Basis for preparation

Disclosure Requirement BP-1 – General basis for preparation of consolidated non-financial report

All material topics of the sustainability activities of VIG (fully consolidated companies) are reported in the consolidated non-financial report or sustainability statement as part of the Group management report, in accordance with both the currently applicable Austrian Sustainability and Diversity Improvement Act (NaDiVeG, EU Directive 2014/95) and the Corporate Sustainability Reporting Directive (CSRD, EU Directive 2022/2464). This covers all sustainability matters in accordance with NaDiVeG and § 267a of the Austrian Commercial Code (UGB). They are presented in chapters ESRS E1 “Climate change” for “Environmental matters in accordance with NaDiVeG”; ESRS S1 “Own workforce” for “Employee matters in accordance with NaDiVeG” and ESRS G1 “Business conduct” for “Respect for human rights and combating corruption and bribery in accordance with NaDiVeG”.

The Corporate Sustainability Reporting Directive (CSRD, EU Directive 2022/2464) was transposed into Austrian law in February 2026, but the provisions of the Austrian Sustainability Reporting Act (NaBeG) are not yet mandatory for the 2025 financial year. As the CSRD had not yet been transposed into Austrian law by the balance sheet date of 31/12/2025, the consolidated non-financial statement is reported on a voluntary basis in accordance with the EU requirements of the CSRD and the European Sustainability Reporting Standards published in this context. The report was prepared voluntarily in accordance with Article 29a of the Accounting Directive (EU Directive 2013/34) and the current ESRS, so that all essential information on sustainability-related impacts, risks and opportunities is disclosed.

Categories of ESRS Standards

The consolidated non-financial report has been prepared and is presented in accordance with the general requirements of ESRS 1. In accordance with the requirements of ESRS 2, VIG fulfils the disclosure requirements for all material sustainability aspects in the areas of governance, strategy, the management of impacts, risks and opportunities, as well as metrics and targets, and complies with the requirements of the topical standards. In accordance with ESRS 1, topics whose impacts, risks and opportunities have been rated as “not material” for both VIG and sustainability matters are not taken into account.

Company-specific disclosures

In addition, VIG discloses company-specific information in ESRS S1 “Own workforce”, ESRS S4 “Consumers and end-users” and ESRS G1 “Business conduct”.

Reporting areas

The disclosure requirements are divided into the following reporting areas:

• Governance (GOV): governance processes, controls and procedures for monitoring, managing and overseeing impacts, risks and opportunities;

• Strategy and business model (SBM): the interaction of the strategy and the business model with the material impacts, risks and opportunities, including how they are addressed;

• Impact, risk and opportunity management (IRO): processes for identifying the impacts, risks and opportunities, assessing their materiality and taking appropriate action to address them;

• Metrics and targets (MT): metrics and defined targets, and progress towards achieving targets.

Double materiality as the basis for the non-financial report

The principle of double materiality is of fundamental importance for the consolidated non-financial report. On this basis, the report aims to give readers an understanding of two key perspectives: on the one hand, the impact of VIG’s activities on sustainability topics (inside-out perspective; impact materiality) and, on the other, how sustainability aspects may affect VIG’s financial position (outside-in perspective; financial materiality). The double materiality assessment thus forms the basis of the consolidated non-financial report. Further details are provided in chapter ESRS 2 IRO-1 “Description of the process to identify and assess material impacts, risks and opportunities”.

Scope of consolidation of the sustainability statement

The consolidated non-financial report is prepared by VIG Holding for VIG (fully consolidated companies) for the reporting period from 1 January 2025 to 31 December 2025. A sustainability statement has therefore been prepared on a consolidated basis. The principles of consolidation have been harmonised between the financial and sustainability reporting and applied consistently. The scope of consolidation of the CSRD sustainability statement therefore corresponds to that of the consolidated financial statements prepared in accordance with IFRS, with the exception – due to the war situation – of selected reporting data for the three insurance companies in Ukraine. These three companies were not included in ESRS S1 “Own workforce”, ESRS S4 “Consumers and end-users” or ESRS G1 “Business conduct”, and nor were they included in the calculation and reporting of emissions from the company’s own operations. The data from the three companies – as they are available centrally – was included in the calculation of the Scope 3.15 emissions in the same way as the other companies. More information on the scope of consolidation and the consolidation method is provided in the consolidated financial statements under “Additional disclosures” in Chapter 21 “Business combinations” and Chapter 22 “Affiliated companies and participations”.

In determining the ESRS scope of consolidation according to the nature and scope of the inclusion of associated companies, no undertakings over which VIG has operational control were identified among the non-consolidated companies in the financial reporting pursuant to IFRS. Greenhouse gas emissions of the at equity companies are recorded on a pro rata basis and taken into account in accordance with the respective ownership interests under Scope 3.15 or separately shown in ESRS E1-6 “Gross Scope 1, 2, 3 and Total GHG emissions.”

The following table shows the companies for which the group exemption from preparation of a separate ESRS-compliant sustainability report is being utilised locally for the 2025 financial year.

Coverage of the value chain

As part of the sustainability statement, the double materiality analysis carried out in 2024 was re-evaluated in the year under review, taking into account the Company’s own business activities and the upstream and downstream value chain. All material impacts, risks and opportunities lie exclusively in the area of own business activities and the downstream value chain; no significant issues were identified in the upstream value chain (only the voluntary Scope 3.6 reporting on greenhouse gas emissions from business trips is to be allocated to the upstream value chain in accordance with the GHG protocol, although the topic was not identified as essential in the materiality analysis, but is included for certain stakeholders due to the assumed relevance). Further information on the value chain can be found in chapter ESRS 2 SBM-1 “Strategy, business model and value chain”.

Disclosure Requirement BP-2 – Disclosures in relation to specific circumstances

Time horizons

The following time horizons have been defined for the purposes of sustainability reporting:

• for the short-term time horizon: a reporting period of up to one year

• for the medium-term time horizon: from the end of the short-term reporting period up to three years

• for the long-term time horizon: from the end of the medium-term reporting period

The time horizon for the medium-term materiality assessment was aligned with the business plan and set at one to three years compared to the 2024 reporting, which defined it as two to five years. The definitions for the short- and long-term time horizon have also been adjusted accordingly. The periods are therefore based on those of VIG’s financial and business planning, enabling a transparent financial quantification. It also ensures consistency between strategic business planning and the assessment of sustainability impacts, risks and opportunities.

Estimates in the consolidated non-financial statement

The full collection of primary data along the entire value chain is made more difficult due to the limited availability of information. This makes it necessary to use estimates to prepare this sustainability statement. This relates to metrics for calculating emissions data in the Company’s internal operations, in underwriting (corporate and retail customers) as well as in asset management including the real estate portfolio and the calculation of remuneration metrics. Existing data gaps were closed by means of extrapolations, which are described below.

Estimates in internal operations

Estimates were made in the year under review for the environmental key figures in the Company’s internal operations, insofar as not all consumption data for the entire year were available for certain companies as of the reporting date of 31 December 2025. Extrapolation data were used on the basis of the existing monthly values from the previous year or missing energy metrics were extrapolated on the basis of the net usable area of the respective company, which were then multiplied by a median value across countries and industries (e.g. median of the reported power consumption per square metre multiplied by the reported net usable area of the Company).

The approach used provides a consistent and reliable basis for the extrapolations and thus ensures that the consumption data are estimated as realistically as possible.

Estimates in underwriting

For underwriting for corporate customers, emissions were calculated in accordance with the “economic activity-based emissions estimate” in accordance with the Partnership for Carbon Accounting Financials (PCAF Standard, Part C, Version 1, November 2022). This calculation is based on average emissions data for the respective industry. The insurance contracts are assigned to the average economic emission intensities of the industry underlying the policyholders. The average cost of risk (i.e. the average written premiums of policyholders in the sector in relation to the revenue generated by policyholders with their company) is used to convert the premiums written under the insurance contracts into an estimate of the insured revenue (representative of the share of the total insurance). The policyholders’ revenue figures are often not recorded in the underwriting system and therefore have to be estimated. The insurance contracts are mapped to industry averages using NACE codes of varying granularity. The NACE code is the classification of economic activities in the European Union (the term “NACE” derives from the French title “Nomenclature statistique des activités économiques dans la Communauté européenne”). This estimate reflects the share of absolute emissions of policyholders that are covered by the insurance contracts. The insurance-associated emissions were calculated by dividing the total absolute emissions by the average cost of risk of the underlying sector to obtain the insured revenue in that industry. This figure was then multiplied by the average emission intensity (tCO₂e/revenue) of the sector in order to obtain the estimated emissions. Alternatively, the premiums written under an insurance contract can be divided by the cost of risk and then multiplied by the average energy intensity of the respective sector. The formula shown below serves to illustrate the calculation logic and schematically shows the underlying influencing factors.

Emissions = [Premiums/average cost of risk] x emission intensity x insurer attribution factor

The emissions data for underwriting (corporate) were calculated in the reporting year with a reporting date of 31 October 2025. This difference in reporting date has no material impact in terms of data quality, since at that time the vast majority of the relevant data was already available and the remaining two months do not cause any significant changes in the portfolio. Since average values are used to calculate the emissions, a certain degree of measurement uncertainty in the reporting year cannot be ruled out. Efforts are made to minimise estimation uncertainty as far as possible. Work will continue to improve data quality in the future.

Emissions in the motor portfolio are calculated in accordance with the PCAF standard (Part C, Version 1, November 2022) “Insurance-Associated Emissions”. For estimation purposes, the “Estimated Vehicle-Specific” approach (Score 2–3) described in the PCAF Standard is used for passenger cars and light commercial vehicles, while the “Estimated Vehicle-Unspecific” approach (Score 4) is applied to other vehicles, as no primary data from policyholders’ motor portfolios are available for an “Actual Vehicle-Specific” approach (Score 1). Using data based on existing insurance contracts, each vehicle with a motor third party liability insurance (MTPL) policy was assigned emission values in the motor portfolio. Based on the data from the individual consolidated companies, which in the reporting year were submitted with a reporting date of 31 October 2025, emissions were calculated using vehicle-specific emissions per 100 km travelled and the annual distance travelled by the vehicle.

For the reporting year, 75.1% (2024: 77.1%) of the reported emissions are already calculated on the basis of the official CO₂e data provided by vehicle manufacturers. The remaining data gap of 24.9% (2024: 22.9%) of emissions results from the fact that vehicle identification numbers (VINs) were not available for all vehicles. Therefore, an approximation based on the known vehicle categories in the respective country is used. The data on assumed kilometres travelled were obtained from public sources. In the case of passenger cars, average mileage was derived from Eurostat publications per country. The earlier reporting date does not result in any significant inaccuracies with regard to the data quality in the motor portfolio, as there are only minor fluctuations and the emission values for the last two months of the reporting year therefore had no material impact on the total emissions. In order to improve the accuracy of the emissions collected in the future, more precise information on the mileage of vehicles and a more complete recording of vehicle types will be sought.

Value chain estimation in asset management

In the area of asset management, 74.1% (2024: 74.8%) of corporate bonds and equities were directly covered by emissions data from an external ESG database of a specialised financial service provider in 2025 (including investment fund units). The coverage rate for government bonds in the reporting year was 99.9% (2024: 99.9%). For more information on estimated emission calculation values in the assessment and availability of primary data, see chapter ESRS E1-6 “Gross Scopes 1, 2, 3 and Total GHG emissions”.

Value chain estimation in the real estate portfolio

The financed emissions from VIG’s real estate portfolio were collected and calculated in accordance with PCAF (Part A, Version 2, December 2022) “Financed Emissions”. Depending on the availability of primary and secondary data, emissions are calculated using three approaches with decreasing data quality. A more detailed description of the calculation of emissions from VIG’s real estate portfolio can be found in chapter ESRS E1-6 “Gross Scopes 1, 2, 3 and Total GHG emissions”, which presents VIG’s greenhouse gas emissions (GHG).

A distinction was made between actual emissions and estimated and calculated emissions when collecting the relevant emissions. For all properties for which verifiable and complete consumption figures are available, the actual emissions can be collected and reported. For all those properties for which no (detailed) consumption data are currently available, the information shown on the energy performance certificate is used to calculate the total emissions. To do this, the estimated energy consumption per m² based on the information in the energy performance certificate is used to calculate the emissions based on an average emission factor for the energy source used. In the case of real estate investments for which neither consumption data nor energy performance certificates are available, estimates are carried out in the same way as for the other investment classes, using approximations from an external specialised financial service provider in accordance with the NACE classification. Consequently, VIG used all three approaches proposed by PCAF (Part A) for calculating the real estate portfolio’s emissions. As data quality increases, the inaccuracy of estimates will gradually decrease in the future.

Sources of estimation and outcome uncertainty

The same method used for the consolidated income statement in financial reporting was used to translate foreign currency amounts into the reporting currency of euros during the financial year in order to ensure consistent and comparable reporting in accordance with ESRS 1 (see “Additional disclosures” in chapter 25.1 “Currency translation” in the consolidated financial statements). Where possible, actual and up-to-date emissions data from the investee companies, taken from the external database used, were used to determine the financed emissions. In the calculation of the remuneration ratios in ESRS S1 “Own workforce”, the salary data are adjusted for purchasing power differences and currency conversion by means of purchasing power parities (PPP) according to Eurostat. The salary data of around 7,000 employees of Austrian VIG companies were used as the basis for determining the median of the annual total remuneration of all employees (excluding the highest-paid individual). The median for the entire VIG was derived based on the distribution of these data. Further information on the calculation methods can be found in the respective metrics in ESRS S1 “Own workforce”.

Changes in preparation or presentation of sustainability information

The results of the first double materiality analysis from 2024 were revised in the reporting year. Identified impacts, risks and opportunities were summarised by topic following a structured process in order to avoid redundancies. In addition, positive impacts in individual cases were transferred to actions. Furthermore, the evaluation process was aimed at further strengthening communication with internal stakeholders on the key issues (see chapter ESRS 2 IRO-1 “Description of the process to identify and assess material impacts, risks and opportunities” in accordance with ESRS 2). As part of the evaluation, measurement schemes were generalised (see chapter ESRS 2 IRO-1) and time horizons were adjusted (see ESRS 2 BP-2 “Time horizons”). In addition to the company-specific topic of social engagement defined in 2024 in ESRS G1 “Business conduct”, two other company-specific topics have been identified: “Artificial intelligence” in ESRS S1 “Own workforce” and “Promoting risk literacy” in ESRS S4 “Consumers and end-users”.

The results of the consolidated materiality analysis are presented in the present sustainability statement in tabular form in ESRS 2 SBM-3 “Material impacts, risks and opportunities and their interaction with strategy and business model”. In addition, at the beginning of each topic chapter, an overview is given of the corresponding impacts, risks and opportunities, including the main measures and underlying concepts, in order to ensure a transparent and comprehensible presentation.

For the information provided under Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation), VIG has adopted the new simplified reporting templates of Commission Delegated Regulation (EU) 2026/73 of 4 July 2025. This approach was applied uniformly to both the investment and underwriting KPIs.

Since the 2025 reporting year, only the portfolios under own management (own risk) have been taken into account for the calculation of the share of green bonds. This adjustment was made to ensure that coverage is consistent with the Responsible Investment strategy.

Reporting errors in prior periods

For the 2024 reporting year, the proportion of employees covered by a collective bargaining agreement increased from 33.6% to 46.5%. The increase is due to an error in the data reported by a company in 2024. The discrepancy was identified and corrected in 2025 as part of expanded validation processes, and the previous year’s figures for 2024 were corrected accordingly. For further details, see ESRS S1-8 “Collective bargaining coverage and social dialogue”.

Disclosures stemming from other legislation or generally accepted pronouncements on the consolidated non-financial report

Disclosures in accordance with Article 8 of Regulation 2020/852 (Taxonomy Regulation) are published in the environmental information in ESRS E1 “Climate change”. Where information has been included in the consolidated non-financial report on the basis of other legislation or recognised standards, this has been indicated in the appropriate places.