2025
Sustainability Report
1 Introduction
2 Governance 3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 2
Content
Introduction 3
About EFG 4
EFG at a glance 5
Chair and CEO message 6
EFG value creation model 8
About this Report 9
Materiality assessment 10
Governance and responsible business practices 11
Governance 12
Responsible business conduct 15
Regulation, compliance and taxes 19
Risk management and risk governance 22
2026 marks the tenth anniversary of EFG's partnership with Team Malizia and its skipper Boris Herrmann. As part of their mission "A Race We Must Win" they compete in some of the world's toughest sailing races and, at the same time, collect ocean climate data to support scientific research as well as raising public awareness about climate change and ocean conservation. Alongside its "Malizia - Seaexplorer" racing yacht, Team Malizia launched a dedicated research vessel "Malizia Explorer" in 2025 that will be used for expeditions to the Arctic and Antarctic. As an extension of its partnership with Team Malizia, EFG also supports The Malizia Mangrove Park in the Philippines.
Business strategy and approach to sustainability 26
Business strategy and company performance 27
Sustainability strategy 30
Client centricity 35
Quality of investment and advisory, and marketing and labelling 39
Responsible investing 41
Digitalisation and innovation 46
Data protection, privacy and cyber security 48
Environment 51
Climate change 52
Climate governance 52
Climate transition approach 53
Climate-related impacts 55
Climate-related risk management 60
Climate metrics 64
Scope 1, 2 and 3 greenhouse gas emissions 64
Other environmental metrics 68
Other nature-related aspects 68
Society and role as an employer 69
Employer of choice 70
Working conditions 76
Diversity, inclusion and equal opportunity 79
Our social commitments 84
GRI content index 88
1 Introduction
1 Introduction
2 Governance 3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 3
© Marin Le Roux / polaRYSE / Team Malizia
1
Introduction About EFG 4
EFG at a glance 5
Chair and CEO message 6
EFG value creation model 8
About this Report 9
Materiality assessment 10
1 Introduction
2 Governance 3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 4
GRI 2-1 |
1 Introduction
About EFG
EFG International AG is a global private banking group offering private banking and asset management services, headquartered in Zurich.
Hereinafter, EFG International and its consolidated subsidiaries are collectively referred to as "EFG Group", "EFG", "we" or "our". EFG International's registered shares (EFGN) are listed on
SIX Swiss Exchange.
EFG has a presence in major financial centres and growth markets.
It has strong roots in Switzerland, with Zurich, Geneva and Lugano serving as hubs for clients as well as for management and operations.
EFG serves clients in over 40 locations worldwide, with a network spanning Europe, Asia Pacific, the Americas and the Middle East.
An entrepreneurial spirit shapes EFG, enabling us to provide comprehensive advice, develop hands-on solutions and build long-term client relationships.
For further information, please refer to the Annual Report 2025 of EFG International.
Entrepreneurial thinking. Private banking.
Welcome to EFG
Download the
Welcome brochure here.
Welcome
The margin notes in this Report contain references to the applicable regulatory requirements and GRI Standards.
1 Introduction
1 Introduction
EFG at a glance
GRI 201-1
2 Governance 3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 5
Net new assets
in CHF billion
Purpose
"Our north star"
Empowering entrepreneurial minds to create value - today and for the future.
Vision
"What we aspire to be"
The private bank of choice for generations of clients, delivering truly personalised service and
11.3
4.2
6.2
8.8
10.1
2021
2022 2023
2024
2025
impartial advice.
IFRS net profit
in CHF million
2028 ambition: Consistent performance and the power of compounding
303.2
321.6
325.2
Consistent value creation
Capture new opportunities for growth
Build on our strengths
Clients
Client-centric CRO1 model
Branding and client experience
Value creation for all stakeholders
Content
Client solutions and advice
Commercial excellence
M&A
NNA growth
Simplicity & Technology
EÆciency and operating leverage
EPS growth
Tech-enabled services and processes
Attractive return on capital
Core foundations
EFG's people
Compliance and risk management
Operational and financial resilience
206 | 202.4 | |||||||
2021 | 2022 | 2023 | 2024 | 2025 |
1 Client Relationship OÆcer (CRO)
1 Introduction
2 Governance 3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 6
Alexander Classen, Chair of the Board (left) Giorgio Pradelli, Chief Executive Officer
As we embark on our next strategic cycle, our vision is to be the private bank of choice for generations of clients.
Chair and CEO message
1 Introduction
GRI 2-22
Dear shareholders, clients, colleagues and other stakeholders,
In 2025, our industry was once again faced with a volatile operating environment, shaped by geopolitical tensions and considerable market uncertainty. Against this backdrop, we continued to focus on the disciplined execution of our strategy of generating sustainable and profitable growth while prudently managing risks and striving to create long-term value for our clients and shareholders.
As we embark on our next strategic cycle, our vision is to be the private bank of choice for generations of clients. Building on our strengths, we will continue to forge lasting relationships with entrepreneurs and wealthy families who are increasingly operating as global citizens and are looking for a private bank that provides impartial advice and truly personalised service.
To ensure our long-term success, we need to seize the opportunities created by some of the underlying trends we are witnessing around the globe. In particular, the forthcoming Great Wealth Transfer is expected to see over USD 22 trillion of assets transferred to Generation X and Millennials by 2034. As partners, we need to understand the Next Generation's needs, priorities and values, including its stance towards purpose-driven investment strategies and its interest in sustainable finance solutions.
We have taken steps to address this shift by establishing our Next-Gen Client Approach - a holistic strategy that is designed to attract and better serve this key group of clients and prospects.
1 Introduction
2 Governance 3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 7
1 Introduction
With our newly launched EFG Next-gen CRO Programme, we aim to develop younger, digitally ftuent talent to complement our more experienced advisors.
To ensure that we can continue to attract and retain top talent who fit well with EFG's culture and values, we remain focused on providing attractive and inclusive employment conditions -including an extensive range of training and development opportunities through the EFG Academy. Reftecting our efforts to provide an exceptional workplace, EFG Asia was named "Employer of the Year" at the 2025 Asian Private Banker Awards for Distinction, while in Switzerland, we earned "Great Place to Work" certification.
Alongside our commitment to our clients and our people, we recognise that EFG has a responsibility to support the transition to a low-carbon economy by aligning our business and operations with the goals of the Paris Agreement. In 2025, we made further progress in the execution of our transition approach. For example, we began sourcing renewable electricity in Switzerland and Liechtenstein and purchased energy attribute certificates for the US, the UK and Hong Kong. We also took initial steps to reduce
our carbon footprint from business travel. In this Sustainability Report, we provide insights into these and other measures to support environmental protection and climate action and help ensure our business remains resilient.
As an integral part of society, we want to serve the interests of the communities in which we live and work. Through 2025, we continued to support humanitarian or charitable organisations such as the International Committee of the Red Cross or Right to Play to help address social challenges and generate positive impact. We also pursued our collaboration with selected partners
in the fields of sport, art and culture who share our values and commitment to excellence - from Team Malizia to the EFG Young Athletes Foundation and from the Peggy Guggenheim Collection to the King's Trust.
Overall, our strategy as a globally active private bank is aimed at creating long-term value for all our stakeholders. This is also reftected in our Purpose "Empowering entrepreneurial minds to create value - today and for the future".
The wide-ranging activities and commitments that we present in this publication reftect our belief that a sustainable approach to business is fundamentally about choosing the right path to balance economic, environmental and social interests. We aim to provide transparency about EFG's progress and performance against our sustainability strategy in this Report, which is prepared in accordance with Art. 964a-c of the Swiss Code of Obligations, the Swiss Ordinance on Climate Disclosures, TCFD Recommendations as well as GRI Standards. We welcome your feedback on any of the topics discussed here.
Alexander Classen Giorgio Pradelli
Chair of the Board Chief Executive Officer
1 Introduction
2 Governance 3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 8
1 Introduction
EFG value creation model GRI 2-6
This model is based on the IFRS Foundation's blueprint and shows how we generate sustained value through our business activities and interaction with our stakeholders, covering both financial and non-financial aspects.
Input 1
Intellectual capital
Client-centric model
Open product architecture
IT platforms and partnerships
Policies, directives and controls
EFG brand value and reputation
Drivers of value
Our Purpose
Empowering entrepreneurial minds to create value -today and for the future
Human capital
Employees' skills and expertise (3,225 FTEs 2)
Global and diverse teams (80 nationalities)
Learning and development opportunities
S
Financial capital
Financial capital from investors
(CHF 2 billion of shareholders' equity)
Deposits and savings
(CHF 31.8 billion of client deposits)
Client Assets under Management (CHF 185.0 billion of Assets under Management)
Social and natural capital
Stable political environment in our home market of Switzerland
ESG-related products and services
Engagement and participation in industry networks
Climate action, environmental resources and carbon footprint
Output 1
Clients and prospects
Long-term client relationships
Impartial advice
Strong compliance culture and prudent risk management
Content innovation and digital acceleration
Employees
E
T
I
Employer of choice (hired 79 new Client Relationship Officers 3 in 2025, voluntary staff turnover rate of 5.2%)
&
C
O
N
T
E
R
E
X
P
E
R
Diverse, equitable and inclusive environment (40% women in the workforce)
N
T
O
U
Empowering and fostering talents (average of 19 hours of training conducted per employee, graduate
training programme)
U
O
Shareholders and investors
A
T
R
M
R
Total dividend paid to shareholders CHF 180 million for the financial year 2024
N
E
L
O
F
T
CHF 1,745 million increase in total market capitalisation primarily through share price appreciation in 2025
&
T
A
L
CHF 19.4 million of interest paid to AT1 holders in 2025
L
U
C
P
R
U
CHF 19.4 billion of loans outstanding
E
R
U
T
O
Society and the environment
Tax contributions and goods and services procured from local small- and medium-sized enterprises (SMEs)
CHF 3.01 billion of AuM in investment products/ services with a dedicated ESG focus 4
Employee volunteering and donations
Strategic climate-related measures
Targeted engagement with policy makers
Vision 2030
The private bank of choice for generations of clients, delivering truly personalised service and impartial advice.
Our corporate values
Accountable
Hands-on
Passionate
Solution-driven
Partnership-oriented
2028 ambition
Consistent performance and the power of compounding
Our approach to sustainability
2Sustaina0bility Repo2rt
5
1 All figures are as of end-2025 unless otherwise stated.
2 Total full-time equivalents (FTEs) shown here are based on the disclosure in the Annual Report 2025 of EFG International. For the Sustainability Report 2025, a different scope applies (see page 9).
3 Includes 28 Client Relationship Officer (CRO) hires approved and entering in 2026 and 67 CROs who were onboarded as part of the acquisition of Cité Gestion and of ISG.
4 This compares with a total of CHF 27.8 billion of Assets under Management (AuM) invested in our New Capital business line of products as well as our discretionary managed assets (excludes Cité Gestion).
1 Introduction
2 Governance 3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 9
GRI 2-2 |
GRI 2-3 |
GRI 2-5 |
1 Introduction
About this Report
Entities included in EFG's sustainability reporting
The Sustainability Report 2025 (the "Report") comprises the non-financial disclosures of EFG International and its consolidated subsidiaries in accordance with Art. 964a-c of the Swiss Code of Obligations (CO), the Swiss Ordinance on Climate Disclosures and the disclosure recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). Further, the content of this Report has been prepared in accordance with the Global Reporting Initiative (GRI) Standards.
Unless otherwise stated, the information in this Report pertains to all legal entities of EFG International. Further, references to governing bodies relate to those of EFG International unless specified otherwise. References to the Annual Report 2025 refer to the Annual Report 2025 of EFG International available at: ar.efginternational.com. The scope of reporting on the sustainability indicators is the same as for the consolidated financial statements in the Annual Report 2025 of EFG International, with the exception of Shaw and Partners Limited and its consolidated legal entities, as well as Cité Gestion and its consolidated legal entities, for which data is not included unless stated otherwise.
Reporting period, frequency and contact point
The reporting period for this Sustainability Report is 01 January 2025 to 31 December 2025, which is aligned with the financial reporting period of EFG International. The Sustainability Report is published annually.
For questions about the Report and/or information disclosed therein, please contact Corporate Communications at: mediarelations@efginternational.com or phone +41 44 226 12 72.
External assurance
The Board of Directors engaged its financial auditor, PricewaterhouseCoopers AG (PwC), to perform independent limited assurance on selected indicators in this Report.
PwC conducted the procedures in accordance with International Standards on Assurance Engagements (ISAE) 3000 (Revised) "Assurance Engagements Other than Audits or Reviews of Historical Financial
Information" and ISAE 3410 "Assurance Engagements on Greenhouse Gas Statements".
The assurance report, which lists the indicators selected, can be found on pages 92 - 93.
The Sustainability Report 2025, including performance indicators, was approved by the Board of Directors of EFG International for publication on 16 February 2026.
Limitations and dependencies
This Report provides information about EFG's sustainability strategy, objectives and performance. Our operations across various countries may be exposed to risks that could also adversely affect our sustainability-related activities and outcomes. Such risks are described in the Annual Report 2025 of EFG International.
The execution of our sustainability strategy depends on factors both within and beyond our control or inftuence, such as government policies; data quality, availability and standardisation; and the availability and evolution of market standards and regulatory requirements.
Disclosures in this Report are inherently limited by: Emerging science; evolving regulatory requirements and market practices; the reliance on estimates and management judgment in the absence of established methodologies; evolving regulatory disclosure requirements and expectations; and the reliance on third-party information and other data that may be immature in some instances.
In this context, we continuously strive to expand and enhance our ESG disclosures and recognise that future comparability in the market will enhance the readers' understanding of our efforts and progress. We continuously review and enhance our data, frameworks and methodologies to align them with evolving regulatory and market standards.
This Report summarises EFG's progress in 2025 in the implementation of its sustainability strategy, acknowledging the impact of the factors
| Art. 964c Para. 1 CO
1 Introduction
2 Governance 3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 10
GRI 3-1 |
mentioned above. This information reftects our current approach to sustainability and reporting methods and may be subject to change without notice as we enhance our data and methodologies. Disclosures may be updated or restated in the future as improvements are made.
1 Introduction
Materiality assessment
Process to determine material topics
High importance
EFG conducts a comprehensive materiality assessment every two years. In 2024, we identified 13 sustainability matters (material topics) for EFG that closely mirrored the material topics in our Sustainability Report 2023.
More information about this process and the stakeholders involved can be found in our Sustainability Report 2024.
Impact materiality
In 2025, the relevance of the 13 material topics reported in the Sustainability Report 2024 was reaffirmed in consultation with the internal stakeholders involved in the prior year's assessment. The inclusion of those 13 material topics in the Sustainability Report 2025 was confirmed by the Executive Committee, the Audit Committee and the Board of Directors. No new topics were identified.
List of material topics
The reporting on material topics (see chapters 2 to 5 of this Report) is performed in adherence to GRI Disclosure 3-3, which requires EFG to explain how it manages each of its material topics and, where possible, to follow the GRI topic standards, which contain guidance on disclosures about specific actions or methods to manage a topic.
Moderate importance
Financial materiality
| GRI 3-2
Quality of investment
and advisory, and marketing and labelling
Data protection, privacy
and cyber security Business strategy and Working conditions company performance
Responsible investing
Employer of choice
Responsible business conduct
Client centricity
Climate change
Risk management and risk governance
Regulation, compliance and taxes
Diversity, inclusion and equal opportunity
Digitalisation and innovation
Moderate importance
High importance
| Art. 946b Para. 1 CO
1 Introduction 2 Governance
3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 11
2 Governance
© Marin Le Roux / polaRYSE / Team Malizia
2 Governance and responsible business practices
Governance 12
Responsible business conduct 15
Regulation, compliance
and taxes 19
Risk management
and risk governance 22
1 Introduction 2 Governance
3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 12
GRI 2-9 |
Governance
Governance structure and composition
The Board of Directors has ultimate responsibility for the supervision of the management of EFG International. The Board of Directors sets EFG's strategic direction and monitors its implementation. As the highest governing body, it has oversight of EFG's business activities and their impacts on the economy, society and the environment, as well as external risks and opportunities for EFG. The Board of Directors has five delegated committees that support it in fulfilling its duties. Three of
2 Governance
these committees have responsibilities pertaining to ESG matters: The Audit Committee has oversight of the control framework underpinning EFG Group's ESG disclosures and metrics as well as oversight of the annual Sustainability Report. The Risk Committee supervises the embedding of ESG factors into the risk management process, and the Remuneration & Nomination Committee is responsible for ESG-related compensation topics and for ensuring they are duly reftected in the related policies.
Further information can be found in the Annual Report 2025 from page 33.
At the end of 2025, the Board of Directors comprised twelve members, all of whom are non-executive directors. The major shareholders
Credit Committee
Remuneration and Nomination Committee
Acquisition Committee
Risk Committee
Audit Committee
of EFG International have representatives who serve on the Board as non-independent members. According to the Organisational and Management Regulations of EFG International, one-third of the members of the Board of Directors shall be independent. At the end of 2025, seven out of twelve members were independent. The biographies of the members of the Board of Directors, as well as a list of their external mandates, can be found in the Annual Report 2025 on
pages 47 - 54.
BOARD OF DIREC TORS
Asset and
Liability Global Product Executive Credit Management Committee Committee Committee
Operational, Regulatory and Compliance Committee
Global Business Committee'
Information Security Committee
Financial Risk Committee
Executive Committee
Country and | Internal | Fiduciary and | Data | Data | ||||||||
Investment | ESG Product | Counterparty | Regulation | Suitability | Protection | Governance | ||||||
(sub) Committee | (sub) Committee | Risk (sub) | (sub) | Oversight (sub) | (sub) | (sub) | ||||||
Committee | Committee | Committee | Committee | Committee |
' Advisory role to the Executive Committee
In the case of the Audit Committee and the Risk Committee, the majority of members (including the Chair) are independent, in line with applicable banking regulations and the Organisational and Management Regulations.
Nomination and selection of Board members
The Board of Directors regularly reviews its size and composition to ensure that collectively, it has the necessary skills and experience to address current and emerging issues relevant to EFG Group's strategic direction and business activities, as well as its operating environment and the regulatory landscape. In doing so, it considers regulations and best practice, as well as the specific needs and best interests of EFG, its shareholders and other stakeholders. During these reviews, it also determines whether additional skills or training are needed to complement its existing competencies. The diversity of the Board of Directors is assessed across gender, age, background and professional
Client Acceptance Committee
| GRI 2-10
1 Introduction 2 Governance
3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 13
GRI 2-11 |
GRI 2-12 |
experience, among other factors. Independence is also an important criterion to ensure compliance with applicable laws and regulations and good corporate governance.
2 Governance
Further information can be found in the Annual Report 2025 from page 41.
Chair of the Board
The Chair of the Board of Directors is an independent member of the Board and has been in office since November 2022.
Role of the Board in overseeing the management of impacts
We are committed to continuously driving the successful execution of EFG's sustainability strategy across our business functions and regions. Our sustainability strategy was approved by the Board of Directors in 2022. The Executive Committee, the Audit Committee and the Board of Directors confirmed the material topics for the financial year 2025.
The Board of Directors is regularly informed by the Executive Committee about key topics such as EFG's financial performance, its interactions with clients and the progress of strategic initiatives, including in sustainability, compliance and risk management topics, as well as employee matters.
In 2025, as part of the annual review process, the Executive Committee, the Risk Committee and the Board of Directors approved the annual updates to EFG Group's risk management and risk appetite frameworks, including ESG-related elements.
Delegation of responsibility for managing impacts
The implementation of our sustainability strategy and the management and monitoring of ESG-related risks are overseen by the governing bodies of EFG International, in line with their statutory competences and responsibilities. Regular progress updates are provided to the Board of Directors and its delegated committees by senior management, as appropriate.
Sustainability governance is supported by the EFG Sustainability Advisory Board (ESAB), which is co-chaired by the Chair of the Board of Directors and the CEO of EFG International. The ESAB comprises the members of the Executive Committee, as well as one further member of the Board of Directors and an external specialist. The ESAB provides strategic advice to EFG's governing bodies on sustainability initiatives, targets, frameworks and strategies. It meets at least twice a year.
The Sustainability Steering Committee (SSTC), chaired by the CEO of EFG International, supports EFG's management in strategic sustainability initiatives and climate measures, in monitoring progress against ESG targets and KPIs, and in non-financial reporting. The SSTC includes the members of the Executive Committee, the Head of Corporate Sustainability as well as senior executives and experts from relevant business areas. The SSTC meets at least every two months and escalates sustainability matters to the competent function heads or governing bodies.
EFG's offering of ESG-related products and services falls within the remit of Investment Solutions and of the Global Product Committee, a delegated committee of the Executive Committee, and specifically its dedicated ESG Product Committee (see page 42).
We continuously review our sustainability governance structure and processes to ensure that we are effectively driving forward our sustainability strategy throughout EFG.
For further information, see the "Climate-related risk management" section on pages 60 - 63.
| GRI 2-13
1 Introduction 2 Governance
3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 14
2 Governance
GRI 2-14 |
GRI 2-15 |
Role of the Board in sustainability reporting
In line with the requirements of the Swiss Code of Obligations
(Art. 964c), the Board of Directors approved the Sustainability Report 2025, including the material topics, and acknowledged the outcome
of the review with regard to Due Diligence and Transparency in relation to Minerals and Metals from Conftict-Affected Areas and Child Labour (DDTrO).
The Sustainability Report is published online and will remain available to the public for at least ten years.
Conflicts of interest
EFG employees have a personal responsibility to promote a rigorous compliance culture by demonstrating the highest level of professional integrity at all times (see page 16), as also stated in the Code of Ethics defined by the Board of Directors. This includes preventing confticts of interest by prohibiting unacceptable forms of private interests and being alert to circumstances in which such confticts may arise.
Confticts of interest are governed by EFG Group's Business Code of Conduct, which was approved by the Board of Directors, and by the General Directive on Confticts of Interest, both of which are regularly updated. The General Directive on Confticts of Interest states that each division or unit within EFG is required to have clear and transparent rules in place to promptly document and escalate any potential or actual confticts of interest, depending on the significance of the matter and applicable internal or external regulations.
Actual or potential confticts of interest are escalated to the local executive committee or local board of directors, as applicable. All actual or potential confticts of interest must be disclosed and are subject to appropriate mitigation measures. All employees are required to complete conftict of interest training on a biennial basis.
Rules governing the escalation and handling of potential confticts of interest in relation to the members of the Board of Directors are set out in the Organisational and Management Regulations (section 7.2) available on EFG International's website.
No member of the Board of Directors held a management position within EFG International in the last three years, and no Board member (either in an individual capacity or as the representative of a third party) has a significant business connection with EFG International or any of its subsidiaries.
Communication of critical concerns to the Board
In accordance with internal policy, and in light of applicable regulatory requirements regarding the corporate governance of banks, EFG
has appropriate governance measures in place to ensure that critical matters are escalated to the responsible governing bodies, including the Board of Directors and/or its delegated committees.
Collective knowledge of the Board
Selected members of the Board of Directors, most notably those representing the Board on the ESAB (see page 13), have specific ESG knowledge.
The Board of Directors completes an annual training programme to strengthen its knowledge of key topics and help it stay abreast of emerging trends, evolving regulations and best practice. In 2025, the Board of Directors received training on the following strategic and governance topics: Internal controls, geopolitical trends, cloud strategy and anti-money laundering (annual update). All training was provided by external experts. In addition, the members of the Risk Committee attended thematic sessions on cyber security and operational resilience provided by internal experts.
Evaluation of the performance of the Board
The Board of Directors and its delegated committees perform annual self-evaluations with the aim of enhancing their governance processes and improving their overall performance. These cover aspects of the Board of Directors' areas of focus, its effectiveness and composition (e.g. skills and diversity) as well as its culture and interaction with management. The outcomes of the evaluation are translated into an action plan and its implementation is monitored by the Board of Directors.
| GRI 2-16
| GRI 2-17
| GRI 2-18
1 Introduction 2 Governance
3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 15
2 Governance
GRI 2-19 |
GRI 2-20 |
Remuneration policies of the Board and the Executive Committee EFG's approach to compensation is governed by the Swiss Code of Obligations, the Articles of Association and the Organisational and Management Regulations of EFG International. EFG deploys a total remuneration approach that includes fixed and variable remuneration
components, as well as statutory and non-statutory benefits. For further information, see the Compensation Report in the Annual Report 2025.
Process to determine remuneration
The Board of Directors is responsible for defining the remuneration principles to support the delivery of the corporate strategy and its long-term objectives. In fulfilling its governance responsibilities, the Board of Directors is assisted by the Remuneration and Nomination Committee, whose members are elected by shareholders. The compensation of the Board of Directors and the Executive Committee is subject to shareholders' approval at the Annual General Meeting. For further information, see the Compensation Report in the Annual Report 2025.
Responsible business conduct
Importance of material topic and impacts
EFG considers responsible and compliant business conduct to be essential to achieve sustainable and profitable growth and to create value for all our stakeholders. We expect our employees to consistently demonstrate the highest levels of professionalism, integrity and personal accountability, as set out in our Code of Conduct and Code of Ethics. In this way, we can safeguard the interests of clients, protect EFG from financial losses or damage, and help to preserve financial market integrity.
From an economic perspective, we believe that responsible business conduct can increase investor confidence, support market stability and foster economic growth and prosperity. Similarly, in terms of social impact, we believe that responsible business conduct helps to safeguard our reputation, thus maintaining the trust of clients, employees and other stakeholders, and to protect human rights.
How we manage the topic "Responsible business conduct": Strategy, policies and governance
Combatting market abuse
EFG is committed to preventing, detecting and reporting market-abusive practices that may arise from client or employee trading activities. Our Group-wide policy and control framework enable us to detect, prevent and report market abuse, such as insider dealing and the unlawful disclosure of inside information or market manipulation. Our General Directive on Market Abuse defines the roles and responsibilities of all employees in this respect.
Further, we maintain oversight and control of employee personal account dealing to ensure adherence to the rules set out in our Business Code of Conduct. We provide role-based training for employees to foster a clear understanding of market abuse risk and of their role in combatting it, and we invest in our system infrastructure to support them in their duties.
| GRI 3-3 a & b
| Art. 964b Para. 2 No. 1 CO
| GRI 3-3 c
| Art. 964b Para. 2 No. 2 CO
1 Introduction 2 Governance
3 Business strategy 4 Environment 5 Society
EFG International AG | Sustainability Report 2025 16
2 Governance
GRI 2-23 |
Policy commitments
To achieve long-term success, we must uphold the highest standards of ethical conduct in every aspect of our work. We expect all employees globally to act with professionalism, diligence and integrity at all times to safeguard EFG's reputation.
Our Business Code of Conduct is incorporated into the contractual agreements of all employees and members of the Board of Directors. It defines the professional standards they must uphold to ensure compliance with applicable laws, regulations and internal rules. It prohibits the misuse of inside information, fraudulent trading, market abuse and all other forms of inappropriate conduct. The principles outlined in the Business Code of Conduct are defined in more detail in general directives, polices and guidelines. An assessment of employee adherence to the Business Code of Conduct is performed annually by Compliance and submitted to the Executive Committee and Risk Committee. Any violation of the Business Code of Conduct may result in
disciplinary measures and, in severe cases of misconduct, could lead to the termination of employment.
In addition, all employees are required to adhere to our Code of Ethics, which is overseen by the Board of Directors and the Executive Committee. The Code of Ethics establishes a moral and ethical framework for employee behaviour that is closely aligned with EFG's corporate values. It covers areas such as combating financial crime and preventing confticts of interest and is further implemented through directives, policies and procedures. Employees' professional conduct is also evaluated as part of our annual employee appraisal process to ensure that it is aligned with our corporate values and our Code of Ethics.
Embedding policy commitments
EFG's Purpose articulates our strengths as a globally active private banking group and what EFG stands for. It builds on our existing Vision and Mission and our entrepreneurial DNA, as well as our five core values that foster a common understanding of EFG's culture and brand (see chart). They form an integral part of our human resources
| GRI 2-24
processes, including performance appraisals and compensation
Our strategic positioning
decisions that consider employee conduct and values. We also expect employees to take ownership by assuming responsibility for their actions and decisions and living up to EFG's standards.
Vision
"what we aspire to"
The private bank of choice for generations of clients, delivering truly personalised service and impartial advice.
Values
"How we do it"
Accountable, Hands-on, Passionate, Solution-driven, Partnership-oriented
Mission
"What we do"
As a leading Swiss private bank, we partner with private and institutional clients around the globe to support them in realising their ambitions. We create sustainable value through our global network of talent, led by trusted Client Relationship Officers and augmented by technology.
Purpose
"Our north star"
Empowering entrepreneurial minds
to create value - today and for the future.
EFG embeds its policy commitments through several measures. These include communicating the importance and purpose of our Code of Ethics and Human Rights Statement to ensure that everyone at EFG understands their individual and collective responsibility to implement and adhere to them. These measures also include the commitment of EFG's senior management to upholding our Code of Ethics and Human Rights Statement, which form an integral part of our policies, processes and decision-making, demonstrating the importance of operational integration. Our onboarding process for third parties addresses human rights topics such as child labour, forced labour (modern slavery) and human trafficking. Contracts with third parties include specific requirements relating to human and labour rights; non-compliance with such requirements may result in the termination of the contract.
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Art. 964j-l CO, DDTrO |
GRI 2-25 |
Conflict minerals and metals, and child labour
EFG performs an annual review to assess whether it is subject to additional reporting requirements under the Swiss Ordinance on Due Diligence and Transparency in relation to Minerals and Metals from Conftict-Affected Areas and Child Labour (DDTrO). In 2025, the review confirmed that EFG is exempt from the due diligence and reporting requirements under the DDTrO for the reporting year.
Process to remediate negative impacts
We are committed to responsible and compliant business conduct at all times, thus safeguarding our reputation among our stakeholders, including clients, employees, investors, shareholders, suppliers and vendors, as well as regulators. We strive to ensure that any grievances from any stakeholder group are handled promptly, fairly and in
accordance with the relevant local legal and/or regulatory requirements.
For clients, we have established a complaints and litigations framework through which they or their legal representatives can notify EFG International of any grievances and seek appropriate remediation measures. More information on our client complaint management process can be found on page 38.
Our employees can communicate their views or concerns (including any grievances) via various channels. They include the whistleblowing mechanism, senior manager feedback processes and the Global Employee Survey (see page 74). EFG's Human Resources function, which is present in each of our locations, seeks to ensure that employee input is promptly addressed.
Human rights
GRI 2-23
EFG recognises its responsibility to help protect human rights within its sphere of inftuence. EFG's Human Rights Statement is based on the International Bill of Human Rights, the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises. The Statement describes EFG's commitments to our employees and clients, as well as to workers in our supply chains
and communities potentially impacted by our operations.
Measures to promote respect for human rights in EFG's relationship with employees are aligned with our Code of Ethics and corporate values. These measures include our commitment to fostering a respectful working environment, equal opportunities regarding work and promotion as well as our employees' health and safety.
We aim to ensure that EFG does not make use of or benefit from child labour or forced labour in any way. We are also committed to complying with applicable labour laws and regulations, to protecting the right to privacy and ensuring the responsible use of data, and to upholding health and safety standards for anyone at our premises.
In addition, our human rights commitments require third parties that provide goods or services to EFG to adhere to minimum standards governing aspects such as the avoidance of child labour, the free choice of employment, freedom of association, working hours, wages and benefits, health and safety, and diversity, equity and inclusion. To ensure this, EFG applies enhanced due diligence processes for contractors and suppliers and has integrated a standard clause on ethics and business conduct into their contractual agreements.
In the provision of financial services, EFG aims to offer solutions that benefit our clients by having a positive impact on the environment and society and we seek to avoid any negative impacts in this area through products, services or client relationships. Finally, our commitment to human rights and broader sustainable development extends to upholding high standards of business conduct, managing our environmental footprint and supporting organisations that promote human rights-related goals.
Additional information on EFG's commitment to respect human rights can be found in our Human Rights Statement.
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GRI 2-26 |
EFG's commitment to offering a safe and supportive working environment and to promoting employee wellbeing and development is part of our Human Rights Statement (see page 17) as well as our general directives on topics such as psychological and physical harassment as well as diversity, equity and inclusion or health, safety and wellbeing.
Mechanisms for seeking advice and raising concerns
EFG encourages employees to report any incident or irregularity they encounter at work without fear of reprisals, thus helping us to take appropriate corrective actions.
The General Directive on Whistleblowing sets out a framework and process for all EFG employees to follow if they become aware of any misconduct or wrongdoing, notably in the areas of fraud, criminal misconduct, breaches of applicable laws and/or external regulations, breaches of internal directives, money laundering, breaches of employment practices, workplace safety failures, discrimination or harassment. This General Directive may be complemented by local specifications governing the whistleblowing process for certain EFG Group entities where required under local laws and regulations.
EFG has robust procedures to ensure that critical issues or concerns are promptly escalated to the appropriate governing bodies. Any notifications of breaches are submitted through a dedicated reporting point and follow a process defined by each local entity. In Switzerland, for example, a secure IT system allows employees to report concerns
anonymously from any computer at any time, whether they are within or outside EFG's offices. The IT system includes a secured post box feature, enabling employees and the specialists reviewing the alleged breaches to communicate on an anonymous basis and to answer questions and share information on the status of the report.
Notifications can be submitted either anonymously or with full details of the whistleblower's identity, depending on their preference. The General Directive on Whistleblowing does not specify any particular language in which notifications have to be made. For each notification received, the local entity appoints an expert with the necessary experience to handle the investigation and informs the appropriate governing body of each local entity overseeing the whistleblowing process so that it can take
appropriate action. To ensure confidentiality, all information and investigative processes are managed in a manner designed to ensure the protection of both the reporting individual and any individuals suspected of breaches or violations. Regardless of the outcome of an investigation, the reporting individual is protected against sanctions and retaliation. Disciplinary measures are taken against individuals found to be responsible for breaches.
Information on the whistleblowing or grievance process for third parties, such as suppliers and clients, can be found on page 17.
Progress in 2025
We continue to review and, where necessary, amend our directives, policies and procedures at least biennially, including those mentioned in our Code of Conduct. In 2025, for example, we updated our General Directives on "Economic Sanctions and Embargoes", "Know Your Client and Anti-Money Laundering", "Tax Transparency" and "Prevention and Detection of Market Abuse" to ensure compliance with the latest regulatory developments.
Monitoring and measuring effectiveness
A consolidated report containing details of all breach notifications submitted through the whistleblowing channels of EFG Group entities, as well as subsequent mitigation actions, is provided to the Executive Committee and the Audit Committee on a semi-annual basis. In 2025, five cases were reported through these channels and were reviewed with no further action being required.
| GRI 3-3 d
| Art. 964b Para. 2 No. 3 CO
| GRI 3-3 e & f
| No. 3 and 5 CO
| Art. 964b Para. 2
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Art. 964b Para. 2 No. 1 CO |
GRI 3-3 c |
Art. 964b Para. 2 No. 2 CO |
Regulation, compliance and taxes
Importance of material topic and impacts
As a globally active private banking group, EFG strives to adhere to the applicable laws, rules and regulations in all the markets in which we operate. Given the size, structure, nature and complexity of our business and our product and service offering, we are inherently exposed to certain compliance risks. We define compliance risk as the risk of legal or regulatory sanctions, material financial loss or the reputational harm that EFG may suffer as a result of failing to comply with laws, regulations, rules, internal standards related to self-regulation, generally accepted practices and codes of conduct related to our banking activities.
Compliance risk also arises in situations where the laws or rules governing certain bank products or the activities of our clients are evolving and expectations from regulators are increasing. This risk exposes EFG to potential fines, civil money penalties, payments of damages, or other risks under civil law. Further, it could, for example, lead to reputational harm or regulatory sanctions imposed by supervisory authorities. We therefore consider effective compliance risk management as an essential foundation of our business and long-term success.
How we manage the topic "regulation, compliance and taxes": Strategy, policies and governance
Our compliance risk management framework is designed with the aim of ensuring that we meet all applicable legal and regulatory obligations and to protect us from potential financial loss, regulatory censure or reputational damage. This framework is based on two main pillars: The definition and implementation of a robust compliance culture within EFG, and the regulatory framework that applies to EFG. In line with
this framework, we adopt appropriate policies and procedures and we establish and maintain an internal control system that meets the requirements of the current and evolving regulatory landscape across all the markets in which we operate.
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Finally, effective compliance risk management is dependent on the existence of an independent Compliance function. We continuously invest in strengthening our human resources and technical infrastructure to support our global compliance efforts.
At EFG, compliance risk is split into two main risk sub-categories:
Financial crime risk: This pertains to the areas of anti-money laundering (AML), know your client (KYC) and know your transaction (KYT) and considers the global nature of financial crime and the importance of ensuring a consistently high level of awareness of the topic among all employees. It also covers risks related to anti-bribery and corruption topics, sanctions, counter-terrorist financing rules
and regulations, as well as tax transparency, and it includes the risk of failing to promptly identify and implement regulatory developments concerning financial crime risk management.
Conduct and regulatory compliance risk: This is the risk that EFG could fail to abide by the letter and spirit of all laws, regulations, regulatory expectations and standards of conduct that apply to its activities and, as a consequence, could incur regulatory censure and sanctions, suffer reputational damage or face litigation risk. Conduct and regulatory compliance risk arises from: i) Breaching our duties towards our clients; ii) failing to detect, monitor or prevent market abuse, and failing to observe appropriate market conduct requirements; iii) failing to properly manage cross-border risk and comply with rules applicable to cross-border activities; iv) failing to perform appropriate oversight of independent asset managers and business introducers; v) failing to appropriately identify and properly manage confticts of interests; and vi) failing to promptly identify
and implement relevant regulatory developments concerning conduct and regulatory compliance risk management.
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We also expect all our employees to consistently demonstrate the highest level of professionalism, integrity and personal accountability.
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They are therefore required to have an appropriate understanding of compliance risks and to be familiar with the latest regulatory
developments that apply to EFG both at a local and a global level. All employees are required to complete mandatory training courses on topics such as financial crime, sanctions, market abuse and confticts of interest, either on an annual basis or as frequently as required
under the current regulations as well as internal policies. These courses are supplemented by targeted training for employees in client-facing roles or other specific areas, as required.
Compliance with laws and regulations
We assign the utmost importance to ensuring that we adhere to all laws, rules and regulations that apply to our business. Provisions for claims and legal proceedings are governed by the accounting standards we use for the preparation of EFG's consolidated financial statements. For further information regarding claims and legal proceedings, please refer to
the Annual Report 2025, note 32 "Provisions" and note 33 "Contingent liabilities".
Combating money laundering and terrorist financing, and sanctions compliance
EFG is committed to complying with all applicable laws and regulations related to financial crime compliance (FCC) and international sanctions. To address FCC risks, we have implemented AML policies, procedures and controls, as well as dedicated tools to detect, investigate and prevent money laundering, terrorist financing and other forms of financial crime. These policies extend to KYC and KYT requirements, enhanced due diligence, client identification and risk classification, ongoing client screening, payment filtering and transaction monitoring. Relationships with clients that may carry higher financial crime risks, such as those with politically exposed persons (PEPs), are monitored more frequently. Training on FCC and sanctions must be completed annually by all relevant employees.
Our control and monitoring processes are reviewed and reinforced on an ongoing basis. If we identify any suspicious transactions or activities, we immediately notify the relevant external money laundering reporting office.
In terms of sanctions, we take all the requisite measures to keep abreast of international sanctions regimes that apply to our business. We have implemented strict policy and control measures to monitor and detect any exposure to sanctioned clients or activities and we take the necessary steps to ensure that we adhere to the applicable requirements of key sanctions regimes worldwide.
EFG recognises that maintaining an effective compliance risk and control framework is an ongoing process. We require all our branches and subsidiaries to perform a compliance risk assessment annually based on a common global methodology. This risk assessment exercise is a collaborative effort between the EFG Group Compliance function and local Compliance teams, with support from other departments if needed. The compliance risk assessment process is updated at least once a year to ensure that we understand the latest compliance risks to which EFG is exposed and that we have a recent assessment of the strength of the measures used to mitigate risk and of the relevant control mechanisms, as well as an understanding of potential gaps and the residual risk that remains.
Anti-corruption
EFG's Group Compliance has a General Directive on the Prohibition and Prevention of Bribery and Corruption, which sets out the minimum standards that must be followed across EFG to combat all forms of bribery and corruption. This General Directive complements the applicable laws and regulations in jurisdictions in which EFG operates and it has been communicated to all employees globally. It includes areas such as offering or accepting of improper gifts, entertainment, political contributions, sponsorships, events, travel and accommodation or other advantages, engaging in charitable giving or recruitment, or making payments to expedite and/or secure routine government action (facilitation payments). In addition, our local entities develop and implement their own procedures to ensure compliance with this General Directive and with local regulatory requirements.
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When EFG conducts business or when services are provided on its behalf, it is subject to local anti-bribery and anti-corruption laws and is generally subject to the Swiss Criminal Code, the U.S. Foreign Corrupt Practices Act, the United Kingdom Bribery Act 2010 and the Singapore Prevention of Corruption Act. In this regard, EFG explicitly prohibits and actively works on preventing any corrupt or improper payments and any activity that facilitates a corrupt or improper payment made by or on behalf of an EFG entity or made through client accounts for any purpose whatsoever.
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EFG prohibits bribery committed by third parties acting on its behalf. EFG performs due diligence on all such third parties, including intermediaries, to reduce the risk of bribery.
To ensure awareness of this topic, all employees, including members of the Executive Committee, are required to complete anti-bribery and corruption training on a biennial basis, and the completion of the relevant courses is monitored.
Controls to ensure employee adherence to the General Directive on the Prohibition and Prevention of Bribery and Corruption are established across the first and second lines of defence. Any suspected cases of bribery, corruption or other breaches are investigated and addressed and a report is submitted to the Executive Committee.
Anti-competitive behaviour
We recognise the importance of compliance with relevant antitrust laws and regulations.
Anti-competitive practices can include collusion between institutions, practices preventing or reducing market competition, monopolisation, price fixing or market dominance practices and other conduct that violates antitrust or competition law.
EFG is not aware of any incidents of anti-competitive behavior or antitrust and monopoly practices, and no legal action was taken against EFG or its employees in these matters in 2025.
Responsible and transparent approach to tax
EFG offers a wide range of services to clients in over 40 locations around the globe. We are committed to complying with all relevant international standards and tax laws in the respective tax jurisdictions and to ensuring taxes are paid where economic value is created.
Our approach to corporate taxation is founded on two key principles:
To act lawfully and with integrity, including by complying with corporate tax requirements
To maintain open and constructive relationships with tax authorities worldwide
EFG has a corporate tax strategy that is reviewed and approved by EFG Group's Chief Financial Officer. Further, we have a robust corporate
tax risk framework in place that is based on tax directives, procedures and internal controls and aims to ensure compliance with our tax approach and principles. This framework and our directives and policies are updated on a regular basis to reftect the latest developments in
this area.
EFG is committed to maintaining a robust tax compliance and tax reporting approach. As a matter of principle, EFG does not accept clients who are not willing to meet requirements for the transparent disclosure of financial information to help prevent financial crime. Client-related tax issues are governed by internal regulations, primarily the General Directive on Tax Transparency, the General Directive on Doing Business in the United States, the General Directive on the Foreign Account Tax Compliance Act (FATCA) and the Qualified Intermediary Regime, and the General Directive on the Common Reporting Standard (CRS).
Progress in 2025
In 2025, we further strengthened our consolidated supervision framework for the Compliance function as well as the operational effectiveness of the internal control system.
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| GRI 3-3 d
| Art. 964b Para. 2 No. 3 CO
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Art. 964b Para. 2 |
Monitoring and measuring effectiveness
If any issue is identified that could give rise to compliance risks, the issue is escalated through regular reporting processes by the Compliance function to the Executive Committee or a delegated committee, which ensures appropriate follow-up until the matter is resolved. The Compliance function also provides the Executive Committee and the Risk Committee of the Board of Directors with an annual compliance risk assessment setting out an independent view on the strength of the risk and control framework, as well as the activities it has conducted during the year to test the effectiveness of the compliance framework. If weaknesses are identified in the design or operation of the control framework, additional measures are set out in an activity plan to reinforce the control environment.
EFG has implemented a risk scorecard for Client Relationship Officers (CROs) to foster a risk-aware and compliant culture and reduce operational risks. The scorecard comprises a set of key risk indicators (KRIs) to monitor CRO adherence to internal policies and regulations, with any breaches resulting in penalty points that can impact the CRO's annual variable compensation. The KRIs cover areas such as compliance with AML and KYC requirements or sanctions, adherence to investment suitability and cross-border policies, as well as regulatory change
risk or litigation. The outcome of the scorecard process is reported on a quarterly basis to the Operational Regulatory and Compliance
Committee, which is a delegated committee of the Executive Committee, and to the Global Business Committee.
Internal and external audits are of key importance in monitoring the effectiveness of the compliance framework and remedying any deficiencies that are identified. Open issues arising from internal audit reviews are regularly monitored to ensure they are resolved within agreed deadlines, with progress reports submitted to the Audit Committee. Any open issues identified during the external audit and regulatory inspections are similarly tracked and reported to the Executive Committee and to the Audit Committee.
Risk management and risk governance
Importance of material topic and impacts
As a global private banking group, EFG operates in an increasingly complex environment with volatile markets, ever stricter regulatory requirements, growing stakeholder expectations and multiple sustainability challenges. We are therefore exposed to a variety of risks in the normal course of business that may impact our financial performance, business goals, reputation, and social, environmental or other objectives. At the same time, we embed ESG aspects into our
risk management process to identify and manage potential adverse impacts that our operations and business activities could have on the economy, environment and society, as well as any associated reputational consequences or other risks (such as greenwashing or litigation risks) affecting EFG and our clients.
How we manage risk: Strategy, policies and governance
EFG regards prudent risk management as an essential part of the way we do business. We strive to systematically and effectively manage risks across business units, geographies and functions to protect the interests of our clients, our investors and our company, to drive sustainable and profitable growth and to create long-term value for all our stakeholders. This diligent approach also helps to safeguard EFG's reputation and the integrity of the Swiss financial centre and the other locations where we operate.
Our robust risk management and risk appetite frameworks enable us to identify, measure and mitigate a broad spectrum of financial and
non-financial risks, allowing us to run our business responsibly and effectively.
We have developed a multi-dimensional approach to risk management that encompasses our business activities and decision-making processes. This approach enables us to increase the resilience of our business − including our products and services as well as our investment processes − with regard to financial risks (including credit, market and liquidity risks) and non-financial risks (such as operational, compliance or legal risks). This also allows us to evaluate the financial materiality of the different risks we face as a globally active private
| GRI 3-3 a & b
| Art. 964b Para. 2 No. 1 CO
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| Art. 964b Para. 2 No. 2 CO
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banking group. At the same time, we see new opportunities emerging in the form of new markets that we can serve and new products and services that we can offer, as well as increased resource efficiency.
EFG also believes that the responsible conduct of employees is essential for sound risk management and that their conduct is shaped by the organisation's risk culture. To ensure an effective risk culture throughout EFG, regular and comprehensive training in risk and compliance topics is completed by employees.
Risk management with three lines of defence
EFG manages its risks in accordance with a three lines of defence model. The model delineates risk ownership across all regions, divisions and support functions as well as oversight by the Risk Control and Compliance functions, and risk assurance by Internal Audit. It is designed to ensure that the organisation has a coherent and comprehensive approach to risk identification, management and monitoring. The model is operated both centrally and within the business units to ensure material business activities and processes are subject to risk management, oversight and assurance. Further information can be found in the Annual Report 2025 from page 99.
Risk frameworks
EFG's risk management framework sets out the overall governance of risks. It encompasses people, policies and processes, as well as systems and controls that are designed to ensure that risks are appropriately identified, measured, monitored, reported and mitigated on an ongoing basis. To achieve this, we have defined different categories in our risk taxonomy, ensuring that defined risk exposures are carefully monitored and controlled.
Our risk management framework is underpinned by our risk appetite framework, which was approved by the Board of Directors and defines the level of risk that EFG is prepared to incur to achieve its strategic business objectives. That level of risk is linked to the risk limit system and inftuenced by EFG's overall risk capacity.
The two frameworks are supplemented by a coherent and comprehensive set of policies, directives and procedures, with accountability being clearly assigned to specific functions across the three lines of defence.
Further information can be found in the Annual Report 2025 from page 100.
Focus on ESG-related risks
The assessment and management of ESG-related risks form an integral
Risk Control and Compliance |
Risk Oversight |
Second line |
Three lines of defence model
Private banking Non-private banking |
Risk Ownership |
First line |
part of EFG's risk management framework. We pursue a risk-based approach, focusing on material ESG topics associated with our products and services and with the industry sectors to which our clients, investments or transactions are linked. Our ESG due diligence procedures continue to evolve in line with the latest developments and market practice.
BoD
Board Committees
ExCo and its delegated Committees
Internal Audit |
Assurance |
Third line |
The governance of ESG-related risks, including those related to climate change, is formalised in our General Directive on ESG-related Risks.
EFG monitors climate-related risks that may affect the existing major risk categories (credit, market, liquidity, business, legal and operational risks) and other nature-related risk exposures on a regular basis, with monthly reporting to the Executive Committee and quarterly reporting to the Risk Committee of the Board of Directors.
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The Internal Audit function performs regular audits to assess the robustness of our risk management set-up. This includes evaluating the ESG climate risk framework with reference to the Basel Committee Guidelines for the effective management of climate-related financial risks.
More information on EFG's climate risk governance and management can be found on pages 52 - 63.
Risk governance
The Board of Directors has oversight of the overall risk management approach and monitors its effectiveness through regular internal risk assessments, audits and controls.
The Board of Directors is supported in this role by sub-committees: The Risk Committee, the Credit Committee, the Remuneration & Nomination Committee, the Audit Committee and the Acquisition Committee. The Risk Committee is the primary advisory committee to the Board for all matters relating to risk and compliance.
The Executive Committee includes the Chief Risk Officer and EFG Group's Head of Legal & Compliance. The Chief Risk Officer leads the Risk Control function, while EFG Group's Head of Legal & Compliance focuses on all compliance risks and all legal matters of EFG Group, as well as regulatory affairs. These two independent functions have clearly defined responsibilities and objectives.
Further, the Executive Committee has several sub-committees to ensure cross-functional alignment on risk topics. The Executive Committee and its delegated committees manage risks in accordance with the adopted three lines of defence model and in alignment with the risk strategy and risk appetite. As part of its remit, the Executive Committee also reviews and validates the Sustainability Report, which is then endorsed by the Audit Committee and approved by the Board of Directors.
Further information can be found in the Annual Report 2025 on page 100.
Progress in 2025
Highlighting the importance that EFG assigns to rigorous risk management, we launched an internal risk culture initiative in October 2025 to remind all EFG employees of their individual and collective responsibility to identify, manage and speak up about any operational risk they encounter in their work. To reinforce employee awareness of this important topic, we also provide mandatory training. In 2025, mandatory training courses covered compliance and other key topics. More information on employee training can be found on pages 72 - 73.
We continued to evolve our risk identification processes based on the provisions of the FINMA Circular "Nature-related financial risks". Starting from 2025, in addition to our established climate-related financial risk assessment, EFG also measures other nature-related financial risk dependencies and impacts in our key portfolios, comprising client Assets under Management, own assets (trading and investment books) and the securities used as collateral for Lombard loans. The assessment of other nature-related financial risks is performed using an internal risk heatmap covering dependencies in terms of soil erosion and
water supply, together with impacts in terms of land use, water use, air pollution, soil waste pollution, emission of toxic soil and water pollutants.
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2025 Risk Technology Award from Risk.net
Monitoring and measuring effectiveness
The Board of Directors, supported by its delegated committees, monitors EFG's role in the economy and society, including its impact on the environment, and the resulting risks and opportunities for EFG.
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| No. 3 and 5 CO
| Art. 964b Para. 2
EFG won the Risk Technology Award from Risk.net in the category "Best in-house risk data initiative" in June 2025 for EFG Digital Risk Pilot, which combines digital acceleration with the core foundations of compliance and risk management. This
solution delivers significant advances in risk management and reporting, leveraging cutting-edge technology to enhance transparency, efficiency and decision-making.
The Board of Directors defined specific metrics in 2023 to monitor progress in this area. These include: i) A reduction of GHG emissions from our own operations; ii) an increase in female representation in senior management (in percentage terms); and iii) an increase in Assets under Management in investment products and services with a dedicated ESG focus.
Outlook
EFG aims to prevent or manage emerging risks: They can be new risks,
Art. 946b, Para. 2 No. 4 CO |
Addressing challenges and mitigating risks
To address challenges and manage and mitigate risks in a rapidly evolving and highly volatile operating environment, EFG deployed a variety of risk management measures (including conducting regular assessments) to identify and address existing and emerging risks that could create potential reputational risks and impact future revenues. This includes monitoring the economic, regulatory and political landscape, as well as developments in new technologies such as artificial intelligence (AI).
EFG regularly carries out stress simulations, both routine and ad hoc, to identify vulnerabilities in key portfolios and to implement mitigation measures in advance. These simulations cover idiosyncratic and
macro-financial stress scenarios, including those involving geopolitical tensions. We continuously monitor regulatory changes that may affect risk management and operational processes. These include, but are not limited to, operational resilience requirements, nature-related financial risk management principles and capital regulations.
Our risk governance and our risk management framework proved effective in a challenging operating environment. EFG's financial performance for the full year 2025 is a testimony to the strength and resilience of our business model and to our ability to deliver attractive risk-adjusted returns throughout the economic cycle.
or they can even be familiar risks that become apparent in new or unfamiliar conditions. Their sources can be natural or human, and often are both. EFG monitors, via regular risk assessments, emerging risks that could create potential reputational risks and impact future revenues.
EFG closely monitors developments in new technologies like AI and cyber as well as economic, regulatory or political changes. EFG is assessing the potential risks and opportunities of AI on its operations and business processes. EFG is applying a cautious, risk-based approach to AI adoption, with robust controls designed to prevent potential harm arising from its use.
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Business strategy and
company performance 27
Sustainability strategy 30
Client centricity 35
Quality of investment
and advisory, and marketing
and labelling 39
Responsible investing 41
Digitalisation and innovation 46
Data protection, privacy
© Marie Lefloch I Team Malizia
and cyber security 48
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Business strategy and company performance
Importance of material topic and impacts
As part of EFG's strategy to generate sustainable and profitable growth, we focus on delivering consistently while building on our strengths. Our client-centric model forms the core of our value proposition and our strategy builds on a strong foundation to ensure the resilience of the business. For the 2026 - 2028 strategic cycle, EFG has also identified further opportunities for growth.
By conducting our activities with a high level of professionalism and
How we manage our business strategy and company performance: Strategy, policies and governance
EFG has begun its new strategic cycle 2026 - 2028. We communicated our strategic plan and financial targets for 2028 to the market on
25 November 2025. Building on the strong results achieved over the past two strategic cycles, EFG wants to continue delivering consistent performance and to unlock the power of compounding. We aim to continue generating double-digit net profit growth of around 15% per annum.
Committed to creating sustainable value for our stakeholders
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integrity, and by delivering high-quality service and advice to our clients, we also strive to ensure EFG's long-term stability and financial strength. Substantial financial losses, but also the erosion of trust,
can have a severe negative impact on the banking sector, the economy and society as a whole. At EFG, we are therefore committed to being
a reliable and resilient financial partner to our clients, shareholders, employees and other stakeholders.
Financial targets 2028 targets Creating value for:
NNA growth' |
Revenue margin |
Cost/income ratio |
RoTE |
avg. 4-6% p.a. |
>85 bps |
68% |
20% |
Our shareholders
Our people
Consistent value creation
Capital management
CET1 management ftoor
Dividend payout
Capture new opportunities for growth
Build on our strengths
Clients
Client-centric CRO1 model
Branding and client experience
Value creation for all stakeholders
Content
Client solutions and advice
Commercial excellence
M&A
Simplicity & Technology
EÆciency and operating leverage
Tech-enabled services and processes
NNA growth EPS growth
Attractive return on capital
Core foundations
EFG's people
Compliance and risk management
Operational and financial resilience
60%
12%
1 Compound Annual Growth Rate (CAGR) over the periods (2026 -2028)
Our regulatorsOur communities
Alongside this plan, we have updated our strategic positioning (see page 16) to evolve our shared understanding of our aspiration and of how our entrepreneurial DNA translates into our client offering and services.
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EFG strives to build lasting partnerships with clients, to deliver longterm economic value and to contribute to economic development for the benefit of all our stakeholders. The model on page 8, based on the IFRS Foundation's blueprint, offers an overview of EFG's approach to
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generating value through our business activities (value drivers) and interactions with our stakeholders to produce outputs. It covers both financial and non-financial aspects of our business.
EFG's ownership structure and governance define a clear strategic direction and longer-term perspective. The Board of Directors is responsible for the overall strategic direction, supervision and monitoring of the business. It delegates the execution of EFG's strategy and the day-to-day management of operations to the Executive Committee. Further information can be found on pages 12 - 15.
Progress in 2025
Our 2023 - 2025 strategic cycle has ended and we have achieved all of the ambitious financial targets that we set in October 2022. Over
the past seven years, EFG has generated strong and sustainable growth, translated it into profitability and delivered attractive returns to shareholders. At the same time, we have transformed EFG and positioned it for the future. Our 2026 - 2028 strategic framework now builds on the strength of our business model across the following three areas: 1) clients, 2) content and 3) simplicity and technology. The focus on these three areas has served us well since 2019.
Our client-centric CRO model (see page 35) is well established and is our engine for growth. We have consistently attracted clients and top talent in recent years. Over the next three years, we want to further elevate our brand and client experience.
We have made strong progress in enhancing our investment content and client solutions, as well as in improving our business performance. Going forward we want to empower our CROs by further improving access to teams of experts and specialist tools.
We have adopted a "simplicity mindset" across our company and have successfully established the core foundations for technology-enabled growth. In this next phase, we will accelerate technology investments to increase scale and drive growth.
Over the past strategic cycle, we focused both on developing our people and on creating strong teams, as well as on regulatory compliance
3 Business strategy
and risk management as prerequisites for growth. We now intend to complement our ambition to achieve organic growth with M&A optionality, leveraging surplus capital and building on strong organic capital generation.
Addressing challenges and mitigating risks
EFG's strong balance sheet and strong capital and liquidity position are the result of our strategic efforts to ensure our financial and operational resilience in a macro environment that remains complex. Current challenges include geopolitical developments, rising levels of national debt and trade tensions. Prudently monitoring and managing financial and non-financial risks, including in stress situations, is an inherent part of the way we do business at EFG (see pages 22 - 25).
We are building on our core foundations, with our strong balance sheet and robust compliance and risk management frameworks, as well as our resilient operating model. Preserving the trust of all stakeholders and maintaining a high level of operational and financial resilience remain our priority.
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1 Introduction
2 Governance
3 Business strategy
4 Environment 5 Society
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No. 3 and 5 CO |
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Monitoring and measuring effectiveness
As a publicly listed company, measuring and regularly reporting on our performance is crucial to keep our investors and other stakeholders informed about our progress, especially given existing and emerging challenges in our operating environment.
In addition, we use a variety of methods to ensure our strategy is progressing effectively. These include:
Audits, reporting and benchmarking: Internal audits, proprietary internal management accounting and reporting systems, employee surveys (see page 74) and compensation benchmarking as well as external financial and regulatory audits.
External and internal peer group analysis: Monitoring, tracking and comparing EFG's financial performance to that of its main competitors in the market.
External stakeholders: Ongoing communication with key stakeholders, such as clients, investors and analysts, regulators, rating agencies, employees, the media and industry associations (see table on pages 33 - 34). We continuously monitor and track how EFG and its performance are perceived in the media and by investors and analysts. In 2025, we conducted our first global client survey (see
page 38).
Outlook
Over the 2026 - 2028 strategic cycle, we aim to consistently deliver against our new strategic plan and unlock the power of compounding. We aim to make targeted investments in the areas that we have identified as further drivers of growth. We will continue to provide regular updates on our progress to the market, while maintaining close relationships with our stakeholders and responding to their evolving expectations.
1 Introduction
2 Governance
3 Business strategy
4 Environment 5 Society
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Sustainability strategy
EFG's sustainability strategy is based on two main pillars: Our responsibility as an asset allocator on behalf of our clients and our responsibility as a firm. It is designed to integrate sustainability aspects and sustainability priorities, such as strategic climate-related measures, into our business model in response to our clients' interest in sustainable finance.
Our priority as a global private banking group is to deliver superior service and advice as well as high-quality investment, wealth and credit solutions to our clients around the globe. At the same time, EFG seeks to support the transition to a more sustainable economy in our role
as an asset allocator on behalf of our clients. We do so by providing greater transparency around investment opportunities, as well as by integrating ESG criteria and ESG-related risk considerations into our investment process. In addition, we aim to further expand our
responsible investment offering. In this way, we are supporting global efforts to realise the UN Sustainable Development Goals (SDGs).
We strive to be an employer of choice that attracts, develops and retains talented professionals. We are committed to providing an inclusive working environment in which all our employees are valued equally and can reach their full potential. As an integral part of society, we are committed to serving the interests of the communities in which we live and work and to helping protect the environment.
Sustainability Framework
Our responsibility as an asset allocator
Allocating capital on behalf of our clients to help drive sustainable
development
Our responsibility as a firm
Striving to meet the expectations of all our stakeholders and strengthening
our sustainable business model
Our advisory capabilities
Responsible investing
ESG-related research and expertise
Commitment to our people
Our social commitments
Commitment to the environment
Responsible business conduct
Code of Ethics
Corporate values
Business Code of Conduct
Corporate governance
The EFG Sustainability Framework aims to create long-term value for our clients, employees and society as a whole to ensure the prosperity of future generations.
