparent business practices. Its strategic lines are corporate governance, ethics and transparency, human rights and supply chain. "D" is for differentiation . The Bank positions itself as an organisation with distinctive core values, thanks to its provision of innovative solutions with the best available technologies, such as artificial intelligence, recognised quality service, and advanced people management. The strategic lines linked to differentiation are: customer relations, people management, sustainable innovation and relations with the local community. "N" is for sustainable business ("negocio sostenible" in Spanish) . It covers aspects related to Bankinter Group's business from a sustainable perspective, incorporating new business opportunities that arise for the Bank, and also addresses ESG risks. The strategic lines linked to this pillar are sustainable finance, climate change, natural capital and cybersecurity. The achievement of business objectives must be compatible not only with regulatory compliance, but also with the development of best practices and national and international standards required for its activity. The Strategic Plan also serves to comply with regulatory requirements in terms of sustainability and following recommendations from international advisors, such as sustainability rating agencies and corporate responsibility observatories. Throughout the report and specifically in each section on specific ESRS, the key sustainability objectives relating to each material IRO are detailed. However, those related to new ESG-related business opportunities are noteworthy, as they are closely linked to the Bank's inclusive strategy with its customers, to help them in the transition to a more sustainable and low-carbon economy.

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