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Mandatum Oyj : Sustainability Review 2025
Mandatum Oyj : Sustainability Review

About this update from Mandatum Oyj
SUSTAINABILITY REVIEW 2025 CONTENTS Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 2 INTRODUCTION 3 About this review 4 This is Mandatum 5 Message from the CEO 7 Sustainability highlights 2025 9 SUSTAINABILITY AT MANDATUM 10 Sustainability governance 11 Sustainability strategy 14 MONEY AS A DRIVER OF CHANGE 18 General approach to responsible investment 19 Sustainability in different asset classes 23 Consideration of climate and nature in investment activities 31 Active ownership and engagement 35 IT ALL COMES DOWN TO PEOPLE 37 Insurance 38 Reward and compensation services 39 LEADING BY EXAMPLE 41 Responsible sales and marketing practices 42 Responsibility for personnel 44 Human rights and labour practices 49 Supply chain management 50 Anti-corruption and bribery 51 Anti-money laundering and counter terrorist financing 52 Data protection 54 Information security and cyber security 57 Environmental impacts of operations 59 Financial responsibility and tax footprint 61 STAKEHOLDER COOPERATION AND DIALOGUE 62 APPENDICES 66 Calculation principles 67 Contact information 69 Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 3 INTRODUCTION Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 4 ABOUT THIS REVIEW This Sustainability Review covers Mandatum plc and its subsidiaries (later Mandatum or the company). Mandatum releases two sustainability-related reports for the reporting year 2025: A Sustainability Statement in accordance with the EU Corporate Sustainability Reporting Directive (CSRD) as part of the Report of the Board of Directors, and this Sustainability Review, which summarises sustainability-linked themes at Mandatum as well as significant actions and results in 2025. Read the Sustainability Statement included in the Report of the Board of Directors here . Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 5 THIS IS MANDATUM Mandatum is a major financial services provider, combining expertise in asset and wealth management and life insurance. Clients include institutional investors, companies, and private individuals. Mandatum offers a broad range of services encompassing asset and wealth management, compensation and rewards, supplementary pensions, and personal risk insurance. Skilled personnel, a strong brand, and a proven investment track record are at the centre of Mandatum's success. The company has been listed on Nasdaq Helsinki since 2023. The company's head office is located in Helsinki. In addition to Finland, Mandatum has offices in Sweden and Luxembourg. Beyond Finland, Mandatum has institutional asset management clients in other Nordic countries, especially in Sweden and in Denmark, and in Central Europe. In total, the company has around 20,000 corporate and institutional clients and 250,000 retail clients. Mandatum has divided its business into four areas: institutional and wealth management, corporate clients, retail clients, and with-profit business. Mandatum aims to become the fastest-growing Nordic asset and wealth manager. During this strategy period, the company's focus is on expanding the foothold of asset management internationally, accelerating the growth of private wealth management in Finland, increasing sales by leveraging excellent corporate client relationships, and improving operational efficiency. BUSINESS AREAS Institutional and wealth management Mandatum offers a wide range of asset and wealth management services to its clients, including institutional investors and high-net-worth private individuals. The broad investment solution offering includes equities, fixed income, corporate bonds, and alternative investments. Corporate clients Mandatum serves thousands of companies throughout Finland at different stages of their lifecycle. For large and medium-sized companies, the main focus is on rewards and compensation, including personal risk insurance, voluntary pension insurance and personnel funds, while smaller companies and entrepreneurs are offered insurance and investment services. Retail clients Mandatum serves retail clients mainly through partners. Clients are offered various investment solutions as well as personal risk insurance. With-profit business In with-profit business, Mandatum serves Finnish retail and corporate clients having with-profit pension insurance. The sales of these policies were discontinued in the early 2000s. Mandatum actively seeks to reduce its with-profit insurance portfolio while focusing on capital-light business. Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 6 AS OF 31 DECEMBER 2025, MANDATUM PLC'S GROUP STRUCTURE WAS AS FOLLOWS (excluding Mandatum Asset Management Ltd's branch office in Sweden as well as real estate and other similar companies accounted as investments): Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 7 MESSAGE FROM THE CEO The year 2025 was successful for Mandatum from a sustainability perspective. Our active work was reflected in the recognition we received in several external assessments. For Mandatum, sustainability means active measures that strengthen the company's success in the long run. Sustainable practices strengthen trust and boost growth, creating value for clients, owners, and society at large. The continuous development of our sustainability work was recognised in the market when Mandatum was included in the OMXH25 ESG Responsible™ Index in its update early in the year. The index tracks the most traded stocks on the Helsinki Stock Exchange and requires meeting certain ESG criteria. Our ESG ratings in 2025 were excellent overall. With an improved score in Sustainalytics' rating, Mandatum was assessed as a low ESG risk company. Our MSCI ESG rating remained at AA, and our ISS ESG Prime status reinforced our position as a leader in our industry. We also achieved exceptionally good results in the PRI responsible investment assessment: we received a full five-star rating in seven out of twelve categories. In the Global Real Estate Sustainability Benchmark (GRESB) assessment, the special common fund Mandatum AM Finland Properties II received a five-star rating for the second time, and Mandatum's own balance sheet portfolio ranked first in its peer group. We also advanced our commitment to support the net-zero goal aimed at mitigating climate change, both in our investments and in our own operations by 2050, by setting interim targets for 2030. Targets were set for direct listed equities and corporate bonds as well as for the Scope 1 and Scope 2 emissions of our own operations. We also prepared our first Climate Transition Plan that outlines how our operations will be steered towards net-zero emissions in line with the Paris Agreement's 1.5-degree target. Key means of reducing emissions include active ownership and influencing portfolio companies' business models. At the heart of Mandatum's HR strategy is an excellent employee experience. This is also reflected in high customer satisfaction, as demonstrated by our Net Promoter Score (NPS) of 79.7. Mandatum was awarded the Great Place to Work certification for 2025-2026. The Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 8 certification is based on an employee survey and is a recognition of the company's high employee satisfaction and strong work culture. We also earned the Siqni Future Workplaces certificate for the fourth consecutive year - this recognition is awarded for exceptional employee insight. As part of the 2025 Report of the Board of Directors, we also published Mandatum's Sustainability Statement in accordance with the Corporate Sustainability Reporting Directive (CSRD). The comprehensive Statement outlines our company's identified sustainability risks, opportunities, and impacts. We will continue to develop our operations for the long term in a way that strengthens sustainability, supports growth in alignment with our strategic objectives, and delivers value to our clients and all of society. Petri Niemisvirta Group CEO Mandatum "Our sustainability work was acknowledged in external assessments." Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 9 SUSTAINABILITY HIGHLIGHTS 2025 EXCELLENT RESULTS IN ESG RATINGS Mandatum once again achieved excellent results in international ESG ratings in 2025. In Sustainalytics' assessment (Q3), the company is in the low ESG risk category with an improved score of 12.3 (scale 100-0), MSCI ESG's rating (Q2) remained at AA (scale CCC-AAA), and ISS ESG's Prime Status (Q4) shows that the company is at the top of its industry also in this assessment. Read more MANDATUM WAS INCLUDED IN THE OMXH25 ESG RESPONSIBLE TM INDEX Mandatum was added to the index in connection with its update on 3 February 2025. The OMXH25 ESG Responsible TM Index includes the most-traded stocks listed on Nasdaq Helsinki that meet certain ESG criteria. The fulfilment of these criteria is based on the Sustainalytics rating, among others. 1 Read more FULL FIVE STARS IN SEVERAL CATEGORIES IN THE PRI ASSESSMENT The annual PRI assessment measures responsible investment practices and the implementation of the UN Principles for Responsible Investment in investment operations. In the latest assessment, Mandatum participated in a total of twelve categories and received the highest five-star rating in seven of them. 2 Read more SUCCESS FOR MANDATUM'S REAL ESTATE PORTFOLIOS IN THE GRESB ASSESSMENT Mandatum AM Finland Properties II received a full five-star rating in the international GRESB sustainability assessment. The portfolio under Mandatum's own balance sheet ranked number one in its peer group. Read more MANDATUM SET INTERIM TARGETS IN PURSUIT OF NET-ZERO EMISSIONS AND PREPARED A CLIMATE TRANSITION PLAN Mandatum made progress toward its commitment of supporting the goal of net-zero emissions in its investments and own operations by setting its first interim targets for 2030. The company also prepared a climate transition plan that outlines how its operations will be steered towards net-zero emissions in line with the Paris Agreement's 1.5-degree target. Read more MANDATUM PARTICIPATED IN THE SHE INDEX FOR THE FIRST TIME The SHE Index measures diversity, equality, and inclusion in companies, with a focus on assessing the realisation and development of gender equality within organisations. Mandatum participated in the index for the first time in 2025 with a score of 82/100, which indicates a very high performance. Read more Source: Nasdaq Index Methodology Source: The 2025 PRI reports: Assessment Report & Transparency Report Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 10 SUSTAINABILITY AT MANDATUM Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 11 SUSTAINABILITY GOVERNANCE Mandatum is committed to developing the sustainability of the Group's operations and related reporting, targets, and their monitoring, in accordance with the interests and expectations of the Group's external and internal stakeholders. Mandatum plc's Board of Directors has the responsibility for and ultimate oversight of Group-level sustainability. The Board of Directors has appointed an Audit Committee whose duties include supervising Mandatum Group's sustainability reporting and other sustainability activities. The main responsibility for sustainability management rests with the Group CEO, who, together with the Management Team, leads the strategic implementation of sustainability. The Group's SVP, Communications, Brand, and Sustainability is in charge of Group-level sustainability and ensures sufficient reporting on the Group's sustainability issues to the CEO. Mandatum has a Sustainability Committee for senior management that promotes and manages Group-level sustainability in accordance with the strategy. The Sustainability Forum develops and coordinates the Group's sustainability work at the operational level and meets at least quarterly. The forum is led by the Head of Sustainability, and its members comprise key representatives of different functions. Sustainability governance is described in more detail in the Sustainability Statement in the Report of the Board of Directors . $$MANDATUM Introduction Money as a driver It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 12 Sustainability at Mandatum MANDATUM PLC'S BOARD AND THE BOARDS OF ITS DESIGNATED SUBSIDIARIES approve the Responsible Investment Policy. of change RESPONSIBILITIES AND DIVISION OF DUTIES IN RESPONSIBLE INVESTMENT are responsible for compliance with the Responsible Investment Policy in each of Mandatum Group's companies. MAM, NAM AIFN, MANDATUM FUND NANAGENENT AND NANDATUN LIFE INSURANCE CONPANY'S MANAGEMENT GROUPS The ESG Committee is responsible for the coordination and development of responsible investment and for outlining related operating methods throughout the organisation. The responsibilities and division of duties in responsible investment are described in the chart below. The portfolio manager is responsible for ensuring the implementation of responsible investment within the investment process. They ensure adherence to the responsible investment policy within their area of responsibility, integrate sustainability analysis into investment analysis, monitor investments from a sustainability perspective, and engage in discussions about potential issues with the ESG team and committee. The ESG Team supports investment operations in issues related to responsible investments, monitors ESG factors or risks in investment objects and monitors adherence to the Responsible Investment Policy. At the core of all operations are existing laws, regulations, and ethically accepted practices. The Group Legal department ensures that landatum Group's operations, including investment operations, product development and governance are carried out in accordance with the applicable national legislation, EU regulations, and regulatory guidelines. The purpose of the Group Compliance is to help the f•1andatum Group companies in managing compliance risks. As a second line function, Group Compliance must be independent of and non- dependent on the business units to avoid conflicts of interest. Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 13 GUIDING PRINCIPLES AND POLICIES Mandatum complies with applicable legislation, official guidelines from authorities, and ethically sound practices in all its operations. In addition, sustainability work is guided by Mandatum's Code of Conduct and by other supplementary policies and guidelines. These principles, together with Mandatum's values and strategy, guide the company's decisions and everything it does. The Code of Conduct describes Mandatum Group's ethical guidelines, principles, and values. The Code of Conduct defines the practices and procedures that must be observed in the business operations of all Group companies. The Code of Conduct also serves as the basis for the Group's policies and guidelines. The content of the Code of Conduct is reviewed at least annually, and amendments and updates are approved by Mandatum plc's Board of Directors. Mandatum also has a separate Group-level Supplier Code of Conduct which sets out the principles and obligations for responsible supply chain management. Key policies related to sustainability include the Responsible Investment Policy and the Sustainable Insurance Policy. Other significant policies and principles for sustainability include the Mandatum Way, Compliance Policy, Human Rights Commitment, Internal Audit Policy, Risk Management Policy, Remuneration Policy, Data Protection Policy, Information Security Policy, Procurement Policy, Outsourcing Policy, Anti-Money Laundering and Counter Terrorist Financing Principles, Engagement Principles, and Disclosure Policy. Code of Conduct Principles and policies WHISTLEBLOWING CHANNEL AND GRIEVANCE MECHANISMS Mandatum has an electronic Whistleblowing channel through which suspected violations and cases of misconduct can be reported. The channel is public and open to the company's employees and stakeholders who detect possible cases of misconduct and violations in the course of their work. Reports can be submitted to the Whistleblowing channel anonymously. In processing reports, Mandatum complies with applicable whistleblower protection legislation and guarantees the necessary safeguards and control measures to protect whistleblowers' personal data and ensure protection against retaliation. The Compliance function processes reports received through the Whistleblowing channel confidentially. Employees and external stakeholders are informed about the Whistleblowing channel and submitting a report on the company's intranet and external websites. In addition, there are other confidential channels for reporting grievances that are available to all employees. Cases of harassment or other inappropriate behaviour can be reported confidentially through the reporting channel on the company's intranet. All reports are treated as confidentially as possible, and only the necessary persons participate in the meetings and correspondence. Employees' representatives have also committed to a high level of confidentiality and employees have been consulted in the planning of the process. Possible personal data breaches and incidents related to operational risks are reported to the Risk Management and Compliance functions via a link on the company's intranet. Whistleblowing channel: Whistleblowing SUSTAINABILITY ISSUES AND RISK MANAGEMENT An effective risk management system is a key part of Mandatum Group's governance structure. The Board of Directors has overall responsibility for risk management, and the CEO is responsible for organising risk management in accordance with the requirements set by the Board of Directors, regulatory frameworks, and other stakeholders. The Chief Risk Officer is responsible for ensuring that risk management is organised appropriately and that the scope is adequate in relation to operations in general. At Mandatum, business risks are divided into three main categories: strategic risks, earnings risks (for example insurance and market risks), and consequential risks (for example operational risks). Sustainability risks are classified as risks that belong to all of the above groups, as they can manifest through different risk categories. Sustainability risks refer to environmental, social, or governance events or circumstances which, if realised, could have a negative impact on Mandatum's business. The risk management framework and internal risk classification model are described in more detail in the Risk Management Policy available on the company's website. Sustainability risks are described in more detail in the Sustainability Statement published as part of the Report of the Board of Directors . Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 14 SUSTAINABILITY STRATEGY Through its Sustainability Strategy, Mandatum seeks to create value and influence and manage risks from the perspective of sustainability themes that are significant for the company and society. The aim of the Sustainability Strategy is to complement and support the Group strategy in areas related to sustainability to enhance their management and effectiveness. The Sustainability Strategy was refined based on the results of the double materiality assessment updated in 2025. In the double materiality assessment, Mandatum has evaluated the impacts of its business operations on the environment and people, as well as the risks and opportunities of various sustainability topics for the company's business. The materiality assessment and its results are described in more detail in the Sustainability Statement published as part of the Report of the Board of Directors . The Sustainability Strategy is built on three key themes. These are responsible investment, sustainable insurance and compensation, and sustainable business. UN SUSTAINABLE DEVELOPMENT GOALS The UN Agenda 2030 and its 17 main goals aim at sustainable development that comprehensively takes into account the environment, economy, and people. Mandatum is committed to promoting the UN Sustainable Development Goals (SDGs), four of which are particularly relevant to the company's operations and impacts: SDG 3 Good health and well-being - Mandatum promotes the wellbeing of its clients through financial preparedness and wealth creation. SDG 8 Decent work and economic growth - Employee satisfaction is strategically important to Mandatum, and the working conditions of investee companies are also monitored, and companies are engaged on a case-by-case basis. In its business operations, Mandatum aims for sustainable growth and a positive client experience. SDG 13 Climate action - Mandatum promotes climate action both in its investment activities and own operations. SDG 16 Peace, justice and strong institutions - Good governance is the foundation for Mandatum's business, and the company also develops the good governance of its client companies through offering rewards and compensation services which promote responsible business. The targets and metrics related to the three key themes are described in the tables on the following pages. For each theme, the UN Sustainable Development Goals (SDG) that are supported by Mandatum's own sustainability targets are also identified. Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 15 MONEY AS A DRIVER OF CHANGE - Theme Target Metric Result 2025 Link to UN SDGs RESPONSIBLE INVESTMENT In Mandatum's view, companies that operate responsibly perform better. By investing responsibly itself, Mandatum makes better-justified investment decisions that align with its long-term sustainability and risk management objectives. Responsible investment involves managing assets in a way that considers environmental, social, and governance Emissions from investments Net-zero commitment: Supporting the goal of net-zero emissions by 2050 in investments. Interim target: Reducing the carbon intensity 1 of direct listed equities and corporate bonds by 75% by 2030, compared to the 2020 baseline. Annual emissions reductions compared to the baseline year The carbon intensity of direct listed equities and corporate bonds was 41 tCO 2 e/EUR million revenue at the end of 2025 and it decreased by 78% compared to the baseline year (baseline value for 2020: 190 tCO 2 e/EUR million revenue). The carbon intensity decreased by 42% compared to the previous year and fell below the target level set for the interim target (47 tCO 2 e/EUR million (ESG) matters in investment analysis, revenue). decision-making, and reporting on investments. Mandatum aims to both understand and account for the sustainability risks and opportunities related to its investments and to identify and mitigate the adverse impacts of its investment activities on the environment, climate, society, employees, human rights, and matters related to combatting corruption and bribery. Biodiversity risks and impacts of investments Active ownership and engagement Evaluating and implementing biodiversity tools, as well as assessing own direct investment products with the help of biodiversity tools. Actively promoting the development of ESG matters and reacting to detected misconducts. Encouraging investee companies to set emissions reduction targets. Proportion of investment products for which a biodiversity assessment has been conducted Number of ESG engagement measures During the first monitoring year of the target, Mandatum carried out a biodiversity assessment at two properties in the Mandatum AM Finland Properties II fund and in one property in the portfolio under its own balance sheet. Mandatum participated in 22 pooled engagement initiatives in 13 different investee companies. The engagement measures were related to themes such as climate, biodiversity, pollution, anticompetitive behaviour, and consumers' and workers' rights. There were 25 active cases at the end of the year. products support the achievement net-zero target of net-zero emissions by 2050. products supporting the products 2 : 100% the development of existing New own investment products and • Proportion of own direct • Proportion of own direct Investment products Scope 1 and 2 Weighted Average Carbon Intensity (WACI) Own direct liquid equity and fixed income products for which carbon intensity has decreased since the first monitoring year, as well as separately defined real estate investment products that promote the net-zero target, in relation to all corresponding Article 8 and 9 products. Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 16 IT ALL COMES DOWN TO PEOPLE -SUSTAINABLE INSURANCE AND COMPENSATION Through its business operations, Mandatum strives to improve the financial security of its clients and promote responsible HR practices of its client companies. Theme Target Metric Result 2025 Link to UN SDGs NPS: 79.7 NPS Transactional customer satisfaction (NPS) in accordance with the annual target. NPS target in 2025: 73-78. Customer satisfaction EUR 8.3 billion (+3.4%) security persons insured through Mandatum. Risk insurance cover Improving financial • Rising trend in the insurance cover for The goal of insurance operations is to promote the wellbeing of clients through financial preparedness and wealth creation. Mandatum offers its clients options for voluntary preparedness that supplement statutory social security. Preparedness and wealth creation also generate value for society. Promoting responsible compensation at client companies Rising trend in commissions promoting responsible compensation. 1 Commissions promoting responsible compensation Data collection was started in 2025, which is why a comparison to the previous year has not yet been conducted. The trend figure will be presented starting from the next reporting year. Mandatum actively promotes responsible compensation in Finnish companies. Responsible compensation supports companies' success and creates wellbeing among the company's employees. At the core of operations is the client's interest and needs. High-quality, accessible, and equitable customer service builds trust, supports client wellbeing, and reduces business risks. Satisfied clients are more committed, creating value for both Mandatum and its client companies. 1) Commissions and compensation solutions for the entire personnel, through which the company promotes transparent and equitable incentive schemes and sets sustainability metrics (includes the design of remuneration systems, development of sustainability metrics, pay surveys for equality plans, market salary surveys, personnel funds, and client events addressing responsible compensation). Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 17 LEADING BY EXAMPLE -SUSTAINABLE BUSINESS Theme Target Metric Result 2025 Link to UN SDGs Responsibility for personnel and sustainable practices are part of building a successful business. The wellbeing of employees is strategically important to Mandatum, and by taking care of it, the company also enhances its operational capability and profitability. Sustainable business management and practices form the foundation of Mandatum's operations. Good governance Employee satisfaction Diversity, equity, and inclusion Employee satisfaction in accordance with the annual target. Siqni index target in 2025: 81-86. 12.3 (on a scale of 100-0), low ESG risk Sustainalytics ESG Risk Rating • Sustainalytics ESG Risk result falling at most into the 'Low Rating Risk' category. Sustainability governance SHE Index in accordance with the annual target. 2025: First reporting year of the metric result, which forms the target's baseline value in the future. Siqni index • Siqni index: 77 SHE Index • SHE index: 82 (on a scale of 0-100), very high performance ensures that Group companies and their personnel, suppliers, and other partners comply with laws, regulations, and generally accepted principles. Financial responsibility means ensuring the continuity, profitability, earnings power, and solvency of operations in all market conditions. Ensuring continuity creates the foundation for the sustainable and responsible management of clients' insurance-related liabilities and clients' investments and pensions for decades. That Anti-money laundering, corruption and bribery Data protection and information security Effective practices and controls to prevent money laundering, corruption, and bribery. The completion rate of data protection and information security training for personnel is 100%. The proportion of active users in the training programme aimed at improving the personnel's preparedness is at least 90%. Money laundering, corruption, and bribery incidents determined by the competent authority (incl. administrative sanctions and non-appealable judgements) Completion rate of data protection and information security training Proportion of active users in the training programme aimed at improving the personnel's preparedness No cases of money laundering, corruption, or bribery confirmed by a competent authority. The completion rate for the data protection training was 99.5% and for the information security training 99.5%. The proportion of active users in the training programme aimed at improving personnel's preparedness was 92.2% at the end of the year. is why risk management is also a key component of the company's financial responsibility. Creating financial wellbeing in society through profitable business Improving the cost/income ratio. 1 • Cost/income ratio • Mandatum's cost/income ratio related to client AuM in 2025 was 49% (trailing 12 months). In addition to paying taxes and creating employment, Mandatum's services generate added societal value. Investment, insurance, and reward and compensation products and services are part of the societal infrastructure that enables the functioning Emissions from own operations Net-zero commitment: Supporting the goal of net-zero emissions by 2050 in own operations. Interim target: Reducing the company's greenhouse gas emissions (Scope 1 and 2) by 42% by 2030, compared to the 2024 baseline. Emissions from own operations (tCO 2 e) Emissions from own operations (Scope 1, 2, and 3) were 1,696 tCO 2 e (according to the market-based method). Scope 1 emissions decreased by 20% and Scope 2 emissions by 98% compared to the previous year. of a modern society and economy. 1) Related to investment and asset management income and expenses. Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 18 MONEY AS A DRIVER OF CHANGE MARKETING COMMUNICATION Always consult the official documentation of the investment product before making any final investment decisions. More information about the consideration of sustainability risks and factors in investment operations is available on Mandatum's website and in product-specific documentation. Mandatum Asset Management Ltd acts as a portfolio manager for and on behalf of Mandatum Group and as an insurance agent for its sister company, Mandatum Life Insurance Company Limited. Unit-linked insurances are issued, and investment baskets are owned by Mandatum Life Insurance Company Limited. Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 19 GENERAL APPROACH TO RESPONSIBLE INVESTMENT At Mandatum, taking sustainability aspects into consideration is part of investment operations. Sustainability is integrated into the investment process, taking into account the special characteristics of each asset class. The assessment of sustainability factors follows the same principle as the selection of investments: the focus is directly on the company, and the decision is based on an analysis of the company and its sector. Mandatum's Responsible Investment Policy defines the company's responsible investment principles and is binding on the entire personnel. The policy describes the minimum level of measures to be taken to address sustainability risks and adverse sustainability impacts. Certain products may be subject to stricter principles and investor engagement procedures. The policy is reviewed and updated annually. Responsible Investment Policy ASSESSMENT OF THE SUSTAINABILITY FACTORS OF INVESTMENTS In addition to financial aspects, the investment analysis looks at factors related to sustainable development and related risks and opportunities. The materiality of sustainability risks varies depending on the investee company's sector and business model. A sustainability risk is an environmental, social, or governance event or condition that, if it occurs, could have a negative impact on the value of the investment. Transition risks refer to how companies are able to adapt their business to a low-carbon and sustainable economy and develop their operations in relation to the expectations of clients and society. Potential sustainability risks related to investee companies' value chains must also be taken into account as part of the investment analysis. In analysing investments, Mandatum also seeks to identify and mitigate the adverse impacts of its investment operations on the environment, society, and employees, as well as promote human rights and issues related to anti-corruption and anti-bribery. In its climate strategy, Mandatum follows the double materiality principle. This means that both the impacts of climate risks on the investee company and the company's impacts on sustainability factors are taken into consideration. IMPACT ASSESSMENT To complement the assessment of sustainability factors, an impact assessment has been incorporated in the analysis of investee companies' business. It is an evaluation of the positive and negative impacts of companies and their net impacts on society and the environment on a wider scale. For some of Mandatum's investment products, the impact assessment uses a model designed by a third-party service provider, the Upright Project, which quantifies the positive and negative impacts of companies in four categories. These are: society, environment, health, and knowledge. In the Upright model, the highest possible net impact score is 100 per cent, but there is no lower limit for negative scores. EXCLUSION OF SECTORS AND PRODUCT GROUPS Mandatum has identified sensitive business areas that are considered to carry more sustainability risks and cause more adverse sustainability impacts than other areas. The Responsible Investment Policy lists the exclusion criteria by sector and product group for direct investments in equities, bonds, and loans that have been defined as promoting environmental or social characteristics (SFDR Article 8) or as having sustainable investments as their objective (SFDR Article 9). The criteria serve as a guideline for portfolio managers in all asset classes. Stricter exclusion criteria may also be applied on a product-by-product basis. Investments in companies in the coal and oil industry that exceed set revenue limits can be allowed for products other than Article 9 products if the company has a credible transition plan based on internal criteria. If an equity or fixed income investment compliant with Article 8 or 9 in the portfolio no longer meets the criteria, Mandatum will divest the investment within a reasonable period of time, taking into account its clients' best interests and the market situation. In addition to sector-specific monitoring, Mandatum complies with statutory exclusions (such as investments excluded on the basis of domestic or international laws, bans, treaties, or embargos). Direct business refers to the manufacture or production of products or services. Indirect business refers to the various parts of the manufacturing or production value chain, such as subcontracting, transportation, or distribution. Mandatum's aim is to reduce exposure to the fossil fuel industry while investing in companies that produce energy from renewable sources or have a clear and credible strategy to transition from fossil fuels to a more sustainable business model. Introduction Sustainability at Mandatum Money as a driver of change It all comes down to people Leading by example Stakeholder cooperation and dialogue Appendices 20 Industry / Product group Percentage of sales Description Zero tolerance Direct business Indirect business Controversial weapons 0% 0% Investments are not made in companies that derive any revenue from the manufacturing, subcontracting, or distribution of controversial weapons. This exclusion applies without exception to anti-personnel mines, cluster munitions, and chemical and biological weapons. It also applies to nuclear weapons that fall outside the scope of the Treaty on the Non-Proliferation of Nuclear Weapons (NPT). 1 Low tolerance Direct business Indirect business Coal 5% 30% Investments are not made in companies that derive over 5% of revenue from mining of coal or whose share of revenue from coal mining subcontracting or distribution of coal exceeds 30%. Investments are not made in companies whose share of revenues from coal-based energy production exceeds 30%. Exemptions may be granted to companies that present a credible transition plan. 2 Tobacco 0% 50% Investments are not made in companies that derive revenue from manufacturing of tobacco products or derive more than 50% of revenue from subcontracting or distribution of tobacco products. Adult entertainment 0% 50% Investments are not made in companies that derive revenue from production of adult entertainment or that derive more than 50% of revenue from adult entertainment industry subcontracting or distribution. Gambling 50% 50% Investments are not made in companies that derive more than 50% of revenue from gambling or gambling subcontracting. Oil 40% 40% Investments are not made in companies that derive more than 40% of revenue from direct business to the fossil oil industry, including exploration, extraction and production of fossil oil. Investments are not made in companies that derive more than 40% of revenue from indirect business to the fossil oil industry, including distribution, refining and processing of fossil oil or production of fossil oil-based energy. Exemptions may be granted to companies that present a credible transition plan. 2 Limits set on direct equity (incl. direct private equity investments) and fixed income as a share of sales by industry/product group, in accordance with the Responsible Investment Policy approved in December 2025. The limits are applied to equity and fixed income investment products that are determined to promote environmental or social characteristics or to be sustainable investments, but they serve as guidelines in other asset classes as well. Investments in companies that derive revenue from nuclear weapons inside the NPT are evaluated against an internal set of criteria. The portfolio manager responsible will prepare a summary of the target company, which will then be reviewed by the ESG team for their opinion. Exemptions may be granted to companies that present a credible transition plan, evaluated against an internal set of criteria.