Annual report
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1 | Mediolanum Group - Annual Financial Report 2025 Mediolanum Group 2025 ANNUAL FINANCIAL REPORT Banca Mediolanum S.p.A. Parent Company of the Mediolanum Banking Group, listed in the Register of Banking Groups Bank listed in the Register of Banks - Member of the National Guarantee Fund and the Interbank Deposit Protection Fund Share capital €600,699,853.40 fully paid up - Tax No. and Milan Companies Register No. 02124090164 - VAT No. 10540610960 of the Banca Mediolanum VAT Group Registered office Palazzo Meucci – Via Ennio Doris 20079 Basiglio (MI) – T +39 02 9049 1 bancamediolanum@pec.mediolanum.it Bancamediolanum.it
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2 | Mediolanum Group - Annual Financial Report 2025 CONTENTS Letter from the Chairman and Chief Executive Officer..................................................................... 4 CORPORATE OFFICERS OF BANCA MEDIOLANUM S.p.A. .............................................................. 7 SCOPE OF CONSOLIDATION AT 31 DECEMBER 2025 ....................................................................... 9 GROUP PROFILE ..................................................................................................................................... 21 CONSOLIDATED REPORT ON OPERATIONS .................................................................................... 26 OPERATING PERFORMANCE .......................................................................................................................... 49 CONSOLIDATED SUSTAINABILITY STATEMENT 2025 ............................................................................ 67 1. General disclosures ............................................................................................................................... 68 2. Environmental disclosures ................................................................................................................ 134 3. Social information ............................................................................................................................... 218 4. Governance information ................................................................................................................... 351 5. Entity-specific disclosures ................................................................................................................. 381 OTHER INFORMATION .................................................................................................................................... 392 CONSOLIDATED FINANCIAL STATEMENTS ................................................................................... 400 NOTES TO THE FINANCIAL STATEMENTS ...................................................................................... 409 Part A – Accounting policies .......................................................................................................................... 410 Part B – Information on the consolidated statement of financial position ........................................ 452 Part C – Information on the consolidated income statement ................................................................ 521 Part D – Consolidated comprehensive income ......................................................................................... 547 Part E – Information on risks and the relative hedging policies ........................................................... 548 Part F – Consolidated equity information .................................................................................................. 660 Part G – Business combinations involving businesses or business units .............................................. 664 Part H – Related party transactions ............................................................................................................ 665 Part I – Share-based payment agreements ............................................................................................. 667 Part L –Segment reporting ............................................................................................................................ 670 Part M – Lease reporting ............................................................................................................................... 676 DECLARATION OF THE FINANCIAL REPORTING OFFICER .......................................................... 679 ANNEX 1 REPORTING REQUIRED UNDER PRUDENTIAL REGULATIONS .................................... 682 INDEPENDENT AUDITOR’S CONSOLIDATED REPORT .................................................................. 685 INDEPENDENT AUDITOR’S LIMITED ASSURANCE REPORT ON THE CONSOLIDATED SUSTAINABILITY STATEMENT ........................................................................................................... 696 2025 Financial Statements ................................................................................................................ 703 2025 INDIVIDUAL HIGHLIGHTS ........................................................................................................ 704 REPORT ON OPERATIONS ................................................................................................................... 711
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3 | Mediolanum Group - Annual Financial Report 2025 INDIVIDUAL FINANCIAL STATEMENTS ............................................................................................ 732 NOTES TO THE FINANCIAL STATEMENTS ........................................................................................... 741 Part A – Accounting policies .......................................................................................................................... 742 Part B – Information on the Statement of Financial Position ................................................................. 772 Part C –Information on the income statement.......................................................................................... 810 Part D – Comprehensive income .................................................................................................................. 827 Part E – Information on risks and the relative hedging policies ........................................................... 828 Part F – Information on capital ..................................................................................................................... 864 Part G – Business combinations involving businesses or business units ............................................. 866 Part H – Related party transactions ............................................................................................................ 868 Part I – Share-based payment agreements ............................................................................................. 870 Part L – Segment reporting ........................................................................................................................... 873 Part M – Lease reporting ............................................................................................................................... 873 DECLARATION OF THE FINANCIAL REPORTING OFFICER .......................................................... 876 INDEPENDENT AUDITOR’S REPORT ................................................................................................ 878 GLOSSARY ............................................................................................................................................ 887
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4 | Mediolanum Group - Annual Financial Report 2025 Letter from the Chairman and Chief Executive Officer Dear Shareholders, 2025 marked a silent but profound hiatus in the international system: the world has stopped seeking order but still cannot live with disorder. The policies and rhetoric of the second Trump Administration have led to the extreme deregulation of international coexistence. Deregulation is affecting the economic and commercial sphere and is at its peak in the radical crisis affecting international law. Just think of the year just ended, of the repeated use of tariffs as a form of economic and political pressure on allies and adversaries; the systematic de-legitimisation of international institutions; and the further crumbling of security agreements between the major powers. Not to mention the increasingly casual use and threat of the use of force: from the Russian invasion of Ukraine, now in its fourth year, to the Israeli and US initiative against Iran last June, culminating a few weeks ago with the beheading of the theocratic regime, to the US intervention in Venezuela that led to the capture of President Maduro. This explosion of various conflicts creates a situation of increasing global insecurity, leading to a progressive but inexorable breakdown of the world order to which we are accustomed. It is the beginning of a ‘new world disorder’. At the same time, in the year just ended, there was no shortage of good news and this allows us to look to the future with hope and optimism. On the medical front, there has been significant progress in a number of areas: from increasingly targeted gene therapies to new resistance antibiotics, to studies on the link between the nervous system and cancer. On the social front, for the first time in history, more than half of the world’s population (52.4%) benefited from a form of social insurance. On the environmental front, photovoltaic-led renewable energy surpassed coal in the global energy mix for the first time in the first half of the year. On the economic front, the resilience of the global economy this year is remarkable despite massive geopolitical changes and ongoing tensions. Many indicators show that economic activity largely absorbed the negative effects of rising US tariffs, resulting in global growth of +3.3% in 2025. In the US, resilient consumption and investment, together with an improving trade balance, supported economic activity despite a slowdown in employment growth. On the monetary policy front, the Federal Reserve started the rate reduction cycle, reiterating a strongly data-dependent approach going forward. In Europe, growth remained positive, albeit moderate, with encouraging signs related to fiscal stimulus and increased defence spending in some countries. The ECB confirmed its rate pause during the year, noting that inflation is gradually moving towards its medium-term target, without the need for further action in the short term. In Asia, the focus remains on Japan and China. In Japan, the fiscal stimulus introduced by the new government came back to the forefront as a supporting factor for growth. In China, exports continue to be an important driver of economic activity, while domestic demand remains weak. In 2025, we saw equity market volatility significantly higher than the previous year. The conflict between AI-fuelled optimism and various causes for concern has led to both declines and increases. The most significant swings occurred on “Liberation Day” last April, with Trump announcing reciprocal tariffs that were then widely revised, but even October and November were quite unstable months. It is in this complex and varied context that the Italian macroeconomic figures have to be read. The Italian economy recorded GDP growth of 0.7%, beating the government’s estimates and outperforming that of the traditional European locomotive, Germany, at +0.2%. On the employment front, the employment rate stood at 62.7% (slightly up from 62.4% at the end of 2024), while the unemployment rate fell from 6.4% to 6%. Narrowing the field of analysis to our reference sector, 2025 was another very positive year for the banking sector. The year just ended was the year of great banking risk and the profits of some groups benefited from the growth in size through aggregations. The growing profitability of the main Italian banks was also confirmed by Borsa Italiana investors, with shares in the sector rising by an average of 53%.
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5 | Mediolanum Group - Annual Financial Report 2025 In this particularly favourable context, Banca Mediolanum achieved absolute results in 2025, confirming the soundness and quality of its business model. The year should not be viewed in isolation, but sequenced analysis with previous years confirms a trend of structural growth that began some time ago. We are therefore delighted to present company figures that can be described as exceptional, for which we would like to thank the men and women of Banca Mediolanum, the Family Bankers and the other staff, who, together, have enabled us to achieve an extraordinary set of results. Indeed, 2025 ended with an extremely solid financial result, in the form of record profits of €1.24 billion, up 11% on the previous year. The contribution margin also rose by 7% to €2.11 billion, while the operating margin, amounting to €1.20 billion, grew by 10% compared to 2024. Total assets under management and administration reached a record €155.80 billion, up 12% compared to 2024. Net Commission income reached €1.31 billion, up +12% year-on-year, thanks to the significant contribution of managed net new money and the positive performance of the markets. The portfolio of loans to Group customers stood at €18.98 billion, up 8% compared to 2024, with a minimal percentage of 0.77% non-performing loans as a percentage of the Group’s total loans. The Common Equity Tier One Ratio (CET1), the Bank’s main indicator of solidity, stood at 23%, a level of absolute excellence in the European banking industry. Given these financial results, the Board of Directors has proposed to the Shareholders’ Meeting a total dividend of €1.25 per share, amounting to approximately €924 million, 25% more than in 2024. This figure consists of an interim payment of €0.60 per share, distributed last November, and a balance of €0.65 per share to be distributed in April. The excellent results announced here are also reflected in the employment capacity of Banca Mediolanum, which further increased its workforce in 2025. Currently the Group has a total of 4,042 employees (+6% compared to 2024), alongside 6,798 Family Bankers in Italy and Spain (+6% compared to 2024). Also worthy of note are the figures for new customer acquisition. The customer base exceeding two million: with a total of 2,032,100, an increase of 6% compared to 2024. With regard to Banco Mediolanum, 2025 also confirmed our Spanish subsidiary as a strong reference point in the financial advisory sector in Spain. Last year the trend of strong growth of the Assets Under Management and Administration continued, exceeding €15 billion, recording an increase of approximately 50% in two years, and setting record results in various areas. Net Inflows Under Management were close to €2 billion, up 35% on the previous year. New lending increased by 18% to €408 million. Finally, new customers grew by 12% to 285,750. The results achieved so far can be explained primarily by our ability, despite the ongoing uncertainty and changing circumstances, to remain faithful to the strategic approach we have always pursued, namely to offer families a single point of contact which they can trust for all their financial, banking, insurance and pension needs through a broadly diversified business model. These results reflect the structural solidity of our competitive model which, in 2025 more than ever, realised its full potential with an unprecedented capacity for deposit-taking: Total Net Inflows amounted to +€11.64 billion, up 11%, while Managed Deposits stood at €9.06 billion, up 18% from last year. Both results make 2025 the best year in Banca Mediolanum’s history.
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6 | Mediolanum Group - Annual Financial Report 2025 Further evidence stems from the fact that Banca Mediolanum participated for the first time in the 2025 EU-wide stress test conducted by the European Central Bank (ECB) and the European Banking Authority (EBA), in collaboration with the Bank of Italy and the European Systemic Risk Board (ESRB). The results of the stress test exercise confirmed the extraordinary financial solidity of Banca Mediolanum, as well as the high quality of the portfolio and operating performance. In particular, the impact of the current adverse scenario on capital ratios places Banca Mediolanum at the forefront of Italian banks subject to stress tests and among the top in Europe. These successes would not have been possible without the commitment and dedication of all the Group’s employees. It was for this reason that, in recognition of their brilliant performance in the year just ended, for the fourth time in six years, an extraordinary bonus of €2,000 was paid to each of our more than 10,000 employees and contract staff in Italy and elsewhere. Once again in 2025, the Mediolanum Group continued its focus on the issue of Sustainability, as an integral part of the Group’s values and culture. This commitment is evidenced by the desire to generate added value for all stakeholders: their success guarantees the sustainability of the Group’s business. We would like to conclude by once again thanking you, the shareholders, all our staff, the Board of Directors, you, the shareholders, and all customers of Banca Mediolanum who once again have accompanied us this year, contributing to the achievement of the excellent results presented here. Giovanni Pirovano Massimo Doris Chairman Chief Executive Officer
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7 | Mediolanum Group - Annual Financial Report 2025 CORPORATE OFFICERS OF BANCA MEDIOLANUM S.p.A.
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8 | Mediolanum Group - Annual Financial Report 2025 BOARD OF DIRECTORS Giovanni Pirovano Chairman Massimo Antonio Doris Chief Executive Officer Annalisa Sara Doris Vice Chairman Paolo Gibello Ribatto Director Francesco Maria Frasca Director Patrizia Giangualano Director Carlo Vivaldi Director Giovanna Luisa Maria Redaelli Director Giacinto Gaetano Sarubbi Director Anna Gervasoni Director Francesca Reich Director Giovanni Lo Storto Director Roberta Pierantoni Director Igor Garzesi BOARD SECRETARY Luca Maria Rovere GENERAL MANAGER PricewaterhouseCoopers S.p.A. INDEPENDENT AUDITOR FINANCIAL REPORTING OFFICER Angelo Lietti BOARD OF STATUTORY AUDITORS Gian Piero Sala Standing Auditor Standing Auditor Chairman of the Board of Statutory Auditors Teresa Naddeo Francesco Schiavone Panni CORPORATE OFFICERS
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9 | Mediolanum Group - Annual Financial Report 2025 SCOPE OF CONSOLIDATION AT 31 DECEMBER 2025
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10 | Mediolanum Group - Annual Financial Report 2025 GROUP STRUCTURE Parent Company, Banking Group and Financial Conglomerate Parent Company of the Insurance Group BANCA MEDIOLANUM S.P.A. 100% Mediolanum Comunicazione S.p.A. 100% 100% Mediolanum Gestione Fondi SGR p.A. 93% Mediolanum International Funds Ltd (Irish company) Banco Mediolanum S.A. (Spanish company) 7% 100% Fibanc S.A. (Spanish company) 99.999% Mediolanum Pensiones S.A., S.G.F.P. (Spanish company) 99.999% Mediolanum Gestion S.G.I.I.C., S.A. (Spanish company) 100% Mediolanum Fiduciaria S.p.A. 100% Prexta S.p.A. 100% FloWe S.p.A. – Società Benefit Mediolanum Vita S.p.A. 100% Mediolanum Assicurazioni S.p.A. 100% Mediolanum International Life Designated Activity Company (Irish company) C 100% 100% PI Servizi S.p.A. C 100% August Lenz & Co. AG – IN LIQUIDATION, formerly Bankhaus August Lenz & Co. (German company) (*) C Parent Company (*) August Lenz & Co. AG in liquidation is no longer part of the Mediolanum Banking Group
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11 | Mediolanum Group - Annual Financial Report 2025 CONSOLIDATED HIGHLIGHTS
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12 | Mediolanum Group - Annual Financial Report 2025 THE MAIN RESULTS OF THE MEDIOLANUM GROUP AS AT 31 DECEMBER 2025 OPERATING PERFORMANCE The Mediolanum Group ended the year to 31 December 2025 with a net income of €1,237.9 million, compared to €1,119.6 million in the comparative year. The operating margin for the period under review grew by +9.6% to stand at €1,199.0 million. The contribution margin increased by + €135.7 million compared with the comparative period mainly due to an increase in net commission income of +€145.0 million, versus a reduction in income from other investments of - €11.7 million. Costs for the period were up by -€30.3 million compared with the comparative period. G&A expenses increased by 4.7% to - €770.7 million (31/12/2024: -€736.2 million), mainly due to higher operating costs; net provisions for risks & charges also increased from - €69.3 million on 31 December 2024 to -€83.6 million in the period under review. During the period, there were positive market effects of + €284.7 million, down by - €108.7 million compared with the comparative period, attributable to the decrease in performance fees (-€120.2 million) only in small part offset by the increase in net profit/losses on investments at fair value (+€11.4 million). Ordinary and extraordinary regular contributions to banking industry items recorded a decrease of +€23.3 million compared with the previous year. Ordinary contributions recorded a decrease of +€12.9 million and include the provision for the contribution to the Life Guarantee Fund of - €19.8 million and the provision for the additional contribution of -€2.4 million to the DGS fund. The reconciliation exercise included both the last tranche of the Deposit Guarantee Scheme (DGS) for -€18.9 million and the first allocation to the Life Guarantee Fund for -€16.2 million. Extraordinary contributions (included in the item “extraordinary items”) also decreased by +€10.3 million; it should be noted that in the previous period the -€11.1 million contribution to the banks rescue fund was recognised and is no longer due in 2025, while in 2025 costs of -€0.8 million in costs related to the write-down of the Atlante Funds were recorded. The item Other extraordinary items recorded an increase of + €113.2 million euros and mainly relates to + €140.1 million in positive tax effects relating to the recovery of IRAP paid on dividends received between 2012 and 2024 by foreign subsidiaries (Judgment No. 599 of 1 August 2025 of the European Court of Justice) partially offset by higher costs deriving from effects relating to the discounting of the up-front stamp duty paid on life products, from the commissions of intermediaries who assisted in the sale of the shareholding in Mediobanca and finally from the higher charge for the year compared to the extraordinary bonus awarded to employees and the Sales Network.
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13 | Mediolanum Group - Annual Financial Report 2025 CONSOLIDATED INCOME STATEMENT DATA Main items in the reclassified consolidated income statement 2,285.3 (795.6) (176.7) 812.1 22.1 (31.6) (3.4) (913.3) (22.6) 284.7 91.5 (337.3) 1,237.9 2,035.2 (693.3) (174.0) 811.2 33.8 (32.7) (3.8) (882.9) (35.5) 393.4 (32.0) (335.3) 1,119.6 (1,500) (1,000) (500) 0 500 1,000 1,500 2,000 2,500 Fees income Network fee costs Other fee- related costs Interest margin Net income on other investments Net impairment losses on loans Other income and expenses Total costs of which Regular contributions to banking industry Market effects Extraordinary items Tax Net result €/Million 31/12/2025 31/12/2024
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14 | Mediolanum Group - Annual Financial Report 2025 Commission income: breakdown by type 63.5 1,414.3 269.2 223.5 258.7 56.1 60.5 1,283.9 252.8 199.4 186.9 51.7 0 100 200 300 400 500 600 700 800 900 1,000 1,100 1,200 1,300 1,400 1,500 Entry fees Management fees Investment management fees Net insurance management revenues Banking service fees Other fees €/million 31/12/2025 31/12/2024 Costs: breakdown by type (770.7) (22.6) (36.4) (83.6) (736.2) (35.5) (41.9) (69.3) (800) (750) (700) (650) (600) (550) (500) (450) (400) (350) (300) (250) (200) (150) (100) (50) 0 Administrative expenses Regular contributions to banking industry Depreciation & amortisation Net provisions for risk and charges €/million 31/12/2025 31/12/2024
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15 | Mediolanum Group - Annual Financial Report 2025 Market effects: breakdown by type ASSETS AND NET INFLOWS TO ASSETS UNDER ADMINISTRATION AND MANAGEMENT Assets under administration and management 256.6 28.1 376.7 16.7 0 50 100 150 200 250 300 350 400 Performance fees Net income on investments at fair value €/million 31/12/2025 31/12/2024 155,799.6 139,956.7 15,486.9 356.0 138,493.3 125,043.5 13,075.3 374.5 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 Total Assets under Administration and Management Italy Spain Germany €/million 31/12/2025 31/12/2024
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16 | Mediolanum Group - Annual Financial Report 2025 Net inflows to assets under administration and management CUSTOMERS Trends in the customer base 1,441 Banking Customers including 69% First Bank including 39% Single Bank (*) Total customers of Banca and Banco Mediolanum 2,032 1,746 286 0 500 1,000 1,500 2,000 2,500 Total Group customers (*) Banca Mediolanum (ITA) Banco Mediolanum (SPA) Units/Thousand 11,638.7 9,709.4 1,954.4 (25.1) 10,443.0 8,973.9 1,503.4 (34.2) (1,000) 1,000 3,000 5,000 7,000 9,000 11,000 Total Net Inflows to Assets under Administration and Management Italy Spain Germany €/million 31/12/2025 31/12/2024
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17 | Mediolanum Group - Annual Financial Report 2025 Average assets per customer1 REGULATORY CAPITAL RATIOS Consolidated capital ratios at 31 December 2025 COMMON EQUITY TIER 1 TIER 1 TOTAL CAPITAL RATIO 23.0% 23.0% 23.0% 1 Customers that are primary current account holders with Banca Mediolanum 70.1 72.7 74.8 77.8 79.2 73.4 80.8 84.1 90.0 80.6 84.4 91.8 96.4 20.0 30.0 40.0 50.0 60.0 70.0 80.0 90.0 100.0 Dec-13 Dec-14 Dec-15 Dec-16 Dec-17 Dec-18 Dec-19 Dec-20 Dec-21 Dec-22 Dec-23 Dec-24 Dec-25 €/thousand Average assets per First Bank current account customer
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18 | Mediolanum Group - Annual Financial Report 2025 Evolution of the Common Equity Tier 1 Ratio Other regulatory capital and liquidity ratios 31/12/2025 31/12/2024 MREL TREA 24.9% 25.9% Leverage ratio 9.5% 7.8% Liquidity Coverage Ratio 371.8% 386.6% Capital adequacy of the Financial Conglomerate 2 €/million 31/12/2025 31/12/2024 Financial conglomerate primarily engaged in banking Capital 4,519 4,189 Banking capital requirements 1,994 1,628 Insurance capital requirements 1,502 1,592 Capital surplus (deficit) 1,023 969 2 Capital adequacy at 31 December 2025 was calculated according to the capitalisation limits communicated by the European Central Bank based on the periodic Supervisory Review and Evaluation Process (SREP). The insurance requirements relate to the latest quarterly report (30 September 2025) of the Mediolanum Insurance Group sent to the supervisory authority. 21.9 19.2 19.5 20.4 20.9 20.6 22.3 23.7 23.0 10 12 14 16 18 20 22 24 Dec-17 Dec-18 Dec-19 Dec-20 Dec-21 Dec-22 Dec-23 Dec-24 Dec-25 VALUES EXPRESSED AS A %
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19 | Mediolanum Group - Annual Financial Report 2025 Changes in the capital surplus of the financial conglomerate 2 primarily engaged in banking 237 581 437 396 459 611 602 714 969 1,023 - 200 400 600 800 1,000 1,200 Dec-16 Dec-17 Dec-18 Dec-19 Dec-20 Dec-21 Dec-22 Dec-23 Dec-24 Dec-25 OTHER INDICATORS Information on the stock 31/12/2025 31/12/2024 Number of ordinary shares (units) 745,400,391 745,278,391 Price at end of period (€) 19.47 11.49 Market capitalisation (€/m) 14,513 8,563 Shareholders’ equity (€/m) 4,494 4,026 Earnings per share (EPS) Euro 31/12/2025 31/12/2024 Basic EPS 1.677 1.515 Diluted EPS 1.663 1.498 Credit indicators 31/12/2025 31/12/2024 Gross NPLs 1.50% 1.47% Net NPLs 0.77% 0.79% Cost of risk 0.16% 0.18%
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20 | Mediolanum Group - Annual Financial Report 2025 Cost indicators 31/12/2025 31/12/2024 Cost/Income Ratio 37.6% 39.90% Acquisition costs/Gross Commission Income Ratio 34.8% 34.10% Operational structure UNIT 31/12/2025 31/12/2024 Number of employees 4,042 3,825 Number of financial advisors 6,798 6,415 For the definitions used in this summary of results, please see the Glossary at the end of the document.
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21 | Mediolanum Group - Annual Financial Report 2025 GROUP PROFILE
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22 | Mediolanum Group - Annual Financial Report 2025 GROUP PROFILE Vision, Mission Vision We believe in a better world, built every day for people and for the planet. We believe in human relationships and in a deep bonds based on freedom. We believe that our informed, positive view of the world and of life makes a real difference. Mission Building long-lasting relationships based on deep understanding, loyalty, faithfulness and transparency. Providing personalised, unique advice with effective, life-long solutions. Acting in an innovative and sustainable way for the well-being of people, families and the community.
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23 | Mediolanum Group - Annual Financial Report 2025 … our values There is no greater value than FREEDOM It is the value through which Mediolanum changed the very notion of the bank. The freedom of a genuine, true relationship with people. It is feeling free to achieve your goals and make your dreams come true. People at the centre Human relationships are the foundation of everyone who works at Mediolanum. Building a RELATIONSHIP helps us understand a person’s plans and helping them to manage their savings and achieve a state of wellbeing. Becoming a trusted partner means growing together. RESPONSIBILITY We are people for people We are fully aware of the social role we play. We know how to act ethically and transparently, even when we have to go against the flow to do so. We are committed to solidarity and to education and development projects, implementing tangible measures with a strong social impact. We believe in constant Improvement We anticipate and meet the needs of people, drawing on our history and our roots. We develop innovative solutions to encourage sustainable behaviours in the public interest. SUSTAINABLE INNOVATION is our commitment. POSITIVITY is making the seemingly impossible possible The foundation of this philosophy of life and business is the knowledge acquired, our experience and the certainty of our work. It is always remaining true to this value and conveying this spirit to people. It is being able to seize opportunities where no one sees them.
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24 | Mediolanum Group - Annual Financial Report 2025 THE MEDIOLANUM GROUP’S COMMERCIAL BUSINESS MODEL Banca Mediolanum’s commercial business model is designed to meet the external and internal requirements of each customer. Thanks to its numerous communication channels, customers can choose how to “use” “their” bank, deciding on the timing and arrangements of their preferred relationship on an ad hoc basis. Banca Mediolanum offers simple, easy-to-access products and services that meet the needs of individuals and households, who are its main targets. Through the Family Bankers®, listed in the Single Register of Financial Advisors, Banca Mediolanum helps its customers to manage their savings and provides investment advice in combination with the products and services it offers. Banca Mediolanum does not simply sell products: it offers solutions. This principle enables us to operate in the various business areas of financial services with the expertise and flexibility necessary to respond better to constant economic, taxation, financial and regulatory changes. The investment strategy is the result of careful study of the world markets and the high level of expertise that Mediolanum has developed in asset management, limiting investment concentration risk.
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25 | Mediolanum Group - Annual Financial Report 2025 A BANK BUILT AROUND THE CUSTOMER Integrated Business Model – Banca Mediolanum MOBILE APP WEBSITE AFFILIATED BRANCHES 5,148 FAMILY BANKERS BANKING CENTRE B.MED ITEM INSURANCE INVESTMENT FUNDS BANK CUSTOMER
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26 | Mediolanum Group - Annual Financial Report 2025 CONSOLIDATED REPORT ON OPERATIONS
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27 | Mediolanum Group - Annual Financial Report 2025 REPORT ON OPERATIONS TO THE CONSOLIDATED FINANCIAL STATEMENTS AS AT 31 DECEMBER 2025 The Mediolanum Group ended the year to 31 December 2025 with net income of €1,237.9 million, compared to €1,119.6 million in the comparative period. THE MACROECONOMIC SCENARIO In the last three months of 2025, the global economy continued to hold up well, despite an environment still characterised by geopolitical tensions and trade uncertainties. After a temporary resurgence of tariff tensions, US President Donald Trump and Chinese President Xi Jinping met in South Korea in late October, agreeing to a one- year truce on their trade respective barriers. The deal helped improve market sentiment in the latter part of year. In the US, macroeconomic data overall continued to surprise in a positively manner over the quarter, albeit with atypical characteristics. Resilient consumption and investment, together with an improving trade balance, supported economic activity despite a slowdown in employment growth. This was partly offset by an acceleration in productivity, which helped keep GDP momentum strong. The federal government’s record shutdown, which began on 1st October and ended on 3rd November, temporarily halted the release of some macroeconomic statistics, generating short-term uncertainty, but did not affect medium- to long-term fundamentals. On the monetary policy front, the Federal Reserve continued the rate reduction cycle initiated in September: with a cut in October and one in December, the Fed Funds corridor was increased to 3.5– 3.75%. The central bank reiterated a strongly data-dependent approach for the future. Official projections indicate only one cut in 2026, while the market is pricing in two, in light of the change at the central bank’s top in May. In Europe, growth remained positive, albeit moderate, with encouraging signs related to fiscal stimulus and increased defence spending in some countries. Political and financial tensions, particularly in France, did not compromise the overall stability of the macroeconomic framework, supported by a still solid labour market. The impact of US tariffs has also so far been limited and not likely to significantly alter the economic cycle. The ECB confirmed its rate pause at its October and December meetings, maintaining a 2% deposit rate and noting that inflation is gradually moving towards its medium-term target, without the need for further intervention in the short term. In Asia, the focus remains on Japan and China. In Japan, the fiscal stimulus introduced by the new government came back to the forefront as a supporting factor for growth. In China, exports continue to be an important driver of economic activity, while domestic demand remains weak. In this context, it is crucial to monitor the achievement of medium-term growth targets and development plans, which are increasingly oriented towards innovation and economic and technological independence, also in accordance with the strategic comparison with the United States. All in all, 2025 ended with a global economy more resilient than expected and inflation gradually normalising, albeit with temporary fluctuations. The tilt of major central banks remained accommodative for most of the year, but towards the end of 2025 there was a shift towards more neutral policies. 2026 is thus shaping up to be a year in which rate cuts will play a less central role, with possible divergence between the major economic areas.
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28 | Mediolanum Group - Annual Financial Report 2025 THE FINANCIAL MARKETS Change (bp) Yield Bond markets 31/12/2024 to 31/12/2025 Q4 31/12/2025 31/12/2024 GOVERNMENT YIELDS United States 2 years (76.86) (13.53) 3.47% 4.24% 5 years (65.68) (1.56) 3.73% 4.38% 10 years (40.20) 1.67 4.17% 4.57% 30 years 6.24 11.26 4.84% 4.78% Germany 2 years 4.00 10.30 2.12% 2.08% 5 years 29.40 13.90 2.45% 2.15% 10 years 48.80 14.40 2.86% 2.37% 30 years 88.00 19.70 3.48% 2.60% Italy 2 years (22.00) (4.20) 2.20% 2.42% 5 years (1.60) 8.80 2.85% 2.87% 10 years 2.90 1.70 3.55% 3.52% 30 years 19.40 (6.20) 4.40% 4.21% SPREADS Italy – Germany 2 years (25.99) (14.45) 0.08% 0.34% 10 years (45.87) (12.71) 0.70% 1.15% Spain – Germany 2 years (2.43) 5.54 0.15% 0.17% 10 years (26.10) (11.35) 0.43% 0.69% CREDIT SPREADS Corporate US IG (2.00) 4.00 0.78% 0.80% US HY (21.00) (1.00) 2.66% 2.87% Euro IG (24.00) (1.00) 0.78% 1.02% Euro HY (44.00) 0.00 2.65% 3.09% Emerging EM Hard Currency (42.00) (21.00) 1.78% 2.20% On the bond side, 2025 ended with a moderate recovery in global prices (+8.2% over the twelve months for the Bloomberg Global Aggregate, +0.2% over the quarter). However, for European investors, the rebound in euro- area government yields and the weakening dollar have limited some of the overall returns. The 10-year U.S. Treasury yield ended the year at 4.17%, down about 40 basis points from early 2025, despite a slight rally in the final month of the year. The yield curve gradually steepened, with steeper declines on short maturities. The 10-year Bund ended 2025 at 2.86%, up by around 49 basis points YoY, with a similar curve steepening dynamic. In Italy, the BTP-Bund spread narrowed significantly over the year, from about 115 to 70 basis points. Credit also performed well, ending 2025 with spreads still low and no signs of tension, as did emerging hard currency bonds.
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29 | Mediolanum Group - Annual Financial Report 2025 Change % Equity markets 31/12/2024 to 31/12/2025 Q4 World indices MSCI All Country World 20.60% 3.03% MSCI World 19.49% 2.87% US indices Dow Jones I.A. 12.97% 3.59% S&P 500 16.39% 2.35% Nasdaq Comp. 20.36% 2.57% European indices STOXX Europe 600 16.66% 6.09% EURO STOXX 21.18% 4.92% FTSE MIB 31.47% 5.19% DAX 23.01% 2.55% CAC 40 10.42% 3.21% AEX 8.27% 0.90% IBEX 35 49.27% 11.84% SMI 14.37% 9.56% FTSE 100 21.51% 6.21% Asian indices NIKKEI 225 26.18% 12.03% MSCI China 28.30% (7.60%) CSI 300 17.66% (0.23%) Hang Seng 27.77% (4.56%) Emerging market indices MSCI Emerging Markets 30.58% 4.33% Equity markets ended the year near all-time highs in 2025, marking the third consecutive year of gains. The MSCI AC World global equity index has gained +20.6% YTD (+3.0% last quarter), reflecting an overall resilient macroeconomic environment and better-than-expected earnings growth. In the US, the S&P 500 reached new all-time highs during the year, surpassing the 6,900 mark, only to close slightly below: its annual performance stood at +16.4%, up +2.3% in the fourth quarter. The Nasdaq was up +20.4% in 2025 (+2.6% in the quarter), confirming the still strong contribution of the technology sector. The main support for US equities came from the S&P 500 earnings growth as valuations remained broadly stable throughout the year, albeit at high levels. Over the course of the year, however, investors progressively increased their geographical diversification. In Europe, the Stoxx 600 grew +16.7% year-on-year (+6.1% over the quarter). Among the main national indices, performance was mixed but overall positive: the DAX closed at +23.0% (+2.6% in the quarter), the CAC 40 at +10.4% (+3.2% in the quarter), the IBEX 35 was particularly strong (+49.3% in the year, +11.8% in the quarter), while the FTSE MIB was up +31.5% in 2025 (+5.2% in the quarter). Japan also participated in the global rally, with the Nikkei up +26.2% for the year (+12.0% in the quarter). In Emerging Markets, the search for opportunities supported the overall performance: the MSCI Emerging Markets index ended 2025 at +30.6% (+4.3% in the quarter), while Chinese equities (MSCI China) returned +28.3% year-on-year, albeit with a correction in the fourth quarter (-7.6%).
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30 | Mediolanum Group - Annual Financial Report 2025 Change % Level Currency 31/12/2024 to 31/12/2025 Q4 31/12/2025 31/12/2024 EUR USD 13.44% 0.10% 1.17 1.04 EUR GBP 5.30% (0.10%) 0.87 0.83 EUR JPY 13.04% 6.04% 184.01 162.78 Dollar Index (9.37%) 0.56% 98.32 108.49 Within currencies, 2025 was marked by a significant weakening of the US dollar (the Dollar Index was down -9.4%). This movement reflected cyclical factors – lower perceived exceptionality of the US economy and easing of monetary policy – and structural factors, related to uncertainties about the currency’s reliability in the new policy environment. However, the depreciation was concentrated in the first part of the year, leaving room for a substantial stabilisation in the second half. Finally, Bitcoin ended 2025 down (-6.4%), recording the fourth annual decline in its history and demonstrating a marked decoupling from the trend in equity markets. Change % Level Commodities 31/12/2024 to 31/12/2025 Q4 31/12/2025 31/12/2024 Bloomberg Commodity Index 11.07% 4.84% 109.69 98.76 Oil (Brent) (15.73%) (8.03%) 62.45 74.11 GOLD 64.58% 11.93% 4,319.37 2,624.50 Commodities had a positive year over all (+11.1%), albeit with a mixed performance. Energy was weaker with Brent ending 2025 at $62.4 per barrel (-15.7% in the year, -8.0% in the last quarter). European natural gas finished the year around €28, down sharply year-on-year (-43.4%). Precious metals, on the other hand, performed very well. Gold has surpassed the US$4,500/oz mark during the year, ending 2025 at around US$4,319 with an annual performance of around +65%. Similar trend for silver. Copper, which had its best year since 2009, was also particularly positive, supported by its key role in electrification processes and the development of artificial intelligence, amid concerns over tariffs and supply chains.
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31 | Mediolanum Group - Annual Financial Report 2025 THE INSURANCE MARKET LIFE PREMIUMS3 The table below shows the new production of individual life policies in the first 11 months of the year: New individual life production by business line Euro/000 Class Number of policies Premiums % Change 2025/2024 Class I 2,049,165 57,983,966 1.9% Class III 780 513,039 1.2% Class IV 657,659 28,515,726 24.6% Class V 106,252 73,773 1.8% Class VI 74,054 148,666 22.9% Italian companies - non-EU 2,887,910 87,235,170 8.4% EU companies 10,528,871 18.7% Total 97,764,041 9.4% In the year to date, new life premiums written amounted to €87.2 billion, 8.4% higher than in the same period of 2024, when a year-on-year decrease of 24.7% was observed. Considering also the new life premiums of the sample of E.U. company agencies, total new life business amounted to €97.8 billion, 9.4% more than in the same period of 2024. With regard to premiums broken down according to class, total Class I premiums amounted to €58.0 billion, 1.9% higher than in the same period of 2024 (when they increased by +12.9%). A significant share of new life production related to Class III (in the exclusive form of unit-linked products, mainly linked to “classic” funds, without forms of financial protection or minimum return guarantee). Since January, new business premium income for Class III thus amounted to €28.5 billion, 24,6% more than in the same period of 2024, when an increase of 67.3% was recorded. Since January, new premium income from Class V policies has amounted to €513 million, 1.2% more than in the corresponding period of 2024. For long-term sickness policies (Class IV), in the whole of November 2025, new premiums reached €74 million, up by 1.8% on the corresponding period of 2024, while new contributions relating to the management of open-ended pension funds, which came in at €149 million, were also up by 22.9%. From January, the number of new policies/subscriptions totalled €2.9 million, up 4.9% compared with the same period in 2024. 3 Source: ANIA TRENDS New Life Business – November 2025
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32 | Mediolanum Group - Annual Financial Report 2025 New individual life production by business line Euro/000 Class Number of policies Premiums % Change 2025/2024 Individual pension plans 361,753 1,500,408 16.2% Pure risk contracts 984,559 1,024,960 4.2% Multi-branch 688,218 34,333,870 31.3% PIR 32,186 840,377 176.0% Other contracts 821,189 49,535,555 22.9% Italian companies - non-EU 2,887,905 87,235,170 8.4% With regard to the various types of products marketed, it should be noted that since the beginning of the year, new premiums/contributions relating to individual pension plans amounted to €1.5 billion, 16.2% higher than in the corresponding period of 2024. From January, new premium income from pure risk contracts amounted to €1.0 billion (of which 57% related to policies not combined with mortgages or consumer credit), with a year-on-year increase of 4.2% compared to the same period in 2024. New premiums for multi-class products, excluding social security products and Individual Savings Plans (Piani Individuali di Risparmio or PIR), came in at €34.3 billion, up +31.3% on the same period in 2024. The volume of new business relating to PIR contracts, mostly brokered through bank and post office branches of a small number of companies, has been €840 million year-to-date, almost triple that of the same period in 2024. With regard to premiums broken down by type of premium and distribution channel, with reference to Italian and non-EU companies, since January, single-premium policies have continued to be the most popular option among policyholders, accounting for 96% of total premiums and 60% in terms of the number of policies. In the year to date, the bulk of new business has come from the banking, postal and financial networks, which accounted for 85% of the new premiums written, unchanged from the figure calculated in the same period of 2024.
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33 | Mediolanum Group - Annual Financial Report 2025 NON-LIFE PREMIUMS4 At the end of the third quarter of 2025, the total premiums (Italian companies and agencies) of the Italian direct portfolio in the non-life sector amounted to €36.2 billion, up 6.4% compared with the end of the third quarter of 2024, when the sector recorded growth of 8.2%. This quarter also confirmed the growth trend that resulted in premium income surpassing, for the first time, € 36 billion in the first nine months of the year. The total increase in non-life premiums at the end of September 2025 was due to the growth in premiums in the Non-Motor division (+7.1%), and the Motor division (+5.4%), but above all to the increase in premiums for the Land Vehicles class (+10.0%) and, to a lesser extent, premiums for the Motor TPL class (+3.8%). The gross premiums of the Italian direct portfolio recorded in the non-life segment are provided quarterly by insurance companies operating in Italy and by the Italian branches of companies having their registered offices in European and non-European countries. The survey included all Italian national companies and around 50 agencies of European companies which, in terms of market share, account for more than 95% of total premiums written. For all Italian companies and agencies of EU and non-EU companies, the premiums recognised at the end of the third quarter of 2025 amounted to €36.2 billion, up 6.4% compared with the end of the third quarter of 2024, when premiums written amounted to €33.8 million, increasing by 8.2% year on year. In particular, domestic and non- European companies recorded an increase of 7.0%, while European company agencies saw a more limited increase of 3.3% (previously +10% at the end of June 2025). The following contributed to the increase in premiums at the end of September 2025: significant growth in the non-life classes other than the Motor segment, with premiums up by 7.1%, accelerating compared with the changes recorded at the end of 2024 (+6.2%) but slowing down compared to March 2025 (+9.9%) and June 2025 (+7.6%); a 5.4% increase in the Motor sector, down following the changes in late 2024 (+10.5%), March 2025 (+8.2%) and June 2025 (+7.5%). More specifically, in the Motor segment, TPL liability premiums increased by 3.8% at the end of September 2025. The particularly positive trend in premiums for the Land Vehicles class (+10.0%) was confirmed. The change in the Motor TPL class was consistent both with the increase in the number of insured vehicles (it is estimated that in the first nine months of 2025 these grew by around 1.5% compared with the same period in the previous year) and with growth in the average premium estimated at the end of June 2025 of around 3%. The Land Vehicles class (including fire/theft, all-risk cover, natural events and vehicle glass), with more than €4 billion in premium income at the end of September 2025, grew by 10.0% compared with the previous year. This result, although slightly lower than the +15.8%, +13.1% and +11.6% recorded at the end of 2024, at the end of March 2025 and at the end of June 2025, confirms a positive trend, despite a 4% reduction in new car registrations in the first nine months of the year, as reported by the ACI. The increase in premiums could be linked to possible technical adjustments to theft cover tariffs, due to the uptick in the phenomenon over recent years, and to cover of natural events and vehicle glass, made necessary by the increased frequency of natural disasters in Italy and the consequent increase in reinsurance costs for companies. The other non-life classes recorded total premium growth of 7.1% at the end of September 2025, mainly driven by the Sickness and Fire classes. Thus: 4 Source: ANIA TRENDS Quarterly Non-Life Premiums – Q3 2025 data
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34 | Mediolanum Group - Annual Financial Report 2025 the sickness insurance business, with premiums of €3.7 billion and an increase of 12.6%, confirms the positive trend in recent quarters; the Fire line of business, with approximately €2.9 billion in premiums, increased by approximately 18% on an annual basis. This was aided, on the one hand, by the increase in premiums (estimated at 3%) attributable to the gradual application of the Cat Nat insurance obligation for companies introduced by the Budget Law and, on the other hand, the entry into the observation perimeter of captive companies specialising in the coverage of these risks (estimated at around 4%). Growth was also seen in the Accident class (with premiums of €3.0 billion and an increase of 2.7%), Other damage to property (with premiums of €3.4 billion, an increase of 4.7%) and TPL General, accounting for €3.8 billion in premiums, up 1.5%. At the end of September, the Miscellaneous Financial Loss, Legal Protection and Assistance classes continued to expand, with increases of +10.3%, +4.5% and +9.6%, respectively. Credit and Suretyship classes also grew (+3.5% and +9.1%, respectively). In the first nine months of 2025, the agencies of companies with registered offices in European countries alone booked premiums of €5.5 billion, up by more than 3% compared to the end of September 2024, (up +10% in June 2025). It should be noted that in the second half of 2025, an important portfolio was transferred abroad to LPS and thus exited the scope of recognition, reducing the change in total premiums compared to 2024. These companies contributed 15.1% to total premium income: 10.7% in the Motor segment and 18.2% in the other non-life classes. For some classes, the percentage exceeded 40%, such as Goods in Transit (43.6%), Aircraft TPL (50.6%) and Credit (83,0%). In contrast, it was very low in the Railway Rolling Stock (absent) and Sickness (6.4%) classes. Motor premium income increased by 3.2%. Motor TPL premiums rose (+2.4%) (previously 25.4% at the end of June 2025) as well as those in the Land Vehicles category (+5.4%, previously +16.8% at the end of June 2025) whereas Non-Motor division premiums rose by 3.4% (+5.1% at the end of June 2025). In particular, General TPL, whose premium income from company agencies (€1,061 million) makes up about a quarter of the total, recorded a slight decrease of 0.2% at the end of September 2025. Among the most representative classes, which accounted for more than €400 million, there was growth in the Accident class (€412 million, +0.1%) and a decrease in the Credit class (€535 million, -0.6%) and the Other Damage to Property class (€430 million, -4.4%).
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35 | Mediolanum Group - Annual Financial Report 2025 THE BANKING MARKET5 BANK FUNDING According to SI-ABI’s initial estimates, in December 2025 customer deposits in all banks operating in Italy – consisting of deposits of resident customers (current account deposits, term deposits, net of those associated with the assignment of debts, deposits redeemable on notice and repurchase agreements; deposits are net of transactions with central counterparties) and bonds (net of those repurchased by banks) – amounted to €2,137 billion, up 2.0% year-on-year (+2.6% in the previous month). In detail, resident customer deposits (current account deposits, term deposits net of those related to the sale of receivables, deposits refundable on notice, repurchase agreements net of transactions with central counterparties) in the same month stood at €1,869 billion and increased by 2.1% (+2.7% in the previous month). Medium and long-term funding through bonds rose +1.1% compared with the previous year (+1.9% in the previous month). Bonds amounted to €268 billion. Foreign deposits increased in November 2025, year on year: in particular, Italian bank deposits amounted to approximately €506.2 billion, +23.4% on the previous year. Foreign deposits accounted for 16.7% of total deposits (14.5% in the previous year). Net funding inflows from abroad between November 2024 and November 2025 were positive at around €95.9 billion. In November 2025, net foreign deposits (foreign deposits minus foreign loans) amounted to €134.8 billion (+8.4% trend change). They represented 7.9% of total domestic lending (7.4% a year earlier), while foreign lending – on the same date – amounted to €371.4 billion. The ratio of foreign loans to foreign deposits was 73.4% (69.7% a year earlier). BANK LENDING According to initial SI-ABI estimates, total loans to Italian residents (private sector plus general government, net of repurchase agreements with central counterparties) stood at €1,663.8 billion in December 2025, an increase of +1.1% over the year (+1.4% in the previous month), calculated including loans not recognised in bank balance sheets because they are securitised and net of changes in outstanding amounts not linked to transactions (e.g. changes due to exchange rate fluctuations, value adjustments or reclassifications). In the same month, loans to Italian residents in the private sector amounted to €1,437 billion, up by + 1.6% compared with the previous year. Loans to households and non-financial corporations stood at €1,294 billion, up 2.3% year on year11 (+2.1% in the previous month). 5 Source: ABI MONTHLY OUTLOOK –January 2026 - Summary
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36 | Mediolanum Group - Annual Financial Report 2025 INTEREST RATE SPREADS With regard to flows, the margin in Italy, calculated in December 2025, as the difference between lending and borrowing rates for new transactions with households and non-financial corporations, was 213 basis points (143 basis points in June 2022, before the rise in official interest rates). The spread between the average rate on Euro-denominated interest-bearing assets vis-à-vis households and non- financial corporations and the average rate on Euro-denominated customer deposits (held by households and non-financial corporations) was 2.55 percentage points in Italy in the same month (2.54% in the previous month). The margin on loans issued to households by banks in the main European countries (calculated as the difference between interest rates on new loans and a weighted average rate on new deposits by households and non- financial corporations) was 118 basis points in Italy in November 2025, lower than the 183 points in Germany and higher than the 80 points in Spain and France. NON-PERFORMING LOANS In November 2025, net non-performing loans (i.e. total bad debts, probable defaults and past due exposures and overdrafts calculated net of write-downs and provisions already made by banks) decreased to €29.7 billion, from €30.1 billion in June 2025 ( €31.3 billion in December 2024). Compared to their peak level of €196.3 billion reached in 2015, they are down by €167 billion. In the same month net non-performing loans accounted for 1.42% of total loans. In June 2025, this ratio was 1.46% (1.51% in December 2024; 9.8% in December 2015). SECURITIES PORTFOLIO Based on SI-ABI initial estimates in December 2025, the total securities in the portfolio of banks operating in Italy amounted to €582.5 billion, down from the previous month (€587.1 billion). According to official Bank of Italy figures updated to November 2025, the value of government bonds on bank balance sheets stood at €396.3 billion, corresponding to approximately 67.5% of the total portfolio. HARMONISED INTEREST RATES IN ITALY AND THE EURO AREA The latest available data on interest rates applied in the euro area indicate that the rate on new bank loans of up to €1 million issued to non-financial corporations was 3.85% in November 2025 (3.82% in the previous month; 4.74% a year earlier), compared with the 4.10% recorded in Italy (4.12% in the previous month; 5.07% a year earlier). The rates applied to new loans to non-financial corporations in amounts in excess of €1 million in the same month were 3.24% on average in the Eurozone (3.26% in the previous month; 4.26% a year earlier), compared with 3.16% in Italy (as in the previous month; 4.15% a year earlier). Finally, in the same month, the rate on current accounts and revolving loans to households was 7.24% in the Eurozone (7.32% in the previous month and 7.96% a year earlier) and 4.67% in Italy (4.73% in the previous month; 5.74% a year earlier).
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37 | Mediolanum Group - Annual Financial Report 2025 THE ASSET MANAGEMENT MARKET6 The figures in Assogestioni’s “2025 Quarterly Map” show that the Italian asset management market ended the third quarter with assets at a record €2,600 billion, chalking up €14.2 billion in the quarter, up sharply from €10.6 billion. Assoreti’s Quarterly Report for the third quarter of 2025 shows that net inflows into financial products and investment services, in the first nine months of 2025 amounted to €41.5 billion, an increase of 19.5% compared to the same period in the previous year ( €34.8 billion). This growth dynamic is attributable to inflows from products in the managed segment, which attract net resources of €26.3 billion (+71.9% YoY). With regard to mutual funds, net inflows amounted to €14.2 billion (+78.1% year-on-year), while net inflows into insurance and pension products amounted to €8.3 billion, more than double the amount in the first nine months of 2024 (+113.6% year-on-year), and business in terms of individual portfolio management totalled €3.9 billion (+11.3% year-on-year). In the first nine months of 2025, net resources for managed financial instruments amounted to €14.5 billion and the flow of net resources into current accounts and deposits was positive at €699 million. At the end of September 2025, the portfolio managed by the Networks of Financial Advisors Authorised to Offer Off-Premises achieved a total valuation of €978.3 billion, a new historical record. Compared to June 2025, the portfolio grew by 3.8%, while the comparison with September 2024 showed an increase of 11.2%. Asset management products amounted to €605.8 billion, up +4.1% on the previous quarter and +10.8% year-on-year. Assets relating to products of the managed segment, on the other hand, stood at €372.5 billion, an increase of 3.2% on the previous quarter and of 11.7% compared to the value in September 2024. In the first nine months of 2025, net inflows into asset management products issued by companies belonging to the same group as the distributing company was positive and amounted to €17.6 billion, up 45.5% year on year, while net investments in products issued by companies outside the group almost tripled to €8.7 billion compared to the previous year (+171.3% YoY). In terms of assets, the end-of-quarter valuation of the products of the group to which it belongs reached €427.6 billion (+10.7% YoY), accounting for 70.6% of assets associated with the managed segment, while 29.4% is made up of third-party products, which amounted to €178.2 billion euros (+11.2% YoY). 6 Source: Assoreti “Activities of the networks of financial advisors authorised to operate off-site”, third quarter 2025; Assogestioni “Quarterly asset management map”, third quarter 2025.
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38 | Mediolanum Group - Annual Financial Report 2025 TREASURY MANAGEMENT Banca Mediolanum The overall net amount of investment in debt securities at the end of 2025 stood at €13,659 million, down €2,038 million from €15,697 million at the end of 2024. €/million 31/12/2025 31/12/2024 Change Financial assets held for trading 299 300 (1) Financial assets measured at fair value through other comprehensive income - 20 (20) Financial assets measured at amortised cost – Debt securities 13,360 15,377 (2,017) Total 13,659 15,697 (2,038) Compared to the total redemption figures for 2025 (€6,262 million), investments made amounted to €4,262 million as a result of purchases of €2,000 million paid earlier in the previous year in order to take advantage of the most favourable market conditions. Over the course of the year, the market saw yields rise in the first quarter and then decline thereafter throughout the second quarter, stabilising at those levels for the rest of the year. From a strategic standpoint, the purchases made during 2025 focused mainly on fixed-rate securities, thereby taking advantage of bond yield levels which, despite the central banks’ normalisation of rates, remained attractive, albeit lower than the previous year. The amount of floating rate securities purchased in 2025 replaced only partially maturing variable rate securities, thus obtaining greater banking book exposure to fixed rates. The securities purchased in 2025 were classified in the strategic ‘Held to Collect’ portfolio. The maturity of the last bond in the Held to Collect and Sell portfolio was reduced to zero in October 2025. Trading ended the year with a portfolio in line with the end of 2024, with most of the bonds heading towards redemption in 2026. The following guidelines were taken into account for new investments made in 2025: 1) issuer diversification; 2) mainly purchases of fixed-rate and securities with a residual life (only 24% of total purchases), including floating- rate securities; 3) the classification of all purchases in the HTC portfolio. In 2025, the process to geographically diversify the issuers in the portfolio banking book (70% concentration in Italian government bonds and 30% in bonds issued by other countries) continued. At the Group level, the percentage of securities issued by countries other than Italy rose to 30.4% (Italian government securities at 69.6%), in line with guidance received from the supervisory authority (the ECB).
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39 | Mediolanum Group - Annual Financial Report 2025 In order to achieve this objective, bonds were purchased (almost all are government bonds) issued by the French Treasury and issues by supranational bodies and organisations linked or subordinate to national central governments. The Held to Collect portfolio, valued at amortised cost and considered by investment policy as the preferred classification for investments in securities, decreased by €2,017 million. All 2025 purchases were classified in the same portfolio, which, net of maturing securities, saw a decrease in the balance of €15,377 million at the end of 2024 to €13,360 million at the end of 2025. The amount of the HTCS (Held to Collect and Sell) bond portfolio, measured at Fair Value to Other Comprehensive Income, went down to zero after the last bond in the portfolio matured. It should be recalled that the HTCS (Held to Collect and Sell) portfolio no longer includes the Mediobanca equity investment following its disposal in July 2025, consolidating the amounts set aside for reserves. The debt securities trading portfolios, measured at Fair Value through P&L (financial assets and liabilities held for trading) ended 2025 with a balance of €299 million, stable compared with 2024. The trading portfolio maintained its historical characteristics of short duration and, equally historically, the composition remained unbalanced between government bonds and a lower percentage of financials. Overall, the weight of government bonds (Italian and Eurozone issuers) in total owned portfolios is 95.22%, down slightly from 94.6% at the end of 2024, while the remainder consists of bonds issued by supranational entities, central government-linked entities and financial covered bonds. The breakdown of portfolios by rate type is 69% fixed rate and 31% variable, confirmation of the transformation embarked on in previous years. All investment instruments are denominated in euro with no exposure to currency risk. The average duration of the portfolios stood at 2.55 compared to 1.7 at the end of 2024, up due to investments in Italian government fixed-rate bonds made to take advantage of yield opportunities on the long end of the curve, while remaining consistent with the group’s traditional low risk profile. With regard to equities, all significant positions were liquidated: Mediobanca, Nexi and almost all of Visa were classified in different portfolios, consistent with the strategic view on stocks. Main economic items €/million 31/12/2025 31/12/2024 Change Net interest income 589.3 599.9 (10.6) Net gains (losses) from trading 20.0 6.4 13.6 Net gains (losses) on the sale of financial assets 1.5 - 1.5 Total 610.8 606.3 4.5
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40 | Mediolanum Group - Annual Financial Report 2025 At the end of 2025, the financial margin increased to €610.8 million compared with €606.3 million at the end of 2024 (+€4.5 million). Also for 2025, the contribution of the net interest income of the securities portfolio remains high, which benefited from its positioning in fixed rate compared to variable rate at the same time as the increase in the average duration of the banking book; this improves the net result of trading activities. In fact, positions measured at fair value (trading assets) posted a positive result of +€20.0 million compared to the end-of-2024 figure of €6.4 million, a fall of €13.6 million, to which the sale of Nexi shares and almost the entire shareholding in Visa shares - both measured at fair value - had a decisive impact. Net interest income decreased to €589.3 million at the end of 2025 from €599.9 million at the end of 2024 (- €10.6 million). Banco Mediolanum As far as Banco Mediolanum’s treasury asset management is concerned, the total investment in securities at the end of 2025 amounted to €1,837 million, slightly down from €1,945 million at the end of 2024. In line with the parent company, Banco Mediolanum’s securities purchase strategy included the entire classification of new purchases in the HTC (Held To Collect) portfolio, which remains the only proprietary portfolio with open positions (HTCs and Trading Book have no positions). Securities purchases during 2025 focused on Italian, Spanish and French government bonds, which accounted for 100% of the securities in the portfolio, most of which are variable-rate. In terms of concentration risk, Banco Mediolanum holds 64.8% of its total HTC portfolio in Italian government bonds and 35.2% in Spanish government bonds. The composition of the portfolio by type of rate is 60.6% fixed-rate and 39.4% floating-rate, a substantial change from previous years which were characterised by floating-rate securities. All investment instruments are denominated in euro with no exposure to currency risk. At the end of 2025, the financial margin stood at €53.8 million (31/12/2024: €65.4 million).
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41 | Mediolanum Group - Annual Financial Report 2025 TRADING IN CUSTOMER SECURITIES 2025 saw moderate global growth accompanied by a slow and gradual decline in inflation. There were also numerous events that affected markets during the year, three categories of events that can be summarised as geopolitical tensions; central bank decisions and macroeconomic data. In the first category, trade wars and tariffs were in evidence; the stance adopted by President Trump was the main cause of the stock market collapse in April 2025. The second category includes interest rate cuts by the ECB and the FED, and the third refers to the growing focus on artificial intelligence (AI) and related emerging technologies, as well as the rally in precious metals linked to the backdrop of global tensions. Equity indices performed well, both in Europe the FTSEMib +30%, the EuroSTOXX50 +18%, the DAX +23%, the FTSE 100 +21%, the IBEX 35 +50%, and overseas, in the US the DOW JONES +13%; S&P 500 +16% and the NASDAQ +20%. The government bond market entailed the usual success of placements, and strong demand from both institutional investors and small savers. The total traded volumes for retail customers were up sharply from the previous year at around €18.3 billion, compared to €16.7 billion in 2024 (+9.6%). 1,137 thousand trades were executed, up 17.8% compared to 965 thousand in the previous year. The total value brokered on the Italian stock market was approximately €8.4 billion, +25% compared to 2024. There was also a significant increase in the total value traded on foreign equity markets, to €2.28 billion. Given the 2024 levels (€2.07 billion) this segment is in a further phase of growth of +10%. The traded value of government bonds, which went from €5,8 billion in 2024 to €5.08 billion in 2025, a dip of 12%. The total value of assets under administration held by retail customers at the end of 2025 stood at approximately €14.681 billion, an increase of 25% compared to December 2024. Specifically, the stock of government bonds increased from €5.2 billion at the end of 2024 to €6.05 billion at the end of 2025. While corporate and bank bonds rose overall by +35% to €0.69 billion, the stock of Certificate MedPlus rose from €3,4 billion to €3.7 billion. The value of securities in the equity segment (Italian and foreign) rose to €4.42 billion (+38%), with the Italian segment at €3.44 billion and the foreign segment at €0.98 billion. At the end of December 2025, repurchase agreements for approximately €7.96 million were in place with customers. A total of 128 placements of Medplus Certificates (including 80 customised issues) took place during the year, of a total value of €1.811 billion. The value of MY STYLE asset management increased from €1,480 million in 2024 to €1,762 million in 2025, up +19%. A comparable increase was recorded for WEALTH asset management, which rose from €154 million in 2024 to €311 million in 2025, +101%.
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42 | Mediolanum Group - Annual Financial Report 2025 NEW PRODUCTS AND MAIN INITIATIVES DURING THE YEAR BANKING SERVICES In 2025, Banca Mediolanum continued to support its customers, confirming the initiatives dedicated to those experiencing financial difficulties or belonging to disadvantaged categories, through ad hoc current accounts, such as the “Conto Accoglienza”, the “Conto Mediolanum Tutor” (dedicated to customers with guardians, the disabled, the incapacitated) and the “Third Sector Entity Account” (designed for organisations operating for civic, solidarity and social utility purposes, not for profits registered on the Single National Register of the Third Sector). Measures were also taken in favour of customers on certain cost items of “Basic Accounts”. The Bank also took the opportunity arising from the “Instant Credit Transfers in Euro Regulation” (Regulation (EU) 886/2024) to improve access to instant payment options for all holders of a bank account in the European Union. Two key steps: 9 January 2025, the introduction of fee parity between SEPA Instant Transfer and SEPA Ordinary Transfer and the introduction of SEPA Instant Transfer in all banking channels and in all accounts in the catalogue (receipt). The Bank has planned to cancel fees for all of 2025 (an initiative renewed until June 2026). For SelfyConto, on the other hand, given the nature of the account, and the positioning of its main competitors, the pricing of SEPA credit transfers (ordinary and instant) was contractually reset to zero in March 2025. 9 October 2025, the introduction of verification of correspondence between the IBAN and the name of the beneficiary for all SEPA credit transfers (known as Check IBAN) and activation of the function for sending instant transfers for current accounts that did not provide this facility. According to the Regulations, customers must also be permitted to set daily/per transaction limits and to implement the instant functionality for all types of SEPA bank transfers (e.g. scheduled, recurring). During the year, the Bank extended its offer to complete the ancillary services offered to current accounts, with reference to the cash management service. From mid-May the following are available: Maxiprelievo Euronet, for cash withdrawals for amounts exceeding €250 (known as Circular withdrawal), up to €1,000 in a single transaction, at ATMs installed by the company Euronet in Italy (free of charge for the whole of 2025 and until June 2026); it should also be noted that in the last quarter, Euronet ATMs were installed in the Special FBOs in Padua and Siena. Maxiprelievo UniCredit, which allows cash withdrawals of more than €250 (i.e. Circular withdrawal) up to €1,000 in a single transaction/day at UniCredit ATMs in Italy (free for the whole of 2025 and until June 2026). Increase in the value of the monthly maximum cash payment at Mooney affiliated points-of-sale from €4,999 to a maximum of €10,000 (again, the service is free until July 2026). In the second half of the year, the cash payment function was activated at the Unicredit Group’s Evoluti ATMs in Italy (from 30 July it is possible to pay in €5 notes with no limit on the amount, except based on the capacity of the individual ATM) and the payment of bank drafts and bank cheques issued in Italy (a facility in operation since 23 September). This type of operation is also free of charge until June 2026.
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43 | Mediolanum Group - Annual Financial Report 2025 The Bank has carried out an overall review of existing collaborations with other operators and banks (Intesa Sanpaolo, Mooney, Unicredit and Euronet) and in view of market developments and the level of customer satisfaction regarding the new services offered since 2025, it was decided to terminate the multi-year agreement with Poste Italiane. As of 1 January 2026, customers can no longer use the payment and cash withdrawal service or issue cheques at the post offices of Poste Italiane. With regard to the world of interest rate offerings, the main promotional initiatives were renewed in 2025, with certain interventions decreasing, mainly as a result of the performance of the reference market. Specifically: Offer rates on 6-month blocked funds differentiated by profiles: current rate of 1.75% for clients classified as Black, Elite and Privilege and 1.25% for the remaining profiles (renewed until 31 March 2026). In addition, in the second quarter we launched the facilitated release initiative on standard time deposits. This new feature enables customers to receive the interest accrued from the day of establishment of the deposit until the day on which the early release is effected, at no additional cost. Promotion of the “Double Chance” investment strategy (standard creditor rates unchanged on both equities and bonds over short and long durations). Specifically: 2.50% per annum gross for the equity sub-fund, duration 3/6/12 months; 1.25% per annum gross for the equity sub-fund, duration 18/24 months; 1.00% per annum gross for the bond sub-fund, duration 3/6/12 months; and 0.50% per annum gross for the bond sub-fund, duration 18/24 months. “Promo vincoli” with a 4% annual gross rate on six-month time deposits subscribed by new and existing customers (with different eligibility requirements) that contributed new liquidity during the validity period of the promo (first slot: 10/01/2025 - 10/03/2025, then renewed from 29/08/2025 to 30/11/2025, paying 3% gross per annum. The initiative providing for the remuneration on free current account balances over €15,000 and up to €1 million for Elite and Black clients was renewed but only until 30 June 2025, in view of the market scenario of falling rates and the desire to promote the conversion of assets into value. With regard to mobility services, during the year, the Telepass initiative was launched, which generally provides for zero fee for a certain period of time and the payment of cashback. To date it is still part of the formula: 12 months zero fee for new subscribers of the Telepass Family, in addition to free shipment of the device and cashback of up to €30 on the motorway journeys in Italy. In addition, from the end of October 2025, the new Telepass request channel was launched via APP BMED, recording an increase in requests from the very first days, thanks to its simplicity and speed of use. Cards With a view to reducing environmental impact, the digital version of the current Mediolanum debit card on the Mastercard Circuit was introduced in December 2025. The zero-fee digital debit card allows you to make online purchases and pay at the same time using a smartphone or smartwatch while you can use the Mooney service to withdraw cash. Subsequently you can request a physical version of the digital card which stores the same information e.g. PIN, expiry date. In the area of value-added products and services dedicated to Banca Mediolanum’s best customers, in mid- December the product offer was enriched with the Centurion card, the exclusive credit card of American Express. In terms of commercial initiatives, activities to promote the penetration and use of digital payments throughout the customer base continued in 2025 through promotional campaigns carried out in collaboration with Nexi and American Express.
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44 | Mediolanum Group - Annual Financial Report 2025 Trading In view of the good results achieved between July and December, the promotion on pricing for securities trading has been extended until 30 June 2026. Promotional pricing, intended for customers who carry out more than 10 transactions each month, for new customers and customers under 30 years of age, provides for a flat fee of €7 (compared with a percentage fee of 0.19% with a minimum of €7 and a maximum of €29) on all Italian and foreign financial markets accessible through Banca Mediolanum. The current promotional pricing therefore, compared to previous promotions, provides for the equalisation of trading fees on all markets, without distinguishing between the various financial instruments, in order to facilitate and make online trading more attractive and accessible. CREDIT Credit services In 2025 Banca Mediolanum proposed commercial initiatives to enrich the product offering in Credit Products with the aim of improving the positioning of products following the gradual reduction in interest rates defined by the ECB. Mortgages The “Step 10 Mixed Mortgage Rate” promotion was renewed and the promotion which provided for a reduction to zero of account set-up costs for the Mediolanum Eco+ loan was reformulated and applied up until 31 December 2025. Banca Mediolanum repriced the list for the entire range of loans, with changes in spread in favour of customers. In addition, the “entry rate” promotion was renewed with a dedicated ceiling, with a fixed rate for the first 18 months (2.60% for Black, Elite and Privilege customers and 3% for all other profiles), followed by a floating rate until the end of the plan. This promotion ended on 14 July 2025. The “after-sale” option was activated throughout the loan range, with a discount of 15 bps if the financed property improves by at least one energy class during the term of the loan. Credit lines With the aim of creating a service differential for customers with substantial assets, in June the bank introduced soft pricing for Mediolanum loans and credit lines, a new Fixed Rate loan with a soft spread and lower loan set-up costs, and a promotion for a variable rate loan with a cap and a narrow spread. Loans In order to improve market positioning, in 2025, Banca Mediolanum undertook a series of re-pricing measures for customers. In particular, adjustments were made to the list of loans to third-sector entities and temporary promotions were introduced on the SelfyCredit Instant digital loan and the Mediolanum Credit loan. In addition, the SelfyCredit Instant loan was upgraded with the option to subscribe via Internet Banking. Throughout 2025, as a result of the change in the macroeconomic situation from the end of 2022 onwards, the bond segment was able to offer attractive returns for customers, and this opportunity was taken up by Banca Mediolanum, which launched the marketing of the Mediolanum Obbligazionario Italia fund of Mediolanum Gestione Fondi at the end of 2024. This instrument, which mainly invests in corporate bonds of Italian companies, aims to achieve growth in capital invested over a 5-year time horizon. In addition, if maintained for at least 5 years, the product qualifies for the tax benefits provided under the 2017 Budget Law (as subsequently amended). In this regard, Banca Mediolanum made the Mediolanum Obbligazionario Italia fund available to its customers throughout 2025.
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45 | Mediolanum Group - Annual Financial Report 2025 During Q2 2025, the Mediolanum Best Brands Irish fund of Mediolanum International Funds, distributed by Banca Mediolanum, was enhanced with the new Mediolanum World Innovative Leaders sub-fund. The aim of this tool is to achieve long-term capital growth by focusing on companies that, by innovating and optimising their processes, are able to generate sustainable growth, as well as companies that, through technological investment, promote environmental, social and governance (ESG) characteristics, optimising the use of resources and improving supply chain management and worker conditions. This instrument is also classified as Article 8 according to European Regulation 2019/2088 (“SFDR”). At the same time, in order to constantly monitor the offering and always take advantage of the best opportunities on the market, the European Small Cap Equity fund of Mediolanum Best Brands altered its investment policy, changing from a European equity fund to a global equity fund, and was consequently renamed Global Small Cap Equity. During Q3, Banca Mediolanum launched the marketing of Private Markets Italia III of Mediolanum Gestione Fondi. The fund follows the success of SME I and II funds, and allows Clients access to the unlisted market, which is an important tool for diversification and offers interesting growth potential. The investment in the fund has a long-term horizon and allows participation in alternative investments, mainly in small and medium-sized Italian companies. Finally, the product also benefits from the typical tax advantages provided for in the legislation for alternative PIRs, such as capital gains tax exemption after five years and inheritance tax exemption. The placement of this product also continued during the fourth quarter of 2025, during which the first placement window closed; a new window is expected to open for the first quarter of 2026. Unit-linked policies In May 2025, the policy marketed by Banca Mediolanum – Mediolanum Intelligent Life Plan of Mediolanum Vita S.p.A. – was enhanced by a new internal insurance fund called the Conservative Bond Fund. This investment solution allows both new customers and those already insured to have greater diversification of their investment, by selecting lower-risk instruments, with the aim of making the most of the opportunities offered by the markets. The new internal insurance fund has a portfolio composition orientated towards bond financial instruments (up to 100%), with the Manager being able to invest on a residual basis in financial instruments representing risk capital. In addition, during the first half of 2025, the new Mediolanum World Innovative Leaders solution of Mediolanum International Funds was included in the entire Mediolanum MyLife unit-linked policy of Mediolanum Vita. Mediolanum My Style and My Style Wealth During the first half of 2025, the new Mediolanum World Innovative Leaders solution was added to the “Mediolanum My Style” and “Mediolanum My Style Wealth” portfolio management service. MEDIOLANUM MEDPLUS CERTIFICATE The sale of certificates continued throughout 2025 with various pay-offs and durations, giving customers the option to receive a specific benefit within an equally well-defined time frame. In addition, during the first quarter of the year, a new conditionally protected capital structure was marketed – whose barrier is observed only at maturity – called the “Coupon Memory Opportunity”, which provides quarterly conditional coupons with memory effect. PROTECTION Over the months, Banca Mediolanum has promoted the importance of protection to safeguard the life projects of its customers and their families.
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46 | Mediolanum Group - Annual Financial Report 2025 In addition to the usual commercial and communication initiatives launched by the Bank, the Italian companies of the Mediolanum Insurance Group have made a significant segment rebranding of stand-alone policies. The offer was then redefined through words that represent a root common to all forms of cover, i.e. “Mediolanum” to maintain the brand identity, and “Protection”, to transfer the values of care, protection and peace of mind in a concrete and immediate manner. This initiative has been configured as a contractual change for existing customers holding protection policies. Personal policies The “Personal Life Serenity Promotion, January 2025 edition” targeted customers who subscribed at the end of 2024 to an investment product, including insurance, with an accumulation plan, and subsequently to the term life insurance policy “Mediolanum Personal Life Serenity” (now “Mediolanum Protezione Vita”) of Mediolanum Vita S.p.A. with sum insured of at least €200,000, and offering 2 months premium in the first year. “Promo Protezione ed. Maggio 2025” (Protection Promotion, May 2025 edition), which rewarded customers who simultaneously took out at least two policies, including “Mediolanum Personal Life Serenity (now “Mediolanum Protezione Vita”) of Mediolanum Vita S.p.A., “Mediolanum Capitale Umano” (now “Mediolanum Protezione Persona”) or “Mediolanum Capitale Casa e Famiglia” (now “Mediolanum Protezione Casa e Famiglia”) of Mediolanum Assicurazioni S.p.A, with 3 months’ free premium in the first year for the second policy taken out and an Amazon voucher. The theme of the importance of protecting oneself in a context marked by profound economic, social and climate change, and in view of the increasing longevity of people, has been promoted through the talk show programme “Shape your Future” in Italy and on national tour. To support the protection of “health”, Banca Mediolanum renewed the “Mediolanum health corner contest” several times during the year; this involves the drawing of prizes among customers participating in “Health Corner” events in Italy where it is possible to undergo a set of measurements made with a specific tool to investigate their lifestyle and receiving a summary of the parameters recorded and a QR Code to access a detailed report. Mediolanum Protezione Casa e Famiglia (formerly “Mediolanum Capitale Casa e Famiglia”) The “home” theme has been of particular and growing importance in recent years, also in view of the effects of climate change, which is a “new normal” to take into account. During the first half of the year, Banca Mediolanum therefore proposed the “Promozione-Capitale – Casa e Famiglia” policy to raise awareness among customers of the “Mediolanum Protezione Casa e Famiglia” policy of Mediolanum Assicurazioni S.p.A., where suitable for their particular insurance needs; in fact, a waiver of the first 3 months’ of the annual premium was planned for subscribers to the policy opting for Property cover – Fire all risks, Property - Civil Liability, Property - Legal Protection in the Home section and the optional additional Property cover for Earthquake and flood and an option to pay the premium in monthly instalments. SelfyCare The March 2025 version of “Promo Self” rewarded subscribers to specific types of products with an Amazon voucher; these products included insurance products, investment products, mutual funds and individual portfolio management services.
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47 | Mediolanum Group - Annual Financial Report 2025 In addition, with a view to responding increasingly better to the needs of its customers, Banca Mediolanum extended to Selfy customers the option of subscribing, in combination with the unsecured loan granted by Santander Consumer Bank and distributed by Banca Mediolanum S.p.A., the optional individual Credit Life policy, again offered by Santander, which provides for cover against the risks of death and permanent total disability from accident and/or illness for all occupational categories as well as loss of employment or total temporary incapacity depending on their employment status at the time of subscription. Mediolanum Capitale Key People The protection of “human capital” plays a particularly important role in protecting against the most significant risks, especially when our business clients also feel a need for protection in the professional sphere as well as “personal”. In 2022, Banca Mediolanum’s distribution offer was enriched with an insurance product dedicated to legal persons wishing to protect the continuity of their business from unforeseen events (Death, Permanent Total Disability and Temporary Total Incapacity from any cause) that affect key figures in the company. Three years after the start of distribution, taking into account customer requirements collected through the Sales Network, the offer was renewed, with distribution - replacing the previous offer - of the “Mediolanum Protezione KeyPeople” product - starting in November. SUSTAINABILITY OF PRODUCTS AND SERVICES During the first quarter of 2025, activities related to the drafting of the 2024 Sustainability Statement were completed, in compliance with the requirements of the European CSRD legislation. In particular, investment and insurance safeguards in the area of climate and governance were presented. In line with the entry into force in February 2025 of the “Instructions of the Bank of Italy, COVIP, IVASS and the Ministry of Economy and Finance for the exercise of enhanced controls on the activities of authorised intermediaries to combat the financing of companies producing anti-personnel mines, munitions and cluster bombs” (26 July 2024), the processes for managing the prohibition of the financing in question have been strengthened. In light of the refinement of certain safeguards and also in view of the Call for Attention of CONSOB with regard to “Adaptation to obligations regarding ‘sustainable finance’ in the provision of investment services” (25 July 2024): in March 2025, the “Financial Products Distribution Strategy Policy of Banca Mediolanum” was revised; in June 2025, the contents of the “Sustainability Information” section of the Bank’s public website, dedicated to transparency on sustainability in relation to the Bank’s activities, both as a participant in the financial markets and in its role as financial advisor (regulatory obligations pursuant to the SFDR), were updated. With a view to the continuous enrichment of the offer with sustainable solutions, in March 2025, a new investment fund of Mediolanum Gestione Fondi was launched in accordance with Article 8 of European Reg. 2088/2019 (“SFDR”): Mediolanum Obbligazionario Italia III: a bond fund, belonging to the Mediolanum Fondi Italia system, focused on the domestic market, which invests mainly in quality securities of listed and unlisted companies. Pursuant to the “Guidelines on the use of environmental, social and governance terms or relating to sustainability in fund names” issued by ESMA in August 2024 activities to adapt the offering of investment funds were therefore completed, leading in some cases to a change of name and in others to enhancement of the sustainability safeguards (e.g. introduction of the PAB exclusion policy) of the product investment policy. In June 2025, the Responsible Investment Policy of Banca Mediolanum was updated, demonstrating the Bank’s commitment to responsible finance. For example, on the occasion of this update, ESG due diligence on third-party management companies and the safeguards relating to the management of the prohibition on the financing of companies involved in the production of anti-personnel mines and cluster munitions established by Law No. 220 of 2021, were rendered in greater detail.
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48 | Mediolanum Group - Annual Financial Report 2025 As required by the relevant European legislation (EU Reg. 2019/2088 and related implementing rules), on 30 June 2025, the annual statement on the main negative effects of investment decisions on sustainability factors was published. During Q3 of 2025, a periodic half-yearly update was carried out on policies, actions, targets and metrics relating to impacts, risks and opportunities (IRO) identified by the double materiality analysis for the area of investments. In addition, in view of the 2025 Sustainability Statement, a new materiality assessment was carried out in relation to the Group’s investments. In September, the periodic analysis of climate indicators of investments provided for in the 2024-2026 Strategic Plan was presented to the Group Coordination and ESG Strategic Development Committee. The Mediolanum Group is currently involved in drawing up a Transition Plan, in accordance with the provisions of the CSRD regulations. In this regard, some of the Group companies, which have roles as Financial Markets Participants, are working on formulating a plan to reduce indirect emissions related to asset management activities. With respect to the national regulatory context, the Bank is assessing certain measures regarding sustainability disclosure in view of the practices highlighted by the Consob Authority in the Call for Attention to Market No. 1 of 2025 (“Adaptation by managers to “sustainable finance” obligations). Consistent with the outcome of the double materiality assessment carried out, the contents on Responsible Finance were prepared for the drafting of the 2025 Consolidated Sustainability Declaration. In particular, the Bank and Group companies that have roles as Financial Advisors or Financial Markets Participants contributed to annual reporting on the following European Sustainability Reporting Standards (ESRS) with regard to responsible finance: ESRS E1 - Climate change ESRS S4 - Consumers and end-users ESRS G1 - Business conduct The Bank is currently preparing the periodic sustainability reporting for the sustainable lines (pursuant to Article 8 of the SFDR) of the individual portfolio management service offered to customers. Finally, it should be noted that in 2025 the Bank participates in various association meetings on the following topics: proposal for a European directive known as “Omnibus” on the simplification of certain sustainability regulations; CONSOB Call for Attention No. 1/25 concerning the adaptation of managers to “sustainable finance” obligations; review of the regulation on sustainability reporting in the financial services sector (SFDR II).
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49 | Mediolanum Group - Annual Financial Report 2025 OPERATING PERFORMANCE Equity and net inflows Group assets under administration and management €/million 31/12/2025 31/12/2024 Chg. vs. Dec-2024 % Chg. vs. Dec-2024 ASSET MANAGEMENT 60,743.5 52,928.9 7,814.6 14.8% Own funds 44,711.9 40,563.6 4,148.3 10.2% Third-party funds 7,032.2 5,510.5 1,521.7 27.6% Financial Containers 8,999.3 6,854.7 2,144.6 31.3% INSURANCE 50,061.7 44,362.5 5,699.2 12.8% Insurance Containers 47,831.4 42,237.8 5,593.7 13.2% Other Insurance Assets 2,230.3 2,124.7 105.6 5.0% OTHER ASSETS UNDER MANAGEMENT 3,665.1 3,520.0 145.1 4.1% Third-party structured notes 3,665.1 3,520.0 145.1 4.1% TOTAL ASSETS UNDER MANAGEMENT 114,470.3 100,811.4 13,658.9 13.5% TOTAL ASSETS UNDER ADMINISTRATION 41,329.3 37,681.9 3,647.4 9.7% Direct funding 29,626.7 27,995.1 1,631.6 5.8% Indirect funding 11,702.6 9,686.8 2,015.8 20.8% TOTAL ASSETS UNDER ADMINISTRATION AND MANAGEMENT 155,799.6 138,493.3 17,306.3 12.5% At 31 December 2025, the assets under administration and management of the Mediolanum Group amounted to €155,799.6 million, an increase of €17,306.3 million compared with the balance at the end of 2024 (31/12/2024: €138,493.3 million). The increase in assets under management of €13,658.9 million was due to the positive contribution of net new money in the period, as well as to the positive effect of the markets observed during the period under review. The increase in assets under management of €3,647.4 million is due to the increased inflows raised through promotional initiatives. Assets administered and managed Italy €/million 31/12/2025 31/12/2024 Chg. vs. Dec-2024 % Chg. vs. Dec-2024 ASSET MANAGEMENT 50,634.6 44,710.9 5,923.7 13.2% Own funds 41,234.6 37,303.5 3,931.0 10.5% Third-party funds 7,032.2 5,510.5 1,521.7 27.6% Financial Containers 2,367.8 1,896.8 471.0 24.8% INSURANCE 47,884.2 42,493.6 5,390.6 12.7% Insurance Containers 45,784.9 40,483.1 5,301.8 13.1% Other Insurance Assets 2,099.2 2,010.5 88.8 4.4% OTHER ASSETS UNDER MANAGEMENT 3,660.8 3,520.0 140.8 4.0% Third-party structured notes 3,660.8 3,520.0 140.8 4.0% TOTAL ASSETS UNDER MANAGEMENT 102,179.6 90,724.5 11,455.0 12.6% TOTAL ASSETS UNDER ADMINISTRATION 37,777.1 34,318.9 3,458.2 10.1% Direct funding 26,778.3 25,215.1 1,563.2 6.2% Indirect funding 10,998.8 9,103.8 1,895.0 20.8% TOTAL ASSETS UNDER ADMINISTRATION AND MANAGEMENT ITALY 139,956.7 125,043.5 14,913.2 11.9%
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50 | Mediolanum Group - Annual Financial Report 2025 Total assets relating to the Italian market amounted to €139,956.7 million at 31 December 2025, up by €14,913.2 million compared with the balance at 31 December 2024 (31/12/2024: €125,043.5 million). Assets under administration and management Spain €/million 31/12/2025 31/12/2024 Chg. vs. Dec-2024 % Chg. vs. Dec-2024 ASSET MANAGEMENT 9,899.5 7,986.8 1,912.7 23.9% Own funds 3,267.9 3,028.9 239.0 7.9% Financial Containers 6,631.5 4,957.9 1,673.7 33.8% INSURANCE 2,030.9 1,725.6 305.3 17.7% Insurance Containers 1,899.9 1,611.3 288.6 17.9% Other Insurance Assets 131.0 114.2 16.8 14.7% OTHER ASSETS UNDER MANAGEMENT 4.4 - 4.4 n.s. Third-party structured notes 4.4 - 4.4 n.s. TOTAL ASSETS UNDER MANAGEMENT 11,934.7 9,712.4 2,222.4 22.9% TOTAL ASSETS UNDER ADMINISTRATION 3,552.2 3,363.0 189.2 5.6% TOTAL ASSETS UNDER ADMINISTRATION AND MANAGEMENT SPAIN 15,486.9 13,075.3 2,411.6 18.4% Total assets relating to the Spanish market amounted to €15,486.9 million at 31 December 2025, up by €2,411.6 million compared with the balance at 31 December 2024 (31/12/2024: €13,075.3 million). Assets administered and managed Germany €/million 31/12/2025 31/12/2024 Chg. vs. Dec-2024 % Chg. vs. Dec- 2024 ASSET MANAGEMENT 209.4 231.1 (21.8) (9.4%) Own funds 209.4 231.1 (21.8) (9.4%) INSURANCE 146.6 143.3 3.3 2.3% Insurance Containers 146.6 143.3 3.3 2.3% TOTAL ASSETS UNDER MANAGEMENT 356.0 374.5 (18.5) (4.9%) TOTAL ASSETS UNDER ADMINISTRATION AND MANAGEMENT GERMANY 356.0 374.5 (18.5) (4.9%) Total assets relating to the German market amounted to €356.0 million at 31 December 2025, down by - €18.5 million compared with the balance at 31 December 2024 (31/12/2024: €374.5 million).
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51 | Mediolanum Group - Annual Financial Report 2025 Group net inflows €/million 31/12/2025 31/12/2024 Chg. % Chg ASSET MANAGEMENT 5,307.4 4,657.8 649.6 13.9% Own funds 2,025.4 3,392.8 (1,367.4) (40.3%) Third-party funds 1,310.9 702.4 608.5 86.6% Financial Containers 1,971.0 562.6 1,408.5 n.s. INSURANCE 4,034.1 2,611.5 1,422.5 54.5% Insurance Containers 4,039.6 2,670.0 1,369.6 51.3% Other insurance products (5.5) (58.4) 52.9 (90.6%) OTHER ASSETS UNDER MANAGEMENT (285.4) 374.1 (659.4) n.s. Third-party structured notes (285.4) 374.1 (659.4) n.s. TOTAL ASSETS UNDER MANAGEMENT 9,056.0 7,643.4 1,412.7 18.5% TOTAL ASSETS UNDER ADMINISTRATION 2,582.7 2,799.6 (217.0) (7.8%) Direct funding 1,648.0 1,801.1 (153.0) (8.5%) Indirect funding 934.6 998.6 (63.9) (6.4%) TOTAL NET INFLOWS TO ASSETS UNDER ADMINISTRATION AND MANAGEMENT 11,638.7 10,443.0 1,195.7 11.4% Total net inflows amounted to €11,638.7 million at 31 December 2025, representing a sharp increase of + €1,195.7 million compared with the comparative period (31/12/2024: €10,443.0 million). In particular, assets under management recorded growth in both Asset Management (+€649.6 million) and Insurance (+€1,422.5 million), while assets under administration contracted by - €217.0 million, particularly blocked fund inflows due to the expiry of promotional initiatives launched in previous years and the transformation into assets under management carried out by Family Bankers. Italy net inflows €/million 31/12/2025 31/12/2024 Chg. % Chg ASSET MANAGEMENT 3,690.3 3,420.2 270.1 7.9% Own funds 1,884.9 2,499.5 (614.6) (24.6%) Third-party funds 1,310.9 702.4 608.5 86.6% Financial Containers 494.5 218.2 276.2 n.s. INSURANCE 3,726.5 2,432.8 1,293.7 53.2% Insurance Containers 3,741.1 2,450.3 1,290.8 52.7% Other insurance products (14.5) (17.5) 2.9 (16.8%) OTHER ASSETS UNDER MANAGEMENT (289.8) 374.1 (663.8) n.s. Third-party structured notes (289.8) 374.1 (663.8) n.s. TOTAL ASSETS UNDER MANAGEMENT 7,127.1 6,227.1 900.0 14.5% TOTAL ASSETS UNDER ADMINISTRATION 2,582.3 2,746.8 (164.5) (6.0%) Direct funding 1,568.2 1,688.2 (120.0) (7.1%) Indirect funding 1,014.1 1,058.6 (44.5) (4.2%) TOTAL NET INFLOWS TO ASSETS UNDER ADMINISTRATION AND MANAGEMENT 9,709.4 8,973.9 735.5 8.2%
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52 | Mediolanum Group - Annual Financial Report 2025 Spain net inflows €/million 31/12/2025 31/12/2024 Chg. % Chg ASSET MANAGEMENT 1,639.0 1,268.5 370.4 29.2% Own funds 162.4 924.2 (761.8) (82.4%) Financial Containers 1,476.6 344.3 1,132.2 n.s. INSURANCE 310.6 182.0 128.6 70.7% Insurance Containers 301.6 223.0 78.6 35.3% Other insurance products 9.0 (41.0) 50.0 n.s. OTHER ASSETS UNDER MANAGEMENT 4.4 - 4.4 n.s. Third-party structured notes 4.4 - 4.4 n.s. TOTAL ASSETS UNDER MANAGEMENT 1,954.0 1,450.5 503.5 34.7% TOTAL ASSETS UNDER ADMINISTRATION 0.4 52.8 (52.4) (99.3%) Direct funding 79.8 112.8 (33.0) (29.3%) Indirect funding (79.5) (60.0) (19.4) 32.4% TOTAL NET INFLOWS TO ASSETS UNDER ADMINISTRATION AND MANAGEMENT 1,954.4 1,503.4 451.0 30.0% Net inflows Germany €/million 31/12/2025 31/12/2024 Chg. % Chg ASSET MANAGEMENT (22.0) (30.9) 9.0 (29.0%) Own funds (22.0) (30.9) 9.0 (29.0%) INSURANCE (3.1) (3.3) 0.2 (5.6%) Insurance Containers (3.1) (3.3) 0.2 (5.6%) TOTAL ASSETS UNDER MANAGEMENT (25.1) (34.2) 9.2 (26.8%) TOTAL NET INFLOWS TO ASSETS UNDER ADMINISTRATION AND MANAGEMENT (25.1) (34.2) 9.2 (26.8%) Protection premium income figures Group €/million 31/12/2025 31/12/2024 Chg. % Chg Combination 47.5 37.4 10.1 27.0% Collective medical expenses 0.2 0.2 - n.s. Stand-alone 198.7 168.5 30.2 17.9% New Business Stand-Alone Products 35.0 32.3 2.7 8.2% Stand-alone portfolio 163.7 136.2 27.5 20.2% TOTAL PROTECTION PREMIUM INCOME 246.4 206.1 40.3 19.5% Total inflows came to €246.4 million (31/12/2024: €206.1 million) with an increase of +€40.3 million. Specifically, there were particularly positive results in the combined policies segment, up +€10.1 million, linked to the dynamics of the loans disbursed by the distributor, Banca Mediolanum, and in the standalone segment, up + €30.2 million, due to the increase in recurring premiums linked to the growth of the policy portfolio.
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53 | Mediolanum Group - Annual Financial Report 2025 Italy €/million 31/12/2025 31/12/2024 Chg. % Chg Combination 47.5 37.4 10.1 27.0% Collective medical expenses 0.2 0.2 - n.s. Stand-alone 192.5 163.8 28.7 17.5% New Business Stand-Alone Products 33.4 30.9 2.5 8.0% Stand-alone portfolio 159.1 132.9 26.2 19.7% TOTAL PROTECTION PREMIUM INCOME 240.2 201.4 38.8 19.3% Total inflows into the Italian market amounted to €240.2 million (31/12/2024: €201.4 million). Breakdown of loans Group disbursed €/million 31/12/2025 31/12/2024 Chg. % Chg Mortgage loans 2,126.6 1,616.0 510.7 31.6% Personal loans 1,137.7 840.5 297.2 35.4% Prexta 691.6 635.8 55.8 8.8% GROUP DISBURSED TOTAL 3,956.0 3,092.4 863.6 27.9% The total disbursed in the period under review increased by + €863.6 million (+27.9%) to €3,956.0 million. This increase is mainly attributable to mortgage loans (+€510.7 million) and personal loans (+€297.2 million) and is due to better market conditions related to the decrease in interest rates, benefiting both product lines. Italy disbursed €/million 31/12/2025 31/12/2024 Chg. % Chg Mortgage loans 1,895.9 1,369.7 526.1 38.4% Personal loans 960.9 739.9 221.0 29.9% Prexta 691.6 635.8 55.8 8.8% ITALY DISBURSED TOTAL 3,548.4 2,745.5 802.9 29.2% Spain disbursed €/million 31/12/2025 31/12/2024 Chg. % Chg Mortgage loans 230.8 246.2 (15.5) (6.3%) Personal loans 176.9 100.7 76.2 75.7% SPAIN DISBURSED TOTAL 407.6 346.9 60.7 17.5%
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54 | Mediolanum Group - Annual Financial Report 2025 Group Portfolio €/million 31/12/2025 31/12/2024 Chg. % Chg Mortgage loans 13,343.1 12,512.4 830.8 6.6% Personal loans 2,728.4 2,437.4 291.0 11.9% Credit facilities 620.5 557.1 63.4 11.4% Prexta 2,290.4 2,111.6 178.9 8.5% GROUP PORTFOLIO TOTAL 18,982.5 17,618.4 1,364.1 7.7% The Group’s total loan stock at 31 December 2025 stood at €18,982.5 million, up by €1,364.1 million compared with 31 December 2024 (31/12/2024: €17,618.4 million). This increase was mainly due to mortgage loans (+ €830.8 million). Personal loans also increased (+€291.0 million), as did loans of the Prexta subsidiary (+ €178.9 million) and lines of credit (+ €63.4 million). Italy Portfolio €/million 31/12/2025 31/12/2024 Chg. % Chg Mortgage loans 12,061.2 11,342.7 718.5 6.3% Personal loans 2,394.6 2,209.5 185.1 8.4% Credit facilities 492.1 461.2 30.9 6.7% Prexta 2,290.4 2,111.6 178.9 8.5% ITALY PORTFOLIO TOTAL 17,238.3 16,124.9 1,113.4 6.9% Spain Portfolio €/million 31/12/2025 31/12/2024 Chg. % Chg Mortgage loans 1,281.9 1,169.7 112.2 9.6% Personal loans 333.9 227.9 105.9 46.5% Credit facilities 128.4 95.9 32.5 33.9% SPAIN PORTFOLIO TOTAL 1,744.2 1,493.6 250.7 16.8%
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55 | Mediolanum Group - Annual Financial Report 2025 RECLASSIFIED CONSOLIDATED INCOME STATEMENT AT 31 DECEMBER 2025 €/thousand 31/12/2025 31/12/2024 Change value % a b c=a-b c/b Entry fees 63,538 60,539 2,999 5.0% Management fees 1,414,323 1,283,868 130,455 10.2% Investment management fees 269,208 252,838 16,370 6.5% Net insurance revenues ex. U-L commissions 223,456 199,391 24,066 12.1% Banking service fees 258,669 186,878 71,791 38.4% Other fees 56,102 51,712 4,390 8.5% Gross commission income 2,285,296 2,035,226 250,071 12.3% Acquisition costs (795,611) (693,251) (102,361) 14.8% Other commission expenses (176,679) (173,962) (2,717) 1.6% Total commission expenses (972,290) (867,213) (105,078) 12.1% Net commission income 1,313,006 1,168,013 144,993 12.4% Net interest income 812,119 811,149 970 0.1% Net income on other investments 22,099 33,821 (11,722) (34.7%) LLP (impairment on loans) (31,631) (32,680) 1,049 (3.2%) Other revenues and expenses (3,376) (3,798) 422 (11.1%) CONTRIBUTION MARGIN 2,112,217 1,976,505 135,712 6.9% G&A expenses (770,678) (736,223) (34,455) 4.7% Regular contributions to banking industry (22,582) (35,509) 12,927 (36.4%) Depreciation & amortisation (36,397) (41,869) 5,472 (13.1%) Net provisions for risk and charges (83,595) (69,320) (14,275) 20.6% TOTAL COSTS (913,252) (882,921) (30,331) 3.4% OPERATING MARGIN 1,198,965 1,093,584 105,381 9.6% Performance fees 256,568 376,738 (120,170) (31.9%) Net income on investments at fair value 28,113 16,683 11,430 68.5% MARKET EFFECTS 284,681 393,421 (108,740) (27.6%) Extraordinary contributions and guarantee funds (776) (11,108) 10,332 (93.0%) Other extraordinary items 92,302 (20,939) 113,241 n.s. EXTRAORDINARY ITEMS 91,526 (32,047) 123,573 n.s. PROFIT BEFORE TAX 1,575,172 1,454,958 120,214 8.3% Income tax (337,264) (335,329) (1,935) 0.6% NET INCOME 1,237,908 1,119,629 118,279 10.6% (*)This income statement was prepared using a schedule that reflects the Group’s management system, which provides for the reclassification of the components of profit before tax by type. It should also be noted that for a correct reading of the tables relating to economic performance, an increase in cost items will have an absolute negative change and a positive percentage change; conversely, a decrease in cost items will have an absolute positive change and a negative percentage change.
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56 | Mediolanum Group - Annual Financial Report 2025 Summary of reclassified income statement performance in 2025 €/million 31/12/2025 31/12/2024 Change Change (%) Net income in the period 1,237.9 1,119.6 118.3 10.6% of which: Commission income 2,285.3 2,035.2 250.1 12.3% Commission income for the period was €2,285.3 million, up by + €250.1 million from €2,035.2 million in the comparative period. In particular, recurring fees ( Management fees and investment services fees ) increased by + €146.9 million compared with the comparative period 2024, due to an increase in the average assets of asset management products. The Insurance Management Result shows an increase of +€24.1 million, largely due to the increased profitability of insurance products classified under IFRS 17 attributable to the financial performance of the Contractual Service Margin (CSM) that increased by + €0.5 billion compared to the figure recorded at 31 December 2024 (31/12/2024: €2.6 million), due to new production and favourable market dynamics, amounting to €3.1 billion at 31 December 2025. Banking service fees and revenues increased by +€71.8 million compared with the comparative period, mainly due to higher certified placement fees (+€57.6 million) due to higher placement volumes, higher fees for e-money and payment instruments (+€10.2 million). Commission expenses (972.3) (867.2) (105.1) 12.1% of which: Acquisition costs (795.6) (693.2) (102.4) 14.8% Other commissions (176.7) (174.0) (2.7) 1.6% Acquisition costs amounted to - €972.3 million, up 12.1% compared with the comparative period (31/12/2024: -€867.2 million). The increase in the Acquisition costs item of - €102.4 million was mainly due to: higher recurring fees (-€62.1 million) attributable to growth in management fees as described above; higher incentive commissions paid to the Family Banker network (- €26.7 million) in view of the net inflow results recorded; higher upfront fees (-€16.8 million) consistent with the entry fees recorded. Item Other commission expenses recorded an increase of - €2.7 million compared with the comparative period. This increase was mainly due to higher management costs of - €8.2 million, due to the increase in the amounts ceded under mandate. Conversely, fees charged on e-money products and services decreased by +€5.6 million. Net interest income 812.1 811.1 1.0 0.1%
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57 | Mediolanum Group - Annual Financial Report 2025 The net Interest income is in line with the comparative period (+€1.0 million). The margin trend is characterised by the stability of average interest-bearing assets, a reduction in market rates (and a lower average 3-month Euribor rate (approximately 140bps) and a change in the ratio between lending and funding. In particular, during 2025, the percentage of total lending of the retail (highest yield) component increased as did the percentage of total inflows of retail inflows (with a lower cost than that of Treasury). Net proceeds on disposal of other investments 22.1 33.8 (11.7) (34.6%) The decrease compared to the comparative period is mainly due to the lower dividend of - € 14.8 million resulting from the sale of Mediobanca stock. LLP (impairment on loans) (31.6) (32.7) 1.1 (3.4%) LLP or impairment on loans came to - €31.6 million, an improvement of +€1.1 million (31/12/2024: - €32.7 million); in view of the positive contribution (+€4.0 million) resulting from the updating of the impairment model for performing exposures thanks to the lower risk level observed in the credit portfolio, and the enforcement of government guarantees relating to certain loans issued in previous years and totalling €1.5 million, there was an increase in the adjustments made by the Prexta subsidiary due to the increase in unsecured personal loans of -€4.4 million. G&A expenses (770.7) (736.2) (34.5) 4.7% G&A expenses increased by - €34.5 million compared with the comparative period, almost entirely due to higher operating costs in the IT area and to the increase in staff costs due to the increase in the average number of employees. Contributions to banking industry (23.4) (46.6) 23.2 (49.8%) of which: Ordinary contributions (22.6) (35.5) 12.9 (36.3%) Extraordinary contributions (0.8) (11.1) 10.3 (92.8%) The Ordinary contributions item decreased by +€12.9 million; it should be recalled that the year 2024 included the last tranche payable to the DGS of - €18.9 million and the first allocation of the guarantee contributions of the insurance sector for -€16.2 million. The figure for the year under review mainly includes the guarantee contribution for the insurance sector for - €19.8 million and a further contribution to the DGS for approximately - €2.4 million. The Non-recurring contributions item decreased by + €10.3 million; the comparative period included a provision the bank rescue fund of - €11.1 million. Costs recorded in 2025 totalling - €0.8 million related to the write-down of the Atlante Funds. Net Provisions for risk & charges (83.6) (69.3) (14.3) 20.6%
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58 | Mediolanum Group - Annual Financial Report 2025 The net provisions for risks and charges item shows an increase of - €14.3 million compared with the comparative year, including - €5.4 million for the increase in the provision for early repayment by the Prexta subsidiary, - €3.3 million for increased provisions for lawsuits and illegal conduct, - €3.2 million for more commercial initiatives and finally - €2.6 million due to the higher cost of indemnities payable to the Sales Network linked to the increase in calculation bases. Market effects 284.7 393.4 (108.7) (27.6%) of which: Performance fees 256.6 376.7 (120.1) (31.9%) Net income (losses) on investments at fair value 28.1 16.7 11.4 68.3% Market effects accounted for €284.7 million, an increase of -€108.7 million on the previous year. Performance fees amounted to €256.6 million, compared with €376.7 million in the comparative period. This decrease is attributable to the lower performance fees of the Irish subsidiary Mediolanum International Fund, amounting to €203.7 million (31/122024: €351.0 million euros) while the performance fees of the Italian subsidiary Mediolanum Gestione Fondi increased to €52.9 million as at 31 December 2025 (31/12/2024: €25.7 million). The “Net income (losses) on investments at fair value” item increased by +€11.4 million, mainly attributable for +€15.8 million to the Nexi stock, which had recorded a decrease in value of - €15.1 million in 2024, but at 31 December 2025 recorded a gain of + €0.6 million, following the sale of the shares in May 2025. There was also a negative effect of -€3.1 million due to lower profits from securities trading and the negative performance of UCIs. Other extraordinary items 92.3 (20.9) 113.2 n.s. The Other extraordinary items item increased by +€113.2 million, with +€140.1 million relating to positive tax effects relating to the recovery of IRAP paid on dividends received between 2012 and 2024 by foreign subsidiaries (Judgment No. 599 of 1 August 2025 of the European Court of Justice) partially offset by higher costs deriving from effects relating to the discounting of the up-front stamp duty paid on life products, from the commissions of intermediaries who assisted in the sale of the shareholding in Mediobanca and finally from the higher charge for the year for the negotiation in respect of the extraordinary bonus awarded to employees and the Sales Network.
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59 | Mediolanum Group - Annual Financial Report 2025 INCOME STATEMENT AT 31 DECEMBER 2025 BY COUNTRY AND BUSINESS AREA The following section provides a commentary on the changes in the income statement by country and business area, where relevant with reclassification of comparative figures. While revenues are originally and directly allocated to products and, by aggregation, to the Result Areas, costs have undergone an allocation process based on varying degrees of attribution to the products and the nature of the underlying processes: Direct costs: costs directly attributed to a product or a homogeneous category of products; Allocated direct costs ; costs subject to allocation using drivers that distribute the cost between various products and/or product categories; Unallocated costs: costs of a strictly administrative nature or related to control or infrastructure processes, for which, based on the characteristics of the cost allocation model, no allocation is made The details of IFRS 8 are set out in the relevant section Operating data by business area. ITALY – BANKING SEGMENT €/thousand 31/12/2025 31/12/2024 Change Change % Banking service fees 246,976 176,342 70,634 40.1% Other fees 866 771 95 12.3% Gross commission income 247,842 177,113 70,729 39.9% Acquisition costs (110,124) (90,705) (19,419) 21.4% Other commission expenses (75,475) (80,956) 5,481 (6.8%) Total commission expenses (185,599) (171,661) (13,937) 8.1% Net commission income 62,243 5,452 56,792 n.s. Net interest income 698,271 675,708 22,563 3.3% Net income on other investments 5,740 479 5,261 n.s. LLP (impairment on loans) (30,972) (31,584) 612 (1.9%) Other revenues and expenses (10,156) (10,124) (32) 0.3% LEVEL I CONTRIBUTION MARGIN 725,126 639,930 85,196 13.3% Direct and indirect costs allocated (234,057) (228,269) (5,788) 2.5% Regular contributions to banking industry (2,747) (19,240) 16,493 (85.7%) LEVEL II CONTRIBUTION MARGIN 488,322 392,421 95,901 24.4% Net income (losses) on investments at fair value 27,286 14,650 12,636 86.3% MARKET EFFECTS 27,286 14,650 12,636 86.3% Extraordinary contributions and guarantee funds (776) (11,108) 10,332 (93.0%) EXTRAORDINARY ITEMS (776) (11,108) 10,332 (93.0%) SEGMENT MARGIN BEFORE TAX 514,832 395,962 118,869 30.0% Profit before tax for the Italy - Banking segment recorded a positive balance of €514.8 million, compared with the positive result of €396.0 million posted in 2024.The growth in net commission income and net interest income, together with the reduction in contributions to the guarantee fund and the positive performance of items at fair led to an increase compared with the comparative period. Revenues from Commission income stood at €247.8 million, up by +€70.7 million year on year. This increase is mainly due to an increase in the volume of certificates placed in 2025.
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60 | Mediolanum Group - Annual Financial Report 2025 Acquisition costs increased by - €19.4 million, primarily due to the placement of certificates. Il Net interest income stood at €698.3 million, an increase compared with the previous year, boosted by lower funding costs compared with the previous year. The Direct and indirect costs allocated increased by - €5.8 million compared with the comparative period, due to the increase in operating, marketing and sales network support costs, in line with the commercial dynamics of the period. These are in addition to the increase in ICT costs linked to the strengthening of the services overseen, partly offset by the reduction in costs attributable to the Flowe subsidiary. The Regular contributions to the guarantee fund item decreased by + €16.5 million. In 2024, the provision was recorded for the last annual contribution to the Deposit Guarantee System (known as the DGS). Market effects were approximately + €27.3 million, up by + €12.6 million compared with the figures for 2024. This increase is mainly due to the disparate performance of the NEXI capital stock between 2024 and 2025. It is further recalled that the Nexi shares were sold in May 2025. Extraordinary items increased by + €10.3 million. In 2024, there was a provision of - €11.0 million made for extraordinary contributions paid to cover previous bail-out operations for banks. ITALY SEGMENT – ASSET MANAGEMENT €/thousand 31/12/2025 31/12/2024 Change Change % Entry fees 34,383 38,815 (4,432) (11.4%) Management fees 746,250 694,386 51,864 7.5% Investment management fees 141,123 134,848 6,275 4.7% Other fees 30,864 29,516 1,348 4.6% Gross commission income 952,620 897,565 55,055 6.1% Acquisition costs (346,777) (319,172) (27,605) 8.6% Other commission expenses (40,784) (43,644) 2,860 (6.6%) Total commission expenses (387,561) (362,816) (24,745) 6.8% Net commission income 565,059 534,749 30,310 5.7% Net interest income 1,459 6,253 (4,794) (76.7%) Net income on other investments 1 74 (72) (98.3%) Other revenues and expenses 798 635 163 25.6% LEVEL I CONTRIBUTION MARGIN 567,318 541,710 25,607 4.7% Direct and indirect costs allocated (114,477) (113,039) (1,438) 1.3% LEVEL II CONTRIBUTION MARGIN 452,841 428,672 24,169 5.6% OPERATING MARGIN 452,841 428,672 24,169 5.6% Performance fees 150,317 196,214 (45,897) (23.4%) Net income on investments at fair value (16) (87) 71 (81.3%) MARKET EFFECTS 150,301 196,128 (45,827) (23.4%) SEGMENT MARGIN BEFORE TAX 603,142 624,799 (21,658) (3.5%) The profit before tax of the Italy - Asset Management segment came in at €603.1 million, down by around -€21.7 million compared with the profit recorded in the same period of the previous financial year of + €624.8 million. The segment reflects a reduction in performance fees, mitigated by the growth in recurring net fees compared to the comparative period.
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61 | Mediolanum Group - Annual Financial Report 2025 Commission income for the period was €952.6 million, an increase compared with the figure recorded on 31/12/2024: €897.6 million). The increase is predominantly attributable to higher recurring fees, deriving from more assets under management compared with the comparative period. Acquisition costs rose by - €27.6 million compared with the comparative period. The increase was mainly due to the increase in recurring fees paid to the sales network of - €25.7 million and in incentive fees, up by - €4.7 million, the result of the commercial performance of products in the segment. Direct and indirect costs allocated increased - €114.5 million) (31/12/2024: - €113.0 million. Market effects decreased by - €45.8 million compared with the comparative period, due to lower performance fees during the period. ITALY – INSURANCE SEGMENT €/thousand 31/12/2025 31/12/2024 Change Change % Management fees 528,938 467,036 61,902 13.3% Investment management fees 104,918 96,503 8,415 8.7% Net insurance revenues (ex U-L commissions) 209,737 188,282 21,455 11.4% Other fees 16,253 14,607 1,646 11.3% Gross commission income 859,846 766,428 93,418 12.2% Acquisition costs (247,450) (206,797) (40,652) 19.7% Other commission expenses (39,859) (32,829) (7,030) 21.4% Total commission expenses (287,309) (239,627) (47,682) 19.9% Net commission income 572,537 526,802 45,735 8.7% Net interest income 56,269 60,722 (4,453) (7.3%) Net income on other investments 3,031 5,614 (2,583) (46.0%) Other revenues and expenses (1,288) (425) (864) n.s. LEVEL I CONTRIBUTION MARGIN 630,549 592,714 37,835 6.4% Direct and indirect costs allocated (126,908) (117,954) (8,954) 7.6% Regular contributions to banking industry (19,774) (16,209) (3,565) 22.0% LEVEL II CONTRIBUTION MARGIN 483,867 458,551 25,316 5.5% OPERATING MARGIN 483,867 458,551 25,316 5.5% Performance fees 87,150 154,936 (67,786) (43.8%) Net income on investments at fair value (33) 273 (305) n.s. MARKET EFFECTS 87,117 155,209 (68,091) (43.9%) EXTRAORDINARY ITEMS (20,215) - (20,215) n.s. SEGMENT MARGIN BEFORE TAX 550,769 613,760 (62,991) (10.3%) The margin before tax of the Italy - Insurance segment came in at +€550.8 million, a decrease of €63.0 million compared with the figure of + €613.8 million recorded in 2024. This segment reflects a decrease in performance fees, offset by growth in recurring fees.
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62 | Mediolanum Group - Annual Financial Report 2025 Fee and commission income for the period was + €859.8 million, an increase of +€93.4 million compared with previous year. Of this increase, +€70.3 million was attributable to recurring fees, due to the increase in assets under management, and +€21.5 million was attributable to the increase in insurance management profits, due to higher net revenues from insurance products classified pursuant to IFRS 17. Acquisition costs rose by - €40.7 million compared with the figure recorded in 2024.This increase was mainly due to higher maintenance fees of -€25.6 million, due to the growth of the portfolio, and to higher incentive fees, linked to the commercial performance of products in the segment, of -€14.7 million. Direct and indirect costs allocated increased (-€9.0 million) The main change is due to the increase in marketing and support costs to the sales Network of - €5.3 million, which is consistent with the commercial trends observed during the period. There was also an increase in the costs of the Irish subsidiary (- €2.0 million) and investment in ICT mainly in the area of Protection (-€2.3 million). Contributions to funds and guarantees item includes -€19.7 million in provisions made in compliance with legislation to protect beneficiaries and those entitled to insurance benefits deducted from life policies if the insurance company is subject to insolvency proceedings (the Life Guarantee Fund). Market effects decreased by -€68.1 million, mainly due to lower performance fees. The Extraordinary Items include the financial effects resulting from the up-front payment of stamp duty due by policyholders at the time of the termination of investments in insurance products. ITALY – OTHER SEGMENT €/thousand 31/12/2025 31/12/2024 Change Change % Other fees 3,562 2,755 807 29.3% Acquisition costs 3,228 (2,313) 5,540 n.s. Net commission income 6,790 442 6,347 n.s. Net interest income 73 134 (61) (45.8%) Net income on other investments 13,011 27,436 (14,425) (52.6%) Other revenues and expenses 5,350 5,136 214 4.2% LEVEL I CONTRIBUTION MARGIN 25,223 33,148 (7,925) (23.9%) Direct and indirect costs allocated (7,276) (6,707) (569) 8.5% LEVEL II CONTRIBUTION MARGIN 17,947 26,441 (8,494) (32.1%) OPERATING MARGIN 17,947 26,441 (8,494) (32.1%) SEGMENT MARGIN BEFORE TAX 17,947 26,441 (8,494) (32.1%) The Italy Other Segment comprises miscellaneous financial items not directly attributable to the other lines of business or relating to common activities.
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63 | Mediolanum Group - Annual Financial Report 2025 SPAIN SEGMENT €/thousand 31/12/2025 31/12/2024 Change Change % Entry fees 29,155 21,724 7,431 34.2% Management fees 134,273 117,156 17,117 14.6% Investment management fees 22,143 20,375 1,768 8.7% Net insurance revenues ex. U-L commissions 13,118 10,396 2,723 26.2% Banking service fees 11,693 10,536 1,157 11.0% Other fees 4,349 3,840 509 13.3% Gross commission income 214,731 184,027 30,705 16.7% Acquisition costs (92,629) (72,364) (20,265) 28.0% Other commission expenses (20,048) (15,921) (4,127) 25.9% Total commission expenses (112,677) (88,285) (24,392) 27.6% Net commission income 102,054 95,742 6,313 6.6% Net interest income 55,235 66,954 (11,719) (17.5%) Net income on other investments 316 219 97 44.3% LLP (impairment on loans) (659) (1,096) 437 (39.9%) Other revenues and expenses 1,917 976 941 96.4% LEVEL I CONTRIBUTION MARGIN 158,863 162,795 (3,931) (2.4%) Direct and indirect costs allocated (84,918) (74,042) (10,876) 14.7% Regular contributions to banking industry (61) (60) (1) 1.7% LEVEL II CONTRIBUTION MARGIN 73,884 88,693 (14,808) (16.7%) Depreciation & amortisation (11,293) (8,524) (2,769) 32.5% Net provisions for risk and charges (6,153) (3,439) (2,714) 78.9% OPERATING MARGIN 56,438 76,730 (20,291) (26.4%) Performance fees 18,079 23,419 (5,340) (22.8%) Net income on investments at fair value 829 1,713 (884) (51.6%) MARKET EFFECTS 18,908 25,132 (6,224) (24.8%) Other extraordinary items (4,218) (4,127) (91) 2.2% EXTRAORDINARY ITEMS (4,218) (4,127) (91) 2.2% SEGMENT MARGIN BEFORE TAX 71,128 97,735 (26,606) (27.2%) The Margin before tax for the Spain segment was a positive €71.1 million, compared with the previous year’s result of +€97.7 million. Commission income rose from €184.0 million in December 2024 to €214.7 million in 2025. This trend was to a large extent due to the increase in recurring fees (+€18.9 million) due to the increase in assets under management, and an increase of €7.4 million in subscription fees, thanks to a positive trend in inflows. Acquisition costs increased by -€20.3 million, reflecting the positive performance of assets under management and the placement of products under management. The Net interest income amounted to approximately + €55.2 million, down by - €11.7 million compared to the comparative period, on the basis of the dynamics of market rates and greater commercial pressure exerted by promotional initiatives for the benefit of customers.
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64 | Mediolanum Group - Annual Financial Report 2025 Direct and indirect allocated costs, consisting of the market’s total general and administrative expenses, increased by -€10.9 million compared with the comparative period. This difference is attributable to −€4.3 million for higher staff costs due to the increase in average headcount, for - €2.9 million for operating costs (customer communication, project consultancy and IT costs); -€1.7 million for physical territorial expansion; for −€1.2 million for legal advice. GERMANY SEGMENT €/thousand 31/12/2025 31/12/2024 Change Change % Management fees 4,862 5,290 (428) (8.1%) Investment management fees 1,024 1,112 (88) (7.9%) Net insurance revenues ex. U-L commissions 601 713 (112) (15.7%) Other fees 208 223 (15) (6.7%) Gross commission income 6,695 7,338 (643) (8.8%) Acquisition costs (1,859) (1,899) 40 (2.1%) Other commission expenses (513) (612) 99 (16.2%) Total commission expenses (2,372) (2,511) 139 (5.5%) Net commission income 4,323 4,827 (504) (10.4%) Net interest income 812 1,378 (566) (41.1%) Other revenues and expenses 3 3 0 0.0% LEVEL I CONTRIBUTION MARGIN 5,138 6,208 (1,070) (17.2%) Direct and indirect costs allocated (489) (442) (47) 10.6% LEVEL II CONTRIBUTION MARGIN 4,648 5,766 (1,117) (19.4%) Depreciation & amortisation (20) (20) 0 0.0% OPERATING MARGIN 4,628 5,746 (1,118) (19.4%) Performance fees 1,022 2,169 (1,147) (52.9%) Net income on investments at fair value 47 134 (87) (64.9%) MARKET EFFECTS 1,069 2,303 (1,234) (53.6%) Other extraordinary items (4) (4) 0 0.0% EXTRAORDINARY ITEMS (4) (4) 0 0.0% SEGMENT MARGIN BEFORE TAX 5,694 8,045 (2,351) (29.2%) The Margin before tax of the Germany segment was €5.7 million. INTERCOMPANY AND RELATED PARTY TRANSACTIONS Transactions with related parties, including intercompany transactions, cannot be classed as atypical or unusual, as they are part of the normal course of Group operations. These transactions are settled under market conditions, taking into account the characteristics of the goods and services provided. In accordance with the provisions of Article 2391-bis of the Italian Civil Code, Article 71-bis of Consob Regulation 11971/99 (Regulation for Issuers) and the recommendations of the Corporate Governance Code, adopted by the Company by specific resolutions of the Board of Directors, the treatment of transactions with related parties is described in the relevant section of the notes.
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65 | Mediolanum Group - Annual Financial Report 2025 SHAREHOLDERS’ EQUITY, TREASURY SHARES AND DIVIDENDS At 31 December 2025, the share capital amounted to €600,700 thousand (31/12/2024: €600,688 thousand) divided into 745,400,391 shares with no par value. The number of treasury shares in the portfolio was 6,176,004 shares totalling €60,571 thousand (31/12/2024: €77,414 thousand). Shareholders’ equity at the end of the 2025 financial year was €4,494 million, compared with €4,026 million a year earlier. With regard to the allocation of earnings for 2024, it should be recalled that the Shareholders’ Meeting of 16 April 2025 resolved to distribute a dividend of €1, of which €0.37 has already been distributed as an interim dividend in November 2024. On 24 April 2025, the balance of €0.63 per eligible ordinary share had been distributed. EPS (earnings per share) amounted to €1,677 compared with €1,515 in 2024. CAPITAL ADEQUACY OF THE MEDIOLANUM FINANCIAL CONGLOMERATE AND OWN FUNDS AT 31 DECEMBER 2025 The calculation of the capital adequacy of the Mediolanum Financial Conglomerate at 31 December 2025, in accordance with the additional supervisory provisions in force, showed that, with the capital requirements of the conglomerate of €3,496 million, the capital resources of the conglomerate to cover the required margin amounted to €4,519 million, with a surplus of €1,023 million: €/million 31/12/2025 31/12/2024 Financial conglomerate primarily engaged in banking Capital 4,519 4,189 Banking capital requirements 1,994 1,628 Insurance capital requirements 1,502 1,592 Capital surplus (deficit) 1,023 969
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66 | Mediolanum Group - Annual Financial Report 2025 Own funds and capital ratios at 31 December 20257 The Mediolanum Group determined the consolidated own funds for supervisory purposes and the related capital ratios according to the regulations in force, as updated by Regulation (EU) 2024/1623, published in the Official Journal of the European Union on 19 June 2024 (also known as CRR3), which introduces the Basel 4 principles into the European legislative framework, amending Regulation (EU) No 575/2013 with regard to credit risk requirements, credit valuation adjustment risk, operational risk and market risk. The most significant changes to the new regulatory framework came into force on 1 January 2025. CET1 was determined by considering the profit for the year of €1,237.9 million net of the proposed distribution of dividends which will be submitted for approval to the next Ordinary Shareholders’ Meeting. The profit for the year calculated therefore amounted to €313.9 million. In light of the above, the Common Equity Tier 1 (CET1) Ratio was 23.0% at 31 December 2025. The leverage ratio was 9.5% (31/12/2024: 7.8%). Reconciliation between the shareholders’ equity of the Parent Company and consolidated shareholders’ equity €/thousand Share capital and reserves Profit Shareholders’ equity Financial statements of the Parent Company at 31/12/2025 3,288,847 1,254,421 4,543,268 Derecognition of intercompany transaction effects - 150 150 Other transactions (32,394) (16,663) (49,057) Consolidated financial statements at 31/12/2025 3,256,453 1,237,908 4,494,361 As the equity investments of the Parent Company are accounted for using the equity method, its shareholders’ equity is substantially in line with consolidated shareholders’ equity. In other transactions, the amount of - €16,663 thousand mainly includes the economic effect of the adjustment of the profitability of insurance products measured at the consolidated level, while the amount of -€32,394 thousand mainly relates to the change in the “profit reserve”. 7 Capital adequacy at 31 December 2025 was calculated according to the capitalisation limits communicated by the European Central Bank based on the periodic Supervisory Review and Evaluation Process (SREP). The insurance requirements relate to the latest quarterly report (30 September 2025) of the Mediolanum Insurance Group sent to the supervisory authority.
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67 | Mediolanum Group - Annual Financial Report 2025 CONSOLIDATED SUSTAINABILITY STATEMENT 2025 Contents 1. General disclosures 1.1 ESRS 2 General disclosures 1.1.1 Basis for preparation 1.1.2 Governance 1.1.3 Strategy 1.1.4 Impact, risk and opportunity management 2. Environmental disclosures 2.1 Disclosure pursuant to Article 8 of Regulation 2020/852 (EU Taxonomy Regulation) 2.2 ESRS E1 Climate change 3. Social information 3.1 ESRS S1 Own workforce 3.2 ESRS S2 Workers in the value chain 3.3 ESRS S3 Affected communities 3.4 ESRS S4 Consumers and end-users 4. Governance information 4.1 ESRS G1 Business conduct 5. Entity-specific disclosures 5.1 Management of the distribution network
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68 | Mediolanum Group - Annual Financial Report 2025 1. General disclosures 1.1 ESRS 2 General disclosures 1.1.1 Basis for preparation Through the transposition of Directive (EU) 2022/2464 (Corporate Sustainability Reporting Directive - CSRD), Legislative Decree No. 125 of 6 September 2024 introduced into the Italian legal system the obligation for various categories of undertakings, including large public interest entities, to prepare annual sustainability reports in accordance with the reporting standards established by the European Commission. As a large public interest entity of the size provided for the implementation of the regulations, the Mediolanum Group has published a Consolidated Sustainability Statement since the 2024 financial year, in accordance with the provisions of Legislative Decree No. 125/24. The process of collecting data and information, for the purpose of drafting this document, was managed in collaboration with the various corporate functions. The data were collected by means of an IT tool, according to the principles of relevance, faithful representation, comparability, verifiability and understandability, as recommended by the qualitative characteristics of information required by the EFRAG’s ESRS (see ESRS 1, section 2). Scope of consolidation [BP-1 DP 5 a; 5 bi] The Sustainability Statement was prepared on a consolidated basis by the Parent Company, Banca Mediolanum S.p.A. (hereinafter also ‘Banca Mediolanum’ or ‘the Bank). The scope of data and information refers to all Companies consolidated on a line-by-line basis in the Consolidated Financial Statements of the Mediolanum Group as at 31 December 2025, ensuring consistency between financial and non-financial information. The information and data reported refer to the year 2025 (from 1 January 2025 to 31 December 2025) and to the activities of the entire Mediolanum Group during the year, unless otherwise indicated. Disclosures in relation to the Value Chain [BP-1 DP 5 c] The disclosures provided in the Sustainability Statement are extended to include information on the material impacts, risks and opportunities (hereinafter also the ‘IRO’) linked to the Mediolanum Group through its direct and indirect business relationships in the upstream Value Chain, mainly attributable to information on suppliers involved in the development of the Group’s products and services, and downstream, mainly attributable to information on distributors (Family Bankers and Agents in financial activities) and on customers reached by banking, protection and asset management/investment services. The document includes material impacts, risks and opportunities related to the upstream and downstream Value Chain based on the results of the double materiality assessment process, in accordance with specific Value Chain requirements. For further details on the materiality assessment, see ESRS 2 General information, paragraph 1.1.3 ‘Material impacts, risks and opportunities and their interaction with strategy and business model ‘. Details of the extent to which policies, actions, targets and metrics that cover or contain data on the Value Chain are clearly highlighted in the topic chapters. [BP-2 DP 10 a]
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69 | Mediolanum Group - Annual Financial Report 2025 The Mediolanum Group, under disclosure obligation E1-6 ‘Gross Scope 1, 2, 3 and Total GHG Emissions’, includes upstream and downstream Value Chain data. [BP-2 DP 10 b; 10 c; 11 a; 11 bi; 11 bii] Generally, the metrics relating to the Mediolanum Group’s own operations present primary data, while the metrics relating to the Value Chain (E1-6 ‘Gross Scope 3 GHG emissions’) present estimated values and therefore have a higher level of uncertainty in terms of measurement and results. Such uncertainty arises from a number of factors, including the complexity of the Group’s Value Chain and the limited availability of timely and directly accessible information, which makes it necessary to use infoproviders or industry studies. However, the accuracy of metrics calculated by proxy is ensured by authoritative sources used at national, European and international level. Disclosures on the causes of uncertainty in estimates and results are described in the section on metrics. The Mediolanum Group periodically reviews Scope 3 emissions measurement approaches with a view to improvement and on the basis of experience and the development of sustainability reporting standards. For further information on measurement approaches, see ESRS E1 Climate change, paragraph 2.1.7 ‘Gross Scope 1, 2, 3 and Total GHG Emissions’. [BP-2 DP 10 d] The Group undertakes to ensure the utmost timeliness in its reporting, favouring, where possible, the use of current data over estimates, in line with best market practices and regulatory developments. Disclosures in relation to specific circumstances [BP-2 DP 9 a] The Mediolanum Group, in line with the definition of short-, medium- and long-term for the purposes of the reporting provided for by EFRAG’s ESRS (see ESRS 1, section 6.4) adopts the following time intervals: short-term time horizon: one year, corresponding to the period adopted as the reporting period for its financial statements; medium-term time horizon: from one year to five years; long-term time horizon: over five years. [BP-2 DP 9 b] The Mediolanum Group has adopted, exclusively as part of the risk materiality assessment process in line with the Mediolanum Group’s ESG Risk Management Policy, a short-term definition that deviates from the time horizon defined by EFRAG’s ESRS (see ESRS 1, section 6.4). With regard to the risk materiality assessment, the Group adopts the following time intervals: short-term time horizon: up to three years; medium-term time horizon: from three to five years; long-term time horizon: over five years. Specific time horizons are used by the Risk Management Function to assess the risks associated with climate change (for further detail, see ESRS 2 General disclosures, paragraph 1.1.4 Impact, risk and opportunity management, and the section ‘Description of the processes to identify and assess material pollution-related impacts, risks and opportunities). [BP-2 DP 13 a; 13 b; 13 c] Quantitative information on the Distribution Network – Family Bankers for 2024 has been reformulated to ensure comparability with 2025 data, following the adoption of a new, updated methodology for classifying professional roles. The main changes between the data previously reported in the 2024 Sustainability Statement and the data presented in this document are therefore attributable to this methodological update and do not reflect substantial changes in the perimeter or composition of the Sales Network. For further details, see Entity-specific disclosures, paragraph 5.1.7 Metrics, ‘Breakdown of Family Bankers by role and gender – Spain’. [BP-1 DP 5 d]
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70 | Mediolanum Group - Annual Financial Report 2025 The Group did not use the option to omit a specific piece of information corresponding to intellectual property, know-how or the results of innovation. [BP-1 DP 5 e] The Group did not make use of the exemption from disclosure of impending developments or matters in the course of negotiation, in accordance with Article 29a(3) of Directive 2013/34/EU. Approval processes and external assurance This Statement was submitted for examination and assessment by the Group Coordination and Strategic Development Committee, in its ESG configuration, on 03 March 2026, and to the Risk Committee on 09 March 2026, and was finally approved by the Board of Directors of Banca Mediolanum on 12 March 2026. The Consolidated Sustainability Statement is also subject to a limited assurance engagement on the part of PricewaterhouseCoopers S.p.A. in accordance with the criteria indicated in the Standard on Sustainability Assurance Engagement (SSAE) (Italy), in accordance with the procedures indicated in the ‘Independent Auditor’s Report’ included in this document. 1.1.2 Governance The Mediolanum Group’s governance model is based on maintaining the existing administration and control structures of the individual subsidiaries of Banca Mediolanum, with the objective of providing stability and continuity for the management of the Group as a whole. With particular regard to the Parent Company, Banca Mediolanum, it recognises the validity of the traditional model (the Shareholders’ Meeting, the Board of Directors and the Board of Statutory Auditors), which is currently considered the most suitable to ensure efficient management and effective supervision. The decision to maintain the traditional type of administration and supervision system is based on a series of reasons relating to an in-depth analysis carried out with reference to both the external regulatory and legislative environment and the internal strategic and organisational environment. In view of the above, it has been concluded that the traditional system is appropriate for the Bank’s requirements and the size and structure of its corporate bodies. This system ensures the pursuit of the objectives of sound and prudent management as well as the requirements of balancing powers and the adequate separation of the strategic oversight, management and control functions indicated by the Supervisory regulations. Role of the administrative, management and supervisory bodies As the strategic supervisory body, the Board of Directors defines the overall governance structure, approves the Bank’s organisational structure, verifies that it has been correctly implemented, and promptly takes corrective measures to address any gaps or inadequacies. The Board is tasked with ensuring the governance of risks to which the Bank is exposed, promptly identifying their sources, their possible dynamics and the necessary safeguards to be put in place. In addition, it is specifically called on to: pursue sustainable success; approve the accounting and reporting systems; oversee the Bank’s public information and communication process; ensure effective dialogue with the management function and the heads of the main corporate functions and verify their choices and decisions over time; assess the business model, being aware of the risks to which this model exposes the Bank, and understand the ways in which the risks are identified and assessed, also taking into account the objectives of solid and sustainable value creation for all Stakeholders;
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71 | Mediolanum Group - Annual Financial Report 2025 incorporate environmental, social and governance (ESG) factors into the strategic guidelines, ensuring that they are periodically reviewed, in relation to the evolution of the business and the external environment, in order to ensure their effectiveness over time. The Board of Directors of Banca Mediolanum has 13 members, appointed by the Shareholders’ Meeting of 18 April 2024, and will remain in office until the date of the Shareholders’ Meeting convened to approve the financial statements for the year ended 31 December 2026. [GOV-1 DP 21 a; 21 d] Members of the administrative, management and supervisory bodies – BoD of Banca Mediolanum S.p.A. UoM 2025 2024 Women Men Total Women Men Total Total number of executive members No. 0 1 1 0 1 1 Total number of non-executive members No. 6 6 12 6 6 12 Total number of members of the administrative, management and supervisory bodies No. 6 7 13 6 7 13 Gender distribution of members of the Board of Director, Management and Supervisory Bodies % 46.15 53.85 100 46.15 53.85 100 [GOV-1 DP 21 d] Gender diversity of the BoD of Banca Mediolanum S.p.A.8 UoM 2025 2024 Average ratio of male to female members of the Board % 85.71 85.71 [GOV-1 DP 21 e] Independent members of the Board of Directors of Banca Mediolanum S.p.A. UoM 2025 2024 Percentage of independent members of the Board of Directors % 76.92 76.92 With regard to the members of the Board of Statutory Auditors (standing and alternate), 50% of the members are male and 50% are female. [GOV-1 DP 21 b] The Group does not present representatives of employees or other workers on the Board of Directors. [GOV-1 DP 21 c] In consideration of the Group’s size and the size of its individual entities, as well as the complexity and specificity of the sector in which it operates, the ideal skills and professionalism for the proper functioning of the Board of Directors were identified for the selection of Representatives (in Italy, this is contained in the document ‘Recommendations to shareholders on the optimal qualitative and quantitative composition of the Board of Directors’, which is published on the Banca Mediolanum website). These responsibilities include a number of areas and topics that are largely prescribed by law, such as to ensure the overall suitability of the Board in carrying out its activities. In addition to the professionalism requirements established by law and mandatory for their appointment, the Directors are required have a high level of knowledge and experience, preferably in specific areas of competence such as, by way of example: 8The gender diversity of the Board of Directors is calculated as: (Total number of female members/Total number of male members) * 100.
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72 | Mediolanum Group - Annual Financial Report 2025 knowledge of the banking sector, financial markets and methods for managing and controlling the risks associated with banking activity; knowledge of the dynamics of the economic and financial system; experience of business management and corporate organisation; the ability to read and interpret the Financial Statement data of a financial institution; corporate expertise (audit, legal, corporate affairs, etc.); knowledge of financial sector regulation; international experience and knowledge of foreign markets; knowledge of socio-political contexts and market mechanisms of countries in which the Banking Group has a strategic presence; knowledge of issues relating to organisation and information systems; knowledge of strategic planning, awareness of strategic business guidelines or the business plan of a lending institution and their implementation; knowledge of the effectiveness of the credit institution’s governance arrangements, aimed at ensuring an effective system of supervision, management and control; experience in accounting and auditing; experience in the training, management and coordination of networks of Financial Advisors and the products distributed by them. In addition, members of the Board of Directors have to meet the requirements of good repute and fairness (in accordance with the provisions of Article 26 of Legislative Decree No.385/1993 (‘TUB’), Article 3 of Ministerial Decree 169, Article 26 of the TUB and Article 4 of Ministerial Decree 169), as well as the requirements of independence of judgement, and, for some of them, the requirements of independence (Article 147b of Legislative Decree No. 58/1998 ‘TUF’)). The skills and experience described above are further broken down in each Group Company and have been acquired through many years of experience in administration, management and control, entrepreneurial and professional activities, audit assignments, statutory audits and management control, advisory activities and university teaching, as well as through experience gained in companies, groups and institutions of significant size, public and private entities, international contexts or contexts with an international vocation, and through studies, research and investigations carried out with research entities. In view of the renewal of the Board, the Boards of Directors of the Parent Company and the Subsidiaries assess the optimal qualitative and quantitative composition of the Board of Directors for the effective performance of the tasks and responsibilities entrusted to them by law, Supervisory Provisions and the Articles of Association. With regard to the Spanish Subsidiaries, the updated skills of the members of the Board of Directors mainly relate to: banking activities and financial markets (including the various financial business areas of the Entity and the geographic markets in which it operates); the legal requirements and regulatory framework (including regulatory compliance); anti-money laundering and countering the financing of terrorism; strategic planning, understanding of business plan strategy and their implementation; risk management (identification, assessment, monitoring, control and mitigation of the main types of risk), and the internal audit system; climate and environmental risks; accounting and auditing; assessment of the effectiveness of measures taken by a credit institution, ensuring effective governance, oversight and controls;
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73 | Mediolanum Group - Annual Financial Report 2025 interpretation of financial information to identify key issues and the adoption of appropriate controls and measures; managerial skills and management experience; information and security technologies; insurance activity; sustainability; human resources; digital marketing. With regard to the Irish Subsidiaries Mediolanum International Funds (hereinafter also ‘MIFL’) and Mediolanum International Life (hereinafter also ‘MILL’), the Directors’ skills tend to mainly cover the following areas: corporate governance and regulatory requirements; risk management; development and implementation of the strategy; finance; information systems and cybersecurity; industry experience; corporate governance/ESG; networking. The skills of Directors and the overall suitability of the Board are verified on the basis of an analysis of the Directors’ CVs and their declarations regarding their professional and educational/training experience. [G1.GOV-1 DP 5 a] The Parent Company’s Board of Directors is responsible for defining the Group’s sustainability strategy, including the matter of responsible conduct, and for approving the Mediolanum Group’s Code of Ethics and Sustainability Policy. The Board of Directors is also responsible for approving and implementing the additional Group policies on responsible conduct. The Irish and Spanish Subsidiaries transpose the policies issued by the Parent Company on conduct and sustainability. Local policies are, where necessary, adapted to ensure compliance with current legislation and local best practices and subsequently submitted to the Board of Directors for approval. At the end of the process, they notify the Parent Company of matters that have been approved. Sustainability governance In order to operate in a manner that is consistent and effective with the defined strategy, Banca Mediolanum, the Parent Company of the Mediolanum Financial Conglomerate, has adopted a specific sustainability governance formalised within the Mediolanum Group’s Sustainability Policy, approved by the Board of Directors in 2019 and most recently updated at the Board meeting of 12 December 2024. [GOV-1 DP 22 b] The Mediolanum Group’s Sustainability Policy outlines the strategy and objectives by which the Group, also referred to as the Financial Conglomerate, intends to operate in order to generate added value for the Stakeholders it has dealings with, in the management of material sustainability matters and the related impacts, risks and opportunities (hereinafter also the ‘IROs’). The Policy aims to: define the strategic guidelines at Group level on sustainability, which are subsequently set out in the specialist policies on the various relevant topics in the area; set out the roles and tasks relating to the double materiality process and management of the material sustainability matters and the related impacts, risks and opportunities;
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74 | Mediolanum Group - Annual Financial Report 2025 set out the governance and operational model adopted in the area of sustainability; increase the level of engagement of the Group’s stakeholders through its commitment to the constant pursuit of the principles contained in sustainability policies and to the achievement of the related ‘material’ results; facilitate the sustainability reporting process; disseminate a culture of sustainability. The specialist policies reported on in the topic sections of the document therefore have to be taken into account, where necessary, by the various corporate structures in the carrying out of normal business activities. [GOV-1 DP 22 a; GOV-2 DP 26 b] The Parent Company’s Board of Directors is responsible for defining the Group’s sustainability strategy, periodically reviewing it in relation to the evolution of the company’s activity and the external context and is responsible for approving the Code of Ethics and Sustainability Policy of the Mediolanum Group. It is also responsible for approving the double materiality assessment, in accordance with Legislative Decree No. 125/2024, and for monitoring the management of processes relating to material impacts, risks and opportunities, about which the Board is regularly updated. Finally, the Board of Directors is responsible for approving the Sustainability Statement included in the Group’s Report on Operations, and for ensuring that the information required by Article 4 of Legislative Decree No.125/2024 is provided in accordance with the provisions of this Decree. In fulfilling this obligation, the Board of Directors acts according to criteria of professionalism and diligence. The Parent Company’s Risk Committee supports the decisions of the Board of Directors on sustainability matters related to the carrying out of the undertaking’s business and the dynamics of its interaction with all stakeholders, including sustainability matters found to be material by the double materiality assessment and also the associated climate-related and environmental risks. In this context, it supports the Board of Directors in monitoring the management of material risks, impacts and opportunities, as well as the progress made in pursuing objectives overseen by the competent corporate Functions. Among its duties, it monitors the compliance of recipients with the ethical values and rules of conduct established in the Code of Ethics. It also coordinates, through the competent functions, initiatives for the dissemination, training and communication of these values and the rules of conduct promoted by Banca Mediolanum and the Companies it controls. It also verifies, in the context of the Risk Appetite Framework (RAF), that the strategic proposal in the sustainability area is in line with the risk strategies, ensuring that the oversight of risks material for the Group also includes risk factors that may fall within the scope of sustainability, such as climate-related and environmental risks. Lastly, the Risk Committee makes a preliminary assessment of the Sustainability Statement for the Board of Directors. The Parent Company’s Appointments and Governance Committee has advisory functions assisting the Board of Directors with regard to Appointments, implementing the provisions of the Corporate Governance Code, and the structure of the main Corporate Governance rules. In performing its duties, the Committee pursues the objective of preventing the decision-making processes of the Board of Directors from being dominated by a single person or by groups of persons that could harm the Bank. With regard to the need to ensure adequate diversification in the collective composition of the Board of Directors, the Appointments and Governance Committee – without prejudice to the obligations imposed by the regulations for listed banks – also contributes to the setting of a target for the proportion of the least represented gender and to the drawing up of a plan to increase this proportion to the set target. With regard to the Mediolanum Group’s Sustainability Policy, it assesses and monitors the sustainability aspects related to governance.
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75 | Mediolanum Group - Annual Financial Report 2025 The Parent Company’s Remuneration Committee supports the Board of Directors in developing remuneration and incentive policies and periodically assesses their overall adequacy and consistency, including in terms of sustainability aspects; it also does this with the aim of ensuring compliance with the principles of plurality, equal opportunities, equity and no gender discrimination, as well as the protection of customer interests (i.e., with particular regard to the remuneration system for financial advisors and the underlying risks, such as the risk of mis-selling). The Board of Statutory Auditors monitors compliance with the provisions of Legislative Decree No.125/2024 and the requirements for the preparation of the Sustainability Statement, and reports on this in the Board of Statutory Auditors’ Report to the Shareholders’ Meeting. In particular, in accordance with Article 19 of Legislative Decree No. 39/2010 (implementing Directive 2006/43/EC on statutory audits of annual accounts and consolidated accounts), the Board of Statutory Auditors is responsible for: informing the Bank’s Board of Directors of the outcome of the statutory audit and the outcome of the activity of certifying the Sustainability Statement, and transmitting to that body the additional report referred to in Article 11 of Regulation (EU) 537/2014, together with any comments; monitoring the process of financial reporting and the Sustainability Statement, including the use of the electronic format, and making recommendations or proposals to ensure its integrity and transparency; monitoring the effectiveness of the undertaking’s internal quality control, risk management and internal audit systems with regard to financial reporting and the Sustainability Statement; monitoring the statutory audit of the separate financial statements and consolidated financial statements, as well as the activity of certifying the Sustainability Statement; verifying and monitoring the independence of the persons responsible for statutory auditing and sustainability auditing, in particular as regards the adequacy of the provision of services other than auditing to the audited entity; being responsible for the procedure for the selection of the persons responsible for the statutory audit. The Supervisory Body – which is currently the Board of Statutory Auditors – monitors the functioning of and compliance with the Organisation, Management and Control Model adopted to prevent offences that fall within the scope defined by Legislative Decree No. 231/2001 and that may give rise to an interest or benefit for the Entity. It is supported by the 231 Unit, the Board of Statutory Audit and Managerial Committees of the Corporate Affairs Division, which prepares and submits for the attention and approval of the Supervisory Body references to Model 231/2001 and any other relevant documentation within the scope of corporate administrative liability (i.e. 231/2001 risk assessment, protocols, specific procedures, etc.) that may be relevant for the preparation of the Sustainability Statement and for the matters referred to and dealt with by Model 231/2001 in effect (e.g. anti-corruption, environmental offences, management of health and safety in the workplace, etc.). The Chief Executive Officer oversees the implementation of the strategic guidelines in the area of sustainability, the RAF (Risk Appetite Framework) and risk governance policies in the area of sustainability and, more generally, relating to ESG matters defined by the Board of Directors. The Chief Executive Officer, assisted by the Financial Reporting Officer, prepares the draft separate and consolidated financial statements, of which the Sustainability Statement is an integral part, to be approved by the Board of Directors before they are presented to the Shareholders’ Meeting. The Chief Executive Officer certifies, in a specific report, that the Sustainability Statement, included in the Report on Operations, has been prepared in accordance with the reporting standards applied pursuant to Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013 and to Legislative Decree No. 125 of 6 September 2024, implementing Article 13 of Law No. 15 of 21 February 2024, and with the specifications adopted pursuant to Article 8(4) of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020.
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76 | Mediolanum Group - Annual Financial Report 2025 The Financial Reporting Officer certifies, in a specific report, that the Sustainability Statement, included in the Report on Operations, has been prepared in accordance with the reporting standards applied pursuant to Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013 and the Legislative Decree implementing Article 13 of Law No. 15 of 21 February 2024, and with the specifications adopted pursuant to Article 8(4) of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020. [GOV-1 DP 22 c] The Group Coordination and Strategic Development Committee in its ESG configuration is a management committee that supports the Board of Directors and the Chief Executive Officer in identifying sustainability matters potentially material for the Group and in defining the relevant strategic guidelines and sustainability policies, including for the purposes of defining and updating the double materiality assessment. The Committee proposes to the Chief Executive Officer and the Board of Directors the development of material ESG initiatives, and also monitors their implementation at Group level. The Committee is periodically informed of the results of the monitoring of processes to manage material impacts, risks and opportunities, including the progress made to pursue the related targets, overseen by the individual competent Functions, before submitting this information to the Risk Committee and the Board of Directors of the Parent Company. Lastly, it examines the Sustainability Statement prior to submitting it to the Risk Committee and the Board of Directors. The Compliance Function oversees the management of compliance risk, according to a risk-based approach, with regard to all business activity, excluding the regulatory areas which, in accordance with law, are overseen by the other Control Functions. Specifically, the Compliance Function carries out both ex ante and ex post control activities to oversee the ESG-related and climate-related risk, particularly with regard to areas that affect customers or potential customers. In the area of product governance, product verification is also ensured, before their marketing, identifying any mitigation actions and informing the Bank’s bodies as part of the Function’s ordinary reporting activities. The Parent Company’s Compliance Function has a coordinating and supporting role, ensuring a uniform and consistent interpretation of the Group’s principles arising from applicable regulatory obligations. The aim of this activity is to ensure that all Subsidiaries adopt an approach which is consistent with regulatory provisions and with shared corporate values in the area of sustainability. The Parent Company’s Risk Management Function is responsible for implementing governance policies and the risk management system and collaborates in defining and implementing the Group’s Risk Appetite Framework (RAF), ensuring, in exercising its Control Function, that the Parent Company’s corporate bodies have an integrated vision of the various risks faced by the Group. Specifically, in the ESG area and with reference to climate-related and environmental risks, the Risk Management Function: promotes a culture of risk management; provides specific technical, methodological and organisational support to all organisational units involved in the process of managing climate-related and environmental risks; contributes to the production of periodic reporting to Senior Management and the Supervisory Authority; periodically carries out simulations relating to hypothetical stress scenarios that generate significant impacts on the forecasts of the economic and financial plan; defines the guidelines for supervising and managing ESG risks within the Mediolanum Group, with reference to the material risks of Group Companies, submitting them to the Board of Directors for approval; collaborates with the Sustainability Office in identifying material sustainability issues (known as the double materiality assessment) with particular reference to risks. The Parent Company’s Risk Management Function is the reference Function for the corresponding functions of the Subsidiaries as regards aspects relating to the assessment and measurement of the Group’s ESG risks.
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77 | Mediolanum Group - Annual Financial Report 2025 The Parent Company’s Anti-Money Laundering Function uses a risk-based approach to oversee money laundering risk and the adaptation of processes to changes in the regulatory and procedural environment in this area. It continuously checks that company procedures are consistent with the objective of preventing and combating infringements of external regulatory provisions (laws and regulations) and internal regulations on anti-money laundering and counter terrorist financing. In carrying out the aforementioned activities, the Function places particular emphasis on the Social/Ethical aspect of ESG issues (e.g., Responsibility to the Community – Combating of money laundering). The Parent Company’s Anti-Money Laundering Function is the reference Function for the corresponding functions of the Subsidiaries as regards aspects relating to the assessment of anti-money laundering matters in connection with sustainability. The Parent Company’s Internal Audit Function is intended, on the one hand, to oversee, in terms of third-level controls, the regular performance of operations and the evolution of risks, including risks related to ESG issues, and, on the other hand, to assess the completeness, adequacy, functionality and reliability of the organisational structure and other components of the internal control system. The Internal Audit Function is also responsible for the Parent Company’s ‘Whistleblowing System’ and for analysing and assessing reports received, in compliance with applicable legislation. The Parent Company’s Internal Audit Function is the reference Function for the corresponding Functions of Subsidiaries as regards aspects relating to the assessment to matters in connection with the Group’s Whistleblowing Systems. Finally, the Internal Audit Function assesses the completeness, adequacy, functionality and reliability of the internal control and risk management system relating to the process for drawing up the Sustainability Statement as part of the third-level audits within its competence. The Administration, Finance and Control Department supports the Chief Executive Officer in decision-making processes, providing information on how to use capital and resources to achieve business results, including targets relating to sustainability issues, in accordance with the Risk Appetite Framework (RAF) defined and approved by the Board of Directors. It oversees the organisational units responsible for preparing financial reporting and forecasts, including the Sustainability Statement, and for identifying and proposing strategic sustainability guidelines. The Sustainability Office, within the Administration, Finance and Control Department, is responsible for supporting the development of the Mediolanum Group’s sustainability strategy, through the search for best practices at market level and their submission to the Group Coordination and Strategic Development Committee in its ESG configuration and to the internal Board Committees, for the subsequent resolutions of the Board of Directors. In detail, the Sustainability Office: supports the Chief Executive Officer in defining the sustainability strategies to be proposed to the Board of Directors after the assessments of the Group Coordination and Strategic Development Committee in its ESG configuration and of the internal Board Committees, updating the Mediolanum Group Sustainability Policy; supports, where required, the Parent Company’s internal communication and info/training activities relating to sustainability; participates in the oversight of social responsibility and solidarity initiatives for the community (granting donations) of Banca Mediolanum and the Mediolanum Group; updates and disseminates, with the support of the Human Resources Department for value and identity aspects, and of all the other organisational units involved in the process, the Code of Ethics defined by the Parent Company, Banca Mediolanum, and, where applicable for specific corporate characteristics, the Code of Ethics of the Subsidiaries. In addition, through the ESG Reporting Team and IRO Oversight, it: coordinates, on an operational level, the Group Coordination and Strategic Development Committee in its ESG configuration;
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78 | Mediolanum Group - Annual Financial Report 2025 develops/manages stakeholder engagement activities and the identification and proposal to the Group Coordination and Strategic Development Committee in its ESG configuration of the material matters in terms of economic, environmental, social and governance sustainability; manages the process of preparing the Sustainability Statement, including the double materiality assessment, in accordance with Legislative Decree No. 125/2024, acting as the point of reference for the Mediolanum Group, for the Italian and foreign Subsidiaries, in defining and collecting sustainability information; coordinates the reporting process in the area of Taxonomy, in accordance with Regulation (EU) 2020/852; manages the periodic monitoring of progress in the pursuit of targets related to material impacts, risks and opportunities, overseen by the individual organisational structures of the competent Parent Company, for the purposes of updating reporting to the Group Coordination and Strategic Development Committee in its ESG Configuration, the Risk Committee and the Board of Directors; oversees ESG ratings and related information flows to specific rating agencies and ESG data providers (S&P, MSCI, Sustainalytics, CDP, etc.). The Human Resources Department implements the remuneration policies for the Group’s employees, in accordance with the Group’s Remuneration Policies and Incentive Policies approved by the Parent Company’s Board of Directors, including with regard to ESG aspects, periodically submitting proposals for updating the policies to the Remuneration Committee, after sharing them with the Compliance Function and the Risk Management Function of the Parent Company for the relevant checks. It disseminates corporate culture and values within the Group by ensuring the application of the principles of fairness, equity and respect for people, as well as Diversity & Inclusion (D&I) policies, which aim to promote the inclusion and enhancement of differences. The Company’s Diversity Manager operates in the Department. The Human Resources Department, in accordance with the applicable regulations and agreements in this regard, provides for procedures for informing the Parent Company’s employee representatives at the appropriate level and discusses with them the relevant information and the means to obtain and verify sustainability information. The Investment Services Department oversees sustainability matters relating to investments, supporting the Group Coordination and Strategic Development Management Committee in its ESG configuration and the Board of Directors in defining the responsible investment guidelines and monitoring the ESG positioning of investment products. Management is also responsible for coordinating Responsible Finance initiatives for the Conglomerate, sending relevant guidelines to the Subsidiaries and ensuring and monitoring their implementation. The Head of the Bank’s Investment Services Department is assisted by the Conglomerate’s Investments ESG Committee, which is tasked with providing support and advice in analysing and monitoring at Conglomerate level the overall ESG positioning of the product offering in this area, in proposals for sustainable investment guidelines, methods for assessing ESG characteristics and any parameters that the offering must comply with at Group level, verifying the consistency of the safeguards undertaken by the Group Subsidiaries in this area. The Business Model and Insurance Services Department oversees areas relating to the sustainability of protection products. It manages the evolution of the customer advisory model with regard to sustainability and the implications for protection products’ sustainability. It is also responsible for the operational implementation of legal and regulatory obligations, training, internal and external communication, defining the content of public disclosure on sustainability, and integrating sustainability risks into business processes.
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79 | Mediolanum Group - Annual Financial Report 2025 The Demand, Supply Chain and Strategic Projects Coordination Department , through the Procurement Division, oversees – in compliance with social responsibility criteria – all activities aimed at acquiring material production factors from the market, ensuring, in terms of times, quality, quantities and locations, the availability of goods and services necessary for performing business activities. The Corporate Services & HSSE Department (Health, Safety, Security & Environment) manages the company’s real estate assets instrumental to the Bank’s business and oversees issues relating to workplace health and safety, as well as the environmental sustainability of buildings. The additional Structures of the Parent Company – involved in processes relating to sustainability matters in various ways – are required to provide support during the operational stages of these processes and to comply with the Code of Ethics and the Code of Conduct adopted by the Group. All the Companies belonging to the Mediolanum Group (also understood as the Financial Conglomerate) comply with the Code of Ethics and the Code of Conduct in force at the Group. They also adopt, by resolution of their own corporate bodies, the principles contained in the Mediolanum Group’s Sustainability Policy, and in addition are responsible for the effective implementation of its principles. [GOV-1 DP 22 c; 22 ci] The Group Coordination and Strategic Development Committee in its ESG configuration is the management committee to which the task of supporting the Board of Directors is delegated, in relation to the monitoring, management and supervision of the Group’s impacts, risks and opportunities. [GOV-1 DP 22 d] In its ESG configuration, the Group Coordination and Strategic Development Committee of the Parent Company is periodically informed of the results of the monitoring of progress made in pursuing targets relating to material impacts, risks and opportunities, overseen by the individual competent Functions, before submitting this disclosure to the Risk Committee and the Board of Directors of the Parent Company. [GOV-1 DP 22 cii] This Committee also supports the Board of Directors and the Chief Executive Officer in defining strategic guidelines and sustainability policies. The Board of Directors, within the scope of its own competence, is responsible for overseeing the management of processes relating to material impacts, risks and opportunities. [GOV-1 DP 22 ciii] In relation to the management of impacts, risks and opportunities, each Department responsible for their specific areas performs first-level controls as part of the process of the double materiality assessment. These controls, carried out by the competent managers, are subsequently verified by the second-level Corporate Control Functions, according to the procedures and tools defined in the internal regulations. Sustainability-related skills and expertise of the bodies [GOV-1 DP 23] Within the Group, sustainability-related skills and expertise play an essential role and are disseminated appropriately. The Boards of Directors have assessed the presence of these skills and expertise, integrating them with continuous Board Induction activity, with the contribution of qualified speakers, in order to increase the skills and expertise of the individual Representatives and, consequently, of the Body as a whole. [GOV-1 DP 23 a] During 2025, the topics discussed during the Induction activities, proposed by the Italian Parent Company, included the following, by way of example: an in-depth study on Artificial Intelligence, entitled ‘ICT risk governance - Artificial Intelligence: opportunities and risks’, presented in January; and ‘The package of new European rules for combating money laundering and terrorist financing – Artificial intelligence in the banking world’ and ‘Artificial Intelligence’, presented in November;
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80 | Mediolanum Group - Annual Financial Report 2025 in relation to the ’Digital Operational Resilience Strategy – DORS’, internal regulations and new processes related to DORS, explored in depth during January; with regard to BCBS239 and Sustainability, the ’Focus on CSRD: regulatory obligations and opportunities’, and the ’Contents of the Consolidated Sustainability Statement’ and the ’Guide on effective risk data aggregation and risk reporting’, presented in February; with regard to risk culture, ‘The value of the risk culture for banks’, ‘Internal Governance & Risk Culture: the ECB perspective’ and ‘Risk Culture in the Mediolanum Group’, explored in depth in March; the topic ‘Methodology for analysing product and customer performance and for overseeing offer positioning’, addressed in April, with an in-depth review of ‘Product, portfolio and customer performance’ and of ‘Methodology, analysis, performance, product and customer and oversight of offer positioning’; In September, the topic ‘Geopolitical Scenarios and Risks, and the 2026–2030 Business Plan’, discussed in detail, and the 2026–2030 ICT Strategic Plan, presented in December. Additional sustainability activities are also carried out by the Subsidiaries, with specific initiatives linked to their respective operational needs. In particular, Banco Mediolanum organises annual training and board induction sessions dedicated to updating the members of the Board of Directors, with a significant focus on ESG issues. In the fourth quarter of 2025, a training session for members of the Board of Directors was held on regulatory developments expected in 2026, including an overview of ESG risks. As regards the Irish Subsidiaries, the Board of Directors evaluates the skill and expertise of all Directors annually, using a matrix covering all relevant areas, including Sustainability. This assessment makes it possible to identify and bridge any training or expertise gaps. [GOV-1 DP 23 b] On the basis of the checks carried out, the Board of Directors provides for the presence of Representatives with ESG expertise for the Group. The presence of this expertise derives both from the professional and training background of the Representatives and from the training and induction activities proposed by the Board itself, which will have to be increasingly directed towards the impacts, risks and opportunities which are material for the Group. Specifically, with regard to the Parent Company, there are four Directors with particular ESG expertise, as a result of their personal training and work experience. The expertise acquired includes matters related to corporate governance, sustainability, the Social Report and gender equality. In particular, the following are present: a Director who acts as Governance and Sustainability Advisor, a member of the EFRAG Governance Working Group for the definition of ESG standards in response to the introduction of the CSRD regulations and part of the Pact for Milan for the development of the SDG reporting aspects of undertakings; a Director who works with a focus on corporate & sustainability governance, including through participation in specialist courses as a key speaker and in association initiatives, in the areas of sustainability, corporate governance, ESG and gender equality; a Director whose distinctive areas of expertise include governance and ESG, with a particular focus on sustainability topics, including the environmental area, having gained experience with technologies and processes with less impact, and the social area, in relation to gender equality and inclusion; a Representative with proven experience in Social Reporting and gender equality. With regard to foreign Subsidiaries, for the Group’s Spanish companies, ESG training for members of the Board of Directors allows for the development of a comprehensive view of the market and business, including sustainability- related aspects. This approach ensures that material impacts, risks and opportunities for Banco Mediolanum can be managed effectively. In Ireland, the Board of Directors is able to monitor the level of expertise of staff on sustainability issues, through regular reporting provided by Human Resources, the ESG team and various corporate functions. [G1.GOV-1 DP 5 b]
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81 | Mediolanum Group - Annual Financial Report 2025 The Board of Directors is composed of members who possess, inter alia, skills and expertise in matters of corporate conduct. In addition, the Chair of the Board of Directors, assisted by the competent structures, organised various Board Induction sessions in 2025 for the Representatives of the Parent Company and other Group Companies, including on business conduct matters, with the contribution of qualified speakers. Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies [GOV-2 DP 26 a] The results of the double materiality assessment are brought to the attention of the Group Coordination and Strategic Development Committee in its ESG configuration, the Risk Committee and the Board of Directors, which evaluate and approve them annually. During 2025, the Group Coordination and Strategic Development Committee in its ESG configuration, the Risk Committee and the Board of Directors were informed of the material impacts, risks and opportunities at meetings on 3, 4 and 6 November 2025 respectively, as part of the double materiality assessment carried out by the Mediolanum Group. The Group Coordination and Strategic Development Committee in its ESG configuration, in its role of supporting the Board of Directors in proposing sustainability matters potentially relevant to the Group and in defining the related strategic guidelines and sustainability policies, is responsible for submitting, through the Sustainability Office, disclosures on material impacts, risks and opportunities to the Risk Committee and to the Board of Directors of the Parent Company. In addition, the Board of Directors, the Risk Committee and the Group Coordination and Strategic Development Committee in its ESG configuration are informed, also as part of the monitoring of impacts, risks and opportunities, about the effectiveness of the policies adopted, the actions undertaken, the metrics analysed and the targets established, where applicable, as well as in relation to the duty of due diligence. [GOV-2 DP 26 c] The Group Coordination and Strategic Development Committee in its ESG configuration (see ESRS 2 General disclosures, paragraph 1.1.2 Governance, section ‘Sustainability Governance’ section, DP 22 c for further details on the role of the Committee) was informed and updated about the material IROs, which are listed in the following sections dedicated to the topic-related standards. By way of example only, topics related to climate change were explored in depth, with reference to the Report on Principles for Responsible Investment (PRB), as well as the Transition Plan for climate mitigation and, with regard to the social dimension, initiatives engaging local communities and the assessment of membership of local associations, as well as endorsement of the UN Global Compact – Manifesto: Business for people and society. In addition to these aspects, the Committee, prior to the Risk Committee and the Board of Directors meeting, was informed about the targets set and the methods of monitoring the IROs, in accordance with the provisions of ESRS 2 GOV-2, which governs the reporting of whether, how and how frequently the Administrative, Management and Supervisory Bodies are informed about sustainability issues —including the IROs—as well as the related policies, actions, metrics and targets. The issues covered were subsequently also discussed at the meetings of the Risk Committee and the Board of Directors of the Group.
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82 | Mediolanum Group - Annual Financial Report 2025 Integration of sustainability-related performance in incentive schemes [GOV-3 DP 29; 29 a; 29 b; 29 c; 29 d; 29 e] Variable remuneration aims to recognise the results achieved by the Company and individuals, through specific incentive plans that establish a direct link between actual remuneration and results attained in the short-, medium- and long-term, in accordance with the defined risk profile and sustainability priorities. Specifically, the short-term incentive system is designed to reward the annual performance of beneficiaries by creating a link between individual and corporate annual remuneration and performance. To this end, a correlation with Consolidated Net Income and an access gate is provided for, based on: the creation of risk-adjusted value; liquidity; capital. Individual performance is assessed on the basis of financial and non-financial targets. The variable remuneration for Key Staff consists of at least 50% in instruments and at least 40% of it is deferred. In particular for the Chief Executive Officer and with regard to the 2025 performance year, two ESG-related indicators have been provided for: ‘Real estate receivables - physical and transition risk’; ‘Risk Culture - Tonfrom the top’. For the 2023-2025 three-year performance period, in line with the Group’s long-term plan, a long-term incentive (LTI) plan was been adopted for a limited number of top managers who are particularly critical for business development (the ‘top key people’). In addition to the access gate in line with the short-term variable remuneration, the Plan establishes performance objectives that reflect strategic priorities in terms of: capitalisation and value creation; corporate sustainability; ESG & climate/environmental governance. The incentive consists of payment in cash and payment in shares of the Parent Company: 60% of the total amount is paid over a six-year period. The Plan includes specific KPIs (Key Performance Indicators) related to ESG factors, and namely ‘Limiting the offering of funds with an ESG rating below certain thresholds’; ‘Obtaining and maintaining ISO 14001 certification’; ‘Obtaining Gender Equality Certification’. Environmental, social and governance sustainability matters, as well as risk management in general, are an integral part of remuneration processes. In this context, a systemic, inclusive and transparent approach is constantly promoted, which also guarantees respect for the principles of plurality, equal opportunities, equity and non- discrimination of any individual. In particular, the remuneration and incentive criteria, based on objective performance-related parameters in line with the medium/long-term strategic objectives, are the best tool for encouraging an even greater commitment from all parties and, consequently, for responding as effectively as possible to the interests of the Group, combining economic growth and sustainable success. The Remuneration Policy, including with reference to short-term and long-term incentive systems, is therefore an expression of the corporate strategy and with it the ESG strategic priorities defined by the Board of Directors. In the context of internal goal-setting processes for beneficiaries of short-term incentive systems based on individual MBO (Management by Objectives) schemes (at each organisational level), specific managerial guidelines are disseminated internally, which require the identification of individual objectives related to ESG factors connected to the responsibilities and decision-making levers of individuals.
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83 | Mediolanum Group - Annual Financial Report 2025 The Board of Directors of Banca Mediolanum develops and periodically reviews the Group’s incentive and remuneration policies with the support of the Remuneration Committee, and is responsible for their correct implementation. Once they have been developed, the policies are submitted to the Shareholders’ Meeting of the Bank for approval and circulated within the Company, including through publication on the Parent Company’s website. Incentive schemes and remuneration policies Variable remuneration (%) 2025 Short-term Incentive Plan 25% 2023-2025 Long-term Incentive Plan 25% [E1.GOV-3 DP 13] Within the framework of the members of the Board of Directors of Banca Mediolanum, the Chief Executive Officer is the only person that receives variable remuneration and is therefore assigned performance targets linked to ESG KPIs. With regard to the Chief Executive Officer’s 2025 short-term incentive – in full continuity with previous years – ESG indicators were included in the individual scorecard, referring to the physical and transition risk relating to real estate receivables monitored at the level of the Risk Appetite Framework, and completing specific issues relating to the Risk Culture - Tone from the top programme. The total weighting of these indicators is equal to 25% of the maximum individual bonus. The indicator relating to real estate receivables is specifically assigned a weighting of 15% of the maximum individual bonus. The Chief Executive Officer of Banca Mediolanum is also one of the beneficiaries of the 2023-2025 Long-Term Incentive (LTI) Plan. An indicator was included in the performance parameters of the Plan for senior managers and top key people – with a weighting of 25% of the total of the objectives sheet for the Plan – that takes into account strategic sustainability initiatives from a long-term perspective, including with reference to climate-related risks. In this regard, two KPIs directly linked to climate-related risks have been identified (i.e. ‘obtaining and maintaining ISO 14001 certification’ and ‘limiting the offer of funds with an ESG rating below certain thresholds’) with an overall weighting of 20% of the total of the Plan’s targets. Of the maximum bonus payable (the maximum total opportunity) on the two plans described above, the maximum percentage of variable remuneration attributable to climate-related targets is 18% (16% in 2024). The non-executive Directors of Banca Mediolanum do not benefit from variable remuneration plans based on performance targets.
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84 | Mediolanum Group - Annual Financial Report 2025 Statement on due diligence [GOV-4 DP 30; 32] The table below provides a mapping of the paragraphs within the Sustainability Statement where information on the due diligence process for sustainability purposes is reported. Basic elements of the duty of due diligence Paragraphs/sections in the Sustainability Statement a) Integrating due diligence into the corporate governance, strategy and model Section ‘Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies’ (ESRS 2 DR GOV-2) Section ‘Integration of sustainability-related performance in incentive schemes’ (ESRS 2 DR GOV-3) Section ‘Material impacts, risks and opportunities and their interaction with strategy and business model’ (ESRS 2 DR SBM-3) Paragraph ‘Transition plan for climate change mitigation’ (ESRS DR E1-1) Section ‘The Group’s approach and policies’ (ESRS E1-2) Sections ‘The Group’s approach and policies’ (ESRS DR S1-1) Sections ‘The Group’s approach and policies’ (ESRS DR S2-1) Sections ‘The Group’s approach and policies’ (ESRS DR S4-1) Entity-specific disclosures: management of the distribution network – Section ‘Policies’ (MDR-P) b) Involving stakeholders at all key stages of due diligence Section ‘Interests and views of stakeholders’ (ESRS 2 DR SBM-2) Paragraph ‘Processes for engaging with own workforce and workers’ representatives about impacts’ (ESRS DR S1-2) Paragraph ‘Processes for engaging with consumers and end-users about impacts’ (ESRS DR S4-2) c) Identifying and assessing negative impacts Section ‘Description of the processes to identify and assess material impacts, risks and opportunities’ (ESRS 2 DR IRO-1) d) Taking action to address negative impacts Sections ‘ Actions’ (ESRS DR E1-3) Sections ‘ Actions’ (ESRS DR S1-4) Sections ‘ Actions’ (ESRS DR S2-4) Sections ’ Actions’ (ESRS DR S4-4) Entity-specific disclosures: management of the distribution network - Paragraph ‘ Actions’ paragraph (MDR-A) e) Tracking effectiveness of actions and communicating Section ‘Targets’ (ESRS DR E1-4; MDR-T) Section ‘Metrics’ (ESRS E1-5; ESRS E1-6) Paragraph ‘Processes to remediate negative impacts and channels for own workers to raise concerns’ (ESRS DR S1-3) Section ‘Targets’ (ESRS DR S1-5; MDR-T) Paragraph ‘Metrics’ (ESRS DR S1-9; ESRS DR S1-14; ESRS DR S1-16; ESRS DR S1-17) Paragraph ‘Processes to remediate negative impacts and channels for Value Chain workers to raise concerns’ (ESRS DR S2-3) Section ‘Targets’ (ESRS DR S2; MDR-T) Paragraph ‘Processes to remediate negative impacts and channels for consumers and end-users to raise concerns’ (ESRS DR S4-3) Sections ‘Targets’ (ESRS DR S4; MDR-T) Entity-specific disclosures: management of the distribution network – Paragraph ‘Metrics and targets’ (MDR-M; MDR-T)
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85 | Mediolanum Group - Annual Financial Report 2025 Risk management and internal controls over sustainability reporting [GOV-5 DP 36 a] The system of internal controls relating to the preparation of this Statement is regulated at Group level and governed by the ‘Regulations on the process of managing the activities of the Financial Reporting Officer - Law 262/2005’. It should also be noted that, as a result of the regulatory updates introduced by the CSRD and Legislative Decree No. 125/2024, the Group has updated the ‘Policy for the Preparation of the Consolidated Sustainability Statement’, which regulates and strengthens the overall roles and tasks and controls carried out during the process of preparing the Consolidated Sustainability Statement. With regard to the main characteristics, the internal control system in relation to sustainability reporting is divided into various groups of second-level controls under the responsibility of the Economic and Financial Analysis and Controls Unit and identified according to a risk-based approach: second-level oversight: controls of the completeness and accuracy of qualitative and quantitative information by verifying the correspondence of the datapoints (defined by EFRAG as the detailed elements of each disclosure obligation) attributed by the business owners within the IT platform used for data collection with what is present in the internal management systems of the owners, and checking that authorisation has been granted by the designated approvers (Reported Content Managers); second-level oversight: checking the completeness of the information included in the Sustainability Statement by controlling the progress of uploading; second-level oversight by means of spot checks on the accuracy of the information entered in the reference system with respect to the final draft of the Sustainability Statement document. During the 2024 financial year, an initial project was launched to identify internal controls aimed at verifying the completeness of the data reported in the Sustainability Declaration, in order to ensure alignment between management sources, the collection platform and the final document. During 2025, this process was consolidated by focusing efforts on strengthening the entire internal control system. In particular, the sample of Datapoints selected in 2024 was examined in depth using a risk ‐based approach, mapping the data production processes in a structured way and identifying the controls applied along the information chain. This activity enabled the strengthening of second-level safeguards, with specific checks on the accuracy and completeness of information intended for sustainability reporting. In addition, new controls were designed and implemented with the aim of ensuring the full compliance of the data entered in the reporting systems. In 2025, a formal testing stage was also carried out in order to assess both the adequacy of the design of the controls and their operational effectiveness, thus completing the evolution of the internal control system towards a more mature model consistent with the requirements of CSRD reporting. Finally, the relevant operating procedure for identifying the datapoints subject to 262 audits for 2025 was formalised. [GOV-5 DP 36 b] The methodology for assessing and prioritising risks relating to the internal control system was formulated by attributing to each datapoint reported in the Sustainability Statement a score based on five different requirements, in order to obtain a classification on three risk steps (low/medium/high). The requirements have increased to seven as of 2025 reporting. The review therefore focused on information relating to qualitative metrics and KPIs in the ESG context, as required by the CSRD (Directive (EU) 2022/2464) and Commission Delegated Regulation (EU) 2023/2772 and examines the supervision of high-risk datapoints only. [GOV-5 DP 36 c]
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86 | Mediolanum Group - Annual Financial Report 2025 The following is a summary of the considerations used to identify the aspects of significance and therefore identify the main risks: Assessment component: an assessment component refers to an element or aspect of a process that involves the assessment, measurement or analysis of certain factors or performance (e.g. in relation to Disclosure Requirement ESRS E1-6 ‘Gross Scope 1, 2, 3 and Total GHG emissions’ and, in general, in relation to additional quantitative environmental reporting requirements). The assessment component may have a grade ranging from low to high, depending on the complexity of the calculation required for the production of the figure; complexity of transactions: depending on the number of contributors, the greater the number of contributions per data item, the greater the complexity of the transaction; new KPI (importance of disclosure for external Stakeholders): data not reported in the disclosure of the previous financial year and therefore representing new information to be obtained; connection with other reporting: cross-cutting and topical information elements from other EU legislation (see Appendix B of ESRS 2: SFDR, Pillar III, Benchmarks Regulation, EU climate legislation); sustainability-related performance metrics embedded in incentive systems: sustainability-related performance metrics considered performance benchmarks or included in remuneration policies; manual nature of the process: manual production and data collection processes (applicable from 2025); history: performance factor (applied since 2025). The high-risk controls identified are assessed on an annual basis in the specific testing session. Should a control be assessed as not fully effective, an ad hoc mitigation strategy and consequent mitigation action will be defined with the control owner. The control subject to mitigation will subsequently be re-tested. [GOV-5 DP 36 d] The reporting of testing on the control points identified, which are based on the Sustainability Statement, and any adaptation actions, are submitted during a dedicated 262 Committee meeting, in which the Internal Audit, Compliance and Risk Management, Chief Data Officer, Data Governance and Administration, Accounting and Financial Reporting Functions are involved. The same results are brought to the attention of the Board of Statutory Auditors and the Supervisory Body of Banca Mediolanum. [GOV-5 DP 36 e] The annual report of the Financial Reporting Officer, which is drawn up at the end of the financial reporting period, and summarises the activities and assessments performed, will also include the section relating to controls in the Consolidated Sustainability Statement. This report is brought to the attention of the Risk Committee, the Board of Directors, the Supervisory Body and the Board of Statutory Auditors of Banca Mediolanum. The certification of the Financial Reporting Officer also refers to the Sustainability Statement. 1.1.3 Strategy Strategy, business model and Value Chain [SBM-1 DP 40 ai; 40 e; 40 f; 40 g; 42 b] Strategy and business model Banca Mediolanum’s business model is aimed at meeting the needs of each customer through a multi-channel offering of products and services. The Group’s aim is to release increasingly flexible and innovative products and solutions that meet the needs of people and households, who are its main targets. Thanks to the Family Bankers, Banca Mediolanum offers its customers targeted, personalised advice that turns into financial education over time, to assist them in making the most important decisions, with the expertise and flexibility needed to respond in the most effective way to the constant economic and financial changes of our time.
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87 | Mediolanum Group - Annual Financial Report 2025 Thanks to the production and distribution of its products and services, characterised by constant innovation, Banca Mediolanum operates with the aim of generating value for all its customers, whether they be households or small- and medium-sized enterprises. Value is generated directly and indirectly through the sustainability pillars that characterise the Group, represented by the following responsibilities: economic responsibility, which, thanks to the Bank’s ethical and sustainable way of operating, ensures the creation of business value and, more generally, the pursuit over time of positive impacts and shared well-being; responsibility towards customers, in particular through a deep understanding of people’s needs, care for their well-being and support in achieving their aspirations, always at the heart of the objectives of the Bank and the Sales Network; responsibility towards staff, thanks to the creation of a positive, rewarding and organised environment, capable of forming a community in which they can express their talent; responsibility towards the community and the environment, thanks to the Group’s choices and strategies, which aim to create a better life for the community and to protect the environment, both through the provision of sustainable products and services and through business management decisions. With the aim of reporting, as required by the ESRS of EFRAG, the key elements of the strategy on material areas of sustainability, information is provided below on the significant groups of products and services offered, as well as on customers and own workforce. A first significant group of products and services entails managing customers’ investments in certain financial instruments and business segments, focusing on financial advisory services to support their investment choices. The Group provides assistance in asset management and investment advice with reference to both the asset management business segment and the insurance segment, through the offering of Life insurance policies. The new Sustainability Plan, included in the Mediolanum Group’s 2026-2030 Business Plan, describes the main actions aimed at addressing the main impacts or material risks or at pursuing material opportunities. With regard to the area of investments, Group Companies that perform the role of financial market participant (FMP) include climate change in their investment policies. Building on action begun in 2024, with a view to setting target consistent with the European approach to carbon neutrality, the Group has adopted new climate targets aimed at reducing the environmental impact of investment portfolios and progressively aligning them with the transition scenarios inspired by the Paris Agreement. In line with the Group’s strategic guidelines, companies operating as financial market participants have set up a monitoring system dedicated to climate indicators and defined specific plans for reducing greenhouse gas (GHG) emissions generated by investment activity. These plans were prepared by the Group’s main asset managers, Mediolanum International Funds and Mediolanum Gestione Fondi (hereinafter also ‘MGF’), and form an integral part of the 2026–2030 Long-term Business Plan (see ESRS E1 Climate Change, paragraph 2.2.4 Financed GHG emissions – Investments, section ‘Targets’, DP 33 for further details). The second significant group consists of insurance protection products and services, through which the Group offers solutions aimed at providing concrete cover in case of unforeseen events. The offer is divided into three different areas: personal protection: solutions for events such as illness, accident and disability that may compromise the person’s health; asset protection: flexible solutions for the protection of the financial stability/professional activities of its customers; property protection: home protection solutions, including for any damage caused by other persons.
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88 | Mediolanum Group - Annual Financial Report 2025 Finally, the third group includes services that support the day-to-day financial management of customers, facilitating payment transactions, liquidity administration and access to credit. These solutions are mainly aimed at retail customers, the Group’s main reference segment, and to a lesser extent to businesses. The offering includes retail deposit products – such as bank accounts and payment cards – and investment products, including secured loans and financing dedicated to specific personal or professional needs. The new Sustainability Plan 2026-2030 marks an evolution in the Mediolanum Group’s commitment to sustainability, particularly with regard to credit products and customer relations, extending the scope of its targets beyond green financing instruments. While it continues to actively promote green loans as a lever for the energy transition of real estate, the Group has extended the integration of environmental criteria more widely and across the loans portfolio, adopting a systemic approach focussed on decarbonisation. This context incorporates the objective of reducing the emission intensity of the residential mortgages portfolio, a key element of the climate strategy applied to credit (see ESRS E1 Climate Change, paragraph 2.2.5 Financed GHG emissions – Credit, section ’Targets’, DP 33 for further details). This approach is accompanied, in line with the strategic supervision already undertaken in the previous Sustainability Plan, by an increasing focus on the social aspects of finance, with particular reference to access to financial services, credit inclusion and the dissemination of economic and financial skills among customers. The scope of the sustainability targets relating to credit and customers includes, among other things, initiatives aimed at: strengthening financial education, through the production and continuous dissemination of accessible and up-to-date information and training content capable of supporting informed financial decisions; promoting virtuous behaviour in the area of ESG, encouraging active customer involvement in initiatives and events dedicated to sustainability issues, also partnering with third-sector entities; facilitating access to credit for young people (under 36), through dedicated financing solutions that reduce barriers to entry into the credit market and support the purchase of a home; the digitalisation of credit products, through a series of investments aimed at improving the efficiency of processes, promoting granting through increasingly innovative digital products and services; strengthening financial inclusion and the fight against usury, through emergency loans - designed to support households throughout Italy who, due to the lack of adequate collateral, are unable to access traditional credit channels, and risk falling victim to usury. The objective of the Sustainability Plan, in keeping with the previous plan, is to extend the agreement to new anti-usury foundations and increase the caps on existing agreements; supporting companies with advanced sustainability profiles through funding designed to enhance businesses that demonstrate a significant commitment to environmental, social and governance (ESG) matters. For further details on the strategic targets defined by the Mediolanum Group, see the sections dedicated to each area. With regard to the foreign subsidiaries, Banco Mediolanum offers a wide range of financial products divided into two large categories, namely banking products (including the Double Chance service) and investment products. Banking products include various types of current account (for example, ’My Account’, the children’s savings account, with 1% interest on balances up to €100,000), deposit solutions with variable returns and the Double Chance service. Instead, investment and insurance products include pension plans, life insurance for pension or savings purposes and a wide selection of funds, both internal and third-party. Lastly, through the venture capital fund TREA Healthcare Ventures, F.C.R., Banco Mediolanum invests in unlisted companies with high growth potential in the healthcare sector, contributing to the development of innovation with a higher risk profile.
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89 | Mediolanum Group - Annual Financial Report 2025 This offer is designed to meet and adapt to the differentiated needs of diverse-profile customers (young people, families, wealthy clients, etc.), offering innovative products, in line with sustainability criteria and responsible management. In addition, the Company has set targets to strengthen its offering of sustainable products and services. In particular, there is a growing commitment to the development of Green credits and ECO Loans, aimed at promoting responsible behaviour among customers and encouraging them both to purchase energy-efficient properties and to choose zero-emission vehicles. These targets aim to propose financial solutions with reduced environmental impact, responding to customer needs and supporting the energy transition, in line with the main directives and targets set by the European regulatory framework on sustainability. The Irish subsidiaries, Mediolanum International Funds and Mediolanum International Life, distribute their products in Italy, Spain and Germany and integrate sustainability principles into operating and investment processes, with the aim of generating lasting value for investors. In this context, MIFL takes a responsible investment approach, which includes the integration of ESG factors, the management of sustainability risks and the active exercise of voting rights to promote positive change in investee companies. Its commitment is also reflected in the adoption of a Responsible Investment Policy inspired by the UN’s 17 Sustainable Development Goals. In addition, for each fund, financial statements and SFDR documentation are prepared annually and are available on the Company’s website. [SBM-1 DP 40 aii] With regard to customers, in 2025 there were approximately 2.03 mln bank customers (customers of Banca Mediolanum and Banco Mediolanum), of which 86% (1.74 mln) referring to the Italian Group Company, and 14% (0.28 mln) referring to the Spanish subsidiary. At Banca Mediolanum, 98% of customers belong to the ‘natural persons’ category and 2% to the ‘legal persons’ category. With regard to natural persons, 53% are men and 47% are women. Customers are more concentrated in the 36- 55 age group (36%), with an average age of 52 years. The breakdown of employees at 31/12/2025 is shown below: [SBM-1 DP 40 aiii] Total number of employees by geographical area UoM 2025 2024 Italy No. 3,118 2,921 Spain No. 483 437 Ireland No. 203 189 Germany No. 7 7
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90 | Mediolanum Group - Annual Financial Report 2025 Value Chain [SBM-1 DP 42; 42 c] The stages of the Mediolanum Group’s 9Value Chain, defined as the entire range of activities, resources and relationships connected to the undertaking’s business model(s) and the external environment in which it operates, are described below. The upstream Value Chain comprises the procurement of goods and services, linked to the purchase of goods and services that mainly relate to the following types of supply: professional services (e.g. advisory and legal services); IT services (e.g. software, hardware, information providers); management services (e.g. security, call centre, office supplies); facilities (e.g. cleaning, canteen); marketing and advertising (e.g., gadgets, advertising services); construction (e.g. renovations, office furnishings). The Group develops products and services in the banking and insurance area, mainly by means of human and technological capital. Own operations therefore include the activities carried out by all the Group’s employees in Italy, Spain, Ireland and Germany. The objective is to meet the needs of its customers, mainly retail and SMEs, through a multi-channel offering. The main operations relate to: product factories and consultancy model; development of distribution channels; management of funding and lending; asset management; underwriting of policies and management of settlements and claims; management of the customer experience. The Group’s distribution activity, developed on three specific channels in order to offer advice to its customers, is located in the downstream Value Chain (Tier 110): Family Banker network in Italy and Spain (6,798 Family Bankers in total); the financial intermediation firm Prexta S.p.A. in Italy (approximately 58 Agents in direct Financial Activity and 558 contract staff); digital channels, mainly apps and the website. Lastly, in the downstream Value Chain (tier 211), there are management and relationship activities with its customers, relating to protection, investment, banking and credit products and services (see ESRS 2 General disclosures, paragraph 1.1.3 Strategy, section ‘Business strategy and model’, DP 40 for further information). The Value Chain for 2025 was identified, continuing the work carried out in 2024, through a desk-based analysis using data and information provided by the key corporate structures, as well as a review of the Group’s business model and documentation. The result of the activity is shown below. 9 The stages of the Value Chain are described in accordance with the provisions of ESRS 1 General Requirements ‘Double Materiality’ AR.9, ESRS 2 SBM-1 – Strategy, business model and Value Chain and the ‘EFRAG Guidelines: IG 1 Materiality Assessment’ (2.6 Consideration for upstream/downstream Value Chain) and ‘EFRAG Guidelines: IG 2 Value Chain (Step A. Understanding the context). 10 Tier 1 identifies the first level of the downstream Value Chain. For the Mediolanum Group, Tier 1 of the downstream Value Chain identifies the channels through which the products and services are distributed and made available to customers. 11 Tier 2 represents the second level of the downstream Value Chain. For the Mediolanum Group, Tier 2 of the downstream Value Chain includes post- distribution activities relating to the management of customer relations and the provision of products and services.
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91 | Mediolanum Group - Annual Financial Report 2025 [SBM-1 DP 42 a] In general, the Value Chain identification and analysis activity was based on a qualitative scenario analysis, mainly focused on industry trends and peer analysis, as well as on some internal analyses based on the assessment of the Group’s products and analysis of the Credit and Investment Portfolio. Interests and views of stakeholders [SBM-2 DP 45 a; 45 ai; 45 aii; 45 aiii; 45 aiv; 45 av] In keeping with the Stakeholder Management process launched in 2019, in 2025 the Mediolanum Group carried out a structured process for the active engagement of its key stakeholders, with the aim of collecting their points of view on the sustainability issues most relevant to the banking sector and assessing their strategic importance for the Group. The Group periodically organises moments to discuss sustainability and the issues considered most important with its Stakeholders and to listen to them, in line with the targets that it aims to achieve. Transparency and active listening are central elements in the process of interaction between the Company and its Stakeholders, allowing their interests and views to be integrated into the Group’s strategy and business model. Through tools such as Customer Satisfaction surveys, listening events and opportunities for discussion, the Mediolanum Group collects and analyses the needs of both external and internal stakeholders. The results of this listening process are a key reference for updating the double materiality assessment. The Stakeholder map is the starting point of the Stakeholder Management model, as it enables relations to be governed with the multiple categories of Stakeholders with which the Company interacts, with a view to preventing risk and enhancing the related opportunities. The methodological approach involves: construction of the Stakeholder tree on several levels, by identifying the main stakeholder categories; priority analysis of the categories of Stakeholders and the main characteristics of the subcategories of stakeholders, based on the various qualitative parameters (e.g. influence, dependence), in accordance with the AA1000 standard; prioritisation of stakeholders by calculating Stakeholder Relevance for each category, based on the parameters defined in the AA1000. The mapping and prioritisation of the Mediolanum Group’s Stakeholders periodically directly involves the Group’s internal functions, which have been asked to approve or update the mapping and prioritisation of Stakeholders. The map of Mediolanum Group Stakeholders is shown below. UPSTREAM OWN OPERATIONS DOWNSTREAM Steps of the Value Chain Procurement of products and services Activities carried out by employees of the Mediolanum Group Distribution channels Protection Banking Savings/Investment Management Description of the Value Chain
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92 | Mediolanum Group - Annual Financial Report 2025 Below are the main categories of Stakeholders and the engagement activities carried out by the Group. Stakeholder category Dialogue methods Customers Customer satisfaction & experience assessment Brand equity survey Regional events Commercial campaigns Social networks Mediolanum Personal Marketing (MPM) and direct mail Mediolanum Magazine Family Banker Network Regular meetings Corporate portal (B.medNet) Sending text messages, emails Commercial pop-ups and push notifications Events Network service and support service Annual surveys of the satisfaction and image of Banca Mediolanum and the main market networks Employees HOMEdiolanum portal Internal TV format for BM OnAir update ‘Let’s talk’ listening space HOMEdiolanum Week newsletter Internal social network - Engage Non-work related activities Info and training events Surveys of satisfaction with the services offered Engagement survey Media Press conferences Press releases Regular meetings Opening of institutional events to media Advertorial pages Publishing products Telephone contacts Social networks EMPLOYEES COMMUNITY SUPPLIERS MEDIA INSTITUTIONS AND REGULATORS FAMILY BANKER NETWORK CUSTOMERS SHAREHOLDERS AND FINANCIAL COMMUNITY INDUSTRY ASSOCIATIONS
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93 | Mediolanum Group - Annual Financial Report 2025 Shareholders and the financial community Investor Relations activities Regular meetings Telephone contacts Roadshow Broker conference Industry Associations Institutional meetings Group representatives on association bodies Institutions and Regulators Dedicated meetings Community Media relations Public relations Customer satisfaction & experience surveys Brand equity survey Local and in-branch meetings and events Fondazione Mediolanum EF activities Social networks Suppliers Regular meetings Telephone contacts Portal Questionnaires [SBM-2 DP 45 b] The results of the involvement of the Mediolanum Group’s stakeholders are used to contribute to the assessment of material issues in terms of social, environmental and economic impacts, thus influencing the outcome of the double materiality assessment carried out according to ESRS 2 IRO-1. In fact, the results of Stakeholder engagement activities were qualitatively integrated into the overall impact assessment process, helping to ensure a more complete and consistent representation of the perspectives of the various stakeholders. [SBM-2 DP 45 c; 45 ci; 45 cii] The Group is adapting its strategy to market developments and the expectations of Stakeholders, with a particular focus on sustainability and climate change. In this perspective, the Climate Transition Plan defined by the Group and the new 2026-2030 Sustainability Plan incorporate the inputs of the Materiality Assessment and constant engagement with Stakeholders, steering alignment between corporate objectives and the creation of value for all stakeholders. [SBM-2 DP 45 d] The double materiality assessment, including the evidence of Stakeholder engagement, is presented to and approved by the Board of Directors of Banca Mediolanum. In addition, the results of the double materiality assessment were discussed and approved with input from the competent Departments. The process was subsequently shared with the workers’ representatives, who were adequately informed on the topics of interest to them. [S1.SBM-2 DP 12; S2.SBM-2 DP 9; S3.SBM-2 DP 7; S4.SBM-2 DP 8] Through Stakeholder engagement procedures, the interests, opinions and rights of stakeholders are heard in order to integrate them, where possible, into the corporate strategy and model. The Group is always careful to share information with and involve its employees, getting them engaged and keeping them updated on the life, news and activities of the business. To this end, the Group implements engagement initiatives through specific tools (events, surveys, etc.) and holds regular meetings and focus groups to gather information useful for the improvement of internal business processes. For further information, see the specific section (ESRS S1 ‘Own workforce’).
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94 | Mediolanum Group - Annual Financial Report 2025 With regard to suppliers, besides dedicated events, a periodic discussion is carried out with their representatives in relation to the main areas of cooperation, including sustainability matters. An ESG questionnaire, set out according to ISO 26000 and ISO 20400, is administered to suppliers eligible in ‘FULL’ mode, i.e. suppliers with which continuous, recurring, long-term and/or high economic value contracts and/or framework agreements are signed. For further information, see the specific section (ESRS S2 ‘Workers in the value chain’). With reference to the Community in question, the Mediolanum Group operates not only through a structured process of the active engagement of key stakeholders in their Communities – including one-to-one interviews with Foundations and Associations – but also through a constant commitment to aspects of daily life not directly linked to financial activities. To this end, it organises events with the aim of disseminating financial culture and participates in various social, cultural and sporting activities, proposing local initiatives to help those situations that require support. For further information, see the specific section (ESRS S3 ‘Affected communities’). Finally, as regards Consumers and end-users, in addition to a structured process of active engagement through one-to-one interviews, customer satisfaction surveys are conducted periodically to assess customers’ satisfaction of the Group. The handling of complaints is also a structured process, designed to understand customer opinions, with the awareness that full customer satisfaction is a key priority in the Group’s strategy. For further information, see the specific section (ESRS S4 ‘Consumers and end-users’). Material impacts, risks and opportunities and their interaction with strategy and business model [SBM-3 DP 48 a] The double materiality assessment process is a fundamental activity preparatory to drawing up the Consolidated Sustainability Statement. It is used to identify the topics on which a company needs to focus its reporting and planning efforts, in line with the requirements of the CSRD and EFRAG’s ESRS12. One of the key elements of the CSRD is the adoption of a double materiality assessment; this is a process aimed at identifying and assessing sustainability issues to be included in the Consolidated Sustainability Statement and requires an analysis of the materiality of sustainability issues from two complementary perspectives: how they influence a company’s financial performance and its long-term value (impacts sustained – ‘Financial Materiality’) and the effects the company has on society and the surrounding environment (impacts generated – ‘Impact Materiality’). Following the entry into force of the CSRD, the Group began a process in 2024 to adapt to the new regulatory requirements, with the aim of aligning its reporting of sustainability issues with the standards required by European regulations. This commitment was maintained in 2025, during which the Group continued its alignment process, updating the double materiality assessment, continuing from the previous year and in accordance with the most recent methodological recommendations issued by ESMA and EFRAG. The sustainability topics considered in the double materiality assessment process in 2025 are defined in the ESRS (sector-agnostic topics), as well as additional entity-specific topics for the Mediolanum Group, in line with the results of the materiality assessment processes of previous years. [SBM-3 DP 48 b] The impacts, risks and opportunities identified influence the company’s strategic choices, also affecting the medium- to long-term targets of the Sustainability Plan and the Climate Transition Plan, as well as the development of any new products and services. These elements are integrated into the decision-making processes and the business model, to ensure resilience and to capture market demand. [SBM-3 DP 48 ci, 48 cii; 48 ciii; 48 civ] 12 European Financial Reporting Advisory Group.
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95 | Mediolanum Group - Annual Financial Report 2025 The double materiality assessment carried out by the Mediolanum Group identified 55 material impacts, risks and opportunities13, as described in the next chapters. Material impacts are directly reflected on society and the environment, for example, through awareness-raising initiatives and the promotion of sustainable products as well as through the generation of indirect GHG emissions. In addition, the material impacts of the Mediolanum Group are closely linked to its strategy and business model. Their identification and assessment are the result of a thorough internal analysis, which includes the examination of corporate operations and the value chain, as well as external analysis, through the study of the regulatory environment, the banking sector and the expectations of Stakeholders. The majority of material impacts occur or may do so over the medium term (2 –5 years). However, there are also significant impacts that have already occurred or may occur in the short term (up to one year) and in the long term (beyond 5 years). Although the material impacts have been identified throughout the Value Chain, they mainly relate to the activities carried out by the Group and to interactions with counterparties in the downstream stages, in particular parties financed or invested in, which represent a central component of the Group’s Value Chain. [SBM-3 DP 48 g] Following a refinement of the double materiality assessment process, aimed at ensuring the presentation of sustainability information in a transparent, consistent and easily accessible way for Sustainability Statement Users, the impacts, risks and opportunities identified in 2024 were streamlined overall. This initiative, aimed at bringing together the issues described in the IROs, led to a significant reduction in their total number. [SBM-3 DP 48 h] As part of the double materiality process, the Mediolanum Group identified impacts, risks and opportunities related to the management of the distribution network that resulted in additional specific disclosures for the Group, in the light of the network’s characteristics. The specific disclosure identified is consistent with the results of the double materiality assessment carried out for FY 2024 (see 5.1 Management of the distribution network for further details on the ‘Entity-specific disclosure’ identified for the Group). The following table provides a summary assessment and the materiality for each sustainability topic, broken down by impact, risk and opportunity, including a description of where these impacts, risks and opportunities are concentrated along the Value Chain (own operations and/or upstream and downstream the Value Chain). For further information on material impacts, risks and opportunities for the Mediolanum Group, please refer to the corresponding ESRS topic. Topic Sub-topic Impacts Risks Opportunities E1 – Climate change Climate change adaptation / Climate change mitigation/Energy S1 – Own workforce Working conditions / / Equal treatment and opportunities for all / Other rights related to work (confidentiality) / / 13 The Subsidiary Flowe, included within the Group’s perimeter, conducted a materiality assessment as part of the process of updating its Impact Report, aimed at identifying the ESG issues which are material for its business model and activities. The results of this assessment led to the identification of impacts, risks and opportunities (IRO) which, although taken into account by the parent company, Banca Mediolanum, in the process of updating double materiality, did not emerge as significant at group level, given the limited impact of the Flowe perimeter on the economic and financial profile and consolidated results.
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96 | Mediolanum Group - Annual Financial Report 2025 S2 – Workers in the Value Chain Working conditions / / S3 – Affected communities Economic, social and cultural rights of communities / S4 – Consumers and end- users Impacts related to disclosures for consumers and/or end- users / Social inclusion of consumers and/or end-users ES – Management of the distribution network / / G1 – Business conduct Corporate culture Protection of whistleblowers / / Supplier relationship management, including payment practices / / Active and passive corruption / / Key: Presence of impacts, risks and opportunities associated with the sub- topics identified IROs relating to own operations of the value chain IROs concentrated upstream of the value chain IROs concentrated downstream of the value chain [SBM-3 DP 48 d] With regard to the assessments carried out by the Mediolanum Group on the risks assessed as significant, the Risk Management Function developed and implemented the ICAAP in order to integrate forward-looking stress test analyses that integrate climate-related risk factors. For further details, see the information reported in the datapoint [SBM-3 DP 48 f], which specifies the ICAAP in relation to the Group’s resilience analysis. However, for assessments performed in terms of current financial effects, see the notes on ‘Part E – Information on risks and the relative hedging policies’ in the consolidated financial statements. With regard to the credit risk assessment methodology for the purposes of estimating expected loss pursuant to international accounting standards, during 2025 the adopted model was refined, including the calibration of climate risk measurement in order to increase its monitoring significance and inclusion in business practices. In this context, from the first quarter of 2025 onwards, appropriate adjustments were made to the existing IFRS 9 accounting models for the loans portfolio, in order to incorporate expected loss components deriving specifically from scenario perspectives related to climate change.
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97 | Mediolanum Group - Annual Financial Report 2025 In relation to ICT risks, the Mediolanum Group has implemented a methodological framework linked to IT risk management and IT security, also drawing on industry regulations and guidelines. Appropriate monitoring indicators have been defined, integrated both in the RAF and as ‘early warning’ instruments, in order to ensure ongoing and timely risk management. The Bank has also systematically taken out an insurance policy to cover Cyber Risk. Moreover, Economic Capital, which is also monitored by RAF indicators and is calculated as the weighted average of historical capital and prospective capital, takes into account all potential losses arising from operational risk events. With regard to the assessments made to identify material opportunities, the Mediolanum Group developed and estimated specific economic valuations on the basis of the strategic decisions set out in the Sustainability Plan that were taken into account during the preparation of the budget. As the analysis of opportunities was concluded before the adoption of the new Plan, the assessments included in the double materiality assessment refer to the previous Sustainability Plan 2024-2026. At the same time, the thematic chapters of this Report set out the main results achieved in relation to the targets of the new 2026‐2030 Sustainability Plan, which is an integral part of the 2026‐2030 Business Plan approved by the Board of Directors at its meeting of 16 December 2025. [EI.IRO-1 AR 15] The impacts arising from climate risks are examined in relation to the credit portfolio (with climate-adjusted LGD adjustments), the AUM portfolio and the proprietary securities portfolio, in order to obtain an overall and integrated view of the effects of climate risk on the Group’s economic and financial parameters. The methodological framework adopted for the assessment of climate and environmental risks is based on scenarios published by the Network for Greening the Financial System (NGFS), which defines different emission trajectories and temperature increases based on sustainability objectives. These scenarios reflect various combinations of objectives and implementation timelines, generating diverse risk profiles for the climate. In particular, transition risk, resulting from the adoption of stricter policies on emissions, mainly affects the value of financial instruments such as equities and bonds, as companies face higher costs to comply with stringent environmental targets within short timeframes. On the contrary, physical risk has a greater impact on the loans portfolio, particularly on the portion secured by real estate, as properties may suffer direct and irreversible damage due to climate change. The main scenarios considered are the ‘Net Zero 2050’, which presupposes immediate actions to reduce global emissions, and the ‘NDC’ (‘Nationally Determined Contributions’), in which governments do not implement policies beyond those currently in place, with the risk of resulting serious and irreversible physical damage. NGFS scenarios are used to determine economic and financial impacts, including the effects on the ECL impairment provision, as well as on the valuation of Assets Under Management (AUM) and securities held at fair value. The climate scenarios affect the calibration of IFRS 9 parameters. In particular, the Climate scenarios are integrated into the IFRS 9 Probability of Default (PD) calibration framework. Regarding Loss Given Default (LGD), the impact of climate risk is estimated through the haircut methodology, which reflects the evolution of the House Price Index (HPI) in different climate scenarios. The LGD curves thus obtained are subsequently used in the stress test framework to determine the impact on the income statement for ICAAP purposes. The approach adopted also extends to strategic risk by measuring the impact of climate risk on funds using the Climate Value at Risk (VaR) metric. This metric measures the percentage change in the value of funds in relation to the chosen climate scenarios, considering impacts related to both transition and physical risks. As part of the ICAAP document, this analysis is used in the exercise of stress on strategic risk, in order to quantify the overall delta of the income statement deriving from an adverse market situation that affects the various types of fees on assets under management (AUM) that contribute to the formation of the Group’s profit. [SBM-3 DP 48 f]
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98 | Mediolanum Group - Annual Financial Report 2025 The double materiality assessment enabled the Group to identify and assess the main risks and opportunities across its Value Chain. This process provided an important information base to support strategic decisions, fostering an aware and sustainable approach to sustainability challenges. In fact, the historical principles on which Mediolanum’s statement is based are still customer-centric, focussed on offering products, credit and investment solutions aimed at developing this relationship. In parallel with the definition of the strategic guidelines through the Business Plan, the Group is committed to analysing its business model in order to ascertain the resilience of its business strategy and model: this activity is carried out with the aim of measuring the Group’s capacity to address the material impacts and risks. This is the direction taken by the ICAAP, i.e. the typical tool adopted by the Mediolanum Group to analyse its business resilience. In fact, the process assesses the impacts that stress scenarios may have on the Group’s results of operations and capital adequacy. The result is a detailed picture of the ability of the Group and its business model to withstand and respond to adverse market conditions. In this context, the ICAAP document takes into account climate risk scenarios that make it possible to assess the impacts on the Group’s two main businesses: credit and asset management. The breakdown of the analysis performed for these businesses is shown below. Credit business – Short- and Medium-term In the context of the ICAAP, with regard to credit risk, the chosen scenario is used within the IFRS 9 PD (Probability of Default) calibration framework, which requires the use of a satellite model in order to recalculate the new stressed PD curve. Once estimated, the PD curve is used to calculate the collective level in the projection years. For the LGD (loss given default) component, data are used to estimate a cost function. This cost measure is applied to the value of historical recoveries of non-performing loans in order to build a stress factor to then be applied to the coverage percentages in production. The coverages thus calculated for Banca Mediolanum’s mortgage portfolio is used to calculate the collective and analytical levels in the projection years. Estimates of the stressed LGD are also used within the framework for estimating residual risk, in order to reduce the value of the properties during the projection years and consequently increase the level of RWA (risk-weighted assets). This process results in a quantification of the impact of climate-related risk that can be used to assess business resilience in the short to medium term. Credit business – Long-term In order to estimate the long-term impact deriving from climate risk factors on Banca Mediolanum’s loans portfolio, the expected credit loss (ECL) is calculated, conditional upon climate scenarios. In particular, the conditional parameter is the loss given default of the retail mortgage portfolio. The conditions of this stress are that the composition of Banca Mediolanum’s portfolio remains constant over time. The process is divided into the following methodological steps: the definition of a haircut, i.e. a percentage of write-downs of the value of the properties, calculated as the ratio of the stressed climate-related risk scenario to the baseline scenario. Asset management business The analysis of the impact of climate scenarios on AUM (assets under management) estimates the effects on the costs and revenues of the investee companies of the funds and consequently calculates the change in the value of the investment. Costs and revenues are projected to 2050 for transition risk, while for physical risk the horizon is 2100. The change in the value of the investment, known as the Climate VaR (CVaR), is obtained by discounting these projections. The CVaR is therefore an indicator obtained with a long-term perspective. However, a short- and medium-term analysis is also carried out, in which the projections discounted in the CVaR calculation are cut at various intermediate time horizons. In this way it is possible to obtain changes in the value of the investment, considering impacts up to 1 year, 3 years, 5 years, 10 years and 20 years.
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99 | Mediolanum Group - Annual Financial Report 2025 1.1.4 Impact, risk and opportunity management Description of the processes to identify and assess material impacts, risks and opportunities [IRO-1 DP 53 a] The double materiality assessment was carried out according to a process that followed the recommendations made by EFRAG through ESRS 1 – General Requirements and the related Implementation Guideline 1 ‘Materiality Assessment Implementation Guidance’. An analysis was also carried out, not only of the impacts, risks and opportunities relating to the Group’s own operations, but also of those relating to its commercial relations and significant relationships upstream and downstream, in line with the recommendations made by EFRAG through Implementation Guideline 2 ‘Value Chain Implementation Guidance’. [IRO-1 DP 53 bi] The double materiality assessment process was carried out taking into account all the entities included in the reporting scope. [IRO-1 DP 53 b] In relation to actual and potential impacts, the materiality assessment process, in line with the Implementation Guidance on the double materiality assessment and the value chain, has been divided into three stages: 1. structured analysis of the context, with respect to the Group’s commercial activities and relations, the European regulatory framework and taking into account sustainability issues relevant to the banking sector and the Group’s specific characteristics; 2. identification of actual and potential impacts relating to environmental, social and governance issues in its operations and in the upstream and downstream Value Chain; 3. assessment and determination of the material impacts relating to sustainability issues, including by means of discussions with the main internal and external Stakeholders of the Group and internal departments, and in accordance with the main reference frameworks. Understanding the context required an analysis of the Group’s activities, its business relationships and the sustainability context in which it operates (with the relevant regulatory requests from external bodies). In particular, the following activities were performed: External context analysis, through (i) benchmarks of the main players in the sector, at national and European level, (ii) regulatory analysis (SFDR, EU Taxonomy, Pillar III, etc.) and (iii) an analysis of sectoral studies and research on the impacts and sustainability risks of the financial sector (UNEP FI, MSCI, S&P, etc.); Stakeholder analysis, i.e. an analysis of the frequency and materiality of Stakeholders within the mapping of main industry competitors in order to prioritise stakeholders and associate each category with the different stage of the Group Value Chain; Assessment of the internal context within the Group and the Value Chain: analysis of the main internal documentary sources and developments of the Mediolanum Group, including, in particular, (i) the 2024 Consolidated Sustainability Statement, (ii) the Group’s ESG Policies and Regulations, (iii) the list of IROs and the 2024 materiality analysis process, (iv) dependency analyses and (v) further information obtained through the involvement of internal functions. Subsequently, the Mediolanum Group identified potential and actual impacts through the creation of an extended list of the impacts attributable to its activities. The starting point was the double materiality assessment process developed for the 2024 Consolidated Sustainability Statement, based on which the long ‐list of impacts prepared during FY 2024 was updated. Each impact was classified according to the direction of the impact (positive or negative) and the type of impact (actual or potential). In addition, each impact was associated with the corresponding stages of the Value Chain and, where possible, was linked to the ESRS topics (topics, sub-topics and sub-sub-topics) presented in Annex A, AR 16 of ESRS 1. Finally, the assessment and determination of the material impacts relating to sustainability matters was carried out. The assessment was carried out in the first instance through a desk assessment by the Sustainability Office according to the parameters defined by EFRAG’s ESRS of likelihood and severity (magnitude, scope and impossibility to remediate), and, subsequently, by the representatives
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100 | Mediolanum Group - Annual Financial Report 2025 of the Group’s main Departments through one-to-one interviews. In order to assess the impacts in a consistent manner, the assessment was also carried out based on the results obtained during FY 2025 stakeholder engagement activities and taking into account the historical series and data reported in the 2024 Consolidated Sustainability Statement. In particular, the results of stakeholder engagement activity were qualitatively integrated into the overall impact assessment. Stakeholder engagement was therefore a factor in the validation or acceleration of the preliminary assessments —the results of which, together with the underlying rationales, were shared with relevant Directors. The assessments were subsequently adjusted or confirmed through direct discussions with the relevant Directors, who have a more in-depth view of issues relating to the activities of the Mediolanum Group. This led to the identification of 32 material impacts, comprising 14 negative impacts and 18 positive impacts. [IRO-1 DP 53 biii] In line with the EFRAG guidelines ‘IG 1 – Materiality Assessment’ and the ESRS, the analysis was accompanied and supplemented by extensive Stakeholder Engagement, aimed at collecting considerations and assessments useful for the double materiality assessment. Overall, the Stakeholder engagement process involved approximately 150 internal and external Stakeholders, using various engagement methods. In particular, the Group adopted targeted approaches for each Stakeholder category, taking into account their specific characteristics and following a competence-based approach. Tools used included focus groups, individual meeting (one-on-one interviews) and dedicated events. Furthermore, as provided for by Article 4, paragraph 9 of Legislative Decree 125/24, the process was duly shared in two meetings with workers’ representatives, who were informed about the matters in their area of responsibility. These representatives discussed the matters identified as material to the Group, particularly with regard to the ‘Own workforce’, and no comments were made. [IRO-1 DP 53 bii] The impacts thus identified and assessed concerned not only the own operations of the Group Companies included in the reporting scope, but also commercial relations, with particular focus on downstream processes and relationships. [IRO-1 DP 53 biv] The materiality of the impacts was assessed according to the parameters described below, whether negative or positive, actual or potential impacts. In particular, with regard to actual negative impacts, materiality was determined on the basis of the significance of the impact, considering the following factors: a) Entity (Scale), i.e. the ‘severity’ of the impact and the external context in which it occurs, b) the Scope, i.e. how the impact is extended/widespread and can be measured in terms of the number of Stakeholders affected or the geographical scope, and c) the possibility of remediation, i.e. to what extent it is possible to remedy it. The Probability of the impact occurring, i.e. the possibility that the impact will occur, was also assessed for the potential negative impacts. Moreover, for each negative impact, any violation of human rights was assessed; if a violation was identified, the severity prevailed over the likelihood of occurrence. With regard to positive impacts, materiality is assessed considering the following factors: (a) the Magnitude and Scope of the actual impacts; and (b) the Magnitude, Scope and Likelihood for potential impacts. A numerical value was assigned to each of the above qualitative parameters and used to calculate a quantitative score to be assigned to each impact assessed. A materiality threshold of impacts of 3 (on a scale of 1 to 5) was also defined: all impacts that obtained an overall total score of 3 to 5 were considered material for the Mediolanum Group. The threshold was determined on the basis of: the distribution of the values obtained from the assessment; alignment with the provisions of ESRS 1 and related implementing guidance No. 1 ‘Materiality Assessment Implementation Guidance’,, which give undertakings the options of setting appropriate qualitative or quantitative materiality thresholds, without, however, prescribing specific elements to be taken into account in determining value.
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101 | Mediolanum Group - Annual Financial Report 2025 [IRO-1 DP 53 c, 53 ci, 53 cii, 53 ciii] The starting point of the process of updating risks was the analysis conducted for the previous year as part of the Financial Materiality process. In this context, in line with regulatory requirements in the context of the CSRD and with EBA Guidelines on ESG risk management, the Risk Management Function and the Compliance Function, in coordination with the Sustainability Office, updated the long-list of risks, in order to include new assessments of potentially material risks, integrating an analysis of the risk factor ‘loss of biodiversity’. The process adopted to identify and assess all the risks related to sustainability topics for the purposes of conducting the double materiality assessment is set out below: Analysis of impacts and aspects and identification of the ESG risks associated with them: following the identification by the Sustainability Office, at Group level, of the impacts and aspects related to sustainability topics (ESRS Topics), the potential ESG risks associated with them were also identified. As for the identification of impacts, the list contained in Annex A, AR 16 of ESRS 1 was also used as a reference for risks. The identification of risks also involved the various Risk Owners, for each Legal Entity of the Banking Group and the Insurance Group, and the Compliance Function. Identification of the companies in the financial conglomerate exposed to potential ESG risks: for each ESG risk identified, the potentially exposed Country and Legal Entity were mapped in order to distinguish the risks relating to the Mediolanum Insurance Group from those relating to the Mediolanum Banking Group and were connected with the respective stages of the Value Chain (Upstream, Own Operations, Downstream); Identification of transmission channels and reference time horizon: for each identified ESG risk, taking into account the potentially exposed company and the relevant business, the transmission channel through which the ESG risk factors occur for traditional risks was mapped, allowing the predominant type of risk to be identified (e.g. Credit Risk, Market Risk, Operational Risk, Compliance risk, etc.). The time horizon (i.e. short-term, medium-term and long-term) within which the potential impact associated with the risk in question is expected to occur was also identified. Assessment of material risks: the materiality of ESG risks was assessed considering the Environmental risk materiality assessments conducted by the Banking Group, according to the ECB Guide (Guide on Climate- related and Environmental Risks - Supervisory Expectations relating to Risk Management and Disclosure) and EBA guidelines (Guidelines on the management of Environmental, Social and Governance risks (ESG risks) and by the Insurance Group in the context of the ORSA, according to EIOPA guidelines. In the context of Financial Materiality, the Mediolanum Group prioritised the analysis of the topic ‘Climate change (ESRS E1)’ and ‘Biodiversity and ecosystems (ESRS E4)’ to assess the financial impact of environmental risks. Banca Mediolanum therefore took action to identify and quantify exposure to environmental risk factors. In addition, the assessment of the risk factors relating to the Social and Governance dimensions was conducted using a qualitative approach. With the support of the level II Control Functions of both the Banking Group and the Insurance Group, qualitative assessments were conducted on the potential financial impact (Severity/Impact) of ESG risks and on the probability that such risks may occur (Probability of occurrence). For the Severity/Impact assessment, a qualitative approach was adopted based on a four-level scale (High, Medium-High, Medium, Low), allowing for the identification of ESG risk factors that could generate a financial impact on the organisation.
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102 | Mediolanum Group - Annual Financial Report 2025 With reference to the Probability of occurrence, different methodologies were adopted depending on the type of risk (overseen by the various functions such as Risk and Compliance) and the reference sector (banking or insurance). All values are expressed simply on a qualitative scale consisting of three levels: Low, Medium and High probability. Based on these indicators, the Group makes qualitative assessments that enable it to define a priority scale in relation to sustainability-related risks. In particular, to identify material risks, a matrix was defined that combines the Severity/Impact and Probability of occurrence assessments: Materiality of Risks Probability of occurrence Low Medium High Severity Low Non-material Non-material Non-material Medium Non-material Non-material Material Medium-High Non-material Material Material High Non-material Material Material The assessment, carried out on the basis of this process, was subsequently shared with the Group’s Departments through dedicated interviews conducted in relation to their respective areas of responsibility. [IRO-1 DP 53 ci] As for the identification of impacts and risks, the list in Annex A, AR 16 of ESRS 1 was also taken as a reference for opportunities. The opportunities long-list identified in FY 2024 was analysed to update the Mediolanum Group’s Opportunities. Each opportunity identified was traced back to the respective value chain stage (upstream, own operations, downstream) and to the EFRAG ESRS topics. [IRO-1 DP 53 cii] The opportunity assessment was made by analysing the probability of occurrence and potential ‘magnitude’. Opportunities with a potential financial impact were assessed according to the following parameters: a ‘potential magnitude’ rating scale, based on the definitions provided by the ESRS; a ‘probability’ rating scale and a further specific scale of the time horizons, based on the definitions provided by the ESRS. In order to calculate the materiality score, the two dimensions of potential magnitude and probability were valued through qualitative reasoning and matrix intersections.
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103 | Mediolanum Group - Annual Financial Report 2025 Probability 1 2 3 4 5 Potential Magnitude 1 Very Low Very Low Low Low Medium 2 Very Low Low Low Medium Medium 3 Low Low Medium Medium High 4 Low Medium Medium High Very High 5 Medium Medium High Very High Very High The assessment was discussed and validated through interviews with the Group’s Departments, for their respective areas of responsibility, with nine opportunities identified as material. [IRO-1 DP 53 c; 53 f] The process to identify, assess and manage opportunities is connected to the strategic planning of the undertaking. In particular, opportunities were identified in the light of the commitments envisaged in the 2024-2026 Sustainability Plan and the Climate Transition Plan, coordinating with the Administration, Finance and Control Department and, in particular, with the Planning, Control and Investor Relations Division. [IRO-1 DP 53 d] The Sustainability Office, within the Administration, Finance and Control Department, manages the double materiality assessment process, in accordance with the provisions of Legislative Decree No. 125/2024. A previously described, the Board of Directors is responsible for approving the double materiality assessment, in accordance with the provisions of Legislative Decree No. 125/2024, and to monitor the management of processes relating to material impacts, risks and opportunities, of which the Board is regularly updated. The double materiality assessment process is governed by internal policies and procedures (Policy for the Preparation of the Consolidated Sustainability Statement of Banca Mediolanum and the related process regulations; ESG Risk Management Policy). [IRO-1 DP 53 e] To ensure adequate business resilience to the possible events and hazards characterising the current and future context, the Mediolanum Group also incorporates ESG impacts and risks into its overall corporate risk management process. To this end, the Mediolanum Group has implemented a process to identify potential ESG risks and defined both the measures to manage them and a framework to assess them. The process of identifying material risks for the Mediolanum Group includes an analysis of the organisational structure and processes and the identification and mapping of the risks that characterise the Group’s activities. This process, which is coordinated by the Risk Management Function, is based on the corporate policies established by the Board of Directors for the system of management and control of business risks, and the regulatory and management methods for assessing the risks to which the Group is exposed. The main activities involved in a materiality assessment for the construction of the general map of significant risks, another process conducted by the Risk Management Function, are as follows: 1. the exclusion of risks not relevant to the Group’s current business environment, nor to the environment assumed in the current business plan. The list is then organised by grouping the risk subcategories according to the Group’s risk management taxonomy; 2. the definition of a materiality threshold, to identify which risks within the Mediolanum Group, from those already defined as applicable and measurable, are material in terms of the Group’s ordinary operations but do not jeopardise the pursuit of its strategy. Material risks are considered for the purpose of ICAAP/ILAAP and stress tests and/or are regularly measured, limited and/or managed;
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104 | Mediolanum Group - Annual Financial Report 2025 3. the identification and mapping of environmental climate risk factors within the traditional risk categories overseen by the Function; 4. the representation of the risks’ significance, through an analysis of the impact of the risks and assessments of their materiality; 5. the assessment, with respect to each identified risk sub-category, of the materiality for each Banking Group Company. Once the scope of the risks deemed material has been identified, the Risk Appetite Framework (RAF) is defined. The RAF is a reference framework that determines the risk appetite necessary to achieve the income objectives of a budget/plan, the tolerance thresholds, the risk limits and risk governance policies and the processes for defining and implementing them, in line with the maximum risk that may be assumed, the business model and the business plan adopted by the Group. The strategic indicators thus defined are therefore intended to support Senior Management in pursuing the Group’s economic and financial objectives, and are therefore subject to an annual review process, in addition to the planning and/or budgeting process. These indicators are monitored on at least a quarterly basis and shared with the Board of Directors through the Risk Dashboard, so that compliance with the pre-established thresholds can be controlled. In particular, with regard to sustainability risks, the strategic indicators of the RAF that take into account environmental (including climate and environmental risk factors), social and governance aspects, with regard to both credit counterparties and own funds and third parties, are as follows: Indicator of the sustainability of corporate loans: a measure to represent the share of exposure that does not reflect sustainable finance criteria. A counterparty’s sustainability is assessed through a summary score (ESG rating) that includes the assessments of the three main aspects of sustainability; an ESG indicator of own funds and third parties: calculated by assigning an ESG rating to each underlying of the reference fund managed and/or placed by the Group, followed by an aggregation of the ESG rating at fund level. This ESG rating summarizes an assessment of a company’s ability to manage its exposure with reference to organisational capacity and level of commitment dedicated to addressing key risks and opportunities, strength and scope of ESG initiatives (e.g. programmes and targets in place to improve performance) and a company’s track record on managing specific ESG risks or opportunities. [IRO-1 DP 53 g] In the context of the double materiality assessment, the Mediolanum Group considered several authoritative external sources, including UNEP FI, MSCI ESG Industry Materiality Map, SASB Materiality Finder and S&P Corporate Sustainability Assessment 2024. In general, the activity was based on a qualitative scenario analysis focused mainly on industry trends, analysis of peers and related trends, as well as on internal data such as those reported in the 2024 Annual Financial Report, and on the assessment of the Group’s products and analysis of the Credit and Investment Portfolio. [IRO-1 DP 53 h] The double materiality assessment was carried out in line with the assessment conducted for the 2024 financial year, in relation to impacts and opportunities, ensuring methodological continuity with respect to the previous year and taking into account the developments in the Group’s activities and processes in 2025. Regarding the risk dimension, in accordance with the EBA’s ESG Risk Management Guidelines, the process was updated to include new assessments of potentially significant risks, strengthening the integration of environmental factors (i.e. loss of biodiversity) into the framework. In addition, the methodological approach adopted was refined to assess the probability of occurrence associated with the risks identified and their materiality.
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105 | Mediolanum Group - Annual Financial Report 2025 Description of the processes to identify and assess material climate-related impacts, risks and opportunities [E1.IRO-1 DP 20 a; AR 9] The process to identify and assess climate-related impacts is part of and contextualised within the double materiality assessment carried out by the Mediolanum Group. In particular, in the process of identifying climate change impacts, the Group first carried out an analysis of the context and the Value Chain, including upstream activities, own operations and downstream activities. The main types of activities along the value chain were subject to qualitative and quantitative screening, based on an analysis of internal evidence, sector analyses and assessments of the nature of the activities, in order to identify the main hotspots in terms of emissions and climate impacts. Based on the results of this analysis, a preliminary long-list of impacts was prepared, developed in continuity with the list adopted in 2024 and subsequently updated on the basis of the evidence that emerged. This long-list was therefore assessed for materiality, also through the involvement of stakeholders (see ESRS 2 SBM-2 DP 45 b; ESRS 2 IRO-1 DP 53 b). [E1.IRO-1 DP 20 c] The opportunities identified refer to the information provided in the 2024-2026 Sustainability Plan. Note that in addition to the opportunities reviewed and confirmed during the 2025 double materiality assessment, a further opportunity related to the Climate Transition Plan was included, as the Group has recently adopted this strategic tool. The development of this Plan involves targeted actions for the ESG pillars, including, for example, the reduction of direct (Scope 1 and 2) and indirect (Scope 3) emissions associated with the investment and credit portfolios, as well as the definition of decarbonisation targets, taking into account the operational and strategic implications for the business. For further information on the process of identifying opportunities, see the datapoint [IRO-1 DP 53 c; 53 f]. For details on the list of material opportunities for the Mediolanum Group, see section E1 ‘Climate change’ (ESRS SBM-3; DP 48 a). For details of the analyses conducted in order to assess the impact of transition risk factors on traditional risk categories, see the datapoint [E1.IRO-1 DP 20 b]. [E1.IRO-1 AR 11 a; 12 a] In order to identify and assess the risks arising from physical and transition risk factors, the specific characteristics of the Mediolanum Group are taken into account. In particular, in line with the Group’s business model, analyses were conducted to promote sustainability and to combat climate change, through the integration of C&E factors into the Group’s overall risk management process. The Risk Management Function adopted a methodological approach, divided into the following stages: 1. the definition of the reference perimeter for each risk category in order to proceed with the identification and mapping of the C&E risk factors as detailed in the context of the datapoint [E1.IRO-1 DP 20 b, 20 c]; 2. the identification of the ESG risk factors, defined in the reporting datapoint [E1.SBM-3 DP 18], the relevant transmission channels through which these risk factors occur for traditional risk and the reference time horizon (shown in the tables below) for each risk category and for each identified perimeter. For further details regarding the time horizons, see the datapoint [E1.IRO-1 AR 11 b]; 3. the definition of specific methodologies for each risk and performing the materiality assessment: in order to adequately integrate climate and environmental risks within the Risk Management Framework, a materiality assessment is carried out for each type of risk, using methods differentiated according to the type of risk taken into consideration (qualitative or quantitative approach). This analysis is conducted on the basis of the defined transmission channels and the time horizons in which the impact of C&E factors on the traditional risk considered is expected to occur, as detailed in the context of the reporting on the datapoints [E1.IRO-1 DP 20 b, 20 c]; 4. the determination, based on Severity and Probability of occurrence, of the materiality of the risks considered: for the purpose of evaluating the materiality of the risks identified for each sustainability issue, and in line with the provisions of the CSRD, two key dimensions —namely Severity/Impact and Probability of occurrence—were analysed, as detailed in the reporting on the datapoint.
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106 | Mediolanum Group - Annual Financial Report 2025 Moreover, for each physical and climate-related transition risk identified in the double materiality process, there is an association of these risks with own operations and/or the upstream or downstream Value Chain of the Mediolanum Group. For each type of risk, the C&E factors identified and their transmission channels, as well as the time horizons associated with them, are set out below. Credit/Counterparty/Concentration Risk Banca Mediolanum identifies and maps the climate-related and environmental risks that affect credit risk. In particular, transition risk factors, such as policies and regulation, technology and market confidence, as well as physical risk factors, arising from extreme or chronic events, including environmental risk factors, are identified. Banca Mediolanum, with particular reference to transition and physical risk factors, has identified the transmission channels shown in the following table. Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Credit/ counterparty/ concentration risk Transition risk: Policies and regulations Impacts on the corporate portfolio due to the process of adjustment towards a low-carbon economy, through the introduction of elements such as: energy efficiency requirements, carbon pricing mechanisms that increase the price of fossil fuels and/or policies to encourage the sustainable use of the region. These factors may affect the profitability of the Bank’s credit counterparties and, consequently, generate a reduction in their credit- worthiness. Impacts on real estate used as collateral for loans by corporate and retail counterparties due to the introduction of specific regulations related to energy classification requirements that could result in a reduction in the value of property used as collateral. The risk is concentrated in the downstream value chain. MT-LT Credit/ counterparty risk Transition risk: Technology Impacts on the corporate portfolio due to technological changes that may render the technologies used by the same obsolete, triggering a process of repricing of the related assets. Moreover, in order to facilitate the conversion process, these counterparties could envisage massive investments in order to renew their production technologies. These factors may affect the profitability of the Bank’s credit counterparties and, consequently, generate a reduction in their creditworthiness. The risk is concentrated in the downstream value chain. MT-LT Credit/ counterparty risk Transition risk: Market sentiment Impacts on corporate counterparties due to the choices of consumers and investors that could shift towards undertakings that distribute products and services that are less harmful to the climate, causing a reduction in the profitability of counterparties that are not embarking on a process of reconversion to a low-emission economy. The risk is concentrated in the downstream value chain. MT-LT
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107 | Mediolanum Group - Annual Financial Report 2025 Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Credit/ counterparty/ concentration risk Acute physical risk: Extreme weather events Impacts deriving from weather events such as storms, floods, fires and heat waves, which may damage the production facilities and disrupt the value chain and business continuity of the Bank’s corporate portfolio. These events could therefore lead to a reduction in the repayment capacity of counterparties. The impact on property provided as collateral by corporate and retail credit counterparties due to acute climate and environmental events that could reduce the value of the collateral and, consequently, generate a reduction in the Bank’s recovery capacity. The risk is concentrated in the downstream value chain. ST – MT - LT Credit/ counterparty/ concentration risk Chronic physical risk: Chronic weather conditions Impacts deriving from longer-term trends, such as temperature changes, rising sea levels, reduced water availability, loss of biodiversity and land and soil degradation, which could affect the ability of counterparts to carry on their business and thus undermine their repayment capacity. Impacts due to which the exposure of property pledged as collateral by credit counterparties to chronic climate and environmental events could reduce the Bank’s recovery capacity. The risk is concentrated in the downstream value chain. MT-LT With reference to the retail loans portfolio, in recent years, in order to reduce exposure to physical risks, the Bank has conducted specific analyses of the impact of physical risk on its credit portfolio and has undertaken periodic monitoring of the geographical distribution and type of properties collateralizing credit exposures. In particular, the Bank found that climate-related risk primarily corresponds to a risk factor in the loans portfolio, where the aspect of physical risk is the main phenomenon that might affect property collateral in the mortgage loan portfolio. The low exposure to corporate counterparties excluded the impact of the physical and transition factor in corporate exposures. The physical risk analysis was conducted by mapping the geographic location of the properties as collateral and overlaying them with the institutional maps of landslides and floods, highlighting a distribution that is consistent with the market and without any particular problems. The transition risk assessment was based on the energy classification of the properties, which was also in line with the national benchmark. Similar activities were carried out by Banco Mediolanum, which assigned a rating (low/medium/high) for the exposure of the loans portfolio to flood and seismic scenarios. The Bank also carries out two-year monitoring on property collateral through third- party appraisals for the definition of the energy class and the related overall risk. For further information on how the Group has screened company assets and activities in order to assess the Bank’s exposure to any physical and transition risks, see the materiality analysis carried out by the Risk Management Function, which analyses, for each traditional risk category, the perimeter subject to the impact of physical and transition risks. See the datapoints 20 b, 20 c of ESRS E1 IRO-1.
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108 | Mediolanum Group - Annual Financial Report 2025 Market risk Banca Mediolanum identifies and maps the climate-related and environmental risks that affect market risk. In particular, the following transition and physical risk factors have been identified: Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Market risk Transition risk: Market sentiment, technology, policies and regulations The risk that the companies in which the Group invests in its proprietary portfolios will be negatively affected by international ‘green’ targets, resulting in market depreciation. The risk is concentrated in the downstream value chain. MT-LT Market risk Acute physical risk: Extreme weather events and chronic weather conditions The risk that serious manifestations of physical risk may cause problems in terms of material damage and disruption to the business of the companies in which the Group invests in its proprietary portfolios. This may lead to a sudden write-down of the Group’s investments in the financial markets. The risk is concentrated in the downstream value chain. ST - MT - LT Liquidity risk Banca Mediolanum identifies and maps the climate-related and environmental risks that affect liquidity risk. With reference to the analysis of the materiality assessments, the Risk Management Function found that climate-related and environmental factors were not material in relation to liquidity risk. In particular, the following transition and physical risk factors have been identified: Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Liquidity risk Transition risk: Market sentiment, technology, policies and regulations Potential impacts in terms of a decrease in the value of high-quality liquid assets in the portfolio (e.g. listed corporate securities) caused by the discontinuation of business activities/business branches, that can no longer be recovered by issuers that are particularly exposed to climate and energy transition risks. The risk is concentrated in the downstream value chain. This risk was found to be not significant. MT-LT Liquidity risk Acute physical risk: Extreme weather events Potential impacts in terms of decreased liquidity reserves as a consequence of extreme environmental events affecting large portions of the customer base (e.g. withdrawal of funds from current accounts or unexpected drawing on credit lines to finance reconstruction/remedial activities/immediate expenses, repayment default/failure of customers damaged by the event, negative impact on the market value of some financial assets in the portfolio). The risk is concentrated in the downstream value chain. This risk was found to be not significant. ST – MT – LT
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109 | Mediolanum Group - Annual Financial Report 2025 Strategic risk Banca Mediolanum identifies and maps the climate-related and environmental risks that affect strategic risk. In particular, the following transition risk factors have been identified: Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Strategic risk Transition risk: Market sentiment, technology, policies and regulations The risk that the underlyings of the products placed with customers contain companies that will be negatively affected by international green targets, with consequent losses in value on the markets. The risk is concentrated in the downstream value chain. MT-LT Strategic risk Acute physical risk: Extreme climate events and chronic weather conditions The risk that serious manifestations of physical risk may cause problems in terms of material damage and business interruption to the companies underlying the products placed with customers. This might lead to a sudden loss in the value of assets under management in the financial markets. The risk is concentrated in the downstream value chain. ST - MT - LT Operational risk Banca Mediolanum identifies and maps the climate-related and environmental risks that affect operational risk. In particular, the following physical risk factors have been identified: Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Operational risk Acute and chronic physical risk: Extreme weather events, chronic weather conditions Among the physical risks, particular attention is paid to acute and chronic events, which could result in the central offices of the Bank being shut down due to landslides and/or flooding. Potential impacts due to an operational standstill in the Bank’s processes caused by climate and environmental events affecting the offices/operating sites of third parties (for further details, see the point below ‘Third-party risk’). The risk is concentrated in the upstream value chain and in own operations. ST – MT - LT
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110 | Mediolanum Group - Annual Financial Report 2025 Third-party risk Banca Mediolanum identifies and maps the climate-related and environmental risks that affect third-party risk. In particular, the following physical risk factors have been identified: Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Third-party risk Acute physical risk: Extreme weather events, chronic weather conditions Physical risks include particular attention to acute events that could result in an operational halt to the Group’s processes due to climatic and environmental events involving third parties with which service contracts of a continuous nature, both ICT and non-ICT, are in place. The risk is concentrated in the upstream Value Chain. ST - MT - LT ICT and security risk Banca Mediolanum identifies and maps the climate-related and environmental risks that affect ICT and security risk. In particular, the following physical risk factors have been identified: Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon ICT and security risk Acute physical risk: Extreme weather events, chronic weather conditions Among physical risks, particular attention is paid to acute events that could cause an operational halt of processes due to climatic and environmental factors involving the critical infrastructures underpinning the essential services of the Banking Group. The risk is concentrated in own operations. ST - MT - LT Reputational risk Banca Mediolanum identifies and maps the climate-related and environmental risks that affect reputational risk. In particular, the following transition risk factors have been identified: Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Reputational risk Transition risk: Market sentiment Potential financial losses resulting from greenwashing practices (or even subject to legal investigation) due to a non-organic approach to C&E matters, including climate- related and environmental matters. In addition, potential negative impacts related to collaboration with suppliers of goods/services that do not operate in compliance with climate-environmental principles. The risk is concentrated in own operations and in the upstream and downstream value chain. MT-LT
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111 | Mediolanum Group - Annual Financial Report 2025 Instead, with regard to the Insurance business, climate and environmental risk factors for each type of risk are identified in the double materiality process. In particular, for Mortality Risk, these factors may determine impacts on mortality/longevity rates, while, for Non-biometric Risks (e.g. Redemption, Reduction, Management expenses), these factors may determine impacts on the frequency and amount of prepayments or costs incurred in managing policies. With reference to Pricing and Reserve Risk of the LoB Fire and other damages to property, the Catastrophe Risk of the LoB Fire and other damages to property, the Pricing and Reserve Risk of Health NSLT and the Catastrophe Risk of Health NSLT, climate and environmental risk factors may have impacts on the frequency and severity of claims. With regard to market risk, climate and environmental risks may affect the cash flows and costs of companies issuing the instruments in which the Group invests, and this may result in a sudden write-down of such assets, while, in relation to operational risk, these factors, and in particular physical risk, may have an impact on the business continuity of the Group companies, due to potential damage to properties owned and to the operating sites of suppliers. Finally, in relation to Reputational risk, C&E risk factors may have a potential negative financial impact resulting from future reputational harm. Moreover, in the Insurance Risk Management Framework, the following climate-related time horizons were considered: Short term (ST): from 1 to 5 years; Medium term (MT): from 5 to 10 years; Long term (LT): 10 years and over. The timing references indicated above were identified on the basis of the EIOPA guidelines provided in the ‘Application guidance on climate change materiality assessments and climate change scenarios in ORSA’ - 2022. The Mediolanum Insurance Group, with particular reference to physical and transition risk factors, has identified the following transmission channels: Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Mortality risk Acute and chronic physical risk: extreme weather events, chronic weather conditions In particular, the risks associated with floods and heatwaves that could result in an increase in mortality are identified. The risk is concentrated in the downstream value chain. MT-LT Non-biometric risks Transition risk: Policies and regulations The risks associated with macroeconomic developments, for example in terms of changes in the level of GDP, inflation or personal wealth, have been identified in particular. These could result in a sudden increase in redemptions or a rise in contract management fees. MT - LT Pricing and reserving risk of the LoB Fire and other damages to property Acute physical risk linked to natural events In particular, the risks related to fires, floods and hail are identified, which could lead to an increase in claims. MT - LT
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112 | Mediolanum Group - Annual Financial Report 2025 Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Catastrophe risk of the LoB Fire and other damages to property Pricing and reserving risk of the Health NSLT Acute and chronic physical risk: extreme weather events, chronic weather conditions In particular, the risks associated with heatwaves that could result in an increase in medical expenses are identified. MT - LT Catastrophic risk of Health NSLT Market risk Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Market risk Transition risk: Market sentiment, technology, policies and regulations The risk that the companies in which the Group invests will be adversely affected by international ‘green’ targets, resulting in market depreciation. MT - LT Market risk Acute physical risk: Extreme weather events and chronic weather conditions The risk that serious manifestations of physical risk may cause problems in terms of material damage and disruption to the business of the companies in which GAM invests. This might lead to a sudden loss in the value of assets in the financial markets. ST - MT – LT Operational risk Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Operational risk Acute and chronic physical risk: Extreme weather events, chronic weather conditions Among the physical risks, particular attention is paid to acute and chronic events, which could result in the central offices being shut down due to landslides and/or flooding. Potential impacts due to an operational standstill caused by climate and environmental events affecting the offices/operating sites of third parties. ST - MT - LT
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113 | Mediolanum Group - Annual Financial Report 2025 Reputational risk Type of risk Risk factor Description of transmission channel and connection with the Mediolanum Group’s value chain Time horizon Reputational risk Transition risk: Market sentiment Potential financial losses resulting from greenwashing practices (or even subject to legal investigation) due to a non-organic approach to C&E matters, including climate- related and environmental matters. In addition, potential negative impacts related to collaboration with suppliers of goods/services that do not operate in compliance with climate-related and environmental principles. MT - LT [E1.IRO-1 DP 20 b, 20 c] As part of the process of adaptation to climate-related and environmental risks undertaken by Banca Mediolanum, the individual climate-related and environmental risk factors having an impact on the Bank were identified and mapped and their materiality assessed. In fact, C&E risks do not solely constitute a distinct risk category but also occur through the traditional risk categories that characterise the banking business (i.e. Credit Risk, Market Risk, Reputational Risk, Liquidity Risk and Operational Risk). In this context, the Bank carried out a detailed analysis of the physical and transition risk factors relevant to the Parent Company and assessed their materiality with respect to traditional risk categories: Financial risks (i.e. Credit Risk, Market Risk, Liquidity Risk, Strategic Risk); Non-financial risks (i.e. Operational Risk, Reputational Risk, Third-party Risk, ICT and Security Risk). This approach enables an assessment of the impact of physical and transition risk factors on the categories of risk associated with the Group’s business, in line with Banca Mediolanum’s business model. To identify and assess the C&E risk factors for each traditional risk category, the reference perimeter, indicated in the sections below on each type of risk, was defined. To adequately integrate climate and environmental risks into the Risk Management Framework, a materiality assessment was carried out for each type of risk and for each perimeter identified, using methodologies (qualitative or quantitative approach) and tools differentiated according to the type of risk considered. This analysis is conducted on the basis of the transmission channels identified and the time horizons in which the impact of the C&E factors on the traditional risk considered is expected to occur, as discussed in the context of the datapoint [E1.IRO-1 AR 11 a]. The analyses carried out using the above tools provide a materiality assessment based on the impact of the individual risk driver, such as transition risk or physical risk, on the total analysis perimeter defined, which varies according to the traditional risk category in question. Below are the materiality bands defined by the Risk Management Function, in order to assess the materiality of climate and environmental risk factors for all the traditional risk categories mentioned above.
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114 | Mediolanum Group - Annual Financial Report 2025 MATERIALITY BANDS High Materiality Medium-High Materiality Medium Materiality Medium-Low Materiality Low Materiality Minimal Materiality In order to identify and assess the risks arising from physical and transition risk factors, the specific characteristics of the Mediolanum Group are taken into account. In particular, the analysis takes into account the safeguards put in place by the Group to support sustainability and the fight against climate change, as well as its overall risk management process. The following analyses were conducted with respect to physical risk and transition risk for each traditional risk and each identified perimeter. Credit/counterparty risk The materiality analysis for credit risk, within the scope of the assessment, covered two dimensions: the corporate portfolio and the retail portfolio (properties as collateral). In particular, for the purposes of conducting the assessment, the following perimeters were determined: the corporate portfolio, for which an analysis of the climate profile of the reference counterparty was conducted, and the retail portfolio, for which an analysis of climate and environmental risk factors was conducted on the properties pledged as collateral. Corporate Portfolio With regard to the Corporate portfolio, the analysis was based on an ESG score which itself incorporates a transition and physical risk component relating to the counterparty under analysis. This is a summary score that expresses the counterparty’s degree of exposure to Environmental (E), Social (S) and Governance (G) risks. In particular, for component E, the following are considered: Transition risk: the score assesses the environmental impact linked to greenhouse gas emissions and energy efficiency arising from the company’s production activity; Physical risk: the score assesses the degree of exposure to physical risk due to natural disasters in the company; The distribution of exposure to corporate counterparties is concentrated between the best or intermediate classes, while for the Very High risk class the concentration corresponds to a minimum materiality level. Retail Portfolio (properties as collateral) With regard to the retail portfolio, an analysis was conducted to assess the impact of climate and environmental risk factors on assets used to guarantee credit exposures. The materiality assessment with reference to Credit Risk is carried out using acute physical risk and chronic physical risk scores, as well as data relating to the energy class of the properties for transition risk. In particular, the analyses concern: • Transition risk: the energy class associated with the property pledged as collateral is considered to assess the impact of transition risk factors. The variable regarding the energy class of the properties can have 7 values: from class A (best) to class G (worst). In particular, the overall percentage of the value of the collateral relating to less virtuous properties in terms of energy efficiency - classes E, F, G – corresponds to a High level of Materiality, indicating a high impact of transition risk factors on Credit Risk;
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115 | Mediolanum Group - Annual Financial Report 2025 • Physical risk: the Materiality of physical risk factors on the retail portfolio is assessed using an acute physical risk score and a chronic physical risk score: o Acute physical risk: the analysis assesses the property’s degree of exposure to acute risks, based on geographical hazard and expected damage. For acute hazards, the risk factors considered were ‘heat wave’, ‘cold front/frost’, ‘fire’, ‘windstorm’, ‘drought’, ‘heavy rainfall’, ‘flood’ and ‘landslide’. With regard to the retail portfolio, the percentage of the value of the guarantees most exposed to acute physical risk factors corresponds to a low materiality level; o Chronic physical risk: the analysis assesses the property’s exposure to chronic risks, based on geographical hazard and expected damage. For the hazards of chronic climate change, the risk factor considered were ‘temperature change’, ‘thermal stress’, ‘wind change’, ‘rainfall change’, ‘sea rise’, ‘water stress’, ‘soil erosion’, ‘soil degradation’ and ‘permafrost defrost’. The retail portfolio has a low level of Materiality, i.e. a low impact of chronic physical risk factors on Credit Risk. Market risk and Strategic risk The materiality assessment with regard to market risk and strategic risk is performed using the UNEP FI Impact Map, which identifies how issuers in different economic sectors have a positive or negative impact on the climate- related and environmental areas connected to transition and physical risk factors, including environmental risk factors, with particular reference to loss of biodiversity. For the materiality assessment, the Impact Map categories attributable to the impact of climate and environmental risk factors were selected, in particular: Climate Stability, Biodiversity & Healthy ecosystems and Circularity. The results of the analyses conducted on market risk (trading book) and strategic risk (managed portfolio) are as follows: • Market risk: the weighted average market value (equities) and nominal value (bonds) of the scores associated with the relevant ATECO sectors of the trading book (Banking Group and Insurance Group) is equal to a low materiality of climate-related and environmental risk factors with regard to Market Risk; • Strategic risk: with regard to the Mediolanum funds (Mediolanum Gestione Fondi, Mediolanum Gestión, Mediolanum International Fund), the weighted value for the market value of the scores associated with this portion of the managed portfolio is equal to a medium-low level of materiality of climate-related and environmental risk factors. Operational risk With regard to Operational Risk, the scope of the assessment consists of owned properties and properties of third parties (for the latter, see the following point - Third-Party Risk). The materiality assessment of Operational Risk is carried out by identifying the properties owned by the Bank and the operating sites of third parties (to which reference is made in the next point - Third-Party Risk), and which of these are located in areas of significant physical risk in Italy, with an impact mainly on the upstream Value Chain. The assessment is performed using the score that provides information on acute physical Risk (e.g. the hazard levels of flood risk and landslide risk) and chronic physical Risk (e.g. cumulative precipitation, maximum and minimum air temperature, snow height, wind speed, rising water, hail and lightning). On the basis of the analyses carried out, the following materiality levels for Operational Risk are recorded with reference to the Bank’s properties: • Acute risk (floods and landslides): with reference to properties owned by the Bank, there is a minimum level of materiality for acute risk, compared with minimum levels of materiality for both hydraulic and hydrogeological risk. With regard to the operating sites of third parties, see the following point - Third- Party Risk); • Chronic risk (cumulative precipitation, maximum and minimum air temperature, snow height, wind speed, rising water, hail and lightning): the level of materiality is medium with regard to the Bank’s properties.
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116 | Mediolanum Group - Annual Financial Report 2025 Third-party risk The scope of assessment covers third parties with which the Banking Group has ‘ongoing’ contracts for ICT and non-ICT services (as defined in the Policy on the Management of Third Party Risk). In the preliminary stage, all Third Parties under a contract with the Banca Mediolanum Group were identified through ongoing agreements relating to the procurement of ICT and non-ICT services. To conduct the analysis, an ESG risk score of an external infoprovider was adopted to ensure the reliability and compliance of the information used. This score incorporates transition and physical risk components relating to the Third Party being assessed, and is a summary indicator of the level of exposure to environmental, social and governance risks. In particular, for component E, the following are considered: • Transition risk: the score assesses the environmental impact for greenhouse gas emissions and energy efficiency of the company’s production activity; • Physical risk: the score assesses the degree of exposure to physical risk due to natural disasters in the company. Following the analysis, it should be noted that the Third Parties analysed 14 are in the most favourable risk bands (Rating 1 and Rating 2), with a residual share in the middle band (Rating 3) and no Third Parties in the worst bands (Rating 4 and Rating 5). This result indicates that there are no significant problems in relation to transition risk, essentially confirming the soundness of Third Parties with respect to the environmental factors considered. ICT and security risk The scope of assessment covers all ICT assets employed to provide support services to the Banking Group and Insurance Group. The assessment of ICT and Security risk related to insufficient ICT security is part of the annual ICT and Security risk analysis campaign, which examines the ICT Assets in operation. The model adopted for conducting this analysis assesses the ICT and security risks to which ICT Assets are exposed in relation to a defined library of cyber threats (including hardware damage due to natural events, e.g. flooding, fire, earthquake, etc.), taking into account the level of effectiveness of existing security safeguards. The calculation of ICT and security risk is based on the: • qualitative and quantitative assessment of the potential impacts on the individual ICT asset in relation to the attributes of Confidentiality, Integrity, Availability and Authenticity; • qualitative and quantitative assessment of the potential probability of the threat occurring. These factors (potential probability and impacts) contribute to defining the potential risk. The residual ICT and security risk is subsequently estimated by calculating the level of effectiveness of the existing security safeguards, which contribute to mitigating the potential probability and/or impact. A dedicated tool is used to carry out the ICT and security risk analysis campaign, implementing the logics described above. If, following the calculation of residual risk, the defined risk appetite threshold is exceeded, a risk treatment plan must be adopted to restore the risk appetite level. The results of the campaign are reported in the document ’Summary report on the ICT and Security Risk Situation’ and submitted to the Board of Directors for approval. 14 The information provider’s ESG ratings used for the analysis do not currently cover third parties located outside the EU27 countries. The current coverage of analyses is 76% of the third parties in scope.
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117 | Mediolanum Group - Annual Financial Report 2025 Liquidity risk The scope of assessment, with reference to Liquidity Risk, refers to the Bank’s liquidity position. With regard to Liquidity Risk, a qualitative analysis was carried out, indicating that the climate and environmental risk factors are not material for the Group’s liquidity profile. The bank has a solid liquidity position which can absorb even severe shocks. The analyses carried out show low average exposure to physical risks, with real estate and current accounts concentrated in low-risk geographical areas. It should also be noted that there is a significant correlation between mortgage and current account assets, both of which are predominantly allocated to geographical areas with low physical risk. This suggests that current account holders are often also beneficiaries of mortgages and related ancillary insurance cover. The presence of ancillary insurance cover and the potential support provided by government intervention in the event of adverse events further strengthen the Group’s resilience, reducing the likelihood of significant cash outflows. Reputational risk For the purposes of identifying and mapping C&E risk factors on Reputational Risk, the scope of assessment covers the perception of members of the Group by customers, counterparties, shareholders, investors and supervisory authorities. In the context of Financial Materiality, with reference to Reputational Risk and regarding CO₂ emissions, the analysis, conducted using a qualitative approach, took into account the initiatives launched by the Group to curb its emissions (e.g. defining targets dedicated to curtailing Scope 1 emissions and achieving numerous environmental certifications (e.g. ISO 14001). [E1.IRO-1 AR 11 b] Within the Risk Management Framework, climate-related time horizons were defined. The time references indicated above were clusterized by referring to the main decisions taken by international institutional bodies to achieve the objectives of reducing environmental impacts. In particular, the following time horizons were identified: Short term (ST): from 0 to 3 years. For the Bank’s recurring activities, the short-term horizon was set to coincide with a period of 1 to 3 years, which corresponds to the time horizon of the ICAAP/ILAAP process; Medium term (MT): from 3 to 5 years. This time horizon was defined by referring to the period indicated by the COP21 of the Paris Agreement of 2015, which provided for the signatory States to periodically review, starting in 2020, the strategies and policies to be adopted in order to achieve the objectives to which they signed up; Long-term (LT): greater than 5 years. For the long term, the thirty-year period from 2020 to 2050 was adopted as the reference. This timeframe was considered a benchmark with reference to the European Parliament’s January 2020 resolution on the European Green Deal, which aims to transform the European Union into a modern, resource-efficient and competitive economy, with the main objective of net-zero greenhouse gas emissions by 2050. The horizons defined in this way used in the analysis of transmission channels with which climate-related and environmental risks have an impact on the traditional risk categories of financial intermediaries. The effects of these climate risks, including physical and transition risk, are then quantified in the ICAAP. The starting point for the year is the three-year horizon developed during the planning stage. The impacts of climate scenarios on assets are calculated taking into account the duration of the item concerned and the method used to account for it. [E1.IRO-1 AR 11 c; 12 b] On an annual basis, the Risk Management Function carries out a quantitative or qualitative materiality assessment of climate-related and environmental risk factors that affect traditional risk categories. In order to assess the impact of ESG factors, in line with the requirements of the EBA guidelines, the Mediolanum Group uses various methods for analysing ESG risks, including those based on exposure, sector and scenarios. Specifically:
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118 | Mediolanum Group - Annual Financial Report 2025 Exposure-based analysis: this analysis makes it possible to assess exposure to ESG risk factors for each risk category, through specific instruments identified to assess the materiality of risk. For further details on the approach taken to assess exposure to ESG risk factors for each traditional risk category, see ESRS E1 IRO-1, datapoints 20b, 20c. As part of the processes for identifying and assessing actual and potential physical risks, the Mediolanum Group adopts a methodological approach, also disclosed in the Pillar 3 report, to assess exposures to non-financial companies and exposures secured by property, taking into account the geolocation of the property or the counterparty’s headquarters. In this regard, the following is a summary of the methodology adopted to assess physical risk and, consequently, to quantify the amount of exposures to non-financial undertakings secured by property, affected by chronic and acute physical risks. The physical risk assessment is divided into two main stages: o Estimation of the hazard level of the region; o Estimation of the vulnerability of the sector/building. With regard to the analysis of the hazard level of the region , the corporate counterparties and properties are ‘superimposed, through their geographical coordinates, on hazard maps showing the degree of exposure of the region to a specific natural or climate hazard. The estimation of the hazard level of the region is based on historical information for that region (with a considerable level of detail); the effects expected from future climate change are also considered, based on the RCP 4.515 scenario. The estimation of the hazard level of the region is integrated with a vulnerability analysis, by assessing the potential economic impacts arising from the occurrence of weather events. For companies, the assessment of the hazard level of the region is integrated with an analysis of the economic impacts that various risks may have on each location, based on its respective economic sector. Sectoral vulnerability is estimated by considering aspects such as the characteristics of production processes and the Value Chain, the presence and storage of goods and machinery and the level of exposure to direct damage. For buildings, vulnerability is estimated according to the intended use of the building (e.g. residential, commercial or industrial), since buildings with different intended uses are constructed using different criteria and therefore respond to stresses caused by natural events in different ways. This approach makes it possible to obtain a synthetic physical risk score, useful for quantifying the overall exposure of the portfolio to non-financial companies and secured properties, taking into account both current and potential risks. As regard the exposure of counterparties to transition risks, the Mediolanum Group, in the process of identifying C&E risk factors and the related transmission channels, considers the degree of vulnerability of counterparties, taking into account the relevant technological developments, the impact of applicable or soon to be adopted environmental regulations that affect the counterparty’s business sector, as well as how the evolution of market preferences and the level of energy efficiency influence exposures to residential or commercial properties. Sector-based methodologies: this is a sector analysis conducted with reference to the AUM portfolio and the proprietary portfolio through the use of a heat map highlighting the ESG risks to which individual economic sectors are exposed. This analysis allows it to map its portfolios according to ESG risk factors and identify any exposures to these risks. With regard to the corporate loan portfolio, in the context of Pillar III public disclosure, the Mediolanum Group reports and monitors exposures to non-financial companies operating in sectors that contribute strongly to climate change (i.e. the sectors referred to in sections A to H and section L of Annex I to Regulation (EC) No 1893/2006). This reporting enables oversight, on a sectoral basis, of exposures sensitive to transition risk and their level of concentration in sectors linked to carbon emissions; 15 This scenario is one of those adopted by the Intergovernmental Panel on Climate Change (IPCC), based on various assumptions in terms of greenhouse gas emission trends (Representative Concentration Pathways – RCP) and global socio-economic changes (Shared Socioeconomic Pathways – SSP).
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119 | Mediolanum Group - Annual Financial Report 2025 Scenario-based analysis: a stress assessment carried out using climate scenarios developed by the Network for Greening the Financial System (NGFS), that explore the impacts of climate change and climate policies. [E1.IRO-1 AR 11 d; 12 c] In identifying climate-related hazards that could influence the assessment of the Group’s exposure and sensitivity to the effects of climate change, Mediolanum relies on the climate scenarios of the NGFS (Network for Greening the Financial System), through which it assesses the Group’s exposure to physical and transition events identified as potentially material. As stated in the datapoint [E1.SBM-3 DP 19 b], Banca Mediolanum has integrated the Climate Risk scenario into its ICAAP, using NGFS stress scenarios for the entire Group, in order to assess socio-economic trends in different combinations of severity characterising climate risk (transition and physical). The impact of these climate scenarios has been assessed according to various aspects: the value of the assets under management and fee margins, the fair value and ECL of the proprietary securities portfolio, and the PD (Probability of Default) and LGD (Loss Given Default) parameters of the retail loans portfolio. In line with what has been established by the Parent Company in the risk identification and assessment process, climate-related risk has also been integrated into the broader ESG risk category for the Insurance Group. The approach adopted is consistent with the climate- related risk guidelines provided by the Mediolanum Financial Conglomerate, taking into account the specific regulatory features of the sector. Also during the 2024 ORSA, the Mediolanum Insurance Group assessed two climate scenarios, consistent with EIOPA regulations, considering their impacts over short-, medium- and long-term time horizons: an increase in temperature – remaining below 2°C, preferably not above 1.5°C; an increase in temperature – exceeding 2°C. The first under 1.5° scenario includes the RCP 4.5 scenario on the underwriting side, corresponding to an increase in temperature of 2.5°C to 3°C compared with pre-industrial levels, and the NGFS Divergent Net Zero 2050 (NZ2050) scenario on the market side. The second over 2° scenario, meanwhile, includes the RCP 8.5 scenario on the underwriting side, corresponding to an increase in temperature of 4°C to 4.5°C compared with pre-industrial levels, and the NGFS Nationally Determined Contributions (NDCs) scenario on the market side. For further information on the scenarios used, see ESRS E1 SBM-3. [E1.IRO-1 DP 21] To ensure a proper measurement of the impacts of climate-related and environmental risk factors on traditional risks, Banca Mediolanum uses, as previously stated, a set of climate scenarios that explore the impacts of climate change and climate policies, with the aim of providing a common reference framework. Each scenario is characterised by an overall level of physical risk and transition risk, determined by the level of ambition of the policies, their timing and the degree of coordination and technological levers. The use of these scenarios, together with the data made available by information providers, allows for the determination of the impact of climate- related and environmental risk factors with reference to credit risk, market risk and strategic risk, as detailed in the reference paragraphs. For further details on the use of climate scenarios for the purposes of the resilience analysis of the Mediolanum Group, see the information on the datapoint SBM-3 DP 48 f. [E2.IRO-1 DP 11 a; 11b] The process of identifying pollution-related impacts, risks and opportunities (IROs) was based on an analysis of the internal context and the Group’s Value Chain, including upstream activities, own operations and downstream activities, considering the nature of the activities and the related operational characteristics.
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120 | Mediolanum Group - Annual Financial Report 2025 The analysis included, in particular: the mapping of the main types of activities carried out along the Value Chain; the analysis of the Group’s operating processes and business models; the assessment of the suppliers, loans and investments portfolio; the collection and analysis of internal qualitative and quantitative evidence. On the basis of the information and evidence that emerged, a preliminary long-list of potential pollution-related IROs was drawn up and then the materiality assessment was carried out on them. Moreover, no consultations with the affected communities were envisaged in the process of identifying the pollution-related IROs. However, in the Stakeholder Engagement process, the topic was explored in depth with certain categories of Stakeholders on the basis of competence and/or interest, in order to gather their point of view. For further information on the Stakeholder Engagement process, see the detailed section (ESRS 2, SBM-2, paragraph Interests and views of stakeholders for further details). [E2.IRO-1 DP AR 9] The ‘Pollution’ area was found to be not material in the double materiality process. [E3.IRO-1 DP 8 a; 8b] The process of identifying water and marine resources-related impacts, risks and opportunities (IROs) was based on an analysis of the internal context and the Group’s Value Chain, including upstream activities, own operations and downstream activities, considering the nature of the activities and the related operational characteristics. The analysis included, in particular: the mapping of the main types of activities carried out along the Value Chain; the analysis of the Group’s operating processes and business models; the assessment of the suppliers, loans and investments portfolio; the collection and analysis of internal qualitative and quantitative evidence. On the basis of the information and evidence that emerged, a preliminary long-list of potential pollution-related IROs was drawn up and then the materiality assessment was carried out on them. Moreover, no consultations with the affected communities were envisaged in the process of identifying the water and marine resources-related IROs. However, in the Stakeholder Engagement process, the topic was explored in depth with certain categories of Stakeholders on the basis of competence and/or interest, in order to gather their point of view. For further information on the Stakeholder Engagement process, see the detailed section (ESRS 2, SBM-2, Interests and views of stakeholders for further details). [E4.IRO-1 DP 17 a; 17 c; 17 d] The process to identify biodiversity and ecosystems-related IROs involved an analysis of both own operations and upstream and downstream activities in the Group’s Value Chain. The analysis process involved the use of tools that take into account the composition of the suppliers, loans and investments portfolio. Specifically with regard to risks and with reference to the analysis of materiality assessments in relation to market risk and strategic risk, the Risk Management Function used the UNEP FI Impact Map, which identifies how issuers in different economic sectors have a positive or negative impact on the climate and environmental areas relating to transition and physical risk factors, including environmental risk factors. Among the environmental risk factors analysed, the UNEP FI Impact Map tool considers factors in the Biodiversity & Healthy ecosystems category; however, for the purposes of the materiality assessments, including for the specific nature of the business carried out by the Mediolanum Group, no significant risks in terms of biodiversity and ecosystems were identified. With regard to Credit Risk, the impact of the risk of biodiversity loss is currently deemed to be non-material, due to the Group’s limited exposure to the corporate counterparty loan segment. [E4.IRO-1 DP 17 b]
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121 | Mediolanum Group - Annual Financial Report 2025 As part of the activity to understand the context, which is required by the double materiality assessment, the Mediolanum Group carried out a qualitative analysis of potential dependencies with regard to the topic of ‘biodiversity and ecosystems’, examining the interactions between its Value Chain and the environmental context. The analysis did not reveal significant direct or indirect dependencies on biodiversity, ecosystems or related services, either at the level of operating sites or along the Value Chain. However, the dependencies identified were taken into account in updating the list of potentially material risks. [E4.IRO-1 DP 17 e] No consultations with the affected communities were envisaged in the process of identifying the biodiversity and ecosystems-related IROs. However, in the Stakeholder Engagement process, the topic was explored in depth with certain categories of Stakeholders on the basis of competence and/or interest, in order to gather their point of view. For further information on the Stakeholder Engagement process, see the detailed section (ESRS 2, SBM-2, Interests and views of stakeholders for further details). [E4.IRO-1 DP 19 a; 19 b] The Group’s sites are not located inside or near biodiversity-sensitive areas. Therefore, the Group did not consider it necessary to adopt mitigation measures for biodiversity. [E5.IRO-1 DP 11 a] The process of identifying resource use and circular economy-related impacts, risks and opportunities (IROs) was based on an analysis of the internal context and the Group’s Value Chain, including upstream activities, own operations and downstream activities, considering the nature of the activities and the related operational characteristics. The analysis included, in particular: the mapping of the main types of activities carried out along the Value Chain; the analysis of the Group’s operating processes and business models; the assessment of the suppliers, loans and investments portfolio; the collection and analysis of internal qualitative and quantitative evidence. On the basis of the information and evidence that emerged, a preliminary long-list of potential pollution-related IROs was drawn up and then the materiality assessment was carried out on them. [E5.IRO-1 DP 11 b] No consultations with the affected communities were envisaged in the process of identifying the resource use and circular economy-related IROs. However, in the Stakeholder Engagement process, the topic was explored in depth with certain categories of Stakeholders on the basis of competence and/or interest, in order to gather their point of view. For further information on the Stakeholder Engagement process, see the detailed section (ESRS 2, SBM-2, Interests and views of stakeholders for further details). Description of the processes to identify and assess material business conduct-related impacts, risks and opportunities [G1.IRO-1 DP 6] The process to identify impacts, risks and opportunities, including as regards matters relating to business conduct, was carried out taking into account all entities included in the reporting scope, the Group’s business activity and the upstream and downstream Value Chain. ESRS Disclosure Requirements covered by the undertaking’s sustainability statement [IRO-2 DP 56]
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122 | Mediolanum Group - Annual Financial Report 2025 Disclosure elements deriving from other EU legislation Disclosure requirement and corresponding disclosure element SFDR reference16 Pillar 3 reference17 Benchmark Regulation reference18 EU Climate Law reference19 Paragraph ESRS 2 GOV-1 paragraph 21 (d) x x 1.1.2 Governance, section ‘Role of administrative, management and supervisory bodies’ ESRS 2 GOV-1 paragraph 21 (e) x 1.1.2 Governance, section ‘Role of administrative, management and supervisory bodies’ ESRS 2 GOV-4 paragraph 30 x 1.1.2 Governance, section ‘Statement on due diligence’ ESRS 2 SBM-1 paragraph 40 (d) i x x x Not relevant ESRS 2 SBM-1 paragraph 40 (d) ii x x Not relevant ESRS 2 SBM-1 paragraph 40 (d) iii x x Not relevant ESRS 2 SBM-1 paragraph 40 (d) iv x Not relevant ESRS E1-1 paragraph 14 x 2.2.2 Transition plan for climate change mitigation ESRS E1-1 paragraph 16 (g) x x 2.2.2 Transition plan for climate change mitigation ESRS E1-4 paragraph 34 x x x 2.2.2 Transition plan for climate change mitigation ESRS E1-5 paragraph 38 x Not relevant 16 Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (SFDR) (OJ L 317, 9.12.2019, p. 1). 17 Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 (capital requirements regulation) (OJ L 176, 27.6.2013, p. 1). 18 Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014 (OJ L 171, 29.6.2016, p. 1). 19 Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (‘European Climate Law’) (OJ L 243, 9.7.2021, p. 1).
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123 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement and corresponding disclosure element SFDR reference16 Pillar 3 reference17 Benchmark Regulation reference18 EU Climate Law reference19 Paragraph ESRS E1-5 paragraph 37 x 2.2.7 Metrics, section ‘Energy consumption and mix’ ESRS E1-5 paragraphs 40-43 x Not relevant ESRS E1-6 paragraph 44 x x x 2.2.7 Metrics, section ‘Gross Scope 1, 2, 3 GHG Emissions’ ESRS E1-6 paragraphs 53-55 x x x 2.2.7 Metrics, section ‘Gross Scope 1, 2, 3 and Total GHG emissions’ ESRS E1-7 paragraph 56 x 2.2.7 - Metrics, section ‘GHG removals and GHG mitigation projects financed through carbon credits’ ESRS E1-9 paragraph 66 x Phase-in ESRS E1-9 paragraph 66 (a); 66 (c) x Phase-in ESRS E1-9 paragraph 67 (c) x Phase-in ESRS E1-9 paragraph 69 x Phase-in ESRS E2-4 paragraph 28 x Not relevant ESRS E3-1 paragraph 9 x Not relevant ESRS E3-1 paragraph 13 x Not relevant ESRS E3-1 paragraph 14 x Not relevant ESRS E3-4 paragraph 28 (c) x Not relevant ESRS E3-4 paragraph 29 x Not relevant ESRS 2- IRO 1 - E4 paragraph 16 (a) i x Not relevant
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124 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement and corresponding disclosure element SFDR reference16 Pillar 3 reference17 Benchmark Regulation reference18 EU Climate Law reference19 Paragraph ESRS 2- IRO 1 - E4 paragraph 16 (b) x Not relevant ESRS 2- IRO 1 - E4 paragraph 16 (c) x Not relevant ESRS E4-2 paragraph 24 (b) x Not relevant ESRS E4-2 paragraph 24 (c) x Not relevant ESRS E4-2 paragraph 24 (d) x Not relevant ESRS E5-5 paragraph 37 (d) x Not relevant ESRS E5-5 paragraph 39 x Not relevant ESRS 2- SBM 3 - S1 paragraph 14 (f) x 3.1.1 Material impacts, risks and opportunities and their interaction with strategy and business model ESRS 2- SBM 3 - S1 paragraph 14 (g) x 3.1.1 Material impacts, risks and opportunities and their interaction with strategy and business model ESRS S1-1 paragraph 20 x 3.1.2 Working conditions and human rights, section ‘The Group’s approach and policies’ ESRS S1-1 paragraph 21 x 3.1.2 Working conditions and human rights, section ‘The Group’s approach and policies’ ESRS S1-1 paragraph 22 x 3.1.2 Working conditions and human rights, section
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125 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement and corresponding disclosure element SFDR reference16 Pillar 3 reference17 Benchmark Regulation reference18 EU Climate Law reference19 Paragraph ‘The Group’s approach and policies’ ESRS S1-1 paragraph 23 x 3.1.3 Health and safety, section ‘The Group’s approach and policies’ ESRS S1-3 paragraph 32 (c) x 3.1.9 Processes to remediate negative impacts and channels for own workers to raise concerns ESRS S1-14 paragraph 88 (b), 88 (c) x x 3.1.10 Metrics, section ‘Health and safety metrics’ ESRS S1-14 paragraph 88 (e) x Phase-in ESRS S1-16 paragraph 97 (a) x x 3.1.10 Metrics, section ‘Compensation metrics (pay gap and total compensation)’ ESRS S1-16 paragraph 97 (b) x 3.1.10 Metrics, section ‘Compensation metrics (pay gap and total compensation)’ ESRS S1-17 paragraph 103 (a) x 3.1.10 Metrics, section ‘Incidents, complaints and severe human rights impacts’ ESRS S1-17 paragraph 104 (a) x x 3.1.10 Metrics, section ‘Incidents, complaints and severe human rights impacts’ ESRS 2- SBM 3 - S2 paragraph 11 (b) x 3.2.1 Material impacts, risks and opportunities and their interaction with strategy and business model
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126 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement and corresponding disclosure element SFDR reference16 Pillar 3 reference17 Benchmark Regulation reference18 EU Climate Law reference19 Paragraph ESRS S2-1 paragraph 17 x 3.2.2 Suppliers, section ‘The Group’s approach and policies’ ESRS S2-1 paragraph 18 x 3.2.2 Suppliers, section ‘The Group’s approach and policies’ ESRS S2-1 paragraph 19 x x 3.2.2 Suppliers, section ‘The Group’s approach and policies’ ESRS S2-1 paragraph 19 x 3.2.2 Suppliers, section ‘The Group’s approach and policies’ ESRS S2-4 paragraph 36 x 3.2.2 The suppliers, ‘Actions’ section ESRS S3-1 paragraph 16 x 3.3.2 Economic, social and cultural rights of communities, section ‘The Group’s approach and policies’ ESRS S3-1 paragraph 17 x x 3.3.2 Economic, social and cultural rights of communities, section ‘The Group’s approach and policies’ ESRS S3-4 paragraph 36 x 3.3.2 Economic, social and cultural rights of communities, section ‘Actions’ ESRS S4-1 paragraph 16 x 3.4.7 Commitments related to the Protection of Human Rights Policy of the Mediolanum Group ESRS S4-1 paragraph 17 x x 3.4.7 Commitments related to the
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127 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement and corresponding disclosure element SFDR reference16 Pillar 3 reference17 Benchmark Regulation reference18 EU Climate Law reference19 Paragraph Protection of Human Rights Policy of the Mediolanum Group ESRS S4-4 paragraph 35 x 3.4.7 Commitments related to the Protection of Human Rights Policy of the Mediolanum Group ESRS G1-1 paragraph 10 (b) x / ESRS G1-1 paragraph 10 (d) x / ESRS G1-4 paragraph 24 (a) x x 4.1.5 Metrics, section ‘Confirmed incidents of bribery and corruption’ ESRS G1-4 paragraph 24 (b) x 4.1.5 Metrics, section ‘Confirmed incidents of bribery and corruption’ List of reporting obligations Disclosure requirement Paragraph ESRS 2 General disclosures BP-1 - General basis for preparation of sustainability statements 1.1.1 Basis of preparation, sections ‘Scope of consolidation’; ‘Disclosures in relation to the Value Chain’; ‘Disclosures in relation to specific circumstances’ BP-2 - Disclosures in relation to specific circumstances 1.1.1 Basis of preparation, section ‘Disclosures in relation to the value chain’; ‘Disclosures in relation to specific circumstances’ GOV-1 - The role of the administrative, management and supervisory bodies 1.1.2 Governance, sections ‘The role of the administrative, management and supervisory bodies’; ‘Governance of sustainability’; ‘Sustainability-related skills and expertise of the bodies’ GOV-2 -Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies 1.1.2 Governance, section ‘Governance sustainability’; ‘Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies’
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128 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement Paragraph GOV-3 – Integration of sustainability-related performance in incentive schemes 1.1.2 Governance, section ‘Integration of sustainability performance into incentive systems’ GOV-4 – Statement on due diligence 1.1.2 Governance, section ‘Statement on due diligence’ GOV-5 – Risk management and internal controls over sustainability reporting 1.1.2 Governance, section ‘Risk management and internal controls over sustainability reporting’ SBM-1 – Strategy, business model and value chain 1.1.3 Strategy, section ‘Strategy, business model and value chain’ SBM-2 – Interests and views of stakeholders 1.1.3 Strategy, section ‘Interests and views of stakeholders’ SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model 1.1.3 Strategy, section ‘Material impacts, risks and opportunities and their interaction with strategy and business model’ IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities 1.1.4 Impact, risk and opportunity management, section ‘Description of the processes to identify and assess material impacts, risks and opportunities’ IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement 1.1.4 Impact, risk and opportunity management, section ‘ESRS Disclosure Requirements covered by the undertaking’s sustainability statement’ E1 – Climate change E1-1 – Transition plan for climate change mitigation 2.2.2 Transition plan for climate change mitigation ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model 2.2.1 Material impacts, risks and opportunities and their interaction with strategy and business model ESRS 2 IRO-1 – Description of the processes to identify and assess material climate-related impacts, risks and opportunities 1.1.4 Impact, risk and opportunity management, section ‘Description of the processes to identify and assess material impacts, risks and opportunities’ E1-2 – Policies related to climate change mitigation and adaptation 2.2.3 Own GHG emissions, section ‘The Group’s approach and policies’; 2.2.4 Financed GHG emissions – Investments, section ‘The Group’s approach and policies’; 2.2.5 Financed GHG emissions – Credit, section ‘The Group’s approach and policies’; 2.2.6 Digitalisation of processes, section ‘The Group’s approach and policies’ E1-3 – Actions and resources in relation to climate change policies 2.2.3 Own GHG emissions, section ‘Actions’; 2.2.4 Financed GHG emissions – Investments, section ‘Actions’; 2.2.5 Financed GHG emissions – Credit, section ‘Actions’; 2.2.6 Digitalisation of processes, section ‘Actions’ E1-4 – Targets related to climate change mitigation and adaptation 2.2.2 Transition plan for climate change mitigation, section ‘Targets’; 2.2.3 Own GHG emissions, section ‘Targets’; 2.2.4 Financed GHG emissions – Investments; section ‘Targets’; 2.2.5 Funded GHG emissions – Credit, section ‘Targets’; 2.2.6 Digitalisation of processes, section ‘Targets’ E1-5 – Energy consumption and mix 2.2.7. Metrics, section ‘Energy consumption and mix’ E1-6 – Gross Scope 1, 2, 3 and Total GHG emissions 2.2.7 Metrics, section ‘Gross Scope 1, 2, 3 and Total GHG emissions’
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129 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement Paragraph E1-7 - GHG removals and GHG mitigation projects financed through carbon credits 2.2.7 - Metrics, section ‘GHG removals and GHG mitigation projects financed through carbon credits’ E1-8 – Internal carbon pricing 2.2.7 Metrics, section ‘Internal carbon pricing’ E2 - Pollution ESRS 2 IRO-1 – Description of the processes to identify and assess material pollution-related impacts, risks and opportunities 1.1.4 Impact, risk and opportunity management, section ‘Description of the processes to identify and assess material impacts, risks and opportunities’ E3 – Water and marine resources ESRS 2 IRO-1 — Description of the processes to identify and assess material water and marine resources-related impacts, risks and opportunities 1.1.4 Impact, risk and opportunity management, section ‘Description of the processes to identify and assess material impacts, risks and opportunities’ E4 – Biodiversity and ecosystems ESRS 2 IRO-1 — Description of the processes to identify and assess material biodiversity and ecosystems-related impacts, risks and opportunities 1.1.4 Impact, risk and opportunity management, section ‘Description of the processes to identify and assess material impacts, risks and opportunities’ E5 – Resource use and circular economy ESRS 2 IRO-1 — Description of the processes to identify and assess material resource use and circular economy-related impacts, risks and opportunities 1.1.4 Impact, risk and opportunity management, section ‘Description of the processes to identify and assess material impacts, risks and opportunities’ S1 – Own workforce ESRS 2 SBM-2 – Interests and views of stakeholders 1.1.3 Strategy, section ‘Interests and views of stakeholders’ ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model 3.1.1 Material impacts, risks and opportunities and their interaction with strategy and business model S1-1 – Policies related to own workforce 3.1.2 Working conditions and human rights, section ‘The Group’s approach and policies’; 3.1.3 Health and safety, section ‘The Group’s approach and policies’; 3.1.4 Work-life balance, section ‘The Group’s approach and policies’; 3.1.5 Training and skills development, section ‘The Group’s approach and policies’; 3.1.6 Equal treatment and opportunities for all, section ‘The Group’s approach and policies’; 3.1.7 Other rights related to work-Confidentiality, section ‘The Group’s approach and policies’ S1-2 – Processes for engaging with own workforce and workers’ representatives about impacts 3.1.8 Processes for engaging with own workforce and workers’ representatives about impacts S1-3 – Processes to remediate negative impacts and channels for own workers to raise concerns 3.1.9 Processes to remediate negative impacts and channels for own workers to raise concerns S1-4 – Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related 3.1.2 Working conditions and human rights, section ‘Actions’; 3.1.3 Health and safety, section ‘Actions’; 3.1.4 Work-life balance, section ‘Actions’;
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130 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement Paragraph to own workforce, and effectiveness of those actions 3.1.5 Training and skills development, section ‘Actions’; 3.1.6 Equal treatment and opportunities for all, section ‘Actions’; 3.1.7 Other rights related to work-Confidentiality, section ‘Actions’ S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities 3.1.2 Working conditions and human rights, section ‘Targets’; 3.1.3 Health and safety, section ‘Targets’; 3.1.4 Work-life balance, section ‘Targets’; 3.1.5 Training and skills development, section ‘Targets’; 3.1.6 Equal treatment and opportunities for all, section ‘Targets’; S1-6 – Characteristics of the undertaking’s employees 3.1.10 Metrics, section ‘Characteristics of the undertaking’s employees’ S1-8 – Collective bargaining coverage and social dialogue 3.1.10 Metrics, section ‘Collective bargaining coverage and social dialogue’ S1-9 – Diversity metrics 3.1.10 Metrics, section ‘Diversity metrics’ S1-10 – Adequate wages 3.1.10 Metrics, section ’Adequate Wages’ S1-13 – Training and skills development metrics 3.1.10 Metrics, section ‘Training and skills development metrics’ S1-14 – Health and safety metrics 3.1.10 Metrics, section ‘Health and safety metrics’ S1-16 – Compensation metrics (pay gap and total compensation) 3.1.10 Metrics, ‘Compensation metrics (pay gap and total compensation)’ S1-17 – Incidents, complaints and severe human rights impacts 3.1.10 Metrics, section ‘Incidents, complaints and severe human rights impacts’ S2 – Workers in the Value Chain ESRS 2 SBM-2 – Interests and views of stakeholders 1.1.3 Strategy, section ‘Interests and views of stakeholders’ ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model 3.2.1 Material impacts, risks and opportunities and their interaction with strategy and business model S2-1 – Policies related to value chain workers 3.2.2 Suppliers, the section ‘The Group’s approach and policies’ S2-2 – Processes for engaging with Value Chain workers about impacts 3.2.3 – Processes for engaging with Value Chain workers about impacts S2-3 – Processes to remediate negative impacts and channels for value chain workers to raise concerns 3.2.4 Processes to remediate negative impacts and channels for Value Chain workers to raise concerns S2-4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions 3.2.2 The Suppliers, section ‘Actions’ S2-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities 3.2.2 The Suppliers, section ‘Targets’
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131 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement Paragraph S3 – Affected communities ESRS 2 SBM-2 – Interests and views of stakeholders 1.1.3 Strategy, section ‘Interests and views of stakeholders’ ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model 3.3.1 Material impacts, risks and opportunities and their interaction with strategy and business model S3-1 – Policies related to affected communities 3.3.2 Economic, social and cultural rights of communities, section ‘The Group’s approach and policies’ S3-2 – Processes for engaging with affected communities about impacts 3.3.3 Engaging with affected communities about impacts S3-4 – Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions 3.3.2 Economic, social and cultural rights of communities, section ‘Actions’ S3-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities 3.3.2 Economic, social and cultural rights of communities, section ’Targets’ S4 – Consumers and end-users ESRS 2 SBM-2 – Interests and views of stakeholders 1.1.3 Strategy, section ‘Interests and views of stakeholders’ ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model 3.4.1 Material impacts, risks and opportunities and their interaction with strategy and business model S4-1 – Policies related to consumers and end- users 3.4.2 Confidentiality, section ‘The Group’s approach and policies’; 3.4.3 Access to (quality) information, section ‘The Group’s approach and policies’; 3.4.4 Access to products and services, section ‘The Group’s approach and policies’; 3.4.5 Responsible business practices, section ‘The Group’s approach and policies’; 3.4.6 Freedom of expression, section ‘The Group’s approach and policies’; 3.4.7 Commitments related to the Policy for the protection of Human Rights of the Mediolanum Group S4-2 – Processes for engaging with consumers and end-users about impacts 3.4.8 Processes for engaging with consumers and end-users about impacts S4-3 – Processes to remediate negative impacts and channels for consumers and end-users to raise concerns 3.4.9 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns S4-4 – Taking action on material impacts on consumers and end-users, and approaches to mitigating material risks and pursuing material opportunities related to consumers and end- users, and effectiveness of those actions 3.4.2 Confidentiality, section ‘Actions’; 3.4.3 Access to (quality) information, section ‘Actions’; 3.4.4 Access to products and services, section ‘Actions’; 3.4.5 Responsible business practices, section ‘Actions’; 3.4.6 Freedom of expression, section ‘Actions’; 3.4.8 Processes for engaging with consumers and end-users about impacts
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132 | Mediolanum Group - Annual Financial Report 2025 Disclosure requirement Paragraph S4-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities 3.4.2 Confidentiality, section ‘Targets’; 3.4.3 Access to (quality) information, section ‘Targets’; 3.4.4 Access to products and services, section ‘Targets’; 3.4.5 Responsible business practices, section ‘Targets’; 3.4.6 Freedom of expression, section ‘Targets’ G1 – Business conduct ESRS 2 GOV-1 – Role of administrative, management and supervisory bodies 1.1.2 Governance, section ‘The role of the administrative, management and supervisory bodies’; ‘Sustainability- related skills and expertise of the bodies’ ESRS 2 IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities 1.1.4 Impact, risk and opportunity management, section ‘Description of the processes to identify and assess material impacts, risks and opportunities’ G1-1 – Corporate culture and business conduct policies 4.1.1 Corporate culture, section ‘The Group’s approach and policies’; 4.1.2 Protection of whistleblowers, section ‘The Group’s approach and policies’; 4.1.3 Management of relationships with suppliers including payment practices, section ‘The Group’s approach and policies’; 4.1.4 Bribery and corruption, section ‘The Group’s approach and policies’ G1-2 – Management of relationships with suppliers 4.1.3 Management of relationships with suppliers, including payment practices G1-3 – Prevention and detection of corruption and bribery 4.1.4 Bribery and corruption G1-4 – Confirmed incidents of corruption or bribery 4.1.5 Metrics, section ‘Confirmed incidents of bribery and corruption’ G1-6 – Payment practices 4.1.5 Metrics, section ‘Payment Practices’ [IRO-2 DP 59]
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133 | Mediolanum Group - Annual Financial Report 2025 The Mediolanum Group reports significant information on impacts, risks and opportunities (IROs) assessed as material on the basis of the reporting obligations related to the specific sustainability matters to which the IROs are connected (see ESRS 1 AR 16). With regard to material IROs associated with entity-specific topics for the organisation, the Group discloses information on policies, actions, targets and metrics, where present. In general, the disclosures associated with the IROs are considered material if, during the double materiality assessment process, they obtain a materiality value above the established thresholds, while no additional thresholds or criteria are used to determine the disclosures to be reported.
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134 | Mediolanum Group - Annual Financial Report 2025 2. Environmental disclosures 2.1 Disclosure pursuant to Article 8 of Regulation 2020/852 (EU Taxonomy Regulation) The European Taxonomy, as defined by Regulation (EU) 2020/852 (EU Taxonomy Regulation), establishes a system for classifying environmentally sustainable economic activities from a climate and environmental perspective. This regulation, in Article 8, introduced disclosure obligations, as from 1 January 2022, for companies and financial market participants that are subject to the reporting obligation pursuant to the CSRD. This section meets precisely this requirement and, in accordance with the most recent regulations, provides a complete analysis for the purposes of assessing the (on- and off-balance sheet) assets of the Mediolanum Group. In particular, the approach adopted for representing the Taxonomy KPIs connected to each of the business activities carried out by Group is explained below. According to the European Taxonomy, economic activities can be considered as: non-eligible: when not described in the Delegated Regulations adopted to indicate the technical screening criteria that make it possible to define an activity as environmentally sustainable; eligible: when described in the Delegated Regulations adopted to indicate the technical screening criteria, regardless of whether they meet one or all of the criteria; environmentally sustainable (hereinafter also ‘aligned’): when, in addition to being described in the aforementioned Delegated Regulations, the economic activities meet all the requirements of Article 3 of Regulation (EU) 2020/852, i.e. they: o contribute to at least one of the six environmental objectives20 (substantial contribution criterion); o do no significant harm to any of the other environmental objectives (Do No Significant Harm criterion, hereinafter DNSH); o operate in full compliance with the minimum guarantees of social protection. Details regarding the methodology and indicators to be used for the reporting required under the Taxonomy Regulation are explained in Delegated Regulation (EU) 2021/2178, recently amended by Commission Delegated Regulation (EU) 2026/73. This change, in line with the simplification of ESG disclosure defined at European level by the Omnibus Package, has been implemented with a view to improving and simplifying the process of reporting and calculating the Taxonomy KPIs for financial and non-financial institutions. Accordingly, the option is included for companies subject to the CSRD to identify the portion of ‘non-material’ activities that may be excluded from the taxonomic analysis, as they are below a materiality threshold. Therefore, starting from FY2025, each company may report pursuant to the Taxonomy by identifying aligned activities, activities that are eligible but not aligned, activities that are not eligible and are not material. The reporting methods for the 2025 Taxonomy that the Mediolanum Group has chosen, in accordance with Commission Delegated Regulation (EU) 2026/73 are set out below, in order to prepare a simplified report and anticipate the regulatory requests for subsequent years. As regards disclosures for credit institutions, these entities must report their eligibility and alignment with the six climate objectives set by the European Taxonomy on the basis of the indications in Annex V, and that the disclosure must be presented in table format using the Templates set out in Annex VI of the new Commission Delegated Regulation (EU) 2026/73. The key performance indicators (hereinafter also KPIs) to be published by these companies are: 20 The six environmental objectives described in Article 9 of the Taxonomy Regulation are: climate change mitigation (CCM), climate change adaptation (CCA), sustainable use and protection of water and marine resources (WTR), transition to a circular economy (CE), pollution prevention and control (PPC) and protection and restoration of biodiversity and ecosystems (BIO).
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135 | Mediolanum Group - Annual Financial Report 2025 the Green Asset Ratio (GAR), which indicates the proportion of assets in the financial statements, in the form of investments and financing, to taxonomy-aligned economic activities; KPIs for off-balance sheet exposures, which contribute to taxonomy-aligned economic activities related to: o financial guarantees in support of loans and advances, and other debt instruments to undertakings; o assets under management; o trading book21; o fees and commissions income from services other than loans and from asset management22. With regard to the obligations of insurance and reinsurance undertakings, Article 6 of Regulation (EU) 2021/2178 requires companies to report, on the basis of what is specified in Annex IX to the aforementioned Delegated Act; in this case, the disclosure must be presented in table format using the Templates set out in Annex X based on the following KPIs: The KPI for investments by insurance or reinsurance undertakings: calculated as the weighted average of investments directed at funding, or associated with, Taxonomy-aligned economic activities; The KPI relating to underwriting activities of insurance and reinsurance undertakings other than Life insurance undertakings: deriving from gross premiums written, corresponding to the Taxonomy-aligned insurance or reinsurance activities in accordance with points 10.1 and 10.2 of Annex II to the Delegated Climate Act23. Lastly, on the basis of the interpretative clarifications published in Commission Notice C/2024/6691 24, parent companies of financial conglomerates ‘should calculate and publish […] a consolidated KPI at Group level in the form of a weighted average of the corresponding KPIs for any banking, asset management, investment and insurance and reinsurance activities, with weighting factors calculated on the basis of the percentage of turnover from the activities in question as a percentage of the total consolidated turnover of the conglomerate’. For the year 2025, the Mediolanum Group exclusively reported the individual KPIs and the respective disclosure models provided for as a credit institution and insurance undertaking in a disaggregated way: the decision not to publish a consolidated KPI at Group level is due to the interpretative doubts that emerged during the preparation of the disclosures, with regard to the identification of the values to be used as weighting factors for the KPIs for the various lines of business. It should also be noted that, as in previous reporting years, the Group’s asset management activity is not reported using the models provided for financial asset managers, as it is included in the Disclosure Templates prepared respectively by the Mediolanum Banking Group (see KPIs for off-balance sheet reporting on managed financial assets) and by the Mediolanum Insurance Group (see KPIs on investments). 21 The publication of the KPI for the trading book and the KPI for fees and commissions income is expected from 1 January 2028. 22 See the previous note. 23 Regulation (EU) 2021/2139. 24 Question 7 of Commission Notice C/2024/6691 on the interpretation and implementation of certain legal provisions of the Disclosures Delegated Act under Article 8 of the EU Taxonomy Regulation on the reporting of Taxonomy-eligible and Taxonomy-aligned economic activities and assets (third Commission Notice), dated 08/11/2024.
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136 | Mediolanum Group - Annual Financial Report 2025 2.1.1 The Mediolanum Group’s approach to Taxonomy reporting In line with the information published in the previous year, for the 2025 Sustainability Report, the Mediolanum Group reports two separate Taxonomy disclosures referring, respectively, to: the Mediolanum Banking Group: which includes the scope of prudential consolidation based on the gross carrying amount of assets in the financial statement at 31/12/2025 and the value of off-balance sheet exposures at the same date; Mediolanum Insurance Group: which includes the companies Mediolanum Vita, Mediolanum International Life and Mediolanum Assicurazioni, based on the gross carrying amount of assets in the financial statements at 31/12/2025 and of off-balance sheet exposures at the same date, in relation to the KPI for investments, and the value of gross premiums written at 31/12/2025, in relation to the KPI for underwriting activities. For the year 2025, the Mediolanum Group calculated its key performance indicators (KPIs) using spot data in the Group’s accounting and management systems and information made available by its counterparties, including with the help of leading market info-providers. In particular, to calculate exposures that are included in the numerator of the Taxonomy KPIs, the Group identified the eligibility and alignment proportions as follows: in the case of loans, debt securities and equity instruments towards companies, exposures were weighted on the basis of the proportions of eligible and aligned turnover and capex declared by the counterparties in their respective CSRD reporting for each of the six environmental targets defined by the Taxonomy; In the case of exposures to investment funds, and as required by the regulations, the analysis concerned the underlying investments (the so-called look through approach), calculating the eligibility and alignment values as explained in the previous point; in the case of investments in securities classified as green bonds, the eligibility and alignment assessment is based on specific information provided by the issuer on the economic activities and projects for which the bond is intended; in the case of loans to households and underwriting, the Group directly verified the compliance of its loans and insurance products with the technical screening criteria required at regulatory level for the identification of taxonomy-aligned eligible economic activities. 2.1.2 Qualitative information to support the disclosure of the Banking Group Starting in previous years, the Mediolanum Group has adopted a number of initiatives to strengthen its commitment to offering customers products consistent with the environmental objectives set out in the Taxonomy Regulation, also ensuring that products with green characteristics which are marketed offer a tangible incentive for customers who wish to sign up for them. With this aim, the Group has launched a series of initiatives related to the contribution to the climate change mitigation and adaptation objectives, including: Mutuo Eco+: In 2019, Banca Mediolanum introduced to the catalogue the Mutuo Eco+ mortgage, a loan with a facilitated spread for buildings with high energy efficiency (EPC of C or higher) for the purposes of purchase, exchange, subrogation and restructuring transactions. During 2024, a promotion was activated for this product that completely eliminated valuation and application costs; Mutuo Mediolanum Bioedilizia+: The Mediolanum Bipedalities+ mortgage is a loan for the purposes of purchase and exchange transactions on property built according to specific sustainability standards with S.A.L.E. (Wood Construction Reliability System) certification, or ‘Casa Clima’ or Arca certification. Green houses are sustainably built according to environmentally friendly construction techniques, using natural certified materials and integrating energy efficiency systems. During 2025, €0.5 million of Mediolanum Bioedilizia+ Loans were granted; Hipotecas Freedom Green:
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137 | Mediolanum Group - Annual Financial Report 2025 Banco Mediolanum provides a catalogue for the Hipotecas Freedom Green product, which is a loan for the purchase of a house with EPC AB or higher. During 2025, €10.9 million of Hipotecas Freedom Green mortgages were granted. After-sales option of ‘Energy class improvement’: Since October 2023, in combination with the ‘Mutuo Mediolanum Casa+’ product, a loan has been available for renovation and refurbishment works on property units: an after-sales option through which the Bank issues a discount of 15 basis points of the spread applied if the property being renovated, at the end of the works, has improved by at least one energy class25. In January 2025, this discount was introduced on Mediolanum’s entire range of mortgage products. After-sales option of ‘Energy efficiency improvement’: Banca Mediolanum provides a catalogue of the ‘Prestito personale Casa+’ product, a personal loan dedicated to energy efficiency works on property units: an after-sales option through which the Bank issues a discount of 15 basis points of the spread applied if the customer, on completion of the works, delivers an invoice to the Bank showing the type of energy efficiency carried out on the building. Green BEES platform: As of September 2024, the entire Banca Mediolanum Sales Network has been using Green BEES (Building Energy Efficiency Simulator): this platform makes it possible to discover, with just a few steps, the energy performance of the property being examined and what renovation measures could improve it, thus increasing in the value of the property. The platform is useful to support customers who would like to undertake an energy upgrade of their property for which they need financing or want to take advantage of the tax deduction deriving from building bonuses. 2.1.3 Disclosures of the Banking Group: methodology and main results With regard to 2025, the legislation requires credit institutions to present key performance indicators in table format, using the templates set out in Annex VI to Regulation (EU) 2026/73, i.e.: Template 0 - Summary of KPIs: to be compiled showing the main euro countervalues and the % values for the main KPI and additional KPIs that credit institutions communicate pursuant to Article 8 of the Taxonomy Regulation; Template 1 - Assets for the calculation of the GAR: to be compiled showing the euro countervalues of on- and off-balance sheet exposures, with details of the exposures that are eligible and aligned with the environmental objectives set out in the Taxonomy regulation, based on turnover and capex. The template is published both with stock values at 31/12/2025 and with flow values, i.e. exposures relating solely to the 2025 financial year; Template 2 GAR – Sector information: the table contains evidence of the ten main exposures of the banking book to the ten main sectors to which the Bank is exposed, identified by the NACE code of the main activity of the counterparties. In addition, the proportion of eligible and aligned activities attributable to the nuclear energy and fossil gas sectors, with reference to the perimeter of the 10 main counterparties identified at sector level, should also be reported; • Template 3 GAR KPI (Stock): % values related to the GAR on the stock of eligible and aligned on-balance sheet exposures, calculated based on the information data disclosed in Template 1; • Template 4 GAR KPI flow: % values related to the GAR on the flow of eligible and aligned on-balance sheet exposures, calculated based on the information disclosed in Template 1; • Template 5 KPI off-balance sheet exposures: % values related to the KPI on the stock and flow of eligible and aligned off-balance sheet exposures. With regard to the stock data on KPIs for off-balance sheet exposures, the % values are calculated based on the data disclosed in Template 1. 25 In order to take advantage of the discount, the client must provide the EPC certification before and after works, in order to certify the actual improvement in terms of energy performance of the property.
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138 | Mediolanum Group - Annual Financial Report 2025 With the adoption of the new Regulation, the KPIs and templates provided for in Annex XII to the previous Commission Delegated Regulation (EU) 2021/2178 relating to activities in the fossil gas and nuclear energy sectors, as reported by the Bank in previous years, have been deleted; the information connected to these economic sectors is presented in a simplified form in Template 2. Each table is published in two versions: using capex, and then turnover, as the weighting factor for exposures to financial and non-financial undertakings. The details of the main results associated with the templates provided for in Regulation (EU) 2026/73 are set out below.
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139 | Mediolanum Group - Annual Financial Report 2025 Template 0: Summary of KPIs Disclosure reference date 31.12.2025 Total exposures to taxonomy-aligned assets (currency*) KPIs (%) KPIs (%) % of coverage (out of total assets) (%) Non-assessed exposures (% of assets covered) (%) Non-assessed exposures (% of assets covered) (%) Turnover-based CapEx-based Turnover-based CapEx-based Turnover-based CapEx-based Key KPI GAR for Stock 1,616.89 1,618.66 11.62% 11.64% 34.80% - - Total exposures to taxonomy-aligned assets (currency*) KPIs (%) KPIs (%) % of coverage (out of total assets) Non-assessed exposures (% of assets covered) (%) Non-assessed exposures (% of assets covered) (%) Turnover-based CapEx-based Turnover-based CapEx-based Turnover-based CapEx-based Additional KPIs GAR flow 361.44 363.14 13.90% 13.97% 5.51% - - Trading book Financial guarantees - - - - - - - Assets under management 1,462.16 2,186.38 10.05% 15.03% 28.29% - - Revenues from fees and commissions *The figures shown are expressed in millions of euros, in line with the remaining models of the Taxonomy.
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140 | Mediolanum Group - Annual Financial Report 2025 Template 0: Summary of KPIs T-1 Total environmentally sustainable assets (EUR million) Turnover-based KPIs Capex-based KPIs % of coverage (out of total assets) % of assets excluded from the GAR numerator for GAR (Article 7(2) and (3) and point 1.1.2 of Annex V) % of assets excluded from the GAR denominator (Article 7(1), and point 1.2.4 of Annex V) Turnover Capex Key KPI GAR for Stock 1,529.67 1,565.65 6.53% 6.69% 56.01% 22.12% 43.99% Total environmentally sustainable assets (EUR million) Turnover-based KPIs Capex-based KPIs % of coverage (out of total assets) % of assets excluded from the GAR numerator for GAR (Article 7(2) and (3) and point 1.1.2 of Annex V) % of assets excluded from the GAR denominator (Article 7(1), and point 1.2.4 of Annex V) Turnover Capex Additional KPIs GAR flow 233.42 234.33 1.00% 1.00% 56.01% 50.09% 43.99% Trading book Financial guarantees - - - - Assets under management 1,106.31 1,663.65 2.87% 4.31% Revenues from fees and commissions
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141 | Mediolanum Group - Annual Financial Report 2025 Template 0 provides a summary of the main KPIs represented in the templates provided for credit institutions. On the basis of the assets covered, which correspond to 34.80% (approximately €13,910.83 mln) of the consolidated assets of the Mediolanum Banking Group at 31/12/2025, the green asset ratio (GAR) in terms of stock for 2025 corresponds to the following: • 11.62% (approximately €1,616.89 mln), taking into account the KPIs relating to the turnover of counterparties for the purposes of the alignment assessment; • 11.64% (approximately €1,618.66 mln), taking into account the KPIs relating to the capex of counterparties for the purposes of the alignment assessment. In line with previous year, the assets that contribute to the calculation of the GAR numerator include both exposures to undertakings subject to CSRD, but above all exposures to household customers; the GAR numerator, in line with the core business of the Mediolanum Banking Group, mainly consists of the latter item, which contributes around €1,608.8 mln to the GAR (both turnover and capex). It should be noted that the increase in the numerator and the consequent improvement in the GAR compared to the previous year are mainly attributable to changes in the regulatory and methodological framework introduced by Commission Delegated Regulation (EU) 2026/73; the new calculation formula for the GAR provides for two important changes relating to the calculation of the numerator and the denominator of the KPI. The first concerns the inclusion of so-called ‘voluntary’ exposures in the numerator, which nevertheless are of little relevance for the Group in relation to FY2025. This item (in row 19 of Template 1) includes exposures aligned with undertakings that are not subject to the CSRD, but that voluntarily publish Taxonomy KPIs. The second amendment concerns the methodology for calculating the GAR denominator. This value, amounting to €13,910.8 million (34.8% of total assets), is determined by the sum of exposures to undertakings subject to the CSRD, exposures to undertakings that voluntarily publish the Taxonomy KPIs and exposures to households that can be analysed from the point of view of the Taxonomy (loans secured by properties, for the renovation of buildings and for motor vehicles)26. Compared to previous financial years, exposures to central governments, central banks and supranational issuers, as well as the trading book, cash and cash equivalents, interbank sight loans and all exposures to EU and non-EU undertakings not subject to the CSRD, were excluded from covered assets, included in the KPI denominator. The denominator therefore only includes total exposures among those that may be evaluated from the Taxonomy perspective, resulting in a significant reduction and a positive impact due to the increase in the percentage value of the GAR, in terms of both stock and flow. To confirm this, the internal analyses showed that, by recalculating the previous year’s GAR Stock using the new methodology described above, a percentage comparable to the results obtained for 2025 is reached, in both the Turnover and Capex versions. For off-balance sheet exposures, the KPI for assets under management (AUM KPI) in terms of stock for the 2025 financial year is equal to: • 10.05% (approximately €1,462.16 mln), taking into account the KPIs for turnover of the counterparties; • 15.03% (approximately €2,186.38 mln), taking into account the KPIs for capex of the counterparties. 26 The GAR denominator may also include exposure values relating to the following: Loans to local governments; collateral obtained through taking possession; other exposures included on a voluntary basis. These items are not included in the denominator by the Mediolanum Banking Group, as they amounted to 0 at 31/12/2025.
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142 | Mediolanum Group - Annual Financial Report 2025 The increase in these KPIs is connected to the regulatory changes to the calculation of the GAR mentioned above. Regarding the AUM KPI, the numerator includes investments aligned with undertakings subject to the CSRD or that voluntarily publish Taxonomy KPIs. Only total investments in these counterparties are included in the KPI denominator; all other investments in types of counterparties not included in the numerator are excluded from this exercise. With regard to the off-balance sheet KPI relating to financial guarantees (FinGar KPI), at 31/12/2025 there were no financial guarantees provided by the Mediolanum Group to counterparties that publish disclosures on their own proportion of eligibility and alignment with the Taxonomy. For this reason, this KPI is not applicable. Detailed information on compiling the Templates required pursuant to Annex VI to Commission Delegated Regulation (EU) 2026/73 is provided below. Template 1: Assets for the calculation of GAR For an easier understanding, the sections of Template 1 are shown below: 1. GAR - Covered assets in both numerator and denominator Assets in the financial statements at 31/12/2025 eligible for the calculation of the GAR, i.e. exposures (loans and advances, debt securities and equity instruments not held for trading) to financial and non-financial companies, households and local governments 27 and collateral obtained through taking possession of residential and non- residential properties. Starting from FY 2025, this section also includes exposures reported on a voluntary basis, within the meaning of Article 7(3) of Commission Delegated Regulation (EU) 2026/73. Starting from FY 2025, this section also includes exposures reported on a voluntary basis, within the meaning of Article 7(3) of Commission Delegated Regulation (EU) 2026/73. 2. Assets not included in the calculation of GAR: Assets in the financial statements as at 31/12/2025 that are not assessable in terms of eligibility and alignment with the Taxonomies and are therefore excluded from the calculation. 3. Off-balance sheet exposures: financial guarantees and financial assets managed with respect to undertakings subject to CSRD disclosure obligations and local public administrations. Details of the methodology used by the Group to verify the eligibility and alignment of exposures to households are provided below, including: Households - Loans secured by residential property This category includes loans for the purchase and possession of residential properties for which the Bank has a property guarantee. The Banking Group, already in previous years, took action to recover the information required to verify the criteria established by the EU Taxonomy with regard to activity ‘7.7 Construction of new buildings’ that contributes to the objective of climate change mitigation. In particular, the Group defined the following methodology applicable to the property portfolio of Banca Mediolanum and Banco Mediolanum: for the substantial contribution criterion, buildings with a high level of energy efficiency were considered, with careful assessment, according to the year of construction and the size of each building, of the energy class (A or higher), the primary energy demand (PED) and the requirements defined for nearly zero energy buildings (NZEB). In order to identify properties that meet the criterion of substantially contributing to the climate change mitigation objective, the Group considered the PED (‘top 15%’) and NZEB (‘90% NZEB’) threshold values, differentiated by climatic area, as reported in the document ‘Percentage distribution of primary energy (PE) values in the Italian national building stock’28; 27 In line with Commission Notice C/2024/6691 (Question 47), these items must only include exposures to local authorities that have purposes: this is not part of the Mediolanum Group’s business, and for this reason this item is not equal to 0 in the Disclosure Templates. 28 Report by CTI and CRIF, published 1/8/2022. The methodology described will be appropriately amended and/or supplemented following the publication of any updates on the thresholds related to the national building stock.
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143 | Mediolanum Group - Annual Financial Report 2025 for the DNSH criterion, the Group developed an assessment, supported by a specific information provider, of the physical risk to which financed properties are subject, in order to consider all the climate hazards identified by the legislation. Households - Building renovation loans This category includes loans for building renovations by the Banking Group’s customers. Loans for these types of purposes were therefore taken into account for the purposes of calculating eligibility, as they are mentioned in Regulation (EU) 2021/2178 as activities contributing to the objective of climate change mitigation29. For this year, the alignment figure with respect to these loans, currently a residual part of the Banking Group’s business, has not been published; for an understanding of the initiatives launched by the Group with regard to renovation loans, see the section entitled ‘Qualitative information to support the disclosure of the Banking Group’. Households - Motor vehicle loans This category includes loans for the purchase of motor vehicles by the Banking Group’s customer households. Loans for these types of purposes were therefore taken into account for the purposes of calculating eligibility, as they are mentioned in Regulation (EU) 2021/2178 as activities contributing to the objective of climate change mitigation30. However, for such exposures, the Bank does not have the information necessary to verify compliance with the criteria provided for in the Taxonomy regarding the calculation of alignment. In view of future reporting years and on the basis of changes in legislation relating to this specific type of activity, the Bank will assess the appropriateness and the methods of obtaining data to verify Taxonomy alignment, including with regard to such exposures. Template 2: GAR – Sector information The Model requires the inclusion of the top 10 exposures to undertakings at NACE sector level, providing the value of eligible and aligned exposures, together with the figure relating to the contribution to the Taxonomy by the economic activities of these undertakings connected with the Nuclear Energy and Fossil Gas sector (lines 11 and 12 of the Template). Template 3 – GAR KPI stock This template includes GAR KPIs on the stock of on-balance sheet exposures, starting from the stock data indicated in Template 1. Template 4 –GAR KPI flow This template includes GAR KPIs on the flow of on-balance sheet exposures generated during the reporting year, starting from the flow data indicated in Template 1. In continuity with the previous year, the flow figure is identified according to the instructions in Commission Communication C/2024/6691 31. Specifically, the methodology adopted by the Group is set out below: with regard to loans to businesses and households, the flow figure was calculated by analysing new loans granted relating to 2025, excluding any repayments made during the year; 29 Activity 7.2: ‘Renovation of existing buildings’. 30 Activity 6.5: ‘Transport by motorcycle, passenger cars and light commercial vehicles’ 31 See FAQ 65 of Commission Notice C/2024/6691 on the interpretation and implementation of certain legal provisions of the Disclosures Delegated Act under Article 8 of the EU Taxonomy Regulation on the reporting of Taxonomy-eligible and Taxonomy-aligned economic activities and assets (third Commission Notice).
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144 | Mediolanum Group - Annual Financial Report 2025 with regard to proprietary investments, the monthly statements from the accounting systems of the Banking Group were considered, in order to take into account only purchases of securities in the portfolio during the year and to exclude any disinvestments. Template 5 – KPI off-balance sheet exposures Within this template, the KPIs for off-balance sheet exposures (financial guarantees and assets under management) are reported, calculated on the basis of the data indicated in Template 1. In addition to the information already given with regard to the change in the denominator of off-balance sheet KPIs, Commission Communication C/2024/6691 defines a clear methodology to be used for the calculation of flow values for on-balance sheet exposures only. Since there is no further regulatory information available on how to assess and calculate the flow data for off-balance sheet exposures, and in particular for the KPI on managed financial assets, the Group determined that gross inflows of managed assets should be regarded as a flow32. 2.1.4 Disclosures of the Mediolanum Insurance Group: methodology and main results In order to fulfil the regulatory requirements, the Mediolanum Insurance Group is required to report: the proportion of investments directed at funding, or associated with, Taxonomy-aligned economic activities (investments KPI), taking into account the value of investments at 31/12/2025 within the perimeter of the Mediolanum Insurance Group; the proportion of Non-Life underwriting activities in terms of gross premiums written (KPI relating to underwriting activity), corresponding to Taxonomy-aligned (re)insurance activities in accordance with points 10.1 and 10.2 of Annex II to Regulation (EU) 2021/2139. In accordance with the regulatory framework, the information must be presented in table format, using the templates in Annex X to the new Commission Delegated Regulation (EU) 2026/73, which replaces the previous Commission Delegated Regulation (EU) 2021/2178. The disclosure for 2025 relating to the perimeter of the Mediolanum Insurance Group is provided below, with an analysis of the main results associated with the above- mentioned KPIs, in line with the new regulatory framework. Investment KPI The regulations require the analysis and reporting of the proportion of investments directed at funding, or associated with, Taxonomy-aligned economic activities: the scope of analysis concerns both direct investments of the insurance undertaking and investments held in relation to Life insurance contracts, the investment risk of which is borne by the policyholders. In particular, for the calculation of exposures that are included in the numerator of the investment KPI, the Group accurately identified the eligibility and alignment proportions of investments with undertakings subject to the CSRD, through the support of specialist infoproviders (see the section ‘The Mediolanum Group’s approach to Taxonomy reporting’). In line with the KPIs analysed for credit institutions, the main changes for the investment KPI concern the calculation of its numerator and denominator. Specifically: in addition to the aligned investments resulting from the analysis of undertakings subject to the CSRD, the numerator also includes investments aligned with undertakings that voluntarily publish Taxonomy KPIs (row 12 ‘Exposures included on a voluntary basis’ of Template 2); the KPI denominator, on the other hand, comprises only total investments in undertakings subject to the CSRD and in undertakings that voluntarily publish the Taxonomy KPIs, with reference to both the Insurance Group’s investments and investments related to life insurance contracts, the investment risk of which is borne by the policyholders. 32 The methodology described will be appropriately amended with the publication of further legislative updates on the subject.
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145 | Mediolanum Group - Annual Financial Report 2025 The FY 2025 result shows an alignment percentage calculated with reference to hedged financial assets (15.69% of the total value of managed financial assets) equal to: 8.11% (€644.4 mln) using the turnover KPI published by the individual counterparties for the weighting of exposures to undertakings; 12.41% (€986.3 mln) using the capex KPI published by the individual counterparties for the weighting of exposures to undertakings. The increase in the KPI for investments compared to the values indicated in disclosure 202433 is partly explained by the increase in the values of alignment with the numerator, related to a greater exposure to CSRD counterparties (+€497 mln) and the proportion of investment in companies that voluntarily publish the Taxonomy KPIs (+€39 mln). However, the greatest impact on results derives from the change in the calculation of the denominator, which - in the previous year - included all investments in undertakings, both EU and non-EU. This change led to a significant reduction in the denominator on the 2025 results of the KPI relating to investments and, consequently, a positive impact on the increase in the percentage value of the KPI, in terms of both stock and flow. KPI related to underwriting activities The proportion of gross premiums written deriving from the Taxonomy-eligible and Taxonomy-aligned Non-Life underwriting activity is shown below. The (re)insurance business is considered to be an economic activity that potentially makes a substantial contribution to the objective of climate change adaptation. Specifically, for the purposes of the eligibility assessments, insurance and reinsurance undertakings are required to verify that both of the following requirements are met34: the insurance services fall within the following perimeter (Line of Business): o medical expenses insurance; o income protection insurance; o workers’ compensation insurance; o maritime, aviation and transport insurance; o fire and other damage to property insurance; o assistance35. the underwriting activity is connected to climate-related hazards, as set out in Appendix A, Annex II to Regulation (EU) 2021/2139. In accordance with previous disclosures, an in-depth analysis was carried out in order to accurately identify the proportion of non-life premiums to be considered eligible, as they are attributable to one of the lines of business identified by the Taxonomy and connected to the underwriting of climate-related hazards. For this activity, specific drivers within the Mediolanum Insurance Group were implemented and also used for the purposes of the periodic requests of the National Supervisory Authority (IVASS), through which it is possible to identify the proportion of premiums covering climate-related risks. This approach identifies a proportion of eligibility equal to 7.97% ( €12.97 mln) of total premium income, in particular attributable to the Ministerial Class 8 – Fire and Natural Forces and Class 9 – Other Damage to Property. With reference to the proportion of Taxonomy-aligned premiums for FY2025, following analyses of the technical screening criteria indicated by Regulation (EU) 2021/2139 (Annex II, points 10.1 and 10.2), the alignment KPI for underwriting was equal to 0, as there are no insurance premiums relating to taxonomy-aligned activities. 33 Equal to 1.37% with respect to turnover and 2.19% with respect to capital expenditure. 34 In accordance with Regulation (EU) 2021/2139, Annex II, point 10.1. 35 Civil liability insurance arising from the circulation of motor vehicles and other motor insurance, although included in the legislation among potentially eligible/aligned activities, is not material for the business of the Mediolanum Insurance Group.
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146 | Mediolanum Group - Annual Financial Report 2025 2.1.5 Disclosures pursuant to Annex VI of Commission Delegated Regulation 2026/73 This section contains the reporting referred to the 2025 financial year on the proportions of Taxonomy-aligned on-balance sheet and off-balance sheet assets for the Mediolanum Banking Group, prepared on the basis of the Templates in Annex VI to Commission Delegated Regulation (EU) 2026/73. All the values in the following Templates are expressed in millions of euro and in % values. Within the Templates, the cells are valued with a dash (‘-’) in the case of values equal to 0, in order to facilitate the reading of the information. If, on the other hand, the value for a specific cell is greater than 0 but is not visible in percentage terms or in millions of euro, the cell is valued with ‘0.00’. Unlike the previous year, the templates provided for by the regulations show ‘exposures included on a voluntary basis’ and ‘non-assessed exposures’. As indicated above, exposures included on a voluntary basis comprise exposures to undertakings that, although not directly subject to the CSRD, publish Taxonomy KPIs on a voluntary basis. Non-assessed exposures, on the other hand, include exposures that have not been considered material by the Mediolanum Group or by the counterparties that the Group finances or in which it invests. In the first case, the Group considered it more appropriate, in line with previous years, to analyse all assets on and off the balance sheet, and did not opt this year for the possibility to exclude some potentially non-material exposures. Instead, the second may be applied starting from the 2025 reporting of counterparty undertakings and will therefore be included in the 2026 Taxonomy disclosure of the Mediolanum Group. For these reasons, the sections of the Templates relating to ‘non-assessed exposures’ were not compiled for the current financial year.
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147 | Mediolanum Group - Annual Financial Report 2025 Template 1 – Assets for the calculation of GAR [Capex Weighting] Stock Disclosure reference date 31.12.2025 Stock million EUR a b c d e f g h i j k l m n o p Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) Non- assessed exposures Of which financing non- material activities of counterparties Of which exposures financing counterparties reporting in accordance with Article 7(9) Of which not assessed considered non- material by the credit institution 1 GAR – Covered assets in both numerator and denominator 13,910.83 11,041.86 1,618.66 1,618.57 0.09 0.00 0.00 0.00 0.00 1,608.97 0.29 2.34 - - - - 2 Loans and advances, debt securities and equity instruments not held for trading eligible for GAR calculation 13,910.80 11,041.85 1,618.66 1,618.57 0.09 0.00 0.00 0.00 0.00 1,608.97 0.29 2.34 - - - - 3 Financial undertakings 381.10 54.50 9.15 9.08 0.06 0.00 0.00 0.00 0.00 0.09 0.28 1.88 - - - - 4 Loans and advances 17.50 3.74 0.07 0.07 - 0.00 - - - - 0.05 0.00 - - - - 5 Debt securities, including use of proceeds 363.60 50.76 9.08 9.01 0.06 0.00 0.00 0.00 0.00 0.09 0.23 1.88 - - - - 6 Equity instruments - - - - - - - - - - - - - - - 7 Non-financial undertakings 11.80 1.51 0.71 0.68 0.03 0.00 0.00 0.00 - 0.07 0.01 0.46 - - - 8 Loans and advances 9.70 0.72 0.36 0.36 - - - - - - - 0.29 - - - 9 Debt securities, including use of proceeds 2.10 0.79 0.35 0.32 0.03 0.00 0.00 0.00 - 0.07 0.01 0.17 - - - 10 Equity instruments - - - - - - - - - - - - - - 11 Households 13,517.90 10,985.84 1,608.80 1,608.80 - - 1,608.80 - - - - - 12 of which loans collateralised by residential immovable property 13,108.73 10,576.67 1,608.80 1,608.80 - - 1,608.80 - - - - - 13 of which building renovation loans 118.48 118.48 - - - - - - - - - - 14 of which motor vehicle loans 290.69 290.69 - - - - - - - - 15 Local government financing - - - - - - - - - - - - - - - 16 Housing financing - - - - - - - - - - - - 17 Other local government financing - - - - - - - - - - - - - - - 18 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - - - 19 Exposures included on a voluntary basis 0.03 0.02 0.00 0.00 - 0.00 - 0.00 0.00 - - 20 Total GAR assets 13,910.83 - - - -
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148 | Mediolanum Group - Annual Financial Report 2025 Disclosure reference date 31.12.2025 Stock million EUR a b c d e f g h i j k l m n o p Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) Non- assessed exposures Of which financing non- material activities of counterparties Of which exposures financing counterparties reporting in accordance with Article 7(9) Of which not assessed considered non- material by the credit institution 21 Assets not included in GAR calculation 26,066.81 22 Central governments and supranational issuers 14,715.06 23 Central banks exposure 343.94 24 Trading book 300.85 25 Undertakings and entities not subject to CSRD 1,938.94 26 SMEs and undertakings (other than SMEs) not subject to CSRD disclosure obligations 1,912.11 27 Loans and advances 1,817.51 28 of which loans collateralised by commercial immovable property 155.58 29 of which building renovation loans 0.38 30 Debt securities 64.28 31 Equity instruments 30.32 32 Non-EU country counterparties not subject to CSRD disclosure obligations 26.83 33 Loans and advances 0.00 34 Debt securities 22.11 35 Equity instruments 4.72 36 Derivatives - 37 On demand interbank loans 65.99 38 Cash and cash equivalents 3.35 39 Other categories of assets (e.g. Goodwill, commodities etc.) 8,698.67 40 Total assets 39,977.64 Off-balance sheet exposures (stock) to Undertakings subject to CSRD disclosure obligations and local governments 41 Financial guarantees - - - - - - - - - - - - - - - - 42 Assets under management 14,547.77 5,591.26 2,186.38 2,033.85 89.87 21.74 32.69 8.05 0.18 347.61 128.5 913.89 - - - - 43 Of which debt securities 7,890.43 2,708.85 1,301.86 1,175.64 85.67 11.08 22.73 6.62 0.11 347.61 73.83 394.99 - - - - 44 Of which equity instruments 6,657.34 2,882.40 884.52 858.21 4.19 10.66 9.96 1.43 0.07 - 54.66 518.90 - - - -
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149 | Mediolanum Group - Annual Financial Report 2025 Template 1 – Assets for the calculation of GAR [Turnover Weighting] Stock Disclosure reference date 31.12.2025 Stock million EUR a b c d e f g h i j k l m n o p Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) Non- assessed exposures Of which financing non- material activities of counterparties Of which exposures financing counterparties reporting in accordance with Article 7(9) Of which not assessed considered non- material by the credit institution 1 GAR – Covered assets in both numerator and denominator 13,910.83 11,037.15 1,616.89 1,616.84 0.04 0.00 0.01 0.00 - 1,608.97 0.17 1.59 - - - - 2 Loans and advances, debt securities and equity instruments not held for trading eligible for GAR calculation 13,910.80 11,037.14 1,616.89 1,616.84 0.04 0.00 0.01 0.00 - 1,608.97 0.17 1.59 - - - - 3 Financial undertakings 381.10 49.30 7.54 7.53 0.01 0.00 0.00 0.00 - 0.09 0.16 1.46 - - - - 4 Loans and advances 17.50 0.02 0.00 0.00 0.00 - - - - - 0.00 0.00 - - - - 5 Debt securities, including use of proceeds 363.60 49.29 7.54 7.53 0.01 0.00 0.00 0.00 - 0.09 0.16 1.46 - - - - 6 Equity instruments - - - - - - - - - - - - - - 7 Non-financial undertakings 11.80 2.00 0.55 0.51 0.03 0.00 0.01 0.00 - 0.07 0.01 0.13 - - - 8 Loans and advances 9.70 1.22 0.26 0.26 - - - - - - - - - - - 9 Debt securities, including use of proceeds 2.10 0.77 0.28 0.25 0.03 0.00 0.01 0.00 - 0.07 0.01 0.13 - - - 10 Equity instruments - - - - - - - - - - - - - - 11 Households 13,517.90 10,985.84 1,608.80 1,608.80 - - 1,608.80 - - - - - 12 of which loans collateralised by residential immovable property 13,108.73 10,576.67 1,608.80 1,608.80 - - 1,608.80 - - - - - 13 of which building renovation loans 118.48 118.48 - - - - - - - - - - 14 of which motor vehicle loans 290.69 290.69 - - - - - - - - 15 Local government financing - - - - - - - - - - - - - - - 16 Housing financing - - - - - - - - - - - - 17 Other local government financing - - - - - - - - - - - - - - - 18 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - - - 19 Exposures included on a voluntary basis 0.03 0.02 0.00 0.00 - - - - - - 0.00 0.00 - - 20 Total GAR assets 13,910.83 - - - -
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150 | Mediolanum Group - Annual Financial Report 2025 Disclosure reference date 31.12.2025 Stock million EUR a b c d e f g h i j k l m n o p Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) Non- assessed exposures Of which financing non-material activities of counterparties Of which exposures financing counterparties reporting in accordance with Article 7(9) Of which not assessed considered non- material by the 21 Assets not included in GAR calculation 26,066.81 22 Central governments and supranational issuers 14,715.06 23 Central banks exposure 343.94 24 Trading book 300.85 25 Undertakings and entities not subject to CSRD 1,938.94 26 SMEs and undertakings (other than SMEs) not subject to CSRD disclosure obligations 1,912.11 27 Loans and advances 1,817.51 28 of which loans collateralised by commercial immovable property 155.58 29 of which building renovation loans 0.38 30 Debt securities 64.28 31 Equity instruments 30.32 32 Non-EU country counterparties not subject to CSRD disclosure obligations 26.83 33 Loans and advances 0.00 34 Debt securities 22.11 35 Equity instruments 4.72 36 Derivatives - 37 On demand interbank loans 65.99 38 Cash and cash equivalents 3.35 39 Other categories of assets (e.g. Goodwill, commodities etc.) 8,698.67 40 Total assets 39,977.64 Off-balance sheet exposures (stock) to Undertakings subject to CSRD disclosure obligations and local governments 41 Financial guarantees - - - - - - - - - - - - - - - - 42 Assets under management 14,547.77 4,753.60 1,462.16 1,378.94 21.99 14.86 39.26 7.10 - 347.61 94.78 550.29 - - - - 43 Of which debt securities 7,890.43 2,293.31 918.37 864.10 19.08 9.24 19.95 5.99 - 347.61 54.98 221.17 - - - - 44 Of which equity instruments 6,657.34 2,460.29 543.79 514.84 2.91 5.61 19.31 1.11 - - 39.81 329.11 - - - -
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151 | Mediolanum Group - Annual Financial Report 2025 Template 1 – Assets for the calculation of GAR [Capex Weighting] Flow Disclosure reference date 31.12.2025 Flow million EUR a b c d e f g h i j k l m n o p Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) Non- assessed exposures Of which financing non- material activities of counterparties Of which exposures financing counterparties reporting in accordance with Article 7(9) Of which not assessed considered non- material by the credit institution 1 GAR – Covered assets in both numerator and denominator 2,600.36 1,877.52 363.14 363.08 0.06 0.00 0.00 - 0.00 355.15 0.23 2.22 - - - - 2 Loans and advances, debt securities and equity instruments not held for trading eligible for GAR calculation 2,600.36 1,877.52 363.14 363.08 0.06 0.00 0.00 - 0.00 355.15 0.23 2.22 - - - - 3 Financial undertakings 253.03 37.73 7.85 7.79 0.06 0.00 0.00 - 0.00 0.35 0.23 1.85 - - - - 4 Loans and advances - - - - - - - - - - - - - - - - 5 Debt securities, including use of proceeds 253.03 37.73 7.85 7.79 0.06 0.00 0.00 - 0.00 0.35 0.23 1.85 - - - - 6 Equity instruments - - - - - - - - - - - - - - - 7 Non-financial undertakings 3.54 1.57 0.49 0.49 0.00 - - - - - 0.00 0.37 - - - 8 Loans and advances - - - - - - - - - - - - - - - 9 Debt securities, including use of proceeds 3.54 1.57 0.49 0.49 0.00 - - - - - 0.00 0.37 - - - 10 Equity instruments - - - - - - - - - - - - - - 11 Households 2,343.80 1,838.22 354.80 354.80 - - 354.80 - - - - - 12 of which loans collateralised by residential immovable property 2,157.14 1,651.56 354.80 354.80 - - 354.80 - - - - - 13 of which building renovation loans 25.52 25.52 - - - - - - - - - - 14 of which motor vehicle loans 161.14 161.14 - - - - - - - - 15 Local government financing - - - - - - - - - - - - - - - 16 Housing financing - - - - - - - - - - - - 17 Other local government financing - - - - - - - - - - - - - - - 18 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - - - 19 Exposures included on a voluntary basis - - - - - - - - - - - 20 Total GAR assets 2,600.36 - - - - - - - - -
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152 | Mediolanum Group - Annual Financial Report 2025 Disclosure reference date 31.12.2025 Flow million EUR a b c d e f g h i j k l m n o p Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) Non- assessed exposures Of which financing non- material activities of counterparties Of which exposures financing counterparties reporting in accordance with Article 7(9) Of which not assessed considered non- material by the credit institution 21 Assets not included in GAR calculation 44,566.67 22 Central governments and supranational issuers 4,503.20 23 Central banks exposure 32,922.24 24 Trading book 6,400.58 25 Undertakings and entities not subject to CSRD 487.82 26 SMEs and undertakings (other than SMEs) not subject to CSRD disclosure obligations 453.69 27 Loans and advances 399.07 28 of which loans collateralised by commercial immovable property 77.10 29 of which building renovation loans 0.33 30 Debt securities 54.63 31 Equity instruments - 32 Non-EU country counterparties not subject to CSRD disclosure obligations 34.13 33 Loans and advances - 34 Debt securities 34.13 35 Equity instruments - 36 Derivatives - 37 On demand interbank loans - 38 Cash and cash equivalents 0.53 39 Other categories of assets (e.g. Goodwill, commodities etc.) 252.30 40 Total assets 47,167.04 Off-balance sheet exposures (flow) to Undertakings subject to CSRD disclosure obligations and local governments 41 Financial guarantees - - - - - - - - - - - - - - - - 42 Assets under management 4,179.62 1,484.61 581.01 533.19 28.28 3.58 12.75 3.16 0.05 136.03 42.17 197.58 - - - - 43 Of which debt securities 3,266.84 1,088.44 471.60 426.61 27.88 2.76 11.33 2.97 0.04 136.03 35.10 132.23 - - - - 44 Of which equity instruments 912.78 396.17 109.41 106.58 0.41 0.82 1.41 0.18 0.01 - 7.07 65.35 - - - -
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153 | Mediolanum Group - Annual Financial Report 2025 Template 1 – Assets for the calculation of GAR [Turnover Weighting] Flow Disclosure reference date 31.12.2025 Flow million EUR a b c d e f g h i j k l m n o p Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) Non- assessed exposures Of which financing non- material activities of counterparties Of which exposures financing counterparties reporting in accordance with Article 7(9) Of which not assessed considered non- material by the credit institution 1 GAR – Covered assets in both numerator and denominator 2,600.36 1,876.34 361.44 361.41 0.01 0.00 0.02 - - 355.15 0.34 1.92 - - - - 2 Loans and advances, debt securities and equity instruments not held for trading eligible for GAR calculation 2,600.36 1,876.34 361.44 361.41 0.01 0.00 0.02 - - 355.15 0.34 1.92 - - - - 3 Financial undertakings 253.03 36.66 6.41 6.40 0.01 0.00 0.00 - - 0.35 0.34 1.75 - - - - 4 Loans and advances - - - - - - - - - - - - - - - - 5 Debt securities, including use of proceeds 253.03 36.66 6.41 6.40 0.01 0.00 0.00 - - 0.35 0.34 1.75 - - - - 6 Equity instruments - - - - - - - - - - - - - - - 7 Non-financial undertakings 3.54 1.46 0.23 0.21 0.00 0.00 0.02 - - - 0.00 0.17 - - - 8 Loans and advances - - - - - - - - - - - - - - - 9 Debt securities, including use of proceeds 3.54 1.46 0.23 0.21 0.00 0.00 0.02 - - - 0.00 0.17 - - - 10 Equity instruments - - - - - - - - - - - - - - 11 Households 2,343.80 1,838.22 354.80 354.80 - - 354.80 - - - - - 12 of which loans collateralised by residential immovable property 2,157.14 1,651.56 354.80 354.80 - - 354.80 - - - - - 13 of which building renovation loans 25.52 25.52 - - - - - - - - - - 14 of which motor vehicle loans 161.14 161.14 - - - - - - - - 15 Local government financing - - - - - - - - - - - - - - - 16 Housing financing - - - - - - - - - - - - 17 Other local government financing - - - - - - - - - - - - - - - 18 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - - - 19 Exposures included on a voluntary basis - - - - - - - - - - - 20 Total GAR assets 2,600.36 - - - -
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154 | Mediolanum Group - Annual Financial Report 2025 Disclosure reference date 31.12.2025 Flow million EUR a b c d e f g h i j k l m n o p Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) Non- assessed exposures Of which financing non- material activities of counterparties Of which exposures financing counterparties reporting in accordance with Article 7(9) Of which not assessed considered non- material by the credit institution 21 Assets not included in GAR calculation 44,566.67 22 Central governments and supranational issuers 4,503.20 23 Central banks exposure 32,922.24 24 Trading book 6,400.58 25 Undertakings and entities not subject to CSRD 487.82 26 SMEs and undertakings (other than SMEs) not subject to CSRD disclosure obligations 453.69 27 Loans and advances 399.07 28 of which loans collateralised by commercial immovable property 77.10 29 of which building renovation loans 0.33 30 Debt securities 54.63 31 Equity instruments - 32 Non-EU country counterparties not subject to CSRD disclosure obligations 34.13 33 Loans and advances - 34 Debt securities 34.13 35 Equity instruments - 36 Derivatives - 37 On demand interbank loans - 38 Cash and cash equivalents 0.53 39 Other categories of assets (e.g. Goodwill, commodities etc.) 252.30 40 Total assets 47,167.04 Off-balance sheet exposures (flow) to Undertakings subject to CSRD disclosure obligations and local governments 41 Financial guarantees - - - - - - - - - - - - - - - - 42 Assets under management 4,179.62 1,311.22 420.35 391.69 10.78 2.10 12.81 2.97 - 136.03 29.77 119.19 - - - - 43 Of which debt securities 3,266.84 959.72 351.51 326.53 10.49 1.67 10.01 2.82 - 136.03 25.15 74.71 - - - - 44 Of which equity instruments 912.78 351.49 68.84 65.17 0.30 0.43 2.80 0.15 - - 4.62 44.47 - - - -
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155 | Mediolanum Group - Annual Financial Report 2025 Template 2: GAR - Sector Information [Capex Weighting] Disclosure reference date 31.12.2025 a b c d e f g h i j Breakdown by sector - NACE 4 digits level (code and label) (million EUR) Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 K64.1.9 - Other monetary intermediation 142.80 - - - - - - - - 2 H53.00 - Other postal and courier activities 9.70 0.72 0.36 0.36 - - - - - 3 B06.10 - Extraction of crude petroleum 0.27 - - - - - - - - 4 H52.2.3 - Service activities incidental to air transportation 0.26 0.03 0.03 0.03 - - - - - 5 C29.10 - Manufacture of motor vehicles 0.19 - - - - - - - - 6 H51.1.0 - Passenger air transport 0.16 - - - - - - - - 7 K66.1.9 - Other activities auxiliary to financial services, except insurance and pension funding 0.16 0.00 0.00 0.00 - - - - - 8 C26.30 - Manufacture of communication equipment 0.15 - - - - - - - - 9 F42.22 - Construction of utility projects for electricity and telecommunications 0.14 0.00 0.00 0.00 0.00 - - - - 10 D35.10 - Electric power generation, transmission and distribution 0.13 0.11 0.11 0.11 - - - - - 11 Nuclear activities 36 0.26 0.00 0.00 12 Fossil gas activities 37 0.26 - - 13 Of which non-assessed exposures - 36 Referred to in Annexes I and II, sections 4.26, 4.27 and 4.28 of Commission Delegated Regulation 2021/2139. 37 Referred to in Annexes I and II, sections 4.29, 4.30 and 4.31 of Commission Delegated Regulation 2021/2139.
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156 | Mediolanum Group - Annual Financial Report 2025 Template 2: GAR - Sector Information [Turnover Weighting] Disclosure reference date 31.12.2025 a b c d e f g h i j Breakdown by sector - NACE 4 digits level (code and label) (million EUR) Total (gross) carrying amount Of which Taxonomy- eligible Of which Taxonomy- aligned Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 K64.1.9 - Other monetary intermediation 142.80 - - - - - - - - 2 H53.00 - Other postal and courier activities 9.70 1.22 0.26 0.26 - - - - - 3 B06.10 - Extraction of crude petroleum 0.27 - - - - - - - - 4 H52.2.3 - Service activities incidental to air transportation 0.26 0.06 0.06 0.06 - - - - - 5 C29.10 - Manufacture of motor vehicles 0.19 0.01 0.01 0.01 - - - - - 6 H51.1.0 - Passenger air transport 0.16 - - - - - - - - 7 K66.1.9 - Other activities auxiliary to financial services, except insurance and pension funding 0.16 - - - - - - - - 8 C26.30 - Manufacture of communication equipment 0.15 0.00 0.00 - - - 0.00 - - 9 F42.22 - Construction of utility projects for electricity and telecommunications 0.14 0.00 0.00 0.00 0.00 0.00 - - - 10 D35.10 - Electric power generation, transmission and distribution 0.13 0.05 0.05 0.05 - - - - - 11 Nuclear activities 38 0.26 0.00 0.00 12 Fossil gas activities 39 0.26 0.00 0.00 13 Of which non-assessed exposures - 38 Referred to in Annexes I and II, sections 4.26, 4.27 and 4.28 of Commission Delegated Regulation 2021/2139. 39 Referred to in Annexes I and II, sections 4.29, 4.30 and 4.31 of Commission Delegated Regulation 2021/2139.
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157 | Mediolanum Group - Annual Financial Report 2025 Model 3: GAR KPI [Capex Weighting] Stock Disclosure reference date 31.12.2025 % (compared to corresponding total covered assets in the denominator) a b c d e f g h i j k l m Taxonomy eligible Proportion of taxonomy aligned in taxonomy eligible Non- assessed exposures Taxonomy aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 GAR - Covered assets in both numerator and denominator 79.38% 11.64% 11.64% 0.00% 0.00% 0.00% 0.00% 0.00% 11.57% 0.00% 0.02% 14.66% - 2 Loans and advances, debt securities and equity instruments not held for trading eligible for GAR calculation 79.38% 11.64% 11.64% 0.00% 0.00% 0.00% 0.00% 0.00% 11.57% 0.00% 0.02% 14.66% - 3 Financial undertakings 0.39% 0.07% 0.07% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.08% - 4 Loans and advances 0.03% 0.00% 0.00% - 0.00% - - - - 0.00% 0.00% 0.00% - 5 Debt securities, including use of proceeds 0.36% 0.07% 0.06% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.01% 0.08% - 6 Equity instruments - - - - - - - - - - - - 7 Non-financial undertakings 0.01% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% - 0.00% 0.00% 0.00% 0.01% - 8 Loans and advances 0.01% 0.00% 0.00% - - - - - - - 0.00% 0.00% - 9 Debt securities, including use of proceeds 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% - 0.00% 0.00% 0.00% 0.00% - 10 Equity instruments - - - - - - - - - - - - 11 Households 78.97% 11.57% 11.57% - - 11.57% - - 14.57% - 12 of which loans collateralised by residential immovable property 76.03% 11.57% 11.57% - - 11.57% - - 14.57% - 13 of which building renovation loans 0.85% - - - - - - - - - 14 of which motor vehicle loans 2.09% - - - - - - - 15 Local government financing - - - - - - - - - - - - - 16 Housing financing - - - - - - - - - - 17 Other local government financing - - - - - - - - - - - - - 18 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - 19 Exposures included on a voluntary basis 0.00% 0.00% 0.00% - 0.00% - 0.00% 0.00% 0.00% 20 GAR - Total GAR assets 79.38% 11.64% 11.64% 0.00% 0.00% 0.00% 0.00% 0.00% 11.57% 0.00% 0.02% 14.66% -
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158 | Mediolanum Group - Annual Financial Report 2025 Template 3: GAR KPI [Turnover Weighting] Stock Disclosure reference date 31.12.2025 % (compared to corresponding total covered assets in the denominator) a b c d e f g h i j k l m Taxonomy eligible Proportion of taxonomy aligned in taxonomy eligible Non- assessed exposures Taxonomy aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 GAR – Covered assets in both numerator and denominator 79.34% 11.62% 11.62% 0.00% 0.00% 0.00% 0.00% - 11.57% 0.00% 0.01% 14.65% - 2 Loans and advances, debt securities and equity instruments not held for trading eligible for GAR calculation 79.34% 11.62% 11.62% 0.00% 0.00% 0.00% 0.00% - 11.57% 0.00% 0.01% 14.65% - 3 Financial undertakings 0.35% 0.05% 0.05% 0.00% 0.00% 0.00% 0.00% - 0.00% 0.00% 0.01% 0.07% - 4 Loans and advances 0.00% 0.00% 0.00% 0.00% - - - - - 0.00% 0.00% 0.00% - 5 Debt securities, including use of proceeds 0.35% 0.05% 0.05% 0.00% 0.00% 0.00% 0.00% - 0.00% 0.00% 0.01% 0.07% - 6 Equity instruments - - - - - - - - - - - - 7 Non-financial undertakings 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% - 0.00% 0.00% 0.00% 0.00% - 8 Loans and advances 0.01% 0.00% 0.00% - - - - - - - - 0.00% - 9 Debt securities, including use of proceeds 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% - 0.00% 0.00% 0.00% 0.00% - 10 Equity instruments - - - - - - - - - - - - 11 Households 78.97% 11.57% 11.57% - - 11.57% - - 14.58% - 12 of which loans collateralised by residential immovable property 76.03% 11.57% 11.57% - - 11.57% - - 14.58% - 13 of which building renovation loans 0.85% - - - - - - - - - 14 of which motor vehicle loans 2.09% - - - - - - - 15 Local government financing - - - - - - - - - - - - - 16 Housing financing - - - - - - - - - - 17 Other local government financing - - - - - - - - - - - - - 18 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - 19 Exposures included on a voluntary basis 0.00% 0.00% 0.00% - - - 0.00% 0.00% 0.00% 20 GAR - Total GAR assets 79.34% 11.62% 11.62% 0.00% 0.00% 0.00% 0.00% - 11.57% 0.00% 0.01% 14.65% -
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159 | Mediolanum Group - Annual Financial Report 2025 Template 4: GAR KPI [Capex Weighting] Flow Disclosure reference date 31.12.2025 % (compared to corresponding total covered assets in the denominator) a b c d e f g h i j k l m Taxonomy eligible Proportion of taxonomy aligned in taxonomy eligible Non- assessed exposures Taxonomy aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 GAR – Covered assets in both numerator and denominator 72.20% 13.97% 13.96% 0.00% 0.00% 0.00% - 0.00% 13.66% 0.01% 0.09% 19.34% - 2 Loans and advances, debt securities and equity instruments not held for trading eligible for GAR calculation 72.20% 13.97% 13.96% 0.00% 0.00% 0.00% - 0.00% 13.66% 0.01% 0.09% 19.34% - 3 Financial undertakings 1.45% 0.30% 0.30% 0.00% 0.00% 0.00% - 0.00% 0.01% 0.01% 0.07% 0.42% - 4 Loans and advances - - - - - - - - - - - - - 5 Debt securities, including use of proceeds 1.45% 0.30% 0.30% 0.00% 0.00% 0.00% - 0.00% 0.01% 0.01% 0.07% 0.42% - 6 Equity instruments - - - - - - - - - - - - 7 Non-financial undertakings 0.06% 0.02% 0.02% 0.00% - - - - - 0.00% 0.01% 0.03% - 8 Loans and advances - - - - - - - - - - - - - 9 Debt securities, including use of proceeds 0.06% 0.02% 0.02% 0.00% - - - - - 0.00% 0.01% 0.03% - 10 Equity instruments - - - - - - - - - - - - 11 Households 70.69% 13.64% 13.64% - - 13.64% - - 18.90% - 12 of which loans collateralised by residential immovable property 63.51% 13.64% 13.64% - - 13.64% - - 18.90% - 13 of which building renovation loans 0.98% - - - - - - - - - 14 of which motor vehicle loans 6.20% - - - - - - - 15 Local government financing - - - - - - - - - - - - - 16 Housing financing - - - - - - - - - - 17 Other local government financing - - - - - - - - - - - - - 18 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - 19 Exposures included on a voluntary basis - - - - - - - - - 20 GAR - Total GAR assets 72.20% 13.97% 13.96% 0.00% 0.00% 0.00% - 0.00% 13.66% 0.01% 0.09% 19.34% -
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160 | Mediolanum Group - Annual Financial Report 2025 Template 4: GAR KPI [Weighting Turnover] Flow Disclosure reference date 31.12.2025 % (compared to corresponding total covered assets in the denominator) a b c d e f g h i j k l m Taxonomy eligible Proportion of taxonomy aligned in taxonomy eligible Non- assessed exposures Taxonomy aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 GAR - Covered assets in both numerator and denominator 72.16% 13.90% 13.90% 0.00% 0.00% 0.00% - - 13.66% 0.01% 0.07% 19.26% - 2 Loans and advances, debt securities and equity instruments not held for trading eligible for GAR calculation 72.16% 13.90% 13.90% 0.00% 0.00% 0.00% - - 13.66% 0.01% 0.07% 19.26% - 3 Financial undertakings 1.41% 0.25% 0.25% 0.00% 0.00% 0.00% - - 0.01% 0.01% 0.07% 0.34% - 4 Loans and advances - - - - - - - - - - - - - 5 Debt securities, including use of proceeds 1.41% 0.25% 0.25% 0.00% 0.00% 0.00% - - 0.01% 0.01% 0.07% 0.34% - 6 Equity instruments - - - - - - - - - - - - 7 Non-financial undertakings 0.06% 0.01% 0.01% 0.00% 0.00% 0.00% - - - 0.00% 0.01% 0.01% - 8 Loans and advances - - - - - - - - - - - - - 9 Debt securities, including use of proceeds 0.06% 0.01% 0.01% 0.00% 0.00% 0.00% - - - 0.00% 0.01% 0.01% - 10 Equity instruments - - - - - - - - - - - - 11 Households 70.69% 13.64% 13.64% - - 13.64% - - 18.91% - 12 of which loans collateralised by residential immovable property 63.51% 13.64% 13.64% - - 13.64% - - 18.91% - 13 of which building renovation loans 0.98% - - - - - - - - - 14 of which motor vehicle loans 6.20% - - - - - - - 15 Local government financing - - - - - - - - - - - - - 16 Housing financing - - - - - - - - - - 17 Other local government financing - - - - - - - - - - - - - 18 Collateral obtained by taking possession: residential and commercial immovable properties - - - - - - - - - - 19 Exposures included on a voluntary basis - - - - - - - - - 20 GAR - Total GAR assets 72.16% 13.90% 13.90% 0.00% 0.00% 0.00% - - 13.66% 0.01% 0.07% 19.26% -
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161 | Mediolanum Group - Annual Financial Report 2025 Template 5: KPI off-balance sheet exposures [Capex Weighting] Stock Disclosure reference date 31.12.2025 % (compared to corresponding total off-balance sheet assets) a b c d e f g h i j k j Taxonomy eligible Non- assessed exposures Taxonomy aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 Financial guarantees (FinGuar KPI) - - - - - - - - - - - - 2 Assets under management (AUM KPI) 38.43% 15.03% 13.98% 0.62% 0.15% 0.22% 0.06% 0.00% 2.39% 0.88% 6.28% - Template 5: KPI off-balance sheet exposures [Turnover Weighting] Stock Disclosure reference date 31.12.2025 % (compared to corresponding total off-balance sheet assets) a b c d e f g h i j k j Taxonomy eligible Non- assessed exposures Taxonomy aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 Financial guarantees (FinGuar KPI) - - - - - - - - - - - - 2 Assets under management (AUM KPI) 32.68% 10.05% 9.48% 0.15% 0.10% 0.27% 0.05% - 2.39% 0.65% 3.78% -
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162 | Mediolanum Group - Annual Financial Report 2025 Template 5: KPI off-balance sheet exposures [Capex Weighting] Flow Disclosure reference date 31.12.2025 % (compared to corresponding total off-balance sheet assets) a b c d e f g h i j k j Taxonomy eligible Non- assessed exposures Taxonomy aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 Financial guarantees (FinGuar KPI) - - - - - - - - - - - - 2 Assets under management (AUM KPI) 35.52% 13.90% 12.76% 0.68% 0.09% 0.30% 0.08% 0.00% 3.25% 1.01% 4.73% - Template 5: KPI off-balance sheet exposures [Turnover Weighting] Flow Disclosure reference date 31.12.2025 % (compared to corresponding total off-balance sheet assets) a b c d e f g h i j k j Taxonomy eligible Non- assessed exposures Taxonomy aligned Breakdown by environmental objective Of which use of proceeds Of which transitional Of which enabling Climate change mitigation (CCM) Climate change adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and ecosystems (BIO) 1 Financial guarantees (FinGuar KPI) - - - - - - - - - - - - 2 Assets under management (AUM KPI) 31.37% 10.06% 9.37% 0.26% 0.05% 0.31% 0.07% - 3.25% 0.71% 2.85% -
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163 | Mediolanum Group - Annual Financial Report 2025 2.1.6 Disclosures pursuant to Annex X of Commission Delegated Regulation 2026/73 This section contains the disclosure relating to the 2025 financial year on the proportions of taxonomy-aligned non-life investment and underwriting activities for the Mediolanum Insurance Group, prepared on the basis of the Templates in Annex X to Commission Delegated Regulation (EU) 2026/73. All the values in the following Templates are expressed in millions of euro and in % values. Within the Templates, the cells are valued with a dash (‘-’) in the case of values equal to 0, in order to facilitate the reading of the information. If, on the other hand, the value for a specific cell is greater than 0 but is not visible in percentage terms or in millions of euro, the cell is valued with ‘0.00’. Unlike the previous year, the templates provided for by the regulations show ‘exposures included on a voluntary basis’ and ‘non-assessed exposures’. As indicated above, exposures included on a voluntary basis comprise exposures to undertakings that, although not directly subject to the CSRD, publish Taxonomy KPIs on a voluntary basis. Non- assessed exposures, on the other hand, include exposures that have not been considered material by the Mediolanum Group or by the counterparties that the Group invests in. In the first case, the Group considered it more appropriate, in line with previous years, to analyse all gross premiums written and Assets Under Management, not opting this financial year for the possibility to exclude some potentially non-material exposures. Instead, the second may be applied starting from the 2025 reporting of counterparty undertakings and will therefore be included in the 2026 Taxonomy disclosure of the Group. For these reasons, the sections of the Templates relating to ‘non-assessed exposures’ were not compiled for the current financial year. Template 1: Underwriting KPI Disclosure reference period 31/12/2025 Economic activities: Non-life insurance and reinsurance underwriting activities Absolute premiums, year t (2025) Proportion of premiums, year t (2025) Absolute premiums, year t - 1 (2024) Proportion of premiums, year t-1 (2024) Currency % Currency % Taxonomy-aligned activities - - - - Nuclear activities40 - - - - Fossil gas activities41 - - - - Taxonomy-eligible activities 12.97 7.97% 9.52 7.14% Nuclear activities42 - - - - Fossil gas activities43 - - - - Non-assessed activities considered non-material - - - - Total 162.67 100.00% 133.30 100.00% 40 Referred to in Annexes I and II, sections 4.26, 4.27 and 4.28 of Commission Delegated Regulation 2021/2139. 41 Referred to in Annexes I and II, sections 4.29, 4.30 and 4.31 of Commission Delegated Regulation 2021/2139. 42 Referred to in Annexes I and II, sections 4.26, 4.27 and 4.28 of Commission Delegated Regulation 2021/2139. 43 Referred to in Annexes I and II, sections 4.29, 4.30 and 4.31 of Commission Delegated Regulation 2021/2139.
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164 | Mediolanum Group - Annual Financial Report 2025 Template 2: Investment KPI Disclosure reference period 31/12/2025 Exposures % Million EUR 1 Total AUM 100.00% 50,686.63 2 Assets covered by the KPI 15.69% 7,950.51 % of covered assets % Turnover based % CapEx based 3 Taxonomy Eligible 35.78% 40.67% 4 Nuclear activities44 0.13% 0.24% 5 Fossil gas activities45 0.89% 0.52% 6 Taxonomy Aligned 8.11% 12.41% 7 Undertakings subject to Articles 19a and 29a of Directive 2013/34/EU 7.89% 12.09% 8 - of which Non-financial undertakings 6.70% 10.74% 9 - of which Financial undertakings 1.19% 1.35% 10 Other covered counterparties and real estate assets - - 11 Investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders 0.08% 0.12% 12 Exposures included on a voluntary basis 0.13% 0.19% 13 Transitional activities 0.53% 0.78% 14 Enabling activities 3.87% 5.88% 15 Nuclear activities46 0.11% 0.10% 16 Fossil gas activities47 0.03% 0.03% Taxonomy aligned per objective % Turnover based % CapEx based 17 Climate change mitigation (CCM) 7.73% 11.89% 18 Climate change adaptation (CCA) 0.06% 0.27% 44 Referred to in Annexes I and II, sections 4.26, 4.27 and 4.28 of Commission Delegated Regulation 2021/2139. 45 Referred to in Annexes I and II, sections 4.29, 4.30 and 4.31 of Commission Delegated Regulation 2021/2139. 46 Referred to in Annexes I and II, sections 4.26, 4.27 and 4.28 of Commission Delegated Regulation 2021/2139. 47 Referred to in Annexes I and II, sections 4.29, 4.30 and 4.31 of Commission Delegated Regulation 2021/2139.
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165 | Mediolanum Group - Annual Financial Report 2025 19 Water and marine resources (WTR) 0.06% 0.08% 20 Circular economy (CE) 0.24% 0.12% 21 Pollution (PPC) 0.03% 0.03% 22 Biodiversity and ecosystems (BIO) - 0.00% 23 Non-assessed exposures - - 24 Exposures financing non-assessed non-material activities of counterparties - - 25 Exposures financing counterparties reporting in accordance with Article 7(9) to this Regulation48 - - 26 Non-assessed exposures considered non-material by the reporting entity - - Breakdown of covered assets % Million EUR 27 Undertakings subject to Articles 19a and 29a of Directive 2013/34/EU 94.03% 7,476.15 28 - of which Non-financial undertakings 58.49% 4,650.13 29 - of which Financial undertakings 35.55% 2,826.02 30 Other covered counterparties and real estate assets 0.66% 52.55 31 Investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders 2.05% 162.79 32 Exposures included on a voluntary basis 3.26% 259.01 48 Commission Delegated Regulation (EU) 2026/73.
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166 | Mediolanum Group - 2025 Annual Financial Report 2.2 ESRS E1 Climate change 2.2.1 Material impacts, risks and opportunities and their interaction with strategy and business model [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Adaptation to climate change/Climate change mitigation/Energy Generation of direct and indirect GHG energy emissions (Scopes 1 and 2) Actual negative impact Own operations Medium term Generation of indirect GHG emissions (Scope 3), in particular those attributable to counterparties included in own portfolio Actual negative impact Entire Value Chain Long term Contribution to counterparties’ adaptation to climate change through the provision of insurance products Potential positive impact Downstream Value Chain (Protection) Long term Increase in the market share of green mortgages, improvement in asset ‘quality’ and improvement in reputation, particularly towards the financial community (e.g. GAR) Opportunities Downstream Value Chain (Banking) Medium term Cost reduction / Economic savings due to the progressive digitalisation of processes and benefits in terms of efficiency, including environmental benefits (e.g. reduced paper use and fewer physical journeys) Opportunities Proprietary Operations, downstream Value Chain (Distribution Channels; Banking) Medium term Improving the Bank’s positioning as a player in the climate transition Opportunities Downstream Value Chain (Asset Management/ Investment) Medium term Physical and transition risks49 Risk Entire Value Chain See footnote [E1.SBM-3 DP 18] Taking into account the regulatory framework, the recommendations and instructions provided by the various international bodies and Supervisory Authorities in the assessment of the risks to which it is exposed, the Mediolanum Group identified and mapped the risks associated with climate change attributable to two risk factors: physical risks and transition risks. To this end, with reference to the identification of climate-related and environmental risk factors, the Group mainly relied on the contribution made by the European Central Bank within the framework of the ‘Guide on climate-related and environmental risks - Supervisory expectations relating to risk management and disclosure’. In fact, in the Guide, the ECB provides a list of risk drivers that, through specific transmission channels, cause climate-related and environmental risks to have an impact on the traditional risk categories of financial intermediaries. The table below shows the climate-related and environmental risk factors as defined by the supervisory bodies, in the context of the above Guide, and divided into physical risk and transition risk: 49For details on risks, see ESRS 2 ‘General disclosures’ section (see the paragraph ‘Impacts, risks and opportunities management’, disclosure requirement E1.IRO 1).
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167 | Mediolanum Group - 2025 Annual Financial Report Risk drivers Physical risk Transition risk Climate-related Environmental50 Climate-related Environmental Extreme weather events Chronic weather conditions Water stress Resource scarcity Biodiversity loss Pollution Other Regulatory policies Technology Market confidence Regulatory policies Technology Market confidence For further details on the process of identifying C&E risk factors and the transmission channels through which these factors occur for traditional risks (e.g. Credit Risk, Market Risk, Operational Risk, Compliance Risk, etc.), see the datapoint [E1.IRO-1 AR 11 a, 12 a]. [E1.SBM-3 DP 19 a] The Mediolanum Group uses the ICAAP as a tool to analyse its own business resilience, assessing the extent to which the impacts of stress test scenarios may affect the Group’s results of operations and financial position. With the help of this tool, Mediolanum measures the ability of the Group and its business model to respond to adverse market conditions (see ESRS 2 General disclosures, paragraph 1.1.3 Strategy, section ‘Impacts, risks and opportunities and their interaction with strategy and business model’, DP 48 f, for further details). With a view to managing ESG risks, following an overall evolution of the stress test framework, the ICAAP report sets out the methodological approach to identifying and classifying risks, broken down into the following operational stages: definition of the long-list of potential risks and analysis of applicability: at this stage an assessment is carried out in order to eliminate the risk categories not applicable with respect to the current/prospective operations of the Mediolanum Banking Group; materiality analysis: this stage involves calculating a materiality score in order to identify the material risk categories for the Group; impact analysis: this stage of the process aims to determine the potential impact that risk categories may have on internal capital, the balance sheet or the profit and loss account. In particular, the impact of the Climate factor was estimated starting from the worst climate scenario among those simulated in the ICAAP 2025. The methodological approach adopted for the purposes of risk mapping is described in the relevant Policy, introducing a more precise quantification of each risk considered to be material. In this context, in order to ensure compliance with regulatory requirements, the stress test framework was strengthened through the integration of climate risk. In particular, adverse weather scenarios were added and the effects on the assets under management portfolio (through a quantification of physical risk and transition risk), the retail loans portfolio (climate-adjusted LGD) and the proprietary securities portfolio were calculated. In implementing the ICAAP, a range of scenarios was considered with the aim of assessing the impact on the plan’s projections, as set out in the ICAAP 2025 Report, of shocks with various causes and modes of propagation and combination. It should be noted that in the scenarios analysed, a Conglomerate perspective is considered, incorporating the impacts of the insurance sector. This involves calculating the effects of material insurance values at the Conglomerate level, focusing from time to time on those principally affected by the assumptions of the scenario considered (such as, by way of example, fees and commissions or net interest income). The scenarios considered consist of two macroeconomic scenarios and three thematic scenarios; within these, climate-related risk is included, in order to assess how climate change may affect the Group’s business. 50 The physical environmental risks were not found to be material in the double materiality assessment.
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168 | Mediolanum Group - 2025 Annual Financial Report The potential impacts of climate change and climate events may differ, depending on the overall path to be taken in terms of the green objectives to be achieved. The climate analysis conducted in the ICAAP report is based on the scenarios produced by the Network for Greening the Financial System (NGFS). These scenarios represent different combinations of objectives and implementation timelines, and therefore different profiles in terms of the risks characterising the climate world: transition risk and physical risk. Transition risk predominantly affects the value of financial instruments such as equities and bonds, as tighter emissions targets mean higher costs for companies that are required to meet them within tight deadlines. In contrast, physical risk has a greater impact on Banca Mediolanum’s loans portfolio, particularly risk secured by property. For further details on the scenarios adopted in order to assess the impact of transition and physical risk factors, see the datapoint [E1.SBM-3 DP 19 b]. With specific reference to the perimeter of the Insurance Group, the activities and main results arising from the Own Risks and Solvency Assessment (hereinafter ORSA) are set out below. The ORSA meets the requirements introduced by the Solvency II Directive and IVASS Regulation No. 32 of 9 November 2016 on Internal Risk and Solvency Assessment and aims, for Italian companies and insurance groups, to carry out a current and prospective assessment of their risk profile and prepare a report describing the results, conclusions and approach adopted for transmission to the Supervisory Authority by the set deadline. The document describes the methods and assumptions used to determine the total solvency requirements and risk mitigation techniques and managerial initiatives used by the Mediolanum Insurance Group to manage significant measurable or non-measurable risks, in accordance with regulatory provisions. Alongside what has been indicated for the ICAAP, the ORSA is the operating method used by the Mediolanum Insurance Group to manage and assess its business resilience, including with regard to the risk factors associated with sustainability matters. In particular, the ORSA describes the quantitative analyses (stress testing techniques and scenario analysis) performed on significant risk factors, indicating the assumptions and results. These analyses include the stress assumptions taken into account in changes in the macroeconomic scenario, the impact that such changes could also have on the forward-looking adequacy of the securities portfolio with respect to the commitments assumed towards the insured by the Mediolanum Insurance Group and the individual Companies that make it up, when the stress assumptions considered occur, as well as any initiatives that might be implemented, in the various scenarios, in order to ensure sound and prudent risk management. With regard to the climate stress scenarios considered, the approach used by the Insurance Group is consistent with the Climate Risk Guidelines defined at the level of the Financial Conglomerate, taking into account the specific regulatory characteristics of the sector. Since a true market-level best practice has not yet been established and given the lack of the data on projections over a long time horizon required for the purposes of the analyses, for the scenarios and stress factors described, reference is mainly made to historical data on the impacts of each risk considered, studies and public sources. The methodology used is based on the general EIOPA guidelines, divided into three steps as described below:
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169 | Mediolanum Group - 2025 Annual Financial Report The approach described involves defining a specific methodology of assessment through climate change scenarios that affects three different risks associated with the business of the Mediolanum Assicurazioni Group: • Life underwriting risks; • Non-Life underwriting risks; • Market risks. [E1.SBM-3 DP 19 b] The Mediolanum Group assesses its ability to withstand, and adapt promptly to, changing conditions arising from short- and long-term climate change, verifying its capital adequacy through specific climate stress test scenarios. This activity is periodically described in the ICAAP and ORSA reports, with regard to the perimeter of the Conglomerate and the Mediolanum Insurance Group, respectively. In particular, the ICAAP report makes it possible to investigate the processes of identification, measurement, management and monitoring of capital adequacy carried out by the Mediolanum Banking Group through a perspective of connection with the Parent Company’s governance functions, operational impacts in the ordinary management of the banking business and the potential evolving lines of development of the process. The process described is periodically analysed and verified through the regular reviewing and updating of the ICAAP report. The information provided in this document refers to the 2025 ICAAP, which was approved by the Board of Directors of Banca Mediolanum on 12 March 2025, in its capacity as Parent Company of the Banca Mediolanum Group. Within the ICAAP report, following the evolution and updating process, the Mediolanum Group integrated the NGFS (Network for Greening the Financial System) stress scenarios, in order to assess the trend in socio- economic parameters in various combinations of severity characterising climate risk (transition and physical). The impact of these climate scenarios was assessed on several dimensions: the Assets Under Management portfolio: an analysis was performed on the change in the value of the funds in relation to the selected climate scenarios (Climate VaR). The output of the model consists of an estimate of the impact on operating profit of the stress assumed on the risk factors selected, in particular on fee margins; the Proprietary securities portfolio: the impact of the shock on the fair value of the securities and in terms of ECL (Expected Credit Loss) was assessed; Loan portfolio: the scenarios affect the calibration of IFRS9 parameters, in particular, the estimate of the Probability of Default (PD) and Loss Given Default (LGD). The appropriate indicators are identified and assessed using the estimated stress factors Choice of climate scenarios to be used For each material risk, the technical risks affected and the portion of the portfolio subject to the identified risks are identified A stress factor for the most significant risks is estimated on the basis of the historical data and adjusting elements are applied on a forward-looking basis for the different scenarios chosen. Definition of scenarios Transformation of scenarios into climate change risks Transformation of the risks of climate change into financial losses 1. 2. 3. 2 1 2.1 2.2 3
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170 | Mediolanum Group - 2025 Annual Financial Report In particular, two ICAAP scenarios were analysed with reference to climate risk, both produced by the Network for Greening the Financial System (NGFS): the Divergent Net Zero (DNZ) scenario, in which the net zero target is reached by around 2050. This climate scenario mainly has an impact on assets under management and proprietary portfolios, as the timing of achieving the objectives is challenging and involves significant costs for companies; the Nationally Determined Contributions (NDC): in this scenario, the climate targets already agreed and potentially yet to be implemented by the States are considered. This scenario therefore has less impact on companies in terms of timescales and costs, but is characterised by greater physical risk. For this reason, the scenario is applied to the assets under management world and to the loans portfolio secured by Banca Mediolanum’s properties. The ORSA report, meanwhile, sets out the forward-looking assessment of the risk profile of the Mediolanum Insurance Group on the basis of the following elements: the forward-looking risk profile and possible changes to this profile; overall solvency needs, in both quantitative and qualitative terms, including in the medium term; the link between the risk profile and overall solvency needs; the significant risk factors that will be subject to additional analysis, including stress tests, reverse stress tests and scenario analyses; coverage of the solvency requirement with the undertaking’s own funds; compliance on an ongoing basis with technical provisions, capital requirements and the composition of own funds; the assessments made by the Mediolanum Insurance Group in the context of adequacy with the application of the Standard Formula to the risk profile of the same. The ORSA report of the Insurance Group was produced by the Risk Management Function of Mediolanum Vita, in coordination with Senior Management and the other Offices involved in the assessment, following the approval of the Board of Directors on 15 May 2025. Description of under 1.5° scenario The first climate scenario applies stress to active mortality and portfolio rates, considering: on the underwriting side, the RCP 4.5 scenario, corresponding to an increase in temperature of 2.5° – 3° compared with pre-industrial levels. It is a stabilisation scenario in which the radiative force stabilises shortly after 2100, without exceeding the target levels in the long run. It was developed by the GCAM modelling team at the Pacific Northwest National Laboratory’s Joint Global Change Research Institute (JGCRI) in the United States; on the market side, in the NGFS Net Zero 2050 (NZ 2050) scenario, the prevailing risk is the transition risk. Description of the over 2° scenario The second climate scenario applies stress to active mortality and portfolio rates, considering: on the underwriting side, the RCP 8.5 scenario, corresponding to an increase in temperature of 4° – 4.5° compared with pre-industrial levels. This is a scenario of a growing increase in greenhouse gas emissions over time. It represents scenarios in the literature that lead to a strong concentration of greenhouse gases in the atmosphere. It was developed using the MESSAGE model and the IIASA Integrated Assessment Framework of the International Institute for Applied Systems Analysis (IIASA), Austria; On the market side, in the NGFS Nationally Determined Contributions (NDCs) scenario, the prevailing risk is physical risk. [E1.SBM-3 AR 7 b]
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171 | Mediolanum Group - 2025 Annual Financial Report For the purposes of identifying potential material events and projecting the relative impacts with respect to the business model, through the ICAAP, the Mediolanum Group carries out forward-looking analyses which, according to specific stress climate scenarios, allow the effects to be verified over a three-year time horizon. With regard to the AUM portfolio, a multi-horizon analysis is conducted. This approach provides for the calculation of the change in the value of the instruments in scope, taking into account the impacts relating to different time horizons covering short-, medium- and long-term windows (1, 3, 5, 10, 20 and 30 years). At each time horizon, the shock is obtained by discounting the estimated impacts up to that horizon, for comparability and readability in the context of the analysis. In the context of ICAAP, a conservative approach was adopted, assuming that the highest shock (30 years) will occur within the ICAAP horizon (3 years) and is then re- proportioned across the individual projection years of the financial year. As proof of the importance that the Mediolanum Group attaches to pursuing the climate transition, it has defined and approved a Transition Plan (See. paragraph ‘2.2.2 Transition Plan for Climate Change Mitigation’ for further details) setting out the specific targets for reducing GHG emissions, according to different time horizons. [E1.SBM-3 DP 19 c] With reference to the above, the analyses of climate risk scenarios for ICAAP purposes verified the resilience of the Mediolanum Group’s business model, with a particular focus on the Group’s two main businesses of credit and asset management. In this regard, the following is a summary of the results of the analyses carried out on these business segments over the short-medium and long term. Credit - short/medium term The application of the stress scenario relating to climate risk on Banca Mediolanum’s loans portfolio has a negligible effect, equal to around one million over the ICAAP time horizon of three years, with an impact on the income statement in line with the base scenario. Credit - long term The stress analysis shows that, all else being equal, the application of a long-term climate risk scenario over 30 years has an impact of approximately 13% on the performing ECL (Expected Credit Loss) projected to date and is therefore negligible in terms of comprehensive income. Asset management - short/medium term At the portfolio level, a potential change in the value of assets under management in the short term (one year) is estimated of -0.11% in the Nationally Determined Contributions (NDC) scenario and -0.39% in the Net Zero 2050 (DNZ) scenario. Over a medium-term (three-year) time horizon, the potential losses would rise to -0.24% and -0.82% in the NDC and Net Zero 2050 scenarios, respectively. The application of the selected NGFS scenarios on the managed portfolio shows that the effect would be negligible in terms of impact on the income statement. Asset management - long term The scenario analysis performed shows that, with the same asset allocation, the cumulative impacts on the value of assets under management are between -3% for the NDC scenario and -7% for the Net Zero 2050 scenario, over the long term (year 2050). For a comparability analysis, the changes in assets under management indicated above are updated to the current date. The estimated impact would not have a significant capital effect.
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172 | Mediolanum Group - 2025 Annual Financial Report ORSA – Under 1.5° scenario results (focus on market risks) There is a decrease in the SCR, due, in particular, to a decrease in the lapse SCR in the Underwriting area and a decrease in the equity SCR on the market side. Own Funds decrease, due to a reduction in future profits. The Non-Life company records an increase in the catastrophe sub-module in both health and underwriting. The surplus is reduced by an average of 7% in all years of the plan. The coverage ratio is always higher than the Risk Appetite level defined in the SRA of the Mediolanum Insurance Group, showing an increasing trend over the plan period. ORSA – Over 2° scenario results (liquidity indicators) There is a decrease in the SCR, due, in particular, to a decrease in the Lapse SCR in the Underwriting area, and a decrease in the Equity SCR on the market side, both more limited than in the under 1.5° climate scenario. Own Funds decrease, due to a reduction in future profits. The Non-Life company records an increase in the catastrophe sub-module in both health and underwriting. The change in Own Funds is commensurate with that of the SCR. The surplus is reduced by an average of 4% in all years of the plan. The coverage ratio is always higher than the Risk Appetite level defined in the SRA of the Mediolanum Insurance Group, showing an increasing trend over the plan period. With regard to the Insurance Group, the approach adopted for the purposes of assessing resilience to climate- related and environmental risks is consistent with the Climate Risk Guidelines provided by the Mediolanum Financial Conglomerate, taking into account the specific regulatory characteristics of the sector. Consistent with the EIOPA regulations, from 2022 onwards, the Mediolanum Insurance Group introduced a qualitative assessment of two climate scenarios into the ORSA analysis: increase in temperature - remains below 2°C, preferably not above 1.5°C; increase in temperature - exceeds 2°C. In 2023, the Mediolanum Insurance Group introduced in the ORSA report a quantitative impact assessment of the climate scenarios described above. the Solvency Capital Requirement, Own Funds and Solvency Ratio were calculated in stress situations and the impact was not material, demonstrating, to date, that the response of the Mediolanum Insurance Group to this type of scenario is adequate. [E1.SBM-3 AR 8 b] To confirm the importance that Banca Mediolanum places on adapting its strategy and business model to climate change, the Group is committed to pursuing and achieving specific objectives, defined and approved within the new 2026-2030 Sustainability Plan. This Plan continues the strategic development lines and the project activities being implemented, already set out in the previous 2024–2026 Sustainability Plan and focuses on environmental issues. In addition, the new Plan is structured to include projects consistent with the Group’s sustainability approach, in keeping with the double materiality assessment carried out and with current regulations. With a view to assessing the Group’s business resilience in the short, medium and long term, Banca Mediolanum carries out focused activities to identify the impacts, risks and opportunities relating to climate change, defining targets consistent with the Group’s commitments. As regards climate, the new Plan takes the form of actions aimed primarily at reducing direct and indirect emissions associated with investment and credit portfolios, providing, in accordance with the requirements of EFRAG’s ESRS and in line with the reporting expectations of the CSRD, for the development and definition of decarbonisation targets, considering the operational and strategic implications for the business (the so-called Climate Transition Plan). In addition, with a view to setting objectives consistent with the European carbon neutrality guidelines, the Group has assessed the adoption of specific climate indicators to measure the current and prospective positioning of investments.
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173 | Mediolanum Group - 2025 Annual Financial Report With regard to investment activities, the Mediolanum Group takes environmental risk factors into account through the analysis and monitoring of the E component of the ESG rating assigned to each investment product and through the monitoring of Principal Adverse Impacts (PAI), i.e. the negative effects of investments on sustainability factors as defined by Regulation(EU) 2019/2088. In particular, in the ‘climate and environment’ area, among the mandatory indicators of principal adverse impacts, the Bank has decided to prioritise matters relating to greenhouse gas emissions. As well as the metrics mentioned above, in order to expand its monitoring of climate in the area of investments, the Mediolanum Group has adopted additional specific climate indicators: • Weighted Average Carbon Intensity (WACI): a backward-looking indicator that represents the weighted average of the ratio of CO2 emissions to the revenues of investee companies and indicates how carbon- intensive the business models of the investee companies are; • Implied Temperature Rise (ITR): a forward-looking indicator that estimates how well companies and investment portfolios are aligned with international global warming containment targets. In line with the provisions of the Sustainability Plan, these investment climate indicators are constantly monitored and supported the definition of the decarbonisation targets set out in the Plan. 2.2.2 Transition plan for climate change mitigation IROs: Improving the Bank’s positioning as a player in the climate transition [E1-1 DP 14] [E1-4 DP 33] In recent years, the financial sector has become increasingly influential in facilitating the transition to a low- carbon economy, not only as a facilitator of access to capital for infrastructure and technological innovation projects, but also as a player responsible for reducing its environmental impact. In this context, Banca Mediolanum intends making an active contribution to the mitigation of climate change and therefore, in December 2025, the Board of Directors of Banca Mediolanum approved the Climate Transition Plan (hereinafter also ‘the Plan’). The Plan sets out the strategic decarbonisation levers and medium-term targets for own emissions (Scope 1 and 2, market-based) and financed emissions (Scope 3, Category 15). The Plan is inspired by the principles of the Glasgow Financial Alliance for Net Zero (GFANZ) and constitutes the framework through which the Bank defines its strategic priorities, the main decarbonisation levers and the actions necessary to reduce its direct and indirect emissions along the entire value chain. Its preparation included a structured consultation with the company functions most involved, who contributed to defining the targets within the area of their responsibilities. The Plan’s targets relating to greenhouse gas emissions, including own emissions and those financed – both within the investment portfolio (Asset Owner) and in the mortgage portfolio – were identified through specific instruments and decarbonisation scenarios for the various perimeters considered. As regards own emissions (Scope 1 and 2, market-based), Banca Mediolanum is targeting a 69% reduction by 2030 compared with 2021, focusing on both the energy consumption of the offices it owns or that are under its operational control, and the fuel consumption of the company fleet. As regards proprietary investments (AO), Banca Mediolanum aims to maintain an emission coefficient of less than 40 tonnes of CO 2 per million euros invested by 2030, limited to Scope 2 and 1 emissions of issuers in its portfolio, while ensuring that more than 95% of investments are placed in countries with decarbonisation plans aligned with the scenario of limiting global warming to 1.5°C. The scope of application of the target is defined as follows: the first target refers to corporate asset classes and open-ended funds held in the Treasury and Insurance portfolios within the Italian perimeter, which represent approximately 2% of the overall value of the portfolio. The second target, on the other hand, applies to all asset classes included in the portfolio, thereby covering 100% of them.
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174 | Mediolanum Group - 2025 Annual Financial Report For AUM, and specifically funds classified within the meaning of Articles 8 and 9 of the SFDR of Mediolanum International Funds and Mediolanum Gestione Fondi, the plan provides for a reduction in the Carbon Footprint (carbon footprint measured in terms of Scope 1 and 2 GHG emissions) of 70% by 2050 compared to 2022, which is taken as the baseline year. Intermediate reduction targets have also been set: 30% by 2030 and 45% by 2040. These targets apply as follows: for MIFL, the funds classified within the meaning of Articles 8 and 9 as of July 2025 (approximately 7% of total AUM); for MGF, the funds within the meaning of Article 8, with the exception of the so-called target date funds (approximately 4% of total AUM). Finally, for the residential mortgages portfolio, Banca Mediolanum focuses its decarbonisation strategy on credit exposures relating to loans granted for the purchase and refinancing of residential properties on the retail market in Italy. The 2030 target includes a commitment to reduce the physical intensity of financed emissions by 25% by 2030, expressed as kilograms of CO2 equivalent per square metre of properties financed, compared to the 2023 level. This metric allows the environmental impact to be recognised in a direct and transparent way, assigning a key role to the energy performance of the properties being financed. The scope of application of the target includes all of the Italian residential mortgages portfolio, excluding only positions for which the data necessary for the analysis are not available; this scope represents approximately 96% of the total value of the portfolio. As part of the Group’s Climate Transition Plan, a preliminary analysis, which has not yet been integrated into the Transition Plan, was carried out on the residential property portfolio in the Spanish retail market. This analysis shows that Banco Mediolanum plays a fully integrated role consistent with the strategic guidelines defined by the Parent Company and also enjoys a virtuous position within the Group, with an emission coefficient at the baseline that is already reduced. [E1-1 DP 16 a] [E1-4 DP 34 e, AR 30 c] The targets set for own emissions (Scope 1 & 2) are aligned with a scenario consistent with the 1.5° temperature increase limit provided for in the Paris Agreement. With regard to financed emissions–, in particular the AO and AUM investment portfolios and the mortgage portfolio–, the level of ambition is not aligned with a 1.5 ° scenario, but instead sets out Banca Mediolanum’s path in its intention to decarbonise its portfolios. In fact, in defining its decarbonization path, the analysis of multiple climate scenarios was integrated, adopting a differentiated approach according to the various operating perimeters. Specific tools and scenarios were used to support the definition of targets. Specifically: Own emissions (Scope 1 and 2 market-based): to define the 2030 target, Banca Mediolanum adopted a methodological approach based on reference scenarios consistent with the main scientific evidence available at international level; Scope 3, Category 15 Financed Emissions – Assets Under Management (AUM): the decarbonisation path was launched through the initiatives of the main asset managers, Mediolanum International Funds and Mediolanum Gestione Fondi, for funds classified within the meaning of Articles 8 and 9 of the SFDR, using the information and projections made available by the infoprovider MSCI ESG Research. The Paris Agreement aims to achieve net-zero emissions by 2050. In support of this ambition, MIFL and MGF aim to reduce the carbon footprint of in‐scope investments by 70% compared to the baseline year. The two Companies may review their targets throughout the plan’ duration and adapt them based on any regulatory and market requirements;
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175 | Mediolanum Group - 2025 Annual Financial Report Scope 3, Category 15 Financed Emissions – Proprietary investments (AO): in formulating their commitments, Banca Mediolanum and Mediolanum Vita consider the allocation of assets across countries, undertaking to ensure by 2030 that at least 95% of investments are allocated to countries with decarbonisation plans compatible with a 1.5°C scenario, through the use of external portfolio monitoring tools (e.g. climate action target). In addition, with respect to the commitment to keep its emission coefficient below 40 tCO2 per mln€ invested, specific decarbonisation scenarios were not taken into account. Scope 3, Category 15 Financed Emissions - Residential mortgages portfolio (RRE): 2030 targets are based on scenarios produced internally from statistical models by CRIF on the evolution of the Italian residential building stock to 2050. The target for the residential mortgages portfolio is not aligned with a Net Zero scenario, taking into account the current characteristics of the Italian property stock and its significant reliance on public incentive programmes for improving the energy rating of buildings. For further details on the targets, see ESRS E1-4 DP 34 and the section ‘Targets’. [E1-1 DP 16 b] [E1-4 DP 34 f; AR 30 a, 30 c] In order to support its targets for reducing GHG emissions for own and financed emissions, Banca Mediolanum identified decarbonisation levers and planned actions that act both on its own emissions and on financed emissions, to support the transition. Specifically: 1. Internal Energy Transition (Own Emissions - Scope 1&2 market-based): electrification of the company fleet, with the progressive replacement of combustion vehicles with electric vehicles and hybrid vehicles; disposal of cogeneration/trigeneration systems in buildings owned by the Group and transition to the exclusive supply of electricity from the grid. 2. Reduction of emissions related to Asset Management (Financed Emissions - Scope 3 Category 15): continuous monitoring and reporting of portfolio emissions; structured engagement activities with issuers and delegated managers; implementation of active sustainable management. The MIFL funds concerned are all multi-manager funds, i.e. whose portfolios are composed of mandates and UCITS funds. Managing these underlying strategies is delegated to asset managers globally. The MIFL investment team worked with all the managers regarding the strategies they manage and agreed on an appropriate approach to carbon footprint reduction for each strategy. Using MSCI, MIFL will monitor the carbon footprint (Scope 1&2) of the strategies on a monthly basis and report to MIFL’s Investment Committee on a quarterly basis and annually to MIFL’s Board of Directors. For any strategy that fails to meet its improvement target, MIFL’s investment team will engage with the manager and agree on the best way to address it, including the divestment of securities, etc. 3. Active portfolio management - Proprietary Investments (AO) (Financed emissions - Scope 3 Category 15): active selection of issuers through ESG screening and analysis of their climate performance; periodic revaluation of the portfolio composition in the light of regulatory developments and best practices; monitoring and periodic reporting of emissions metrics, supporting the transparency and evaluation of environmental performance.
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176 | Mediolanum Group - 2025 Annual Financial Report 4. Support for energy efficiency - Residential Mortgages Portfolio (RRE) (Financed Emissions - Scope 3 Category 15): strengthening the provision of green mortgages, with priority given to energy-efficient properties (EPC classes A, B, C); targeted support and financing for improving the energy performance of less efficient buildings (EPC classes E, F, G); systematic introduction of the application for an updated energy performance certificate (EPC) following renovations and energy-class improvements; activation of specific agreements to facilitate the issue of or for updating the EPC for customers. [E1-1 DP 16 c] [E1-4 AR 30 c] Banca Mediolanum has set aside a long-term budget to support the implementation of the Climate Transition Plan, mainly, but not only, aimed at reducing operational emissions and aligning investments with the established climate targets. In particular, with respect to operating and capital expenditure (OpEx and CapEx) to support the climate transition commitment, the methods for implementing the Transition Plan include: measures of a technical nature and to renew plants, instrumental to achieving own emission reduction targets, including the decommissioning of trigeneration plants powered by natural gas and the concurrent implementation of machinery powered exclusively by renewable electricity taken from the grid. These works are planned for the period 2027–2029, with an estimated investment of approximately €700,000 per plant, with reference to the sites of Fermi Galeno and Meucci Galvani. The additional operating costs (OpEx) are marginal and will be monitored following the implementation of the works, with particular reference to the evolution of electricity expenditure and the impacts on the technical management of buildings; the definition and implementation of the methods to be followed to make investment choices compatible with the targets set in relation to the financial portfolio for asset management (AUM) and proprietary investments (Asset Owner). On the basis of the lines of action identified to date, the expected economic requirement is mainly attributable to operating costs (OpEx), relating to the strengthening of the databases on issuers’ emissions, the structural integration of climate metrics within capital allocation models and ESG scorecards, and the enhancement of tools dedicated to scenario analysis and climate stress tests. Additional operating charges are associated with the periodic updating of the methods for allocating emissions, for the calculation of the tCO 2/€m coefficient, necessary for continuous monitoring of the portfolio’s alignment with the climate targets set by Banca Mediolanum. At present, no CapEx investments are planned, as the required activities are predominantly methodological and analytical in nature, aimed at consolidating internal processes, rather than infrastructure or technological needs that would require material investments; the combination of CapEx and OpEx closely correlated with the gradual transformation of the Bank’s credit offering towards products more focused on the efficiency of financial real estate: IT investments, commercial measures and incentives for customers to support the decarbonisation of the financed residential sector in a progressive and measurable manner. These include IT implementation costs that may be capitalized, instrumental to the development of new products and processes supporting the sustainable finance strategy, such as the introduction of new green mortgages and the adaptation of information systems. In this context, estimated IT investments of approximately €15,000 are planned for the repricing of the Eco+ Mortgage product and approximately €40,000 for the implementation of the new Eco+ Supergreen product, dedicated to energy class A properties. At the same time, Banca Mediolanum has provided an incentive for customers carrying out energy redevelopment work, by paying the cost of the Energy Performance Certificate (EPC) after the works have been completed. This
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177 | Mediolanum Group - 2025 Annual Financial Report is a recurring operating expenditure and provides for a contribution of €100 per loan, for a total amount estimated at approximately €20,000 per year. A structured customer retention process is also being defined, with the aim of protecting customers with energy-efficient properties by introducing selective spread reductions in the event of passive subrogation risk. The economic impact of this initiative is currently being assessed and will be defined as part of the subsequent implementation stages of the Plan. For the loans portfolio perimeter, there is also an expense item relating to advisory services aimed at supporting the implementation of the initiatives of the Transition Plan. The estimated amount for 2026 is €48,800 (including VAT). To prepare this plan, during 2025, operating expenses (OpEx) amounting to €120,780 were incurred. For further information, see the MDR-A in ESRS E1-3 section ‘Actions and resources relating to climate change policies’ in the paragraphs: 2.2.3 Own GHG emissions, 2.2.4 GHG financed emissions – Investments, 2.2.5 GHG financed emissions – Credit, 2.2.6 Process digitalisation. [E1-1 DP 16 c] Financial resources allocated to the action plan UoM 2025 Financial resources allocated to the action plan (OpEx) € 120,780.00 Financial resources allocated to the action plan (CapEx) € 0.00 [E1-1 DP 16 d] With regard to Mediolanum Gestione Fondi, at present, there are no ‘blocked’ greenhouse gas emissions from key products or assets. Given the scope on which the Transition Plan has been formalised to date, it is not expected that such emissions will compromise the achievement of the GHG emissions reduction targets or generate transition risks. With regard to Mediolanum International Funds, a qualitative assessment was carried out on the indirect emissions potentially generated over time by the key assets and products in scope. While acknowledging that delegated third-party managers used by MIFL have plans to reduce GHG emissions that are not fully under MIFL’s control, MIFL considers that: some of the funds covered by the plan apply PAB or CTB exclusion criteria; MIFL continuously monitors investment portfolios to ensure that the objectives are achieved, addressing any critical misalignments relative to the projected trajectory. In light of such evidence, it is not considered that the emissions analysed could compromise the achievement of greenhouse gas reduction targets or generate significant transition risks. [E1-1 DP 16 e] In relation to the objectives and plans aimed at aligning economic activities with the criteria established by Commission Delegated Regulation (EU) 2021/2139, Banca Mediolanum has launched, as part of its credit activities, a number of initiatives (including an optimisation of its offering and communication on green loans; agreements and incentives to promote the energy efficiency of buildings; mortgage subrogation and advisory campaigns for the acquisition of new green customers; customer care and retention) aimed at strengthening its commitment to offering products consistent with the environmental targets set out in the Taxonomy Regulation. In support of these actions, the Banca Mediolanum Group allocated a total of approximately €55,000 in CapEx and €1.5 mln in OpEx. [E1-1 DP 16 j; 16 i]
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178 | Mediolanum Group - 2025 Annual Financial Report During 2024, analyses were conducted to screen own emissions and the financed emissions of the portfolios, with the aim of assessing the current positioning (as-is) and identifying the initial priority perimeter for intervention. Emission reduction targets were subsequently defined in 2025, along with the main decarbonisation levers for the perimeters identified. At present, no progress has been made in implementing the plan, as it was structured during 2025 and approved by the Board of Directors of Banca Mediolanum, after review by the Risk Committee and the Group Coordination and ESG Strategic Development Committee, in December 2025. The planned measures will be progressively implemented from 2026, with the consequent monitoring of progress. [E1-1 DP 16 g] Given the nature of the activities carried out, Banca Mediolanum does not meet any of the exclusion criteria indicated above and is therefore not excluded from the EU benchmarks aligned with the Paris Agreement. [E1-1 DP 16 h] Banca Mediolanum’s Climate Transition Plan is fully integrated with its general corporate strategy and financial planning. The approach requires climate policies to be aligned with the strategic targets of the Group’s 2026-2030 Strategic Plan, and the requirements of the Corporate Sustainability Reporting Directive (CSRD). The Bank has involved the main corporate functions, such as the Administration, Finance and Control; Investment Services; Business Model and Insurance Services; Corporate Services and HSSE; and Credit Departments, as well as the sustainability areas of the Italian and foreign subsidiaries – Spanish and Irish – in defining and implementing the Plan, ensuring that decarbonisation targets are an integral part of decision-making processes. The governance of the plan is ensured by a coordination system that includes the Group Coordination and ESG Strategic Development Committee, the Risk Committee and the Board of Directors, that supervise the implementation and monitoring of climate-related activities. The Risk Management function and other structures support the assessment and integration of climate risks, while financial planning involves monitoring resources and allocating the necessary budgets, including staff and advisory services, to support the implementation of the plan. Monitoring and periodic reporting are used to assess alignment with climate targets and to take corrective action if necessary.
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179 | Mediolanum Group - 2025 Annual Financial Report Targets [E1-4 DP 32; 34 a; 34 c; 34 d; AR 24; ESRS 2 MDR-T DP 80] Target Target KPI Target year Scope Year and baseline value Units of measurement Progress at 31/12/2025 Scope 1&2 market- based emissions -69%; 1.827 tCO2e 2030 Italy 2021 5,810 tCO2e tonnes CO2 equivalent - t CO2e 2,603.49 tCO2e Carbon footprint Asset Management (AUM) – MIFL51 -30%; 22.6 tCO2e/€mln -45%; 17.8 tCO2e/€mln -70%; 9.7 tCO2e/€mln 2030 2040 2050 Ireland Funds within the meaning of Articles 8 – 9, SFDR52 2022 32.3tCO2e/ €mln tCO2e per €mln invested - tCO2e/€mln` 23.41 tCO2e/€mln Carbon footprint — AUM - MGF53 -30%; 18.5 tCO2/€mln -45%; 14.6 tCO2e/€mln -70%; 7.9 tCO2e/€mln 2030 2040 2050 Italy Funds within the meaning of Articles 8, SFDR54 2022 26.50 tCO2e/ €mln tCO2e per €mln invested - tCO2e/€mln` 5.15 tCO2e/€mln Carbon footprint Property investments (AO) <40 tCO2e/€mln 2030 Italy 2024 20.59 tCO2e/€ mln tCO2e per €mln invested - tCO2e/€mln 21.30 tCO2e/€ml n Property investments (AO) >95% investments in countries aligned with +1.5°C 2030 Italy 2024 - % of investments in countries aligned with +1.5°C 97.00% Residential mortgage portfolio (RRE) -25%; 32.3 kgCO2e/m² 2030 Italy 2023 42.90 kgCO2e/m² kg CO2 equivalent per m2 - kgCO2e/m2 40.85 kgCO2e/m² 51 The carbon footprint (Scope 1 and 2) is calculated using the Investor Allocation ( €M) approach, in line with Commission Delegated Regulation (EU) 2022/1288 and the MSCI ESG Research guidelines. This method allocates emissions in proportion to the investment weight with respect to the undertaking’s value, focusing exclusively on Scope 1 and Scope 2 emissions (thus excluding Scope 3). Emissions data come from MSCI ESG Research (enterprise value, investment value). The methodology conforms to the SFDR (Regulation (EU) 2019/2088), to Commission Delegated Regulation (EU) 2022/1288, and is designed to be aligned with the European and international sustainability frameworks. The use of Scope 1 and Scope 2 emissions, the Investor Allocation methodology and monthly calculation frequency ensures that the targets are measurable, transparent and scientifically sound. 52At 31 July 2025. 53 At a methodological level, MGF used the information and estimates from the infoprovider MSCI ESG Research to draw up projections to identify the emission reduction target that the SGR could achieve by 2050, as well as intermediate targets (by 2030 and 2040). These projections are constructed by adopting 2022 as the baseline year and assuming that the issuers in the portfolio at the date of the analyses –, kept stable for representative purposes –, will actually achieve the publicly declared emission-reduction targets. 54 Except for so-called target date funds.
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180 | Mediolanum Group - 2025 Annual Financial Report The above objectives are monitored on a quarterly basis. For information on MDR-T (f), (g) and (h), see above in the context of disclosure E1-1 on the Transition Plan for Climate Change Mitigation. [E1-4 DP 34 b] Consistency between emission reduction targets and the perimeter of the GHG inventory is ensured through: a specific distinction between: o own Scope 1 and 2 (market-based) emissions relating to the energy consumption of offices owned by the company and the company fleet; o financed Scope 3 emissions, broken down by specific activity boundaries (AUM, property investments, residential mortgages portfolio); the definition of specific targets for each perimeter, consistent with the nature of the emissions and with the metrics used to measure them; the use of recognised tools and scenarios to ensure the alignment of the reduction trajectories identified. [E1-4 AR 25 a] The baseline values of climate targets are set for specific activity perimeters and use metrics consistent with the nature of the emissions considered. In particular, for Scope 1 and 2 emissions, the target is defined referring to the Science Based Target initiative (SBTi) tool, while for the residential mortgages portfolio, the baseline value and targets are compared with climate scenarios and emission trajectories developed using dedicated tools. With regard to own emissions, the 2030 targets were defined according to the Science Based Targets initiative (SBTi) methodologies, consistent with the objectives of the Paris Agreement. For asset management, the decarbonisation trajectory was launched through the initiatives of the main asset managers, Mediolanum International Funds and Mediolanum Gestione Fondi, referring to the funds classified within the meaning of Articles 8 and 9 of the SFDR. With respect to Asset Owner investments, the Bank undertakes to ensure by 2030 that at least 95% of the investments are allocated to countries with decarbonisation plans compatible with a 1.5°C scenario, consistent with the EU taxonomy. Finally, for the loans portfolio, the 2030 targets are based on scenarios processed internally based on statistical models developed by CRIF on the evolution of the energy classes of the Italian residential assets to 2050, supplemented by periodic monitoring of the alignment with the emission pathways defined by the CRREM tool and the CRREM 1.5°C GHG pathways, to support the identification of the main decarbonisation levers. 2.2.3 Own GHG emissions The Group’s approach and policies Banca Mediolanum and the Group Companies are constantly committed to minimising the environmental impact generated by businesses through the adoption of policies for the optimisation of consumption and the management of natural resources and waste. In addition to the use of certified management systems, energy from renewable sources and systems for saving energy and resources in the offices, Mediolanum believes that awareness among staff of the adoption of increasingly environmentally friendly behaviour plays a central role in reducing the environmental impact of working activities as well as outside the corporate context. Over the years, the Mediolanum Group has developed various Policies designed to ensure the proper management of the above impacts. In addition to the Code of Ethics and Sustainability Policy of the Mediolanum Group, which set out its approach and general guidelines, the main Policy for managing impacts related to own GHG emissions is the Policy on Health, Safety and the Environment. [E1-2 DP 25] The following Policies address climate change mitigation and climate change adaptation aspects. [E1-2 DP 24; ESRS 2 MDR-P DP 65]
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181 | Mediolanum Group - 2025 Annual Financial Report IROs: Generation of direct and indirect GHG energy emissions from own operations (Scope 1 and 2) Mediolanum Group Sustainability Policy The Mediolanum Group has adopted a ‘Sustainability Policy’ that describes the various material sustainability topical areas, i.e. the ‘Responsibilities’. From the point of view of environmental responsibility, the Mediolanum Group is committed to plans and activities intended to reduce environmental impacts. The ‘climate change’ topic represents the importance of the matter for the Group, and guides its ongoing commitment to adapting and mitigation the environmental impacts generated by the business activity. This involves policies to optimise energy consumption and management of natural resources and waste, use of certified management systems, energy from renewable sources, systems to save energy and resources in offices, dematerialisation of products and services through the digitalisation of documentation and raising staff’s awareness of an environmentally compatible conduct. From the point of view of indirect impacts, it involves, with regard to investments, taking climate change into account in the Group’s investment policies and, with regard to financing activities, promoting facilitated financing solutions to support sustainable choices and encourage responsible customer behaviour. Furthermore, the Group has pursued its continual improvement of the sustainable management of events due to environmental impacts, focusing its attention on standards in accordance with ISO 20121 standards. For further information on the Policy and related MDR-P, see ESRS G1-1 DP 7, paragraph 4.1.1 Corporate Culture. Health, Safety and Environment Policy Content and objectives The Mediolanum Group has adopted a policy on occupational health and safety and environmental protection, with the most recent update approved in 2023. The Policy formalises the Group’s principles in the management of occupational health and safety, by implementing the reference standards set out in UNI EN ISO 14001:2015 and UNI EN ISO 45001:2023. In particular, with regard to the environment, four areas of responsibility have been identified (purchase and consumption of sustainable products, energy and climate change, waste management and culture of environmental protection) that are applied in the path of implementation of the integrated management system and are set out in specific objectives. With reference to climate change and the reduction of Scope 1 and 2 emissions, the Group is committed to limiting environmental impact by optimising consumption and reducing waste, encouraging forms of sustainable mobility, researching energy solutions in line with the best market standards and promoting energy self-generation initiatives, in order to contribute to the reduction of CO2 emissions. Scope of application The Policy applies and is extended to various stakeholders, ranging from Group employees, suppliers and/or contractors, to non-employees and third parties in general who are in the workplace. The Policy is issued by Banca Mediolanum as the Parent Company of the Mediolanum Conglomerate and is adopted by the recipient Subsidiaries. Highest level of management responsible for implementation The updating and review of the Policy is the responsibility of the Head of the Health Safety Security & Environment (HSSE) Section in the role of ‘Head of the Management System’, in coordination with the other organisational units and following verification by the Employer, in order to ensure that the organisation is continually compliant and appropriate for the pursuit of the objectives indicated. Regulations and reference standards The main legislative and regulatory references to workplace health and safety and environmental protection used in the implementation of the Policy are Legislative Decree No. 81/2008 ‘Implementation of Article 1 of Law
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182 | Mediolanum Group - 2025 Annual Financial Report 123 of 3 August 2007 on the protection of health and safety in the workplace’; Legislative Decree No. 152/2006 ‘Environmental standards’; UNI EN ISO 45001:2023 ‘Occupational health and safety management system’ and UNI EN ISO 14001:2015 ‘Environmental management systems’. Stakeholder involvement and dissemination methods The Group is committed to periodically analysing the needs and expectations of workers and stakeholders in terms of workplace health and safety and the environment, encouraging and soliciting their active participation, and to disseminating the Policy, making it known and available, in particular, to all stakeholders, with the aim of making them aware of the commitments made by the organisation in the area of workplace health and safety and the environment. In addition, the Group undertakes to disseminate and make available and easily accessible the documentation on occupational health and safety, including management documents, to the various actors (e.g. workers, customers/suppliers, supervisory authorities/bodies, etc.) based on the various levels of authorisation. The Group’s Spanish and Irish Companies also adopt an environmental policy that sets out their commitment to protecting the environment and that pursues these objectives through the adoption and implementation of the international standards ISO 50001:2018 and ISO 14001:2015 for the Spanish Companies and ISO 14001:2015 for the Irish Subsidiaries. Actions [E1-3 DP 28; 29 a; 29 b; 29 ci; 29 cii; 29 ciii; ESRS 2 MDR-A DP 68] IROs: Generation of direct and indirect GHG energy emissions from own operations (Scope 1 and 2) With regard to the environment, in the context of the integrated management system, areas of responsibility and objectives are identified. The actions taken for each area of responsibility are set out below. Energy efficiency measures The Mediolanum Group is committed to researching and adopting energy solutions, referring to the highest market standards, characterised by reduced emissions and high energy performance for the operation of buildings, in strict compliance with regulations. With regard to energy efficiency, during 2025, the adoption of smart working made it possible to moderate the operation of the building heating and cooling systems, while maintaining the minimum comfort level in each Campus building. In order to increase the efficiency of the plants through devices designed to monitor and regulate machines and processes, termed PLC (Programmable Logic Controller), a feasibility study of a system of automation of the plants (Building automation) is planned. The Group has adopted initiatives to self-generate electricity, thermal energy and refrigerating energy such as trigeneration, to enable sustainable energy consumption that reduces CO 2 inputs and is a concrete environmental benefit. At its Milan 3 City headquarters, two trigeneration plants are installed to enable the simultaneous self-generation of electricity, thermal energy and refrigerating energy, through the use of co-generators and absorption refrigeration units. The plants, powered by methane gas, self-generate electricity to power daily end-user consumption (lights, personal computers, motive power and all services, including air conditioning). The plant consists of two separate and independent plants located on the roof of the Meucci-Galvani and Galeno-Fermi buildings. To make the plants more efficient, the electrical output of the two units was connected to the Archimede and Galilei-Voltas building and to the nursery. In addition to providing self-generated electricity, these connections also provide an uninterrupted power supply (backed by UPS units and generators) to 100% of the workstations.
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183 | Mediolanum Group - 2025 Annual Financial Report With reference to 2025, the plant covered the needs of the MI3 City Campus. In particular, it managed to meet 23.07 % of the electricity requirement, providing a partial contribution to heating and air-conditioning services. With the Trigeneration plants present on the Campus of MI3 City of Basiglio, in 2025, 3,113.67 MWh were internally generated, out of 13,493.92 MWh used, producing the hot water necessary for heating and cold water for cooling. With reference to Banco Mediolanum, photovoltaic panels were installed at the Barcelona headquarters in 2024. No new installations were built during 2025; however, the plants already present contributed to improving the site’s energy efficiency and to reducing emissions associated with electricity consumption (see ESRS E1 Climate Change, paragraph 2.2.7 Metrics, section ‘Energy consumption and energy mix’ for further information on the consumption of self-produced renewable energy). Since 2018, Banco Mediolanum has also implemented an energy management system conforming to ISO 50001, for a more efficient and sustainable use of energy. This certification is also in force for 2025. Since April 2019, the Irish office has been in the Exchange Building, IFSC (theexchangeifsc.com/), a building accredited with a LEED GOLD standard and a BERA3 rating that translates into a 50% reduction in energy consumption and a 51% reduction in carbon emissions. Sustainable mobility The Group promotes sustainable mobility by helping to reduce CO 2 emissions. Following the Decree of the Ministry of Ecological Transition of 12 May 2021, the position of Company Mobility Manager was introduced, and a home-to-work travel plan (PSCL) for employees is drawn up annually. The Mobility Manager is tasked with raising awareness of sustainable mobility matters, through the development and monitoring of the workplace travel plan, and to promote training and guidance actions to encourage sustainable mobility. Regarding sustainable mobility, in 2025: the shuttle bus service linking the Basiglio headquarters with the municipalities of Milan and San Donato was confirmed. Approximately 60% of the costs are borne by the company and refer to private transport; the use of public transport to travel to the workplace is encouraged through a special agreement with ATM (Azienda di Trasporto Milanese, the Milan Transport Company) for annual urban travel passes at a discounted price; a further 15 rapid charging units were installed, increasing the total to 107 charging stations for electric vehicles, with more increases planned for the next few years. Banca Mediolanum also provides DKV cards, supplied by a leading European company specialising in services for corporate fleets and in cashless solutions for refuelling and electric charging. The cards are assigned to managers and employees that have company cars, according to the type of car they use: a multi-function card, for both refuelling and electric charging, for plug-in cars; a refuelling card for cars which only run on fuel. In Spain, Banco Mediolanum encourages its executives to choose company vehicles with a low environmental impact and, in particular, hybrid, plug-in and electric vehicles. This initiative comes to fruition at the end of the vehicle lease: to date, the Company fleet consists of 19 vehicles, comprising 18 hybrids and 1 vehicle. In addition, the Company signed an agreement with ‘Taxi Ecológic’ to manage the movements of employees and contract staff within the Barcelona Metropolitan Area. Taxi Ecológic offers its services with a guarantee of sustainable mobility, as it has ISO 14001 certification and all the vehicles in its fleet conform to the latest EU regulations on CO2 emissions.
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184 | Mediolanum Group - 2025 Annual Financial Report In addition, specifically with regard to the Group’s Irish Companies, sustainable mobility initiatives were also confirmed in 2025. In particular, the commitment to a more efficient use of resources and reduction of emissions continued through a number of initiatives such as, for example, encouraging employees to use greener transport methods under programmes such as ‘Bike to Work’ and ‘Tax Savers Public Transportation’. ‘Bike to Work’, in particular, allows bicycles to be purchased at reduced prices, while the Tax Savers Public Transportation programme gives employees the chance to purchase discounted season tickets on local transport. These measures help to encourage a more environmentally friendly mobility. Culture of environmental protection and purchase and consumption of sustainable products The Mediolanum Group is committed to raising awareness and involving users - both employees and external contract staff - in the adoption of sustainable behaviour, with the aim of ensuring the correct application of the procedures to be implemented with regard to environmental protection. The Group also researches and promotes innovation initiatives aimed at reducing the consumption and waste of resources. Eco-compatible working methods are applied at the Group’s Head Office through a series of easy-to-implement measures for staff which, over the years, has led to a tangible containment of both costs and environmental impact and to the development of more informed operating habits and conduct. For example, consolidated practices that have been continuously updated over the years, include the configuration of photocopiers with automatic shutdown settings, to help save electricity. In addition, Banco Mediolanum has implemented an ISO 14001 Environmental Management System, which certifies business development in compliance with the natural environment and pollution prevention, effective in 2025. In 2020, the Irish Group companies were also awarded ISO 14001 certification, with ongoing annual renewals until 2025. UoM Capex Opex Financial statement item Contributions for energy efficiency initiatives55 € 414,083.87 48,216.38 66,474.12 59,170.00 Capex - 90 - Property, plant and equipment Opex – 190 b) Other administrative expenses Targets IROs: Generation of direct and indirect GHG energy emissions from own operations (Scope 1 and 2) [E1-4 DP 32; 33; ESRS 2 MDR-T DP 80] The Mediolanum Banking Group is committed at all times to reducing energy consumption and its environmental impact, through the adoption of high-efficiency plants and the implementation of sustainable management practices. Initiatives include energy efficiency projects for operating structures and internal management systems, with the aim of minimising direct and indirect emissions. In parallel, the Group promotes a responsible procurement policy by selecting electricity suppliers that guarantee the quality and sustainability of their own energy portfolio, through Guarantee of Origin (GO) certificates. For further information, see ESRS E1-4, paragraph 2.2.2 Transition Plan, DP 33 for climate change mitigation. 55 The total of Capex and Opex was reported; the figure includes several initiatives carried out in 2025, aimed at energy efficiency.
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185 | Mediolanum Group - 2025 Annual Financial Report 2.2.4 Financed GHG emissions – Investments The Group’s approach and policies Since 2021, Banca Mediolanum and the Group Companies, which operate as financial market participants (FMPs), have been implementing specific responsible investment policies. [E1-2 DP 25] The following Policies address climate change mitigation and climate change adaptation aspects. [E1-2 DP 24; ESRS 2 MDR-P DP 65] IROs: Generation of indirect GHG emissions (Scope 3), in particular those attributable to counterparties included in own portfolio; Contribution to counterparties’ adaptation to climate change through the provision of insurance products Responsible Investment Policy of Banca Mediolanum Content and objectives Through its Responsible Investment Policy, Banca Mediolanum supports the transition to a more sustainable economy, in line with the European Union’s 2015 Action Plan, and aims to reduce the long-term indirect GHG emissions resulting from its investment activities. The Responsible Investment Policy, the latest update of which was approved by the Board of Directors of Banca Mediolanum in 2025, considers responsible investment to be a medium to long-term strategy that, in the assessment of undertakings and institutions, integrates financial analysis with environmental, social and governance analysis, in order to create value for investors and for the Company as a whole. According to the Policy, in carrying out the process of investment and therefore participation in the financial markets, the Bank takes ESG criteria into account in the selection of economic instruments and activities in which to invest and in the selection of financial partners, third-party management companies, that support it in investment activity. The sustainability positioning of investment products and the financial portfolio as a whole, as well as the approach adopted by third-party management companies, are constantly monitored by the Bank to ascertain their compliance with the criteria and guidelines established. In order to carry out the appropriate assessments used to make investment decisions, Banca Mediolanum uses information and data processed by market players with consolidated methodologies that are consistent with its own approach, thereby ensuring an objective point of view, as well as access to the most up-to-date information. The Bank believes that it is necessary to assess the negative effects on the sustainability factors generated through its activities and has therefore adopted dedicated safeguards and measures. The Bank considers sixteen mandatory PAI indicators (pursuant to Regulation (EU) 2019/2088) against which financial products are measured. The Bank has identified four priority PAI indicators primarily based on the following drivers: core values that inspire the corporate mission and vision; the availability of data for each indicator from the reference provider (MSCI ESG Research). Based on these drivers, in the Climate and Environment area, out of the nine mandatory indicators of the principal adverse impacts on sustainability applicable to investments in investee companies, the Company decided to prioritise the issue of greenhouse gas emissions: PAI 1 - Greenhouse gas emissions; PAI 2 - Carbon footprint; PAI 3 - GHG intensity of investee companies. In the Social and Governance area, out of the five mandatory indicators for principal adverse impacts on sustainability applicable to investments in investee companies, the Bank has chosen to prioritise gender diversity, identifying the following as a priority indicator:
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186 | Mediolanum Group - 2025 Annual Financial Report PAI 13 - Board gender diversity. In line with the requirements of the SFDR, the Bank has selected two additional indicators alongside the mandatory ones: Additional PAI in the environmental area: PAI 4 - Investments in companies that do not take initiatives to reduce carbon emissions. Additional PAI in the social area: PAI 9 - Lack of a human rights policy. Scope of application The Responsible Investment Policy is aimed at all Banca Mediolanum structures that implement investment decisions, with regard to both the products and services issued and offered to customers (e.g. both individual portfolio management and own-account investment activity. The Bank applies investment criteria consistent with Articles 8 and 9 of the SFDR and complies with the prohibition on financing companies involved in the production of anti-personnel mines and cluster bombs. Highest level of management responsible for implementation The Policy is approved by the Board of Directors of Banca Mediolanum. The Chief Executive Officer, in his/her capacity as a management body, implements the strategic guidelines in the area of sustainability and, in general, those related to ESG issues defined by the Board of Directors. He/she also defines and manages the implementation of a structured process to approve investments, the distribution of new products or services or the launch of new activities or entry into new markets. Regulations and reference standards The Bank has developed its Responsible Investment Policy based on the United Nations Principles for Responsible Investments (UN PRI) and taking into account the main legislative and regulatory references on the subject such as, but not limited to, the SFDR (Regulation (EU) 2019/2088), the Taxonomy Regulation (Regulation (EU) 2020/852) and regulatory technical standards (RTS (EU) 2022/1288). Method of dissemination The Responsible Investment Policy is available on the Bank’s website at www.bancamediolanum.it, in the section ‘Sustainability Information’. Internally, the Policy has been disclosed through a circular and is available to employees on the company intranet. Banca Mediolanum Product Sustainability Policy Content and objectives Through the Policy in question, Banca Mediolanum promotes the digitalisation of the process of underwriting and use of the products of each line, and encourages the creation of products specifically related to sustainable issues, including climate change and a reduction in CO2 emissions. Banca Mediolanum, as manufacturer and distributor, acts in such a way that environmental, social and governance factors are taken into account throughout its ‘production process’. This is reflected, for example, in the design of digital solutions to reduce environmental impact; in the transparency of contractual conditions to encourage informed choices; in the development of inclusive and accessible products/services, also through the use of technology at the service of the customer; in the oversight of sales processes and in the progressive expansion of the range of sustainable products. The Bank’s offering is constantly monitored to ensure its quality and positioning in terms of sustainability over time, applied to all the main areas: banking, credit and protection products and services; investment products and services; responsible investment processes and the distribution of financial products.
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187 | Mediolanum Group - 2025 Annual Financial Report Scope of application The Policy is directly applicable to all of the Bank’s organisational units, with reference to the processes for the design, creation and management of products and services available to customers, including banking, credit, protection and investment products. Highest level of management responsible for implementation This Policy is approved by the Board of Directors of Banca Mediolanum – the Parent Company of the Mediolanum Group. The Chief Executive Officer, in his capacity as a management body, is responsible for implementing strategic guidelines in the area of sustainability, the RAF (Risk Appetite Framework) and risk governance policies in the area of sustainability and, more generally, relating to ESG matters defined by the Board of Directors. Regulations and reference standards Banca Mediolanum has developed the Policy, taking into consideration the main European and national regulations, including, but not limited to, the SFDR (Regulation (EU) 2019/2088 on sustainability -related disclosures in the financial services sector), the CSRD (Directive (EU) 2022/2464 as regards corporate sustainability reporting), MiFID (Directive (EU) 2014/65), IDD (Directive (EU) 2016/97 on insurance distribution), and EBA guidelines (EBA/GL/2015/18 and EBA/REP/2020/28) on Product Oversight and Governance (POG). Method of dissemination Internally, the Policy has been disclosed through a circular and is available to employees on the company intranet. Externally, the principles of the Policy are described through sustainability reporting. Banca Mediolanum’s Policy on investment advisory services and distribution strategy for financial instruments and insurance investment products Content and objectives As a distributor of investment products, Banca Mediolanum favours the transition to a more sustainable economy by assessing the commitment of its partner producers to ESG issues and making climate-related investment solutions available to its customers, among other things. The Investment Advisory Services Policy and distribution strategy for Banca Mediolanum’s financial instruments and insurance investment products, the latest update of which was approved by Banca Mediolanum’s Board of Directors in 2025, aims to: understand the risks and opportunities not captured by conventional financial analysis; monitor the possible contribution of products to the generation of negative – significant or potentially significant – impacts on sustainability factors. The process of integrating sustainability considerations takes place in two stages: analysis (assigning an ESG score to investment products and assessing their positioning on the basis of ESG metrics) and monitoring (continuous verification of the ESG score of each distributed investment product and identification, within the range, of any products with an inadequate ESG positioning in order to activate appropriate mitigation actions). In the process of selecting the financial instruments to be distributed, Banca Mediolanum carries out an ESG assessment of the third-party management companies that produce the instruments (Due Diligence). As distributor, the Bank considers the principal adverse impacts (PAI) on sustainability factors and therefore includes in its product catalogue products that take into account the adverse effects of investments on environmental, social and governance factors. Sustainability risks are integrated into the financial advisory process carried out by the Bank, in particular: collecting customer sustainability preferences by completing a specific questionnaire entitled ‘Personalised Advice Profile’ with respect to the possibility of subscribing to financial instruments with sustainability characteristics;
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188 | Mediolanum Group - 2025 Annual Financial Report offering customers one or more products from the catalogue that reflect their sustainability preferences. Scope of application This Policy is directly applicable within all the Bank’s organisational units involved in the strategy for the distribution of investment products covered by the advisory service. Highest level of management responsible for implementation The Policy is approved by the Board of Directors of Banca Mediolanum. The Chief Executive Officer also approves the services and products offered to customers, ensuring their compatibility with the needs, characteristics and objectives of target customers and proposes the distribution strategy to the Board of Directors. Regulations and reference standards Banca Mediolanum has developed its own Financial Product Distribution Strategy Policy, taking into account the main European and national regulations, including, but not limited to, MiFID II (Directive (EU) 2014/65), Directive (EU) 2016/97 on insurance distribution (IDD), and the SFDR (Regulation (EU) 2019/2088) on sustainability-related disclosures in the financial services sector). Method of dissemination Internally, the Policy has been disclosed through a circular and is available to employees on the company intranet. Externally, the principles of the Policy are described through sustainability reporting. Responsible Investment Policy of Mediolanum Gestione Fondi Content and objectives Mediolanum Gestione Fondi’s Responsible Investment Policy (last updated in November 2024), describes how the SGR integrates the analysis of risks and sustainability factors in its investment processes, in accordance with the principles set at group level by the Parent Company, Banca Mediolanum, and in compliance with the provisions of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector. The responsible investment approach adopted by MGF is based on the following four aspects: the integration of sustainability factors and risks into the investment process: based on an analysis of the information from infoproviders selected by the SGR regarding the ESG rating assigned by them to the companies subject to analysis and possible investment, to the continuous monitoring of news in the area of sustainability, both at macro level and at individual issuer level; the monitoring of sustainability risks in the investment process: where the SGR checks that the ESG score of funds is satisfactory overall and stable over time and that overall exposure to companies/UCIs with a low rating (so-called laggards) or without any rating, falls within the limits approved by the Company’s Board of Directors on the basis of the specific investment policy of each fund; consideration of the principal adverse impacts on sustainability factors deriving from investment activities, in order to monitor, contain and reduce, in the long term, the effects of investment choices that determine negative impacts on sustainability factors; shareholder action and engagement: this includes, where appropriate, organising specific meetings with issuing companies (individual engagement or collective engagement with other institutional investors), with the aim of understanding their exposure to ESG risks/opportunities, but also of raising awareness among the management of the companies in which they are invested, or in which they would like to invest, towards a constant commitment to improving corporate governance practices and good social/environmental conduct.
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189 | Mediolanum Group - 2025 Annual Financial Report Scope of application The principles contained in the Responsible Investment Policy of Mediolanum Gestione Fondi apply to the investment activities carried out by MGF for all the products managed (also received under delegation from third parties), consistently with the specific features of each product, as indicated in the offer and/or contractual documentation for the products. The SGR requires any delegated third-party managers to adhere to the instructions contained in the Policy or have adopted their own consistent guidelines. Highest level of management responsible for implementation The Board of Directors is responsible for defining the principles on responsible investment contained in the Responsible Investment Policy of Mediolanum Gestione Fondi. The Chief Executive Officer verified the correct application of the principles contained in the document. Regulations and reference standards Mediolanum Gestione Fondi has adopted the Responsible Investment Policy in order to comply with the transparency objectives established by Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector and by Commission Delegated Regulation (EU) 2022/1288, supplementing Regulation (EU) 2019/2088. Since 2023, the SGR has been a signatory to the United Nations Principles for Responsible Investment (PRI), and Mediolanum Gestione Fondi has been an ordinary member of the Sustainable Finance Forum. Lastly, since 2017, MGF has adhered to the Italian Principles of Stewardship of Assogestioni, the Asset Management Association. Adopted in 2013, these principles are for companies that provide collective asset management or portfolio management services in order to encourage dialogue and collaboration between management companies and the listed issuers in which they invest. Method of dissemination The Responsible Investment Policy of Mediolanum Gestione Fondi is available on the Company’s website www.mediolanumgestionefondi.it, in the section ‘Sustainability Information’. Internally, the Policy has been disclosed through a circular and is available to employees on the company intranet. Responsible Investment Policy of Mediolanum International Funds Content and objectives The Responsible Investment Policy of MIFL, the latest update of which was approved in 2025, considers responsible investment a medium/long-term strategy that, in the assessment of companies and third-party asset managers, integrates financial analysis with environmental, social and good governance analysis, in order to create value for investors and for society as a whole. MIFL is committed to supporting all 17 United Nations Sustainable Development Goals (SDGs); in particular, it has prioritised the following goals: (i) gender equality (SDG 5), (ii) affordable and clean energy (SDG 7), (iii) responsible consumption and production (SDG 12) and (iv) climate action (SDG 13). To measure its impact on these SDGs, MIFL selected 6 priority PAIs: PAI 1 Greenhouse gas emissions (including Scopes 1, 2 and 3), PAI 2 Carbon footprint, PAI 3 GHG intensity of investee companies, PAI 5 Share of non-renewable energy consumption and production, PAI 9 Hazardous waste and radioactive waste ratio and PAI 13 Board gender diversity. Since 2021, through the PAI indicators, MIFL has been monitoring its AUM with respect to the climate. In 2025, MIFL launched a project to define a plan to reduce the CO2 generated by investments. This plan aims to reduce the modified Carbon Footprint by 70% (Scope 1 and 2) by 2050 (compared to 2022, the baseline year), with respect to products considered within the meanings of Articles 8 and 9 as of July 2025. In compliance with Italian Law No. 220 of 2021, MIFL complies with the prohibition on all forms of financing, including through investment, of companies involved in the production of anti-personnel mines and cluster
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190 | Mediolanum Group - 2025 Annual Financial Report bombs. In this regard, MIFL applies the ‘Mediolanum Group Policy on combating the financing of companies producing anti-personnel mines, cluster munitions and sub-munitions’ issued by Banca Mediolanum. Scope of application The Responsible Investment Policy applies to MIFL’s Assets Under Management and not only to those assets classified within the meaning of Article 6 or 8 and 9 of the Sustainable Finance Disclosure Regulation (SFDR). In organisational terms, the policy applies to both the multi-management and Single Securities investment teams. Highest level of management responsible for implementation The Board of Directors and Chief Executive Officer of MIFL are respectively responsible for approving and implementing the Policy. Regulations and reference standards MIFL, as part of the Mediolanum Group, has developed its Responsible Investment Policy taking into account the main European and national regulations, including, but not limited to, the SFDR (Regulation (EU) 2019/2088) on sustainability-related disclosures in the financial services sector), the guidelines on the use of environmental, social and governance terms or those relating to sustainability in fund names, and the Taxonomy Regulation (Regulation (EU) 2020/852). Method of dissemination The Responsible Investment Policy of Mediolanum International Funds is available on the Company’s website www.mediolanuminternationalfund.it, in the section ‘Sustainable investments’. Internally, the Policy has been disclosed through a circular and is available to employees on the company intranet. Policy on Responsible Investment of Mediolanum Vita Content and objectives The Responsible Investment Policy of Mediolanum Vita, the latest update of which was approved in 2025, outlines the investment guidelines, with specific reference to the integration of ESG criteria in investment decisions. The Policy provides for the integration of sustainability risk assessments into the investment process, including the selection of and investment in funds and securities, as well as the assessment of third-party management companies. Policy implementation is monitored by analysing sustainability risks and considering the principal adverse impacts (PAI) on sustainability factors, in order to limit the potentially adverse impacts associated with investment activities over time. The Company considers 16 mandatory PAI indicators (pursuant to Regulation (EU) 2019/2088). In accordance with the requirements of the SFDR, and the approach established by the Parent Company, the Company monitors and prioritises the following four indicators: PAI 1 - greenhouse gas emissions, PAI 2 - carbon footprint, PAI 3 - GHG intensity of investee companies, PAI 13 - Board gender diversity. Regulation (EU) 2019/2088 requires the selection of two other optional indicators - one environmental and one social. In accordance with the approach previously defined for prioritising PAIs, Mediolanum Vita selected: PAI 4 Environmental - investments in companies without carbon emission reduction initiatives, PAI 9 Social - lack of a human rights policy. The continuous measurement of indicators over time serves to monitor the risk of investment-related potentially adverse impacts on sustainability factors and their improvement in the long term. Mediolanum Vita, in line with the Parent Company’s instructions for the Conglomerate, has embarked on a process of gradual internalisation of climate matters into the internal risk, organisational and business processes and safeguards. In general, in terms of investments, Mediolanum Vita periodically monitors the positioning of products in relation to specific climate indicators. In compliance with Italian Law No. 220 of 2021, Mediolanum Vita complies with the prohibition on all forms of financing, including through investment, of companies involved in the production of anti-personnel mines and
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191 | Mediolanum Group - 2025 Annual Financial Report cluster bombs. In this regard, Mediolanum Vita applies the ‘Policy on combating the financing of companies producing anti-personnel mines, munitions and cluster sub-munitions of the Mediolanum Group’ issued by Banca Mediolanum. Scope of application The Policy applies to the investment activities of Mediolanum Vita with reference to investments on own account, the assets underlying the investment and pension insurance products and the portfolio received under a management mandate from Mediolanum Assicurazioni. The Responsible Investment Policy is directly applied within all of Mediolanum Vita’s organisational units. Highest level of management responsible for implementation The Policy is approved by the Board of Directors of Mediolanum Vita. The Chief Executive Officer implements strategic guidelines and decisions on the integration of ESG principles within the Company, as well as the application of the Policy. The Markets and Insurance Assets Unit is responsible for preparing and updating it. Regulations and reference standards Mediolanum Vita has developed the Responsible Investment Policy, based on the United Nations Principles for Responsible Investments (UN PRI), of which it is a signatory. In drafting the Policy, it also took into account the main legislative and regulatory references on the subject, including, but not limited to, the SFDR (Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector), the Taxonomy Regulation (EU 2020/852) and EU Delegated Regulation 2022/1288, which supplements EU Regulation 2019/2088 with regard to regulatory technical standards (RTS). Method of dissemination The Responsible Investment Policy is available on the Company’s website at www.mediolanumvita.it, in the section ‘Sustainability Information’. Internally, the Policy has been disclosed through a circular and is available to employees on the company intranet. Policy for Products and Responsible Investment of Mediolanum International Life Content and objectives The Policy for Products and Responsible Investment, which was last updated in 2024, also outlines the roles, procedures and tools to support the integration of ESG factors into investment processes. MIL has appointed MIFL, a Group Company, as its delegated investment manager. MIFL provides discretionary portfolio management services to MIL. The delegated manager has implemented a responsible investment policy that demonstrates its commitment to integrating environmental, social and governance factors into its investment analysis and decision-making processes and into the active exercise of shareholder rights, and is in line with Banca Mediolanum’s approach. Although there may be substantial differences between the legal structures and the mandates conferred by different customers, the delegated manager follows a consistent process and implements a common governance framework for all its investment management activities. To help focus its responsible investment ambitions, MIL has decided to prioritise four Sustainable Development Goals (SDGs): SDG 5 Gender equality, SDG 7 Affordable and clean energy, SDG 12 Responsible consumption and production and SDG 13 Climate action. The impact on these priority SDGs is monitored through Principal Adverse Impact (PAI) indicators, with a focus on six key indicators which are tracked by the delegated manager through monitoring activities, engagement and voting policies consistent with the selected SDGs. The ‘ESG integration’ approach, adopted by MIL and outlined in its Policy, is applied to the investment decisions of the assets underlying insurance products in different ways, depending on the type of financial instrument, its materiality and its ability to influence ESG characteristics. For the purposes of this definition of Policy, the relevant assets may be classified as investment fund and securities.
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192 | Mediolanum Group - 2025 Annual Financial Report Scope of application The Policy applies to the investment activities of Mediolanum International Life dac with regard to both its own investments and those of the underlying assets of its insurance and investment products. Highest level of management responsible for implementation The Board of Directors and General Manager of MIL are responsible for approving the Policy and for its implementation. Regulations and reference standards MIL establishes the Policy to meet the transparency rules and objectives established in Regulation (EU) 2019/2088 on sustainability-related disclosures and Commission Delegated Regulation (EU) 2022/1288. In addition to the SFDR, MIFL takes other regulatory guidelines, expectations and/or obligations into account in its approach to responsible investment, including: the ESMA guidelines on funds’ names using ESG or sustainability-related terms; Law No. 220 of 9 December 2021, as amended. Method of dissemination The Policy for Products and Responsible Investment is reviewed at least once a year and made public on the MIL website. Política sobre la Estrategia de Distribución de los Productos Financieros/ Politica sulla Strategia di Distribuzione dei Prodotti Finanziari di Banco Mediolanum Content and objectives The purpose of the Financial Products Distribution Strategy Policy, with the last update approved in April 2025, is to define the offering model of Banco Mediolanum for products subject to the investment advisory service. The principles governed by the Policy therefore apply to operating procedures for profiling, assessing appropriateness and suitability, and procedures relating to the marketing of products. Banco Mediolanum combines economic and profitability objectives with social, environmental and governance (ESG approach) objectives in its financial instrument selection process. In order to pursue these objectives, the Bank develops and adopts an approach aimed at: integrating sustainability risks into financial advice; considering the main adverse impacts on sustainability factors in consulting. As distributor, Banco Mediolanum considers the principal adverse impacts (PAI) on sustainability factors and therefore includes in its product catalogue products that take into account the adverse effects of investments on environmental or social and governance factors. Sustainability risks are integrated into the financial advisory process carried out by Banco Mediolanum, in particular: collecting customer sustainability preferences by completing a specific questionnaire, with respect to the possibility of subscribing to financial instruments with sustainability characteristics; offering customers one or more products from the catalogue that reflect their sustainability preferences. Scope of application The Policy applies directly to all the organisational units of Banco Mediolanum involved in the strategy for the distribution of investment products covered by the advisory service. Highest level of management responsible for implementation The Policy has been approved by the Board of Directors of Banco Mediolanum. The Chief Executive Officer is responsible for applying the principles and guidelines governed by the Policy.
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193 | Mediolanum Group - 2025 Annual Financial Report Regulations and reference standards Banca Mediolanum has developed its own Financial Product Distribution Strategy Policy, taking into account the main European and national regulations, including, but not limited to, the SFDR (Regulation (EU) 2019/2088) on sustainability-related disclosures in the financial services sector), MiFID II (Directive (EU) 2014/65), Directive (EU) 2016/97 on insurance distribution (IDD) and the Taxonomy Regulation (Regulation (EU) 2020/852). Method of dissemination Internally, the Policy is available in a dedicated repository on the company intranet, where it can be viewed by employees. Externally, the principles of the Policy are described through sustainability disclosures. ESG risk integration policy of Mediolanum Gestión and Mediolanum Pensiones/Política de integración de riesgos ESG de Mediolanum Gestión y Mediolanum Pensiones Content and objectives The aim of the ESG Risk Integration Policy is to gather the general principles of action for the integration and assessment of sustainability risks and for the identification, management and moderation of possible PAIs in the investment process of Mediolanum Gestión and Mediolanum Pensiones. Both companies (Mediolanum Gestión and Mediolanum Pensiones) combine their economic and profitability targets with their social, environmental and governance targets (ESG approach). In pursuit of the above objectives, the Companies are developing and adopting an approach for: understanding, through environmental social and governance (ESG) factors, any risks and opportunities not detected by conventional financial analysis; monitoring the possible contribution of products to the generation of adverse impacts - significant or potentially significant - on sustainability factors. Once the necessary information has been obtained, the process for their analysis and assessment can be divided into two stages: analysis (the allocation of ESG scores through a series of metrics to determine, from a quantitative perspective, whether it is possible to invest in a given asset based on the sustainability risk present) and monitoring (continuous review of the ESG metrics and scores of each product, as well as the information used for their assessment, in order to identify and moderate possible deviations, and to report them, if necessary, to those responsible for their resolution). Mediolanum Gestión and Mediolanum Pensiones may delegate investment management to third-party entities. In this case, it will be the responsibility of these entities to correctly apply the sustainability risk integration guidelines contained in the relative Policy. Scope of application The Policy applies to the directors, shareholders, managers, employees and agents of both Companies (Mediolanum Gestión and Mediolanum Pensiones). Highest level of management responsible for implementation The ESG risk integration policy is approved by the Boards of Directors of the respective Companies and the Chief Executive Officer is responsible for the application of the principles and guidelines set out therein. Regulations and reference standards The main laws and regulations used to prepare this document are as follows: Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying the details of the content and presentation of the information in relation to the principle of ‘do no significant harm’.
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194 | Mediolanum Group - 2025 Annual Financial Report CNMV Communication of 18 February 2021, on the application of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector. CNMV Questions and Answers on Sustainability Regulations Applicable to Financial Products: Regulation 2019/2088 (SFDR) and Regulation 2020/852 (taxonomy). Method of dissemination The ESG Risk Integration Policy is available on the websites of Mediolanum Gestión and Mediolanum Pensiones respectively, in the section ‘Disclosure of Sustainability Information’. The Policy is also available in a repository on the company intranet, where it can be viewed by employees. IROs: Physical risks and transition risks associated with climate change ESG Risk Management Policy of the Mediolanum Group Content and objectives In 2024, Banca Mediolanum, as the Parent Company of the Banca Mediolanum Group, updated the ‘Mediolanum Group ESG Risk Management Policy’, which focuses on understanding and assessing how ESG risks may impact the risks that characterise the business lines and strategies defined by the Group. The framework adopted in the aforementioned Policy allows the Group to have specific management indicators that are monitored continuously, as well as to outline climate and environmental risk factors, transmission channels and to carry out appropriate materiality screening, in accordance with the various types of risk, data and tools available, on traditional risk categories. The Policy on ESG Risk Management of the Mediolanum Group incorporates the internal documentation in effect within the framework of the Risk Management Function pertaining to the type of risk in question, to which reference is made. Like all the other risk management policies, it was set out following the adoption of the Risk Appetite Framework (RAF) document by the Mediolanum Group. The document, having presented the reference strategic principles and guidelines for managing ESG risks, also describes the ESG risk identification and assessment processes (with the relative allocation of roles and responsibilities) and the applicable integration and governance models for the entire Mediolanum Group (i.e. both the Banking Group and the Insurance Group). The Mediolanum Group monitors climate and environmental risks through metrics integrated into the Risk Appetite Framework and banking processes, including the sustainability indicator for corporate credit, designed to represent the share of exposure that does not meet sustainable finance criteria, and the ESG indicator for own funds and third-party funds. In synergy with the process envisaged for Banca Mediolanum regarding ESG Risk Management, the Mediolanum Insurance Group has defined and uses Key Risk Indicators (KRIs) to limit the offer of funds with investment policies that are less sensitive to ESG issues and to measure the share of assets that do not comply with certain sustainability standards. During the first quarter of 2026, this Policy will be updated, in order to ensure full consistency with the guidelines published by the EBA, Guidelines on the management of ESG risks (EBA/GL/2025/01). These Guidelines (EBA/GL/2025/01) provide guidance for the management of ESG risks, establishing minimum standards and reference methodologies for identifying, measuring, managing and monitoring ESG risks, clarifying that these risks are not a new category of risk for a banking enterprise, but act as drivers that may affect all traditional risk categories. In this perspective, the Group is committed to integrating ESG factors and risks holistically within its risk management framework, developing strategies, policies and processes and robust systems for the identification, measurement, management and monitoring of these risks in the short, medium and long term.
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195 | Mediolanum Group - 2025 Annual Financial Report This includes taking a forward-looking approach and incorporating scenario analysis, starting with climate factors, to test the resilience of the Group’s business model and risk profile to the negative impacts of ESG factors. Scope of application The Policy is directly applicable within all of the organisational units of the Bank and is sent to all the Companies making up the Mediolanum Group, so that they can adopt it by resolution of their own corporate bodies, without prejudice to any specific provisions of local jurisdictions and their respective Supervisory Authorities. Highest level of management responsible for implementation The Chief Executive Officer, in his capacity as a management body, is responsible for implementing strategic guidelines in the area of sustainability, the RAF (Risk Appetite Framework) and risk governance policies in the area of sustainability and, more generally, risks relating to ESG matters defined by the Board of Directors. Regulations and reference standards With specific reference to climate and environmental (C&E) risks, this document has been prepared in accordance with the EBA’s ‘Guidelines on the management of environmental, social and governance risks’, the ECB’s ‘Climate and Environmental Risks Guide’ and EIOPA’s Delegated Regulation (EU) 2021/1256, amending Delegated Regulation (EU) 2015/35 (delegated acts) on the integration of sustainability risks into the governance of insurance and reinsurance undertakings. This Policy ensures compliance with obligations for the definition of a framework that enables the identification, measurement/assessment, monitoring and management of climate and environmental risks and the establishment of regular and transparent reporting mechanisms aimed at ensuring timely, precise, concise, understandable and substantial communications in this regard. Stakeholder involvement As part of the definition of the ESG Risk Management Policy, the Parent Company set itself the objective of ensuring proper management and mitigation of sustainability-related risks, also in order to protect the direct interests of internal stakeholders, while promoting the continuity and resilience of the Mediolanum Group’s business. Method of dissemination The ESG Risk Management Policy is part of the corporate internal regulations and is therefore available to all employees and internal stakeholders on the Mediolanum Group’s corporate systems.
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196 | Mediolanum Group - 2025 Annual Financial Report Actions [E1-2 DP 28; ESRS 2 MDR-A DP 68] IROs: Generation of indirect GHG emissions (Scope 3), in particular those attributable to counterparties included in own portfolio In order to facilitate the transition to a more sustainable economy and climate change mitigation in the financial system, the Group Companies have implemented a series of actions: 1. publication of the Statement on the principal adverse impacts of investment decisions on sustainability factors; 2. monitoring of climate indicators; 3. engagement; 4. offering sustainable climate-related products. 1. Publication of the statement on the principal adverse impacts of investment decisions on sustainability factors All the Group Companies that act as financial market participants (FMPs) published in June 2025 the update of the Annual Statement (in accordance with the provisions of Article 2 of Commission Delegated Regulation (EU) 2022/1288) that contains the measurement of the negative effects of investment activity on sustainability factors. This statement helps with both understanding the impact of investments on sustainability factors and promoting greater transparency towards investors and the market in general. For each of the indicators, transparency is provided on the value for the reporting period and on the actions undertaken or planned to achieve long-term improvement. This Statement includes a representation of the actions carried out/planned in relation to adverse effects. The value of the published indicators refers to the products and services for which Group Companies make investments. The monitoring of the PAI indicators is performed on a quarterly basis, while the Principal Adverse Impact Statement is published every year (by 30 June each year for the previous year). The objective of the monitoring is to produce a long-term improvement in indicators, particularly those identified as priority indicators, in the long term. Comparing 2024 with both previous periods, i.e. 2023 and 2022, an overall positive trend for most indicators, including priority indicators, is noted. 2. Monitoring of climate indicators In accordance with the 2024-2026 Business Plan, since the beginning of 2024, the Group Companies that operate as financial market participants have established the monitoring of a specific set of climate indicators. These include: The E component of the ESG rating; PAI 1 – Absolute CO2 emissions; PAI 2 – Carbon footprint; PAI 3 – Carbon intensity; Additional PAI 4 – Investments made in undertakings that do not have initiatives in place to reduce carbon emissions; Weighted Average Carbon Intensity (WACI); Implied Temperature Rise (ITR). This monitoring is formalised in quarterly reports and, for each Group Company, is subject to periodic information flows to the respective senior managers.
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197 | Mediolanum Group - 2025 Annual Financial Report The indicators monitored refer to the products and services for which the Group Companies make investments. Analysis of the selected climate indicators shows a substantial alignment with the market and a slight improvement compared with the first measurement. 3. Engagement The Group Companies are committed to positively influencing the reference financial ecosystem by pursuing engagement with third-party management companies and investee companies. Banca Mediolanum In the reporting year, Banca Mediolanum conducted a climate due diligence assessment on third-party management companies through the ESG Due Diligence Questionnaire (ESG-DDQ). This activity, which supported the selection of third ‐party management companies, focused on verifying companies’ decarbonisation targets and the compliance of the products offered with the Paris ‐Aligned Benchmarks (PAB) and Climate Transition Benchmarks (CTB). Based on the results of this assessment, the Bank plans to refine the criteria of the questionnaire to align them with regulatory developments and intensify the dialogue with companies showing gaps. The target is third-party management companies that issue financial instruments in which the Bank invests. Engagement with third-party management companies is ongoing and is aimed at improving their long-term approach to sustainability. Currently, there have been no cases of actual material harm directly attributable to the activities related to the Bank’s investments that have required specific remedial actions. Mediolanum Gestione Fondi Mediolanum Gestione Fondi (MGF) believes that ongoing dialogue with investee issuers allows long-term value to be protected by proper risk management. To this end, MGF adheres to the Italian Stewardship Principles issued by Assogestioni, the application of which is detailed in the ‘Policy of Commitment and Exercise of Intervention and Voting Rights Relating to Financial Instruments held by the Managed UCIs’, approved by the Board of Directors and published on the Company website. During 2025, MGF held around 300 meetings with investee issuers, of which around 50 related to environmental, social and governance matters. Engagement is one of the safeguards established through Mediolanum Gestione Fondi’s Responsible Investment Policy, which applies to all assets under management, to all geographical regions and to the entire Investment Team. With regard to environmental matters, the meetings held by MGF focused on the issuers in which the SGR holds significant equity investments or the companies for which the analyses carried out revealed a need for further analysis. MGF carries out continuous monitoring in order to detect any critical issues. The main ways of helping to mitigate material impacts related to significant shareholdings in specific companies are the organisation of individual or collective engagement, possible manifestation of dissent at the Shareholders’ Meeting and possible partial or total divestment.
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198 | Mediolanum Group - 2025 Annual Financial Report Mediolanum International Funds With regard to Mediolanum International Funds, the manager selection team (multi-manager team) collaborates at least twice a year with each investment team for all external strategies classified as Article 6 of the SFDR. During 2024, at the time of the last available survey, the team collaborated with all external managers responsible for 121 strategies (latest available data). During 2024, the Single Securities Fundamental Equities team collaborated with 50 target companies in its portfolios on topics directly related to priority PAIs for MIFL. There was an improvement in five of MIFL’s six priority PAIs in 2024 compared to 2023, although the data provider (MSCI ESG Research) changed its approach in 2024 for two of the indicators, making the values not directly comparable: the increase in absolute value of PAI 1 Greenhouse Gas Emissions was mainly due to the growth of assets under management. The reduction in the indicators, Carbon Footprint (PAI 2) and Emissions Intensity (PAI 3), is mainly due to changes in the investment portfolios and improvements in the emissions data of underlying companies. For PAI 5 (Share of Non-Renewable Energy Consumption and Production) and PAI 9 (Hazardous Waste Ratio), during the reporting period - the calendar year 2024, MSCI included not only the information reported by the investee companies but also estimated data, to improve the coverage of the data of this indicator. Therefore, the 2024 value cannot be directly compared with the values of previous years. PAI 13 (Board Gender Diversity) remained stable with a slight improvement. In 2025, MIFL voted on a number of proposals regarding greenhouse gas emissions, including directors’ responsibility for risk mitigation strategies, support for shareholder proposals that require greater transparency on greenhouse gas emissions and strategies, and voted in favour of shareholder proposals requiring companies to report on climate change actions. Engagement is one of the safeguards established by MIFL’s Responsible Investment Policy, which applies to all assets under management, all geographic regions and the entire Investment Team. The engagement and proxy voting actions detailed in the MIFL Responsible Investment Policy are performed on an annual basis. That is, for each calendar year, the actions are performed, monitored and reported. The full results of 2025 engagement activities have not yet been finalized and will be available in the first quarter of 2026. Mediolanum Vita Mediolanum Vita performs annual due diligence on third-party management companies, in order to assess and monitor their commitment to their approach to sustainability. Due diligence may be carried out by examining the available documentation and administering specific questionnaires, or by engaging the investment manager directly. The due diligence (or qualitative assessment) on third-party managers is carried out by the Active Insurance Markets Unit, with the advice of the MIFL Advisor for the asset managers of the funds underlying the My Life and Mediolanum Intelligent Life Plan policies, assigning a score based on the level of integration of ESG factors. The assessment is mainly based on the following five aspects: External Assessments & Ratings: adherence to international initiatives promoting dialogue on sustainability matters (Principles for Responsible Investment, Principles for Sustainable Insurance, Stewardship Principles) and external assessments (e.g. UnPRI, Mercer, Shareaction, etc.); ESG Governance: implementation of an internal regulatory framework (possible remuneration policy related to ESG objectives) and structures focused on sustainability (the presence of a dedicated team, number of resources and related responsibilities); ESG Philosophy & Tools: the presence of responsible investment approaches within investment processes (e.g. an ESG or sustainability policy) and use of specialist information providers (e.g. the number of external providers used to support the ESG approach);
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199 | Mediolanum Group - 2025 Annual Financial Report UN SDGs, Environmental and Social Considerations: consideration of the United Nations Sustainable Development Goals (SDGs), PAIs and any climate goals and decarbonisation targets (e.g. adherence to the Net Zero Asset Managers Initiative (NZAMI), climate report). ESG integration within the parent’s fund range: a range of sustainable products within the meaning of the SFDR Regulation (% of funds with ESG integration process, Article 8 and Article 9). In addition to the qualitative assessment, the Insurance Markets and Assets Unit also verifies sustainability indicators (such as ESG ratings and scores, PAIs and climate indicators), monitoring their evolution over time to identify any critical issues. Where necessary, benchmarking and engagement activities are carried out. In addition, asset managers mentioned in public reports of alleged greenwashing or regulatory violations (e.g. Law 220/2021) are also monitored and engaged. The scope of this activity consists of the third-party investment companies that issue the products for which Mediolanum Vita plays the role of financial market participant (FMP). The due diligence on third-party management companies is ongoing, updated annually and aimed at improving their approach to sustainability in the long term. Any asset managers that are deemed to be of negative quality are subject to further investigation and/or engagement. The objective is to improve the integration process for asset managers that are ‘laggards’ and/or those with a negative qualitative assessment (score 1). Since the start of monitoring, there have been no asset managers with a negative qualitative assessment. In 2025, engagement activities were conducted with some asset managers with sustainability indicators (e.g. Carbon Footprint – PAI 2 or Carbon Intensity – PAI 3) that were above the average of the funds in the same category, with the aim of promoting improvement over time and increasing awareness of sustainability information. Further engagement activities concerned asset managers mentioned in public reports of alleged greenwashing or regulatory violations (e.g. Law 220/2021). Mediolanum Gestión SGIIC, S.A. and Mediolanum Pensiones SGFP, S.A. Since 2022, Mediolanum Gestión SGIIC, S.A. and Médiolanum Pensiones SGFP, S.A., as part of the process of integrating sustainability risk, have been monitoring the companies and assets in which they invest, examining their strategy, financial and non-financial results, capital structure and environmental, social and corporate governance (ESG) aspects. This monitoring is carried out by various means, taking into account the nature and volume of the exposure of both entities to the investee companies, including, inter alia, economic information platforms, corporate financial reports and ESG assessment tools. In addition, both entities recognise the importance of shareholder participation and the contribution that ESG considerations can make to investment outcomes. In this context, both entities interact with companies when more information is needed on questions such as strategy, financial and non-financial performance, risk, capital structure and ESG matters. In such cases, both entities actively participate by voting on the resolutions of the annual general meetings of shareholders in accordance with the established voting policy. In addition to exercising voting rights, there are other participation initiatives, such as the disclosure of voting to the companies and Chief Executive Officers, proactive management of litigation and continuous engagement with the portfolio companies to improve their sustainability performance. The scope of this activity consists of the third-party management companies that issue the investment financial instruments for Mediolanum Gestión and Mediolanum Pensiones, as financial market participants (FMP). Engagement activities with third-party management companies are ongoing and aim to improve their approach to long-term sustainability.
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200 | Mediolanum Group - 2025 Annual Financial Report For investment companies in which some aspects were found to not fully comply with their principles, the Group Companies (Mediolanum Gestión and Mediolanum Pensiones) voted against decisions that were not in line with the principles established in the voting policy linked to sustainability aspects and a dialogue was established with the companies concerned to understand the reasons. In 2025, for Mediolanum Gestión, 16.28% of the vote contested were motivated by decisions not aligned with climate change mitigation targets. Similarly, for Mediolanum Pensiones, the figure of 16.87% was due to the lack of alignment with the positive approach to combating climate change. 4. Offering sustainable climate-related products To promote the transition and to help mitigate climate change, the Group Companies have provided their customers with certain sustainable climate-related investment products and services. These investment solutions are intended for all customers of Banca Mediolanum and Banco Mediolanum in line with their investment profiles and sustainability preferences. In particular, the offer includes approximately 20 investment solutions pursuant to Regulation (EU) 2019/2088 distributed among portfolio management services and investment funds of the various Group companies. Depending on their characteristics, these solutions promote environmental and social aspects or pursue specific sustainable investment target with exposure to topics such as energy efficiency, renewable energy and sustainable mobility. Details of individual solutions are described in information available online. [E1-2 DP 29 a] The actions described above in the context of the DP 28 are part of a process of a gradual focus on reducing GHG emissions associated with investments and, in this context, have helped to outline the approach subsequently formalised in the Transition Plan, approved by the Board of Directors of Banca Mediolanum in December 2025. In particular, the decarbonisation levers identified in the Transition Plan constitute the reference framework in which the initiatives already undertaken during 2025 are placed. Therefore, for further information on decarbonisation levers related to investments, see the Transition Plan (see ESRS E1 Climate Change, Paragraph 2.2.2 Transition Plan for Climate Change Mitigation, DP 16 b), as it reflects the strategic approach already started, through the actions described. [E1-2 DP 29 b] As regards results in terms of reducing GHG emissions, no timely and targeted monitoring of emissions-related impacts attributable to individual actions implemented had already been started in 2025. The structured monitoring system for financed emissions and the results of their reductions is in fact linked to the implementation of the Transition Plan, which will be fully operational from 2026 onward. However, the Transition Plan reports the data relating to current progress with respect to the objectives defined for investments, providing an initial picture of the overall progress, pending the start of systematic monitoring of individual actions as from 2026. [E1-2 DP 28; ESRS 2 MDR-A DP 68] IROs: Contribution to counterparties’ adaptation to climate change through the provision of insurance products Banca Mediolanum’s commitment to creating sustainability-focused products also includes part of Mediolanum Assicurazioni’s ‘home’ insurance offering, which includes, inter alia, coverage of damage caused by flooding, catastrophic events and natural events. In this case, the ‘Mediolanum Protezione Casa e Famiglia’ product, if taken out with the ‘Earthquake and Flood’ option, which covers damage to buildings as a result of catastrophic events, pays compensation if an earthquake or flood causes damage to the building. Through catastrophic event coverage and flood coverage, Banca Mediolanum and Mediolanum Assicurazioni implement safeguards aimed at climate change adaptation. This coverage, and coverage of property fire and explosions, are also very important in mitigating risk at the banking/credit and national level.
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201 | Mediolanum Group - 2025 Annual Financial Report The ‘Property - Earthquake and Flood’ coverage, available in the ‘Mediolanum Protezione Casa e Famiglia’ policy, is offered to all private customers of Banca Mediolanum. It is also offered individually to all customers who have already taken out a ‘Fire and Explosion’ policy with Mediolanum Assicurazioni. IROs: Physical and transition risks The Group integrates ESG risks in its internal capital and liquidity adequacy assessment processes (ICAAP and ILAAP), using climate scenarios to estimate the impact on credit risk, market risk, strategic risk and liquidity positions. One of the objectives of the Risk Management Function is to identify climate and environmental risks in order to understand and measure their impacts on the Company and Group environment, in the short, medium and long term, including in order to guide strategic decisions and ensure, by taking this route, the resilience of its business model. In this context, within the Risk Appetite Framework, the Group defines indicators, limits and thresholds related to ESG factors, in line with the results of the materiality assessment and with its own risk inventory. Targets IROs: Generation of indirect GHG emissions (Scope 3), in particular those attributable to counterparties included in own portfolio; Contribution to counterparties’ adaptation to climate change through the provision of insurance products [E1-4 DP 32; 33; ESRS 2 MDR-T DP 80] In accordance with the 2024-2026 Business Plan, since the beginning of 2024, the Group Companies that operate as financial market participants been monitoring a specific set of climate indicators and plan to set climate targets by 2026. In accordance with this commitment, the Group’s main asset managers, Mediolanum International Funds and Mediolanum Gestione Fondi, each prepared a plan to reduce the greenhouse gas (GHG) emissions generated by their investment activity. In particular, from 2026 both companies aim to reduce their Carbon Footprint by 70% (calculated on Scope 1 and Scope 2 emissions) by 2050, compared with 2022, generated by the investments selected in the case of MIFL and by the investments of the funds included in the analysis, in the case of MGF. These targets are part of the Transition Plan and the Group Sustainability Plan 2026-2030. For further information, see ESRS E1 Climate Change, paragraph 2.2.2 Transition Plan for Climate Change Mitigation, DP 33. The reduction targets formulated are therefore relative, since they are based on the Scope 1 and Scope 2 GHG emissions generated by investee companies in relation to their value (enterprise value) and the amounts invested. Stakeholder involvement was an integral part of the process of formulating the targets. MIFL consulted both internal and external stakeholders to identify and prioritize key material sustainability issues. These included MIFL’s ESG Team, MIFL’s Investment Committee and the delegated managers of the MIFL funds included in the analysis. With regard to MGF, the Emission Reduction Plan is inspired by the Net Zero Investment Framework (NZIF) – a guide created to support investors in defining investment strategies and targets in line with the net-zero emissions target by 2050 – thus contributing to the transition to a low-carbon economy with specific reference to the Asset Management context. The drafting of the reduction target involved corporate management and the governing bodies. The involvement of any external stakeholders will be assessed at a later date, during the periodic review of the targets and the scope of the analysis that will be implemented by the SGR in the coming years.
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202 | Mediolanum Group - 2025 Annual Financial Report The two Companies have defined specific decarbonisation levers, crucial for the actual achievement of the assumed targets: on the one hand, monitoring and engagement, which do not entail direct impacts on the composition of the portfolio and which allow for the identification of sectors and issuers that must be monitored as a priority, as well as companies to be actively involved; on the other hand, active sustainable management, in which managers may assess changes in the composition of the portfolio by favouring issuers that are more in line with net zero targets, albeit in compliance with economic and financial considerations. The Net Zero Investment Framework metrics, used to assess the degree of alignment of each issuer with the net zero targets defined by the framework, are applied by the infoprovider MSCI ESG Research, which provides services to the SGR. These metrics have been officially recognized by the Science Based Target Initiative (SBTI), an international organisation that supports companies in setting emissions reduction targets compatible with climate science. Tt the date of these analyses, however, the recognition obtained by the metrics does not concern the MSCI ESG Research estimates used to calculate future projections. Consequently, the recognition by SBTi cannot be extended to the objectives set by MGF. The Company ensures substantial consistency with climate science, since it includes, in the simulations performed, the targets set by issuers, in some cases recognized by SBTI. 2.2.5 Financed GHG emissions – Credit The Group’s approach and policies IROs: Increase in the market share of green mortgages, improvement in asset ‘quality’ and improvement in reputation, particularly towards the financial community (e.g. GAR) [E1-2 DP 24; 25; ESRS 2 MDR-P DP 65] In addition to the Code of Ethics and the Sustainability Policy of the Mediolanum Group, which refer to its approach and general guidelines, the main policies for managing impacts related to climate change mitigation and energy in the Credit area are Banca Mediolanum’s Product Sustainability Policy (see ESRS E1-Climate change, paragraph 2.2.4 Financed GHG emission-Investment, section ‘The Group’s approach and policies’ for further details on the minimum reporting requirements of the Policy), which defines how to integrate the sustainability dimension of products throughout the ‘production process’, including in relation to banking and credit products and services, and the internal Credit regulations. Within internal credit regulations, financing transactions with counterparties that have economic activities with strong environmental impact and with corporate purpose/activities not operating in sectors/fields that may expose the Bank to reputational risks (e.g. EROs, weapons, etc.) or that are in a serious state of economic depression are generally prohibited; it is also specifically prohibited to finance companies established in any legal form, based in Italy or abroad, that, directly or through Subsidiaries or affiliates, carry out activities that are part of the production chain for anti-personnel mines, cluster munitions and sub-munitions, of any nature or composition, or parts thereof. In addition, starting from 2021, some ESG safeguards were introduced, consisting of an assessment of ESG factors in the corporate credit portfolio (see ESRS G1 Business Conduct, paragraph 4.1.1 Corporate Culture, section ‘Actions’ for further information). With regard to the retail loans portfolio, in 2023, at the same time as the migration of the origination platform, information on the Energy Performance Certificate (EPC) and the physical risk score of the property were included in the credit assessment processes to secure the credit relationship. Banco Mediolanum also adopts the policies defined by the Parent Company, in particular the Code of Ethics, the Sustainability Policy and the internal credit regulations.
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203 | Mediolanum Group - 2025 Annual Financial Report Actions [E1-2 DP 28; ESRS 2 MDR-A DP 68] IROs: Increase in market share of ‘green’ mortgages, improvement in the ‘quality’ of assets and enhanced reputation, particularly towards the financial community (e.g. GAR); Generation of indirect GHG emissions (Scope 3), in particular those attributable to counterparties included in own portfolio To promote the transition and to help mitigate climate change, the Group Companies have over time provided their customers with certain sustainable climate-related credit products. The Mediolanum Bioedilizia+ mortgage is a loan for the purposes of purchase and exchange transactions on property built according to specific sustainability standards for environmentally-enhanced building with S.A.L.E. (Sistema di Affidabilità Legno Edilizia or ‘reliability in timber construction’) certification. (Wood Construction Reliability System) certification, or ‘Casa Clima’ or Arca certification. Green houses are sustainably built according to environmentally friendly construction techniques, using natural certified materials and integrating energy efficiency systems. During 2025, €0.54 mlnn was granted, or 0.03% of the total mortgages granted. Through the ‘Casa +’ initiative, the Group confirms its commitment to meeting the needs of its customers and, at the same time, supporting the construction sector by offering mortgages and subsidised loans for property renovation. This is also in line with the regulatory framework, which provides tax breaks for property renovations, energy reclassifications and measures to improve seismic risk, on the first home. The aim is to upgrade energy classes and reduce environmental impact through investment in alternative energy solutions, supporting sustainable construction projects. During 2025, the following were granted: • €14.29 mln in Casa+ mortgages, equal to 0.75% of total mortgages granted; • €20.63 mln in Casa+ loans, equal to 2.15% of total loans granted. As of April 2019, Banca Mediolanum’s customers can apply for a mortgage with a reduced spread (Mutuo Mediolanum Eco+), secured by a first mortgage, for buildings with high energy efficiency (energy class B, A, A+) for the purposes of purchase, exchange and subrogation transactions. In May 2024, the target was expanded to include Class C properties and the product was also repriced with a spread reduction from a minimum of 15 bps to a maximum of 30 bps. In 2025, €257.56 million in Mediolanum Eco+ mortgages were granted, representing 13.6% of total mortgages granted. Since 2025, the ‘after-sales’ option, which discounts the spread by 15 bps if the property financed improves by at least one energy class after renovation, initially for the Casa+ mortgage only, has been extended to all types of mortgages. Greenhouse gas (GHG) emissions, measured in kgCO2, recorded a decrease compared with the 2023 baseline, from 42,90 kgCO2 to 40,85 kgCO2. Banco Mediolanum also promotes energy efficiency through: Hipotecas Freedom Green/Mutui Freedom Green: a product dedicated to the purchase of properties with A or B energy certification. In 2025, €10,883,450 was granted in Freedom Green loans, equal to 5% of the total loans disbursed for home purchases. In terms of the overall portfolio, properties with an A or B energy class accounted for 7.4% as at 31/12/25; Eco Vehicle Loan/Eco Vehicle Loans: a product dedicated to the purchase of electric or hybrid vehicles with the ‘0 CO2 emissions’ label, offering higher financing and more advantageous terms. During 2025, €7,129,300 in ECO car loans were granted, representing 12.9% of total vehicle guarantee loans. Finally, during 2025, the Mediolanum Group carried out an in-depth analysis of the mortgage portfolio to ensure its alignment with the Group’s Climate Transition Plan (see ESRS E1 Climate Change, paragraph 2.2.2 Transition Plan for Climate Change Mitigation for further details), which sets concrete emission reduction targets and contributes to the decarbonisation of the portfolio.
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204 | Mediolanum Group - 2025 Annual Financial Report [E1-2 DP 29 a] The actions described above in the context of the DP 28 are part of a process of a gradual focus on reducing GHG emissions financed through credit and, in this context, helped to outline the approach subsequently formalised in the Transition Plan, approved by the Board of Directors of Banca Mediolanum in December 2025. In particular, the decarbonisation levers identified in the Transition Plan constitute the reference framework in which the initiatives already undertaken during 2025 are placed. Therefore, for further information on decarbonisation levers, see the Transition Plan (see ESRS E1 Climate Change, Paragraph 2.2.2 Transition Plan for Climate Change Mitigation, DP 16 b ), as it reflects the strategic approach already started, through the actions described. [E1-2 DP 29 b] As regards results in terms of reducing GHG emissions, no timely and targeted monitoring of emissions-related impacts attributable to individual actions implemented had already been started in 2025. The structured monitoring system for financed emissions and the results of their reductions is in fact linked to the implementation of the Transition Plan, which will be fully operational from 2026 onward. However, the Transition Plan reports the data relating to current progress with respect to the objectives defined for investments, providing an initial picture of the overall progress, pending the start of systematic monitoring of individual actions as from 2026. Targets IROs: Increase in market share of ‘green’ mortgages, improvement in the ‘quality’ of assets and enhanced reputation, particularly towards the financial community (e.g. GAR); Generation of indirect GHG emissions (Scope 3), in particular those attributable to counterparties included in own portfolio [E1-4 DP 32; 33; ESRS 2 MDR-T DP 80] Target Target KPI Year target Scope Baseline year and value Progress at 31/12/2025 Maintenance of an annual concession percentage of ‘Prestamo vehiculo ECO’ (zero‐emission vehicles) on the total of secured loans for the purchase of vehicles56 Annual percentage of ECO loans aligned to 12% 2030 Spain 2024 12.40% 12.90% Maintenance of a minimum portfolio level of loans granted for AA/AB energy-certified residential properties compared to total loans granted Percentage of the portfolio relative to AA/AB energy- certified residential properties ≥ 6% 2030 Spain 2024 6% 7.40% 56 Given the uncertainty in terms of regulatory developments affecting the automotive industry . 2024 data: electric passenger car registrations 11.4 % in Spain. Source: ANFAC, Spanish Association of Car and Truck Manufacturers.
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205 | Mediolanum Group - 2025 Annual Financial Report Increase in the share of ‘Hipotecas Freedom Green’ mortgages for purchasing residential properties with AA/AB energy certification as a share of total mortgages granted for houses The percentage of the portfolio relating to Hipotecas Freedom Green is 7.50% 2030 Spain 2024 5.50% 5.00% The above objectives are supplemented by a further target, included in the Transition Plan (see ESRS E1 Climate Change, paragraph 2.2.2 Transition Plan for Climate Change Mitigation ), relating to the reduction of financed emissions. In particular, the target set for 2030 provides for a reduction in the physical intensity of emissions financed by the mortgages portfolio from 42.87 to 32.3 kgCO 2 equivalent per square metre (kgCO 2e/m²). This new target replaces the two residential mortgage portfolio objectives set out in the previous 2024-2026 Sustainability Plan. For further information on the target, see ESRS E1 Climate Change, paragraph 2.2.2 Transition Plan for Climate Change Mitigation, DP 32. 2.2.6 Digitalisation of processes The Group’s approach and policies The Group’s main policies on sustainability and business conduct set out specific commitments on mitigating climate impact by dematerialising processes, including the Mediolanum Group’s Sustainability Policy and the Code of Ethics (see ESRS G1-1 Business conduct, paragraph 4.1.1. Business culture, section ‘The Group’s approach and policies’ for further details on the minimum reporting requirements of the Policies). In particular, within the Sustainability Policy, specifically in the pillar linked to responsibility to the community and the environment, the Mediolanum Group outlines its commitment to plans and activities aimed at reducing environmental impacts, including the dematerialisation of products and services through the digitalisation of documentation. The Group’s Spanish and Irish companies adopt the Mediolanum Group’s Sustainability Policy, supplementing it with the adjustments necessary to take account of specific national aspects. [E1-2 DP 24; 25; ESRS 2 MDR-P DP 65] IROs: Cost reduction / Economic savings due to the progressive digitalisation of processes and benefits in terms of efficiency, including environmental benefits (e.g. reduced paper use and fewer physical journeys) In addition, in the Sustainability Policy for Products, Banca Mediolanum defines certain guidelines to be followed, as a manufacturer and distributor, so that environmental, social and governance factors are taken into account throughout its ‘production process’. One guideline is aimed at the commitment to design solutions that are as much as possible based on digital processes and supports to limit the consumption and indirect production of CO2 in the environment. This policy refers to climate change mitigation.
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206 | Mediolanum Group - 2025 Annual Financial Report Actions [E1-3 DP 28; ESRS 2 MDR-A DP 68] IROs: Cost reduction / Economic savings due to the progressive digitalisation of processes and benefits in terms of efficiency, including environmental benefits (e.g. reduced paper use and fewer physical journeys) In 2025, the Communication and Network Support Office consolidated its role as the reference for the Sales Network, thanks to the expansion of the channels and the creation of personalised content. In this context, My Marketing is Banca Mediolanum’s platform dedicated to customisable promotional and advertising material. It plays a central role in supporting the Sales Network, integrating innovation, efficiency and sustainability. Configured as a true e-commerce activity, My Marketing provides all the tools necessary to support the commercial negotiations, while ensuring compliance with the brand identity and the Group guidelines. During 2025, the platform was fully reorganised again to offer a more intuitive and faster browsing experience, allowing Family Bankers to easily locate the materials best suited to their needs. During the year, more than 25,000 orders were placed, of which about 4,300 were personalised, a significant increase compared with previous years. These data highlight not only the efficiency of the tool, but also the growing importance of personalisation and sustainability in support of the Network. At the same time, the digital offering brochure was further expanded, to include 78 available products in 2025 and over 20,000 downloads. These materials represent a modern and sustainable solution, reducing environmental impact through complete dematerialisation and contributing to climate change mitigation by reducing the consumption of physical resources. Alongside the digital materials, physical materials designed for specific contexts were developed, reflecting a strong commitment to sustainability. In fact, each product is made using production processes that meet high standards of environmental responsibility, including the use of FSC certified paper and the use of solar energy through dedicated photovoltaic systems. In terms of environmental sustainability, since the end of 2025, for all new master record entries, communications relating to the individual, i.e. not attributable to one or more specific contractual relationships (e.g., requests to update personal data, etc.) or concerning multiple specific relationships at the same time, are available exclusively online, in the Personal Area of Internet Banking and the Mediolanum App. In addition, the credit dematerialisation project, which started in November 2025, will aim to reduce the paper communications sent relating to loan agreements, mortgages and Selfy products (SelfyShop, SelfyCredit Instant and Selfy PayTime). Remaining on the topic of the efficiency of processes and the reduction of environmental impacts, during 2025 a programme was launched for the digitalisation of the operations of legal entities. The first projects that will go into in production during 2026 concern the digitalisation of the onboarding process and the possibility of digitally subscribing to investment products. These projects will not only bring environmental benefits, but will also improve operational efficiency. The initiatives to digitalise the underwriting processes launched by Banca Mediolanum as the distributor of MIFL and MIL products (e.g. digital signature of contractual documentation with savings in CO 2 emissions) generate environmental benefits that are also reflected in the activities of the latter. In line with the Group’s approach, Banco Mediolanum, as the distributor of MIFL and MIL products, also pursues similar initiatives for the digitalisation of underwriting processes, further contributing to reducing environmental impact. In particular, in 2025 Banco Mediolanum continued its digitalisation of operating processes, with the aim of streamlining activities, reducing the burden on staff and customers and cutting down on paper use. Finally, for Group Companies in Ireland, the transfer of the entire corporate IT infrastructure to cloud applications, starting in 2022, has resulted in further savings in terms of CO2.
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207 | Mediolanum Group - 2025 Annual Financial Report With regard to banking products and services, in 2025 Banca Mediolanum also invested in digitisation in order to meet the new needs of its increasingly smart and digital customers. In 2025, it also continued the process of improving banking products and services relating to sustainability, expanding, in May 2025, the monthly deposit limit from €4,999 to €10,000 for the Mooney service, offering an immediate advantage to customers, i.e. the possibility of paying in higher amounts monthly. The service is part of a digital and green-oriented development plan, using the application of Banca Mediolanum as the only platform through which the customer can operate. It also reduces cash management costs, including in terms of environmental sustainability and the supply chain (e.g. CO2 reduction due to the transportation of ATM refilling/emptying staff). The extension of the maximum amount of the deposit service alone has responded to customers’ appreciation for this specific service. In fact, 89% of the transactions carried out with Mooney only concern this service. Thanks also to the increase in the maximum deposit limit, the use of the Mooney service for the period January– November 2025 recorded a 49% increase compared to the same period in 2024, both in terms of the number of transactions and, above all, in the geographical area where cash use is highest. The service also contributes to meeting basic transactional needs, which to date are not always met by banks due to the rationalisation of bank branches, which leaves customers without a physical reference for basic banking transactions. Therefore, the Mooney withdrawal and payment service is constantly evolving; further developments are also being assessed for the future, in order to respond increasingly to the needs of customers and the Sales Network. At the end of 2025, a total of 315,000 Mooney withdrawal and deposit transactions were recorded, a 45% increase compared to the end of 2024, with approximately 51,000 users, +30% compared to the previous year. As in 2024, a clear prevalence of deposits (89%) over withdrawals (11%) was confirmed. As for credit products in the reporting year, digital loans were offered through the Selfy PayTime product, which allows current account movements to be divided into instalments by granting one or more loans, the maximum amount payable was increased to €5,000 and the maximum duration to 60 months. The request for division into instalments is made by the customer directly by application and the outcome and the related granting are ‘instant’. During the subscription process, all the information about the product and the pricing applied is provided to customers, enabling them to make an informed choice. A total of €27.4 mln was disbursed in 2025.
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208 | Mediolanum Group - 2025 Annual Financial Report Targets IROs: Cost reduction / Economic savings due to the progressive digitalisation of processes and benefits in terms of efficiency, including environmental benefits (e.g. reduced paper use and fewer physical journeys) [E1-4 DP 32; 33; ESRS 2 MDR-T DP 80] Target Target KPI57 Year target Scope Baseline year and value Progress at 31/12/2025 Increase in the total amount of digitised loans granted to customers Digital loans granted 1,425 mln 2030 Italy 2024 182 mln 372.50 mln 2.2.7 Metrics Energy consumption and mix [E1-5 DP 37] The Italian Companies of the Mediolanum Group purchase energy through players with which they contract the supply of electricity and gas on an annual basis. In addition, two trigeneration plants, powered by methane gas, have been installed at the Milan 3 City office to enable the simultaneous self-generation of electricity, thermal energy and refrigerated energy, through the use of co-generators and absorption refrigeration units. The electricity taken from the grid, 100% from renewable sources with guarantee of origin, and the electricity produced by trigeneration cover the needs of the entire campus of Milan 3 City. In addition, hot and cold water for air conditioning is self-generated, again through the trigeneration system, supporting the climate control systems within the buildings. All the installations of the Spanish Group Companies are powered by external energy and the contractual energy comes from 100% renewable sources with guaranteed origin. At the building in Av. Diagonal 668 (Palacete Abadal), work on the installation of photovoltaic solar panels for energy self-generation was completed in July 2024. In the event of a power supply failure, diesel-powered generating sets (generators) are available. These generator sets are started annually for operational testing. The Group’s Irish Companies also purchase electricity from 100% renewable sources. In addition, a portion of the energy purchased by the centralised management of the building is also 100% renewable. [E1-5 DP 37 a; 37 b; 37 c; 37 ci; 37 cii; 37 ciii; AR 34] Energy consumption and mix UoM 2025 2024 Total consumption of energy from fossil sources MWh 12,136.58 11,194.64 Percentage of fossil sources in total energy consumption % 56.41 52.29 Total energy consumption from nuclear sources MWh 0 0 Percentage of energy consumption from nuclear sources as a percentage of total energy consumption % 0 0 Consumption of renewable fuels MWh 0 0 Consumption of electricity, heat, steam and cooling from renewable sources, purchased or acquired MWh 9,332.45 10,192.99 57 Compared to the previous 2024-2026 Sustainability Plan, the Target was recalibrated in relation to the change in the macroeconomic scenario (rates and historical context).
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209 | Mediolanum Group - 2025 Annual Financial Report Consumption of self-generated renewable energy without use of fuels MWh 45.87 19.80 Total consumption of energy from renewable sources MWh 9,378.32 10,212.79 Renewable sources as a percentage of total energy consumption % 43.59 47.71 Total energy consumption related to own operations MWh 21,514.90 21,407.43 [E1-5 DP 39] Production of non-renewable and renewable energy UoM 2025 2024 Production of non-renewable energy MWh 3,113.67 2,808.60 Production of renewable energy MWh 45.8758 19.80 [ESRS 2 MDR-M DP 75] The energy consumption and mix metrics (E1-5) are used to measure performance with respect to the following impacts: ‘Generation of direct and indirect GHG energy emissions (Scopes 1 and 2)’. [ESRS 2 MDR-M DP 77 a] For the Group Companies, electricity consumption is calculated at year-end on the basis of bills, invoices and data recorded by the accounting system, using a new tool (PowerBI). Consumption in December, if no precise data is available, is estimated through an end-of-year projection based on the previous months, using invoices issued by the energy supplier. Consumption data are uploaded to the new tool monthly. All energy consumption was converted into MWh using the conversion factors provided by DEFRA59, which make it possible to determine the calorific values and densities typical of the reported fuels. The information in this metric does not include data relating to the Company August Lenz & Co. AG, which has been in liquidation since 1 July 2023. No estimates were used for these data since, given the small number of employees, the estimated consumption is less than 1 MWh. The exclusion of this value therefore does not affect the validity of the calculation. [ESRS 2 MDR-M DP 77 b] In relation to the energy consumption and mix metrics, no external bodies, other than the entity issuing the certificate of compliance, are involved for data validation. 58 With reference to the value of self-generated renewable energy without fuels, it should be noted that the increase stated in the energy-mix table is attributable to the commissioning of the photovoltaic system in July 2024. Since the plant was operational for less than half a year in the first reference period, the significant increase recorded in 2025, more than two-fold, is consistent with the full annual use of the infrastructure. 59 UK Government GHG Conversion Factors for Company Reporting – 2025.
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210 | Mediolanum Group - 2025 Annual Financial Report Gross Scope 1, 2, 3 and Total GHG emissions [E1-6 DP 44 d; 52; 52 a; 52 b] Total GHG emissions UoM. 2025 2024 Total location-based GHG emissions tCO2eq 9,724,324.1260 4,783,467.08 Total market-based GHG emissions tCO2eq 9,722,001.0361 4,780,444.72 [E1-6 DP 53] GHG intensity based on net revenues UoM 2025 2024 Intensity of location-based GHG emissions (total GHG emissions vs net revenues) tCO2eq/€ 2.5862 1.24 Intensity of market-based GHG emissions (total GHG emissions vs net revenues) tCO2eq/€ 2.5863 1.24 [E1-6 DP 55; AR 55] Net revenues UoM 2025 2024 Net revenues used to calculate GHG intensity €/thousand 3,763,702 3,867,305 For the purposes of calculating the intensity of location-based and market-based GHG emissions, the positive components taken from the consolidated income statement at 31.12.2025 were used in the denominator. It should also be noted that, for the purposes of the definition, the item ‘170. Balance of financial revenues and costs relating to insurance management” was also considered, given the specific nature of the insurance business. [ESRS 2 MDR-M DP 75] The metrics of Gross Scope 1, 2, 3 and Total GHG emissions (E1-6) are used to assess performance with respect to the following impacts: ‘Generation of direct and indirect GHG energy emissions (Scope 1 and 2)’; ‘Generation of indirect GHG emissions (Scope 3), in particular those attributable to counterparties included in own portfolio’. [ESRS 2 MDR-M DP 77 a] The reporting on this metric on Gross Scope 1, 2, 3 and Total GHG emissions does not include data for August Lenz & Co. AG, which has been in liquidation since 1 July 2023. No estimates were used for these data since, given the small number of employees, the estimated consumption would be less than 1 MWh. The exclusion of this value therefore does not affect the validity of the calculation. Please refer to the individual sections for details of the methodologies and significant assumptions underlying the metrics. [ESRS 2 MDR-M DP 77 b] In relation to the metrics on Gross Scope 1, 2, 3 and Total GHG emissions, no external entities, other than the entity issuing the certificate of compliance, are involved for the validation of the data. Scope 1 [E1-6 DP 48 a; 48 b; 50 a; 50 b] Gross Scope 1 GHG emissions UoM 2025 2024 Gross Scope 1 GHG emissions tCO2eq 2,593.73 2,412.43 Consolidated accounting group tCO2eq 2,593.73 2,412.43 Investees with operational control tCO2eq - - Percentage of gross Scop 1 GHG emissions from emissions trading systems % 0 0 [E1-6 DP AR 39 b; ESRS 2 MDR-M DP 77 a] 60 The significant deviation from 2024 is due to the inclusion, starting in 2025, of a new asset class in Scope 3, Category 15 (Investments). In particular, sovereign debt was also included in the calculation, resulting in a significant increase in the value of emissions compared with the previous year. 61 See note 60. 62 See note 60. 63 See note 60.
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211 | Mediolanum Group - 2025 Annual Financial Report For Group Companies, Scope 1 GHG emissions relate to gas consumption for electricity generation (Banca Mediolanum) and consumption attributable to the company car fleet and long-term rental vehicles (petrol and traction diesel). The slight rise in emissions is mainly due to a higher consumption, particularly of fuels such as petrol and natural gas. For the calculation of gross Scope 1 GHG emissions, the sources of conversion factors are the ‘Guidelines on the application in the area of banking operations of the European Sustainability Reporting Standards (ESRS) in environmental matters - Focus on Disclosure Requirements E1-5, E1-6’ - December 2025 version. These guidelines provide coefficients and conversion factors in line with those defined at the national level (ISPRA in the National Inventory Report and Common Reporting Format), European coefficients, and other international coefficients (GHG Protocol). The greenhouse gases included in the calculation of emissions, specified in the guide, are CO2, CH4 and N2O. The unit of measurement used is tCO2eq. The conversion of greenhouse gases into tonnes of CO2 equivalent was performed in line with the most recent Global Warming Potential (GWP) values published by the IPCC with a one-hundred year horizon. With regard to Banco Mediolanum, the calculation of gross Scope 1 GES emissions is carried out using, as a source of conversion factors, the document ‘Factores para los informes anuales de emisiones’ issued by the Spanish Ministry for Ecological Transition (MITECO). [E1-6 AR 43c] It should be noted that Scope 1 biogenic CO 2 emissions are not applicable as these categories of greenhouse gas emissions reported by the Mediolanum Group do not include sources deriving from the biodegradation of biomass or the use of fuels of biogenic origin. Scope 2 [E1-6 DP 44 b; 49 a; 49 b; 50 a; 50 b] Gross Scope 2 GHG emissions UoM 2025 2024 Gross Scope 2 location-based GHG emissions tCO2eq 2,332.85 3,022.36 Consolidated accounting group tCO2eq 2,332.85 3,022.36 Investees with operational control tCO2eq - - Gross Scope 2 market-based GHG emissions tCO2eq 9.76 0 Consolidated accounting group tCO2eq 9.76 0 Investees with operational control tCO2eq - - [E1-6 DP AR 45 d; AR 45 e] It should be noted that, for the Mediolanum Group, the portion and types of contractual instruments used for the purchase and sale of energy combined with energy production attributes, came to zero. In addition, Scope 2 biogenic CO 2 emissions, lime Scope 1 emissions, are not applicable as these categories of greenhouse gas emissions reported by the Mediolanum Group do not include sources deriving from the biodegradation of biomass or the use of fuels of biogenic origin. The decrease in Scope 2 Location-based emissions is mainly due to the use of solar panels in Spain, already installed the previous year. By contrast, the slight increase in Scope 2 market-based emissions is mainly attributable to the provision, in 2025, of DKV cards, already used for refuelling, also for charging electric vehicles. For further details on the DKV cards, see ESRS E1, paragraph 2.2.3 Own GHG emissions, section ‘Actions’. [E1-6 DP AR 39 b; ESRS 2 MDR-M DP 77 a]
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212 | Mediolanum Group - 2025 Annual Financial Report For the calculation of gross market-based GHG emissions, the electricity covered by Guarantees of Origin certificates, which represents almost all of the electricity purchased by the Group, was multiplied by the emission factor of 0, in accordance with the guidelines ‘ABI Lab - European Sustainability Reporting Standard (ESRS) Support Document on Environmental Reporting - Focus on reporting obligations E1-5, E1-6 – December 2025 version’. The sole exceptions refer to the consumption of electricity purchased for charging electric vehicles at charging points located outside the MI3 City area, not covered by GO, which are attributed a market-based Scope 2 value of 9.76 tCO2eq. With regard to the calculation of gross location-based GHG emissions, the emission factors provided for in the ABI Lab Guidelines on the Bank’s application of the European Sustainability Reporting Standards (ESRS) were applied to Banca Mediolanum, while the average national emission factors provided by IEA 2025 were applied to the foreign Companies64. The greenhouse gases included in the calculation of emissions, specified in the guide, are CO 2, CH4 and N 2O. The unit of measurement used is tCO2eq. The conversion of greenhouse gases into tonnes of CO2 equivalent was performed in line with the most recent Global Warming Potential (GWP) values published by the IPCC with a one-hundred year horizon. With regard to Banco Mediolanum, the calculation of gross Scope 2 market-based GES emissions is carried out using, as a source of conversion factors, the document ‘Factores para los informes anuales de emisiones’ issued by the Spanish Ministry for Ecological Transition (MITECO). Scope 3 [E1-6 DP AR 46 i] In the context of the calculation of Scope 3 GHG emissions for the year 2025, with reference to the categories provided for in the GHG Protocol, six significant emissions categories have been identified for the Mediolanum Group: Category 1 – Purchased goods and services. This category refers to emissions deriving from the purchase of goods and services during the reporting year; Category 5 – Waste generated during operations. This category refers to emissions deriving from the disposal of waste produced by the organisation during the reporting period; Category 6 – Business travel. This category refers to emissions deriving from employees’ business trips by train, air, taxi and own car and, therefore, is financed by the Group; Category 7 – Employee commuting. This category refers to emissions deriving from employees travel between home and the workplace; Category 14 – Franchising. This category refers to emissions deriving from the travel between home and the workplace of the Family Bankers operating in Italy and Spain, as well as from the energy consumption of the Italian and Spanish offices for power and heating; Category 15 – Investments/portfolio. This category refers to emissions generated by equity and bond investments, as well as by the mortgages and corporate loans of the Mediolanum Group. Starting from 2025, the scope of calculation was extended through the inclusion of sovereign debt as a new asset class, while the methodologies applied to the other components remained unchanged compared to previous years. 64 IEA Emissions Factors 2025.
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213 | Mediolanum Group - 2025 Annual Financial Report With regard to the other Scope 3 indirect emission categories covered by the GES Protocol (Category 2 – Capital Goods; Category 3 – Fuel and energy related activities not included in Scope 1 and 2; Category 4 – Upstream Transport and Distribution; Category 8 – Upstream Leasing Activities; Category 9 – Downstream Transport; Category 10 – Processing of Products Sold; Category 11 – Use of Products Sold; Category 12 – End of Life Treatment of Products Sold; Category 13 – Downstream Leasing Activities), internal analyses were performed to assess their applicability and relevance to the business model adopted. As a result of these assessments, it was decided to exclude them from reporting, as they are considered not relevant and not applicable. [E1-6 DP AR 39 b; AR 46 h; ESRS 2 MDR-M DP 77 a] The categories being assessed were classified and measured on the basis of the recommendations of the GHG Protocol, a reporting standard that provides calculation tools and methodologies for measuring and quantifying own emissions of climate-altering gases. The reference methodology used to measure only the category linked to portfolio investments is defined by the Partnership for Carbon Accounting Financials (PCAF) Standard, which provides for the choice and applicability of different approaches based on the type of asset and the level of quality of the calculation. The calculation methods used by the Mediolanum Group for the Scope 3 categories identified are shown below: Category 1 - Purchased goods and services: includes data relating to the purchase of durable goods (such as furniture items) and non-durable goods (particularly paper). The emission factors used are issued by the Department for Environment, Food and Rural Affairs (DEFRA) for the use of materials (2025 emission factors); Category 5 - Waste generated in operations: data on waste flows and their destination are included. The emission factors used are issued by the Department for Environment, Food and Rural Affairs (DEFRA) for waste disposal (2025 emission factors). The emissions were calculated taking into account the disposal system actually used; Category 6 - Business travel: data on the mileage of Mediolanum Group employees in trains, cars and aircraft are included. The emission factors used are issued by the Department for Environment, Food and Rural Affairs (DEFRA) for business travel emissions (air, sea, land; 2025 emission factors); Category 7 - Employee commuting: emissions were calculated based on the results of the 2024 survey (three-year survey) provided to employees on company mobility and on data on average attendance at the Group’s offices. These data were used for the sole purpose of identifying the distribution of the kilometres travelled on average on the basis of the transport mode used. The emission factors of the Department for Environment, Food and Rural Affairs (DEFRA) relating to the transport mode used (2025 emission factors) were applied to the kilometres travelled. This category of Scope 3 emissions also includes GHG emissions from teleworking. In order to quantify these emissions, data on the IT media used by employees and remote working days were requested. The Ecoact paper ‘Homeworking emissions Whitepaper’, which takes into account the average use of electricity per desk, was used to obtain the kWh consumption of each medium; Category 14 - Mobility and offices of Family Bankers: emissions were calculated based on the results of the 2025 surveys (annual surveys) of the Italian and Spanish Family Bankers, who provided data on their mobility habits and energy consumption linked to the offices in which they operate. The data collected were used to estimate emissions from work travel (e.g. travel to get to customers, business events and other work activities). In addition, in order to estimate emissions, the distribution of kilometres travelled on average was determined, broken down by transport mode. The relevant DEFRA 2025 conversion factors were applied to these distances, differentiating between private/company cars (petrol, diesel, LPG, electric), public transport and motorcycles/scooters. In addition to emissions from travel, emissions from the energy consumption of offices used by the Family Bankers were calculated. For electricity consumption, the survey data and, where available, the regular consumption of the Italian offices were
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214 | Mediolanum Group - 2025 Annual Financial Report used. The emissions were calculated by applying the location-based emission coefficient (the Italian Institute for Environmental Protection and Research (ISPRA) for Italy, Comisión Nacional de los Mercados y la Competencia (CNMC) for Spain). For the consumption of natural gas (heating), the data declared in the survey were used, applying the specific emission factor for Sm³ (Catalan Oficina del Canvi Climàtic (OCCC) for Spain, ISPRA for Italy); Category 15 - Investments: o with regard to the investment activity carried out by the Group in its capacity as Asset Management, Insurance and Asset Owner, a calculation approach was applied which involved the calculation of individual emissions relating to corporate counterparties (Scope 1 and Scope 2) broken down into the value of the investment made with respect to the total value of the Company invested (EVIC); in addition, for 2025 the calculation was also extended to the Group’s bond investments in sovereign issuers, following the guidelines of the PCAF standard in relation to the ‘Sovereign debt’ asset class65; o With regard to loans to non-financial companies, the ratio between the exposure at 31/12/2025 and the company’s total assets was calculated for each counterparty. The ratio was then multiplied by the total emissions figure for the undertaking, calculated as the sum of each local unit on the basis of turnover and the associated sector, using a statistical calculation model considering Scope 1, Scope 2 and Scope 3 emissions; o with reference to retail customer mortgages, the ratio of the exposure at 31/12/2025 to the valuation of the relevant property was calculated, for each mortgage. The ratio was then multiplied by the surface area and by the CO2 emissions per square metre of the property.66 [E1-6 DP 44 c; 51] Scope 3 categories UoM 2025 2024 1. Purchased goods and services tCO2eq 43.71 34.56 5. Waste generated during operations tCO2eq 9.23 23.58 6. Business travel tCO2eq 783.98 931.20 7. Employee commuting tCO2eq 2,174.71 2,078.99 14. Franchising tCO2eq 11,986.03 11,773.19 15. Portfolio tCO2eq 9,704,399.88 4,763,190.77 Total Scope 3 emissions tCO2eq 9,719,397.5467 4,778,032.29 [E1-6 AR 46 g] 2.8% of Scope 3 emissions were calculated using primary data68. [E1-6 AR 46 j] 65 The Group calculates the financed emissions figure for the ’sovereign debt’ asset class based on the value of the emitting countries production-based national emissions, which include emissions generated within national borders, including domestic consumption and exports. The value of these emissions is then calculated using an attribution factor, i.e. the ratio of the investment to GDP at purchasing-power parity (PPP), as recommended by the PCAF standard, to eliminate distortions due to exchange rates and price differences. 66 The figure for financed emissions regarding residential loans is calculated at 93.4% on the basis of the primary data from the EPC for the financed property, recovered directly by the Bank or through information providers; for the remaining portion of the financed emissions, equal to 6.6%, the figure is estimated on the basis of the portfolio averages for the loans granted at Banca Mediolanum and Banco Mediolanum, respectively. 67 The significant deviation from 2024 is due to the change in the method for calculating Scope 3 Category 15 (Investments) emissions, introduced in 2025. In particular, sovereign debt in the reporting scope was also included in the calculation, which resulted in a significant increase in value compared with the previous year. 68 In particular, Category 1, 5 and 6 emissions are calculated using 100% primary data. Category 7 emissions are estimated through surveys of company mobility and office attendance data. Category 14 emissions combine estimates (FB mobility surveys) and primary office energy consumption data (20.4%). With regard to Category 15 emissions, proxy data are used for equity and bond investments (including sovereign debt securities), as well as for corporate loans; for mortgages, the emissions figure is calculated from the portfolio’s analytical data (93.4% coverage) and, to a marginal extent, based on an estimate of the portfolio’s average emission value.
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215 | Mediolanum Group - 2025 Annual Financial Report Scope 3 biogenic CO2 emissions are not applicable as these categories of greenhouse gas emissions reported by the Mediolanum Group in this regard do not include sources deriving from the biodegradation of biomass or the use of fuels of biogenic origin. [ESRS 2 MDR-M DP 75] The metrics of Gross Scope 1, 2, 3 and Total GHG emissions (E1-6) are used to assess performance with respect to the following impacts: ‘Generation of direct and indirect GHG energy emissions (Scope 1 and 2)’; ‘Generation of indirect GHG emissions (Scope 3), in particular those attributable to counterparties included in own portfolio’. [ESRS 2 MDR-M DP 77 b] In relation to the metrics on Gross Scope 1, 2, 3 and Total GHG emissions, no external entities, other than the entity issuing the certificate of compliance, are involved for the validation of the data. Scope 3: Portfolio Detail The following is a breakdown of emissions intensity by: Asset class; Global Industry Classification Standard (GICS) sectors; Geographical area. Asset class The table below shows the total emissions of the Group’s financial portfolio: Asset class 2025 2024 Equity investments in undertakings 2,435,228.41 2,468,843.73 Bond investments in undertakings 1,515,504.59 1,550,731.76 Sovereign debts 5,035,924.81 - Mortgages 286,889.29 269,623.01 Corporate loans 430,852.78 473,992.28 Total 9,704,399.8969 4,763,190.77 69 The significant deviation from 2024 is due to the inclusion, starting in 2025, of a new asset class in Scope 3, Category 15 (Investments). In particular, sovereign debt was also included in the calculation, resulting in a significant increase in the value of emissions compared with the previous year.
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216 | Mediolanum Group - 2025 Annual Financial Report GICS sectors The breakdown of absolute emissions by reference GICS sectors is shown below: 2025 Absolute emissions (Tonne/CO2eq) Product sector Loans Asset Mgt Own assets Insurance Total Emissions weight (%) Materials 17,646.10 967,922.30 2,324.39 603,747.46 1,591,640.25 16.40 Utilities 28,583.48 542,281.74 296.49 267,900.63 839,062.34 8.65 Energy 1.47% 418,722.38 858.77 235,203.04 654,785.67 6.75 Industry 98,555.60 266,656.14 767.46 185,486.31 551,465.51 5.68 Property 360,298.13 5,016.40 0.18 3,527.68 368,842.40 3.80 Luxury goods 125,241.14 92,483.61 244.89 63,770.48 281,740.12 2.90 Information technology 5,501.78 59,448.32 2.31 53,614.16 118,566.57 1.22 Consumer staples 80,362.36 43,900.51 191.53 40,327.78 164,782.18 1.70 Health 830.30 15,501.44 0.74 13,437.61 29,770.10 0.31 Finance 14.26 15,695.32 158.80 11,424.88 27,293.27 0.28 Communication services 707.43 24,552.86 188.27 11,412.25 36,860.82 0.38 Sovereign debts - 1,288,564.34 2,047,027.34 1,700,333.13 5,035,924.81 51.89 Other - 2,446.88 19.73 1,199.24 3,665.85 0.04 Total 717,742.07 3,743,192.25 2,052,080.92 3,191,384.65 9,704,399.8970 100 2024 Absolute emissions (Tonne/CO2eq) Product sector Loans Asset Mgt Own assets Insurance Total Emissions weight (%) Materials 13,437.82 916,468.99 1,390.22 582,887.17 1,514,184.19 31.79 Utilities 57,057.21 572,151.68 717.55 301,637.61 931,564.05 19.56 Energy 0.03 496,304.19 805.96 278,602.38 775,712.57 16.29 Industry 170,758.16 258,352.63 696.15 183,168.32 612,975.26 12.87 Property 330,297.48 6,339.12 36.39 6,055.53 342,728.52 7.20 Luxury goods 90,325.44 99,087.69 172.81 63,293.58 252,879.52 5.31 Information technology 5,495.44 44,740.33 14.55 38,251.36 88,501.68 1.86 Consumer staples 75,013.49 45,216.66 122.56 35,708.72 156,061.43 3.28 Health 595.25 15,682.30 5.27 13,026.43 29,309.25 0.62 Finance 21.03 13,603.59 198.96 12,555.79 26,379.37 0.55 Communication services 613.93 19,814.74 73.35 10,976.62 31,478.65 0.66 Other - 1,253.35 0.00 162.93 1,416.27 0.03 Total 743,615.28 2,489,015.27 4,233.77 1,526,326.45 4,763,190.77 100 70 See note 60.
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217 | Mediolanum Group - 2025 Annual Financial Report Geographical area The breakdown of absolute emissions and their portfolio value, broken down by geographical area, is shown below. 2025 2024 Tonne/CO2eq % emissions Tonne/CO2eq % emissions Europe 5,831,922.59 60.10 2,016,096.06 42.33 Other - supranational 128,277.36 1.32 - - Great Britain 106,558.39 1.10 95,603.88 4.10 America 1,707,174.32 17.59 1,377,279.05 28.92 Asia 288,771.03 2.98 195,302.74 2.01 Emerging markets 1,641,696.20 16.92 1,078,909.04 22.65 Total 9,704,399.89 71 100 4,763,190.77 100 GHG removals and GHG mitigation projects financed through carbon credits [E1-7 DP 58] The Mediolanum Group does not implement initiatives for GHG removals and/or storage; as a result, this disclosure obligation is not included in the 2025 Consolidated Sustainability Statement. Internal carbon pricing [E1-8 DP 62] The Mediolanum Group does not apply internal carbon pricing systems; accordingly, this disclosure requirement is not included in the 2025 Consolidated Sustainability Statement. 71 See note 60.
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218 | Mediolanum Group - 2025 Annual Financial Report 3. Social information 3.1 ESRS S1 Own workforce 3.1.1 Material impacts, risks and opportunities and their interaction with strategy and business model [S1.SBM-3 DP 13 a] One of the drivers that has always characterised the Group is placing people at the centre and focusing attention on the needs of customers and its staff. This clear guiding principle allows us to be always focused on our business model, consistent with the values and identity of the business, attentive to technological innovation and to the ongoing search for excellence in customer service, the premise for achieving economic results that are always positive, in a long-term and sustainability-based perspective. The centrality, involvement and active participation of the human factor in the business processes are fundamental objectives of the tools of management and development of organisational conduct. As stated in the Group’s Code of Ethics, the fundamental and irreplaceable points of competitiveness of the Group include the commitment to bring out the best professional skills of people, the active participation of resources in the processes that involve them and the facilitation of the system of internal communications promoting the culture of listening and the circulation of information. [S1.SBM-3 DP 14] All own workers that may be exposed to material impacts on the part of the undertaking, including impacts directly related to own operations and the Value Chain, are included in the scope of the reporting and were considered in the double materiality assessment. [S1.SBM-3 DP 14 a] The Group’s employees subject to material impacts are employees at the Group’s operating sites, particularly in Italy, Spain and Ireland. [S1.SBM-3 DP 14 b] The material adverse impacts that arose in the context of the double materiality process are mainly related to individual, mainly potential incidents, and isolated episodes such as: measures against violence and harassment in the workplace (incidents of harassment); employment and inclusion of people with disabilities (potential lack of integration of workers with disabilities); health and safety (potential harm to workers resulting from occupational accidents and illness); confidentiality (potential loss of confidential data and information); gender equality and equal pay for equal work (gender inequality between men and women in the overall workforce and, in particular, in senior positions and/or in corporate career development processes; potential inequality in gender and/or pay for equal work). The indicated impacts are adequately managed and overseen and may affect all categories of workers within the Own Workforce. [S1.SBM-3 DP 14 c] The material positive impacts identified in the context of the double materiality process are related to the Group’s activities in the development and protection of human capital and are mainly aimed at the Group’s employees at the operating sites. The positive impact of training programmes, performance appraisal systems and professional development plans is determined by the activities promoted by the Group in the area of training, assessment and development (e.g. career growth, internal movement and job-posting, succession planning, onboarding activities and specific projects such as ‘Feedback ForYou’ and the establishment of the Mediolanum Empowerment & Employability Centre).
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219 | Mediolanum Group - 2025 Annual Financial Report The positive impacts associated with the protection of a work-life balance and employees’ mental and physical well-being are determined by the activities promoted by the Group (see ESRS S1 Own Workforce, paragraph 3.1.4. Work-life balance section ‘Actions’, for further details on the Group’s activities) regarding corporate welfare, workplace health and recruiting and retention processes. Lastly, the positive impact related to secure employment, the adequacy of working hours and pay, respect for social dialogue and collective bargaining derives from the application of national collective bargaining agreements (CCNLs) in the sector with economic benefits in excess of the contractual minimum levels on average and with benefits in addition to those established by the general rules of countries with regard to health and social security coverage. [S1.SBM-3 DP 14 d] During the materiality assessment process, a material opportunity was identified for harnessing the value of human capital, thanks to the preparation of initiatives and activities that include aspects related to training and skills development. In particular, in the assessment process, it was shown that the development and training programmes, curated by the Corporate University, aim to guarantee the continual development of professional expertise and will increasingly aim to combine the strengthening of technical skills with the refinement of soft skills, a distinctive element for the Group in conduct towards customers. [S1.SBM-3 DP 14 e] In the double materiality assessment process, no material impacts on Own Workforce were identified that might result from transition plans aimed at reducing negative impacts on the environment. [S1.SBM-3 DP 14 fi; 14 fii] With regard to the Mediolanum Group’s Own Workforce, no transactions at serious risk of forced or compulsory labour exist. As explained in the Mediolanum Group’s Policy for the Protection of Human Rights, the Group does not knowingly make use of any form of forced or compulsory labour. [S1.SBM-3 DP 14 gi; gii] With regard to the Mediolanum Group’s own workforce, there are no transactions at serious risk of child labour. As explained in the Policy for the Protection of Human Rights, the Mediolanum Group rejects child labour and complies with the provisions of the ILO Convention or the minimum working age established in the countries (provided that it is more protective than the ILO Convention). [S1.SBM-3 DP 15] With reference to the impacts identified in the double materiality assessment, no particularly exposed categories of workers are identified that may be impacted in a differentiated way. [S1.SBM-3 DP 13 b] With regard to the actual positive impact related to the presence of training programmes, performance appraisal systems and professional development plans, an opportunity was identified related to the improvement of human capital thanks to the preparation of initiatives and activities that include aspects related to training and skills development. This opportunity is linked to the strategy and business model, as these initiatives favour the Group through its ability to attract and retain talent, ensuring alignment between internal skills and strategic business needs. In addition, the possible departure of staff may result in a significant loss of skills and intangible assets for the company. Initiatives to protect human capital are therefore designed to minimise the risk of loss of the organisation’s knowledge and experience capital, particularly that regarded as most distinctive and critical for business development. The Mediolanum Group is also strongly reliant on its human capital, which has a decisive impact not only on its financial performance, but also on its reputation, compliance and innovative capacity. [S1.SBM-3 DP 16] The positive and negative opportunities and impacts related to Own Workforce identified in the double materiality assessment concern the entire corporate population of the Mediolanum Group. No material risks related to the subject were identified. [S1-1 DP 19] The Policies relating to Own Workforce apply to the entire corporate population, unless otherwise indicated.
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220 | Mediolanum Group - 2025 Annual Financial Report 3.1.2 Working conditions and human rights [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Safe employment/working hours/adequate wages/social dialogue/freedom of association, existence of works councils and rights to information, consultation and participation of workers/collective bargaining Creation of a stable and secure working environment that ensures fair conditions in terms of employment, working hours, wages, social dialogue and freedom of association, favouring the well-being and satisfaction of the Group’s employees. Actual positive impact Own operations Medium term The Group’s approach and policies The Mediolanum Group takes a responsible approach to working conditions, based on full compliance with human rights and the regulations in force in the countries in which it operates. Secure employment is guaranteed through open-ended contracts and the application of national collective bargaining agreements for the sector. In cases of corporate restructuring, the Group ensures that there is a harmonious exchange of views with the social partners to manage any transfers in a fair and responsible way. Dialogue with employees is constant, with listening initiatives and professional development pathways that aim to protect human capital and reduce the risk of loss of distinctive skills for the business. Over the years, the Mediolanum Group has developed various policies aimed at ensuring proper management of this impact. In addition to the collective bargaining agreements, the Code of Ethics and the Mediolanum Group’s Sustainability Policy, which refer to its approach and general guidelines, the main policies for managing impacts related to ‘working conditions’ are the Group’s Policy for the Protection of Human Rights, agile working agreements and remuneration policies. [S1-1 DP 19; ESRS 2 MDR-P DP 65] IROs: Creation of a stable and secure working environment that ensures fair conditions in terms of employment, working hours, wages, social dialogue and freedom of association, favouring the well-being and satisfaction of the Group’s employees Code of Ethics One of the key principles of the Code of Ethics is the integrity and dignity of the person. The Mediolanum Group ensures the physical and moral integrity of its staff, working conditions that respect individual dignity and safe and healthy working environments. The Group’s staff are offered equal employment opportunities on the basis of professional skills and performance, without any discrimination, with full respect for the rights of the individual. For further information on the Code of Ethics and related MDR-P, see ESRS G1 Business Conduct, paragraph 4.1.1 Business Culture, Group Approach and Policies. Group remuneration policies In the context of its remuneration policies, the Mediolanum Group adopts various principles to ensure their neutrality, with the aim of minimising gaps in every respect, including gender differences.
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221 | Mediolanum Group - 2025 Annual Financial Report Collective Bargaining and Additional Safeguards In Italy, the Mediolanum Group applies various CCNLs in relation to the Company in question. The CCNLs applied are as follows: The CCNL for executives and professional personnel in the credit, financial, and instrumental sectors (Credit CCNL), CCNL ANIA, which governs relations between insurance undertakings and non-executive employees, the CCNL for trade, tertiary companies, distribution and services and the CCNL for private broadcasting companies. Within the Group, the most widely applied agreement is the Credit CCNL. The application of relevant National Collective Bargaining Agreements ensures safeguards for working hours, wages, workplace safety and social dialogue. In addition to these, Supplementary Company Contracts (CIA) offer additional benefits such as subsidised healthcare cover, performance bonuses, supplementary pensions, paid leave for personal and family needs, and welfare initiatives. Agency workers also enjoy the same safeguards provided for by the CCNLs and CIAs. The relevant CCNLs and CIAs are applied to all employees, guaranteeing full rights and protection, as provided for by Italian legislation. All CCNLs and CIAs comply with international standards and comply with national labour laws. In Spain, the Collective Agreement regulates the employment relationship of the banking staff of Banco Mediolanum. The Agreement contains the relevant salary tables and defines working conditions, including rules on promotions, leave, holidays, working hours and furlough. The agreement applies to all bank employees. [S1-1 DP 20; 22] In line with its corporate culture, the Mediolanum Group undertakes to respect and promote Human Rights as part of its activities and to prevent, with the aim of minimising, any breach directly caused by its actions. The Mediolanum Group’s Policy for the Protection of Human Rights, approved in 2020 and updated in 2025, sets out the Group’s commitment to the protection of Human Rights according to the highest international standards72. The Mediolanum Group’s Policy for the Protection of Human Rights explicitly addresses trafficking in human beings, forced labour and child labour. [S1-1 DP 20 a; 20 b] With regard to respect for Human Rights, including the labour rights of its own workers, the Group Policy provides specific commitments regarding: the prevention of discrimination and practices that violate the dignity of persons: to this end, providing equal opportunities for access to work and promotion is a basic principle for the Group, ensuring at all times that persons are not discriminated against on grounds of gender, race, age, religion, origin, disability, marital status, sexual orientation or social status. The Group is also committed to maintaining a work environment free from harassment, abuse, intimidation or violence; the mindful rejection of forced labour and child exploitation; in particular, the Group complies with the provisions of the ILO Convention or the minimum working age established in the countries (provided that it is more protective than the ILO Convention); respect for freedom of association and collective bargaining: the Mediolanum Group recognises the fundamental rights of workers to form and associate with trade unions or representative bodies. The Group also ensures respect for freedom of expression, trade union activity, collective bargaining and the recognised protection of employee representatives in accordance with the labour legislation of each country; 72 Including, in particular, ‘The International Bill of Human Rights’, the ‘ILO Declaration on Fundamental Principles and Rights at Work’, the ‘Tripartite declaration of principles of the International Labour Organization’” and the ‘OECD Guidelines for Multinational Enterprises’.
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222 | Mediolanum Group - 2025 Annual Financial Report protection of employee health: the Mediolanum Group considers the safety and health of its employees to be fundamental and prioritises improvements in working conditions. Moreover, the Group complies with the requirements set forth in the laws of each country in this regard and takes appropriate measures to ensure workplace safety and health; the provision of decent work: the Group remunerates employees according to criteria of fairness, on the basis of their training, experience, role and responsibility and socio-economic context, and also guarantees employees the right to rest, in compliance with applicable legislation; employees are offered flexible ways of working that allow them to balance their professional career with other interests and responsibilities. The Group is also committed to creating a working environment that supports the work-life balance of each employee; the right to the protection of personal data and privacy. [S1-1 DP 20 b; 20 c] The Mediolanum Group ensures, including through periodic discussions with key Stakeholders, the precise identification of any adverse impacts and defines appropriate processes to mitigate and manage them effectively, using tools for dedicated listening and dialogue. For further details on own worker involvement and remedial measures, see the detailed sections ( SBM-2 in ESRS 2 General disclosures, paragraph 1.1.3 Strategy, section ‘Interests and views of stakeholders; ESRS S1 Own Workforce, paragraph 3.1.8 Involvement of own workers and employee representatives on impacts; ESRS S1 Own Workforce, paragraph 3.1.9 Processes to remedy negative impacts and channels for own workers to raise concerns). [S1-1 DP 21] For further information on the Mediolanum Group’s Policy for the Protection of Human Rights and the relative MDR-P, see ESRS S3 Affected Communities, paragraph 3.3.2 Economic, social and cultural rights of communities, section ‘The Group’s approach and policies’ for further details. Actions [S1-4 DP 38 c] The Group ensures a stable and well-being-oriented working environment for employees by providing permanent contracts, with the aim of promoting job security and productivity. It also protects occupational levels by promoting qualification, upskilling and reskilling programmes, in order to respond to ongoing developments in the labour market. The adequacy of working hours is ensured by compliance with national legislation and collective bargaining agreements. The Group has adopted flexible hours models for the purposes of work-life balance and recognises the right to disconnect, promoting a sustainable balance between work and personal well-being. In terms of remuneration, the Group implements a policy of annual increases based on merit and career development pathways, ensuring adequate and motivating remuneration. The valorisation of organisational roles and the relevant measurement of the competitiveness of remuneration, compared with the external market, takes place using consolidated international methods, ensuring fairness and transparency. Lastly, dialogue with trade unions is structured and regulated by the Industrial Relations Protocol, which defines a model of structured trade union relations, favouring constructive discussion and the implementation of shared measures for the well-being of workers. [S1-4 DP 37; ESRS 2 MDR-A DP 68] IROs: Creation of a stable and secure working environment that ensures fair conditions in terms of employment, working hours, wages, social dialogue and freedom of association, favouring the well-being and satisfaction of the Group’s employees
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223 | Mediolanum Group - 2025 Annual Financial Report Reskilling and upskilling activities In 2025, the Mediolanum Group confirmed its ability to retain staff, recording a voluntary turnover rate of 3.1%, a sign of a strong bond between the Company and its people. In order to preserve employment stability and prevent negative impacts on people, the Group has adopted a proactive approach based on: qualification, upskilling and reskilling programmes to support skills development and ensure employability; targeted recruitment plans, which in 2025 led to the hiring of 298 new employees, strengthening organisational capacity and operational continuity. In addition, the IT Academy project was launched in May 2025, involving the recruitment of approximately 90 new graduates over three years, with the aim of replacing an external project contribution. To support this initiative, a comprehensive training programme was developed, consisting of 30 days of in-person classroom training delivered by external trainers, involving two classes for a total of 29 new employees. These actions are part of a long-term strategy aimed at combining employee well-being, the Group’s attractiveness and organisational resilience, creating a sustainable competitive advantage. In 2025, the Group confirmed its collaboration with INTOO, a company specialising in career transition processes. The initiative involved a group of professionals from different backgrounds, with the aim of: supporting an understanding of the working environment and business developments; raising awareness of current and required skills for effective performance; offering professional coaching to support their development. The following aspects are covered: analysis of role matching and mapping of experience, technical skills and personal characteristics; definition of a personalised development plan, in collaboration with INTOO, aimed at understanding the role in relation to corporate objectives; drafting of a targeted action plan to fill any potential gaps and promote professional growth. This initiative is part of the Group’s upskilling and reskilling strategy, aimed at ensuring employability, continuous development and alignment with market developments. The implementation of initiatives on the themes of ageing, generational diversity, professional development and employability, as part of ongoing induction programmes for young recruits, along with targeted professional growth paths for them. Through the ‘Mediolanum Employability & Empowerment Center’ project, development and reskilling activities continued for all generations, in line with the evolution of the skills required in the various areas. Employment stability In a constantly changing work environment, job stability is a strategic pillar. The offer of permanent contracts demonstrates the company’s commitment to its staff, creating a serene and productive environment. Job security fosters motivation, involvement and contributes to organisational success. Investing in stable employment means valuing people’s skills and growth potential, while also strengthening the Group’s ability to attract and retain talent seeking not only professional development but also continuity and stability. The Mediolanum Group adopts a policy focused on employment stability as a strategic lever to ensure continuity, competence and organisational resilience. With more than 97.9% of employees in Italy hired on permanent contracts, the Company has consolidated a working model that encourages the creation of cohesive teams able
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224 | Mediolanum Group - 2025 Annual Financial Report to face the challenges of the market with determination. At the same time, the use of fixed-term contracts is managed in a targeted and responsible manner, limited to temporary needs linked to specific projects or activity peaks. This flexibility makes it possible to maintain operational efficiency and speed of response, without compromising the soundness of the employment system. Moreover, these fixed-term contracts often represent a route into stable positions, strengthening the Group’s ability to attract and retain talent over the long term. Working hours and the right to disconnect The Mediolanum Group complies with regulations in force in Italy that regulate limits on daily working time. Moreover, the reference duration for specific tasks is also defined more precisely in the national collective bargaining agreements and may be less than the limit indicated by the general rule. Flexible start and end times are offered, as well as a large time slot for the daily lunch break. The right to disconnect is considered a fundamental aspect of ensuring the well-being of employees. According to this right, workers are entitled to fully disconnect from work outside of working hours, without feeling obliged to respond to emails, messages or calls. The Company actively promotes this practice through clear policies and internal communications that emphasise the importance of respecting rest and recovery times. Application of the National Collective Bargaining Agreement, remuneration policies, dialogue with trade unions The Mediolanum Group guarantees full application of all the provisions of the National Collective Bargaining Agreements (CCNL), including those relating to the salary adjustment of employees and contractual increases established by renewals of the CCNL. The Group provides average remuneration above minimum contractual levels, supplemented by company-level bargaining arrangements. Remuneration is determined according to clear and transparent criteria, based on the role held and the related responsibilities. The remuneration policy is designed to attract, motivate and retain qualified personnel, while ensuring consistency with the Group’s strategic objectives. The Group uses well-established, internationally recognised methodologies to assess the value of organisational roles. The adoption of these methodologies, together with their constant updating, makes it possible to carry out accurate analyses aimed at ensuring fairness and internal transparency, as well as competitiveness with the external market. The centrality of the Group’s people entails full protection of workers’ rights by maintaining constant contact with trade union representatives to safeguard employment. Discussions with Trade Union Organisations are governed by the provisions of the National Collective Bargaining Agreement for the sector, as well as specific agreements relating to trade union relations and trade union freedoms, which allow for the implementation of a specific model of trade union relations within the Group, strongly focussed on continuous, constructive, timely dialogue, based on the search for shared solutions. There are currently five trade unions in the Group, involved through regular meetings. The Human Resources Directorate is assisted by the Human Resources Regulatory Advisory Unit for specialised oversight of labour, social security and tax legislation, ensuring that employee-related processes comply with regulations. The Irish Group Companies offer their employees numerous benefits, including health and life insurance, paid leave, educational support, flexible working, well-being programmes and employee incentives. At the Irish Subsidiaries, working hours are monitored through in-house instruments and attendance tools, ensuring that the provisions of the ‘1997 Working Time Act’ are upheld. Lastly, ongoing dialogue with employees
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225 | Mediolanum Group - 2025 Annual Financial Report is ensured through the involvement of the Human Resources Department; there are currently no trade union relations within the Irish organisation. The Group’s Spanish companies have recorded a steady growth in employees, with a significant increase in 2025. For the well-being of its people, Banco Mediolanum implements various measures set out in the Equality Plan, that support a work-life balance, and provide recommendations for digital disconnection, health programmes and occasions for team building, in order to promote a positive environment. The initiatives are disseminated through the ‘Mediolanum Home’ company intranet. In accordance with the specific Collective Agreement, Banco Mediolanum also provides measures for flexible hours and other initiatives to ensure a balance between personal and organisational needs. [S1-4 DP 38 d] The application of the rules of the national employment contracts that the Group applies is in itself a guarantee of the protection and security on which the person and his/her family can rely. The sector CCNL provides a perspective of stability over time and strong social protection in a series of employee life events. This commitment is monitored through the verification and analysis of statistics and reports containing data on the percentage of company turnover and/or turnover by professional category, and the number of resources that have had their contracts stabilised (for example, transformation of an agency contract into permanent employee and/or transition to permanent apprenticeship). 73 To monitor changes in employees’ well-being at work, engagement and/or satisfaction surveys are also offered to all employees by the Human Resources Department. With respect to the adequacy of working hours, all the main records of work attendance, as well as absences and ordinary working hours and overtime hours (where applicable) are constantly monitored on a monthly basis. The Company ensures and promotes the taking up of leave due during the year for the mental and physical well-being of employees, with awareness campaigns for managers and staff, monitoring trends in holidays taken and planned during the year. With regard to the adequacy of pay, each year Mediolanum carries out an accurate and structured monitoring of the adequacy and competitiveness of company salaries, through a series of targeted remuneration analyses. These include a comparison with industry benchmarks, to check the company’s salary positioning relative to the target market, and a study of internal trends, with a focus on the distribution of average pay. These analyses can identify any deviations and opportunities for improvement. Lastly, to take into account employee satisfaction with social dialogue and/or collective bargaining, some significant factors are monitored, such as the number of disputes, the rate of voluntary turnover, the analysis of engagement surveys and the monitoring of holiday take-up plans. [S1-4 DP 43] The internal functions involved in managing impacts are the Human Resources Department and the organisational units involved, such as Human Resources Management and Development, Development and Compensation Systems, Human Resources Administrative Management and Human Resources Regulatory Advisory, which interact on an integrated level with each other. The Human Resources Department also manages the above impacts in the foreign Companies. In particular, the Departamento de Personas for the Spanish Companies and Human Resources for the Irish Companies. 73 For Italy, 21 internships were converted into regular employment contracts during 2025.
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226 | Mediolanum Group - 2025 Annual Financial Report Targets [S1-5 DP 46; ESRS 2 MDR-T DP 80] IROs: Creation of a stable and secure working environment that ensures fair conditions in terms of employment, working hours, wages, social dialogue and freedom of association, favouring the well-being and satisfaction of the Group’s employees Target Target KPI Year target Scope Baseline year and value Progress at 31/12/2025 Employees on permanent contracts % of employees on permanent contracts >90% 2030 Group 2024 (95.55%) 97.60 % The Mediolanum Group is committed to ensuring employment stability, maintaining an annual share of employees on permanent contracts of more than 90%. Target Target KPI Year target Scope Baseline year and value Progress at 31/12/2025 Voluntary turnover % of voluntary turnover as a proportion of total employees <5% 2030 Italy 2024 (3.77%) 3.10 % % of voluntary turnover as a proportion of total employees <7% Spain 2024 (3.20%) 6.63 % The Group’s Italian and Spanish Companies undertake to keep voluntary turnover low, within a threshold consistent with the country’s reference context. Target Target KPI Year target Scope Baseline year and value Progress at 31/12/2025 Qualifying training course for young people under 30 at the Mediolanum Investment Academy number of resources aged under 30 who annually join the training programme (5 participants) 2030 Ireland 2024 (5 participants) 5 participants Mediolanum International Funds launched the Mediolanum Investment Academy project, with the aim of offering a two-year specialised training course leading to possible permanent employment. The programme aims to involve a group of young talented people each year, facilitating their professional development and supporting their potential entry into the Group. [S1-5 DP 47 a; 47 b; 47 c]
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227 | Mediolanum Group - 2025 Annual Financial Report The Mediolanum Group adopts an employee-centric focus, encouraging their active involvement in processes and in defining and monitoring corporate objectives through tools for managing and listening to the workforce. To integrate the perspectives of its Own workforce in the decision-making process and impact assessment, the Company maintains constant dialogue through the Human Resources Department and has implemented a structured process to collect feedback and suggestions, in order to identify lessons learnt and opportunities for improvement arising from business performance. This process includes: engagement and satisfaction surveys periodically given to all employees, with an analysis of results to guide corrective actions and wellness initiatives; dedicated listening channels (e.g. internal platforms and HR helpdesk) to collect proposals and reports. The feedback collected is integrated into decision-making processes and sustainability plans, ensuring transparency and an active participation of the workforce. The monitoring of performance in relation to voluntary turnover objectives and the maintenance of a percentage of employees on permanent contracts is overseen periodically by the Human Resources Department through reports. 3.1.3 Health and safety [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Health and safety Harm to workers resulting from occupational accidents and illness Potential negative impact Own operations Medium term The Group’s approach and policies The Mediolanum Group considers the promotion of workplace health and safety to be an integral part of its values and organisational culture. The Group acts with the aim of creating long-term added value for all stakeholders by protecting the health and safety of its workers, scrupulously complying with the applicable provisions. Over the years, the Group has defined various Policies aimed at ensuring proper management of this impact. In addition to the Code of Ethics and the Mediolanum Group’s Sustainability Policy, which set out its approach and general guidelines, the main policy for managing health and safety impacts is the Health, Safety and Environment Policy. [S1-1 DP 19; 21; ESRS 2 MDR-P DP 65] Health, Safety and Environment Policy Content and objectives; Regulations and reference standards In 2021, Banca Mediolanum adopted a Policy on Workplace and Environmental Health and Safety, which describes the Company’s commitment to managing workplace health and safety and environmental protection, pursuing these objectives with the adoption of the integrated management system for workplace health and safety and the environment through the implementation of the reference standards indicated by ISO 45001:2023 and ISO 14001:2015, for a continual improvement in its operations. Scope of application The Policy, issued by Banca Mediolanum as the Parent Company of the Mediolanum Conglomerate, is directly applied within the Bank and the Group companies based in Italy, in light of the services agreement in force.
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228 | Mediolanum Group - 2025 Annual Financial Report Highest level of management responsible for implementation The Policy, approved by the Employers of the Italian Companies of the Mediolanum Group and shared by the respective Boards of Directors, is sent to the foreign Subsidiaries as a Group provision for its implementation, according to a criterion of applicability in compliance with local legislation and the territorial context. Banco Mediolanum adopts the Italian reference policy, with the sole exception of the absence of ISO 45001 certification. Accordingly, the document incorporates specific references to the PRRLL (Prevention of Risks to Health and Safety at Work) regulations and eliminates any reference to ISO standards. There is also a section dedicated to preventive and specialist activities, which sets out the principles consistent with Banco Mediolanum’s Risk Prevention Plan. The Group’s Irish companies also implement the guidelines defined by the Parent Company and adopt best industry practices, in compliance with local legislation. [S1-1 DP 23] As part of the management system pursuant to UNI EN ISO 45001 (the international standard that establishes the requirements for an occupational health and safety management system), for which the Parent Company Banca Mediolanum has been certified since 2024, there is a specific accident management procedure aimed at mitigating the causes, where possible, and monitoring accidents using specific KPIs. Actions [S1-4 DP 37; ESRS 2 MDR-A DP 68] IROs: Harm to workers resulting from occupational accidents and illness During 2025, with reference to the Group’s Italian companies, the following assessments of risks to worker health and safety were updated: explosive atmospheres, chemical atmospheres, noise, hand-arm vibrations and whole-body vibrations. Both MIFL and Banco Mediolanum adopt the Parent Company’s approach. Specifically, the Spanish subsidiary conducts regular risk assessments in accordance with local legislation and implements initiatives to foster a corporate safety culture, as well as undertaking dedicated evaluations when extra measures are required for specific situations. [S1-4 DP 38 a] The Group Companies update their workers’ health and safety risk assessment annually. Actions resulting from periodic controls and the risk assessment are promptly implemented and managed according to their relevance. In addition, the Group Companies periodically inform, educate and train all employees on occupational health and safety matters, in order to create an established corporate safety culture. [S1-4 38 d] With specific reference to the Group’s Italian Companies, the effectiveness of the actions is monitored within the framework of the ISO 45001 and ISO 14001 certification maintenance process, through first-party and independent audits carried out annually. The results of the audits determine the maintenance of the certifications and are reported to the Supervisory Bodies of the individual Companies, as well as to the Management Bodies. In the Group’s Spanish Companies, an internal performance monitoring process is in place in order to pursue the continual improvement of results. Psychosocial risks are also analysed periodically through collaboration with a company specialising in the prevention of occupational risks. Thanks to this analysis, improvement actions are identified with the involvement of the managers of each department.
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229 | Mediolanum Group - 2025 Annual Financial Report In Ireland, the Senior Management and the Office Manager are responsible for implementing and maintaining occupational health and safety rules through annual certification processes, monitoring and targeted actions where necessary. The Safety Representative ensures that these rules are being applied correctly. A dedicated working group has also been set up, meeting twice a year to assess the progress of activities and any improvement measures. [S1-4 DP 39] The Group has defined a structured process for identifying, assessing and managing occupational health and safety risks, aimed at eliminating or minimizing workplace accidents and occupational diseases. The process involves the adoption and periodic updating of procedures, process regulations and operating instructions, as well as the systematic analysis of incidents without consequences for individuals and near misses to proactively investigate potential risk scenarios. The risk assessment for workers is carried out using specific methodologies for each risk factor, considering both safety and health risks (such as those related to accidents and occupational health). The analysis incorporates the assessment of tasks and operational areas, including historical data on accidents and health monitoring. Overall, a risk matrix that combines probability and severity of events is used. At the end of the assessment, the necessary actions are defined and, with the support of the company-appointed doctor, health protocols are established, if necessary, for tasks. Based on the findings, the Employer prepares a programme of actions that specifies priorities, resources, responsibilities and timelines. This process ensures full compliance with the obligations established by Italian Legislative Decree 81/2008 (Articles 17 and 28). [S1-4 DP 41] The Employer periodically assesses, with the support of the Health and Safety Officer, all risks (social security, health and mental health), bringing the results to the attention of the health and safety governance structures, including the Workers’ Safety Representatives, and any mitigating actions are prepared. Regular information is provided to workers on the risks present in the workplace, including through the provision of periodic training as well as through communications and interventions via corporate channels. [S1-4 DP 43] In order to prevent any workplace accidents and to ensure the implementation of legal obligations in the area of workplace health and safety and environmental protection, all workers are required, each in relation to their own roles and responsibilities, to scrupulously comply with the contents of the Policy, the related procedures and the environmental and safety directives in the performance of their work. Through its Senior Management, the Group exercises effective leadership on the matters indicated in the Policy, overseeing the management system from the highest level of management, thus making it a key component of its organisation, processes, activity and core business. All the persons provided for by Legislative Decree No. 81/08 on the matter of health and safety collaborate according to their respective powers. The Head of the Health Safety Security Environment (HSSE) Sector is the person appointed by the Employer who coordinates the health and safety and environment activities of the Companies based in Italy and governs coordination with Companies abroad. The Head of the Integrated Management System is the person appointed by the Employer and who ensures the correct implementation and application of the processes of the integrated management system, also checking, updating and managing the system documentation. In addition, Banco Mediolanum has a governance structure that provides for the creation of a ‘Health & Safety Committee’, with people identified to manage health and safety issues appointed as committee members.
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230 | Mediolanum Group - 2025 Annual Financial Report Targets [ESRS 2 MDR-T DP 72; 81 a; 81 b] To date, the Mediolanum Group has not set quantitative measurable objectives aimed at achieving results in terms of workplace health and safety. However, within the framework of the Health and Safety Management System, it monitors the effectiveness of the policies and actions adopted, including through performance assessment, in order to pursue continual improvement of the results set in the light of the voluntary UNI EN ISO reference standards, as well as the integrated ISO 45001 and ISO 14001 Management System . The monitored parameters include, for example: the number of health inspections carried out compared with the number scheduled; the percentage completion of mandatory training scheduled and delivered; the number of evacuation drills carried out compared with the number scheduled; and the number of first-party audits of health and safety-related processes. 3.1.4 Work-life balance [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Work-life balance Protection of the work-life balance and mental and physical wellbeing of Group employees Actual positive impact Own operations Medium term The Group’s approach and policies The Mediolanum Group actively promotes corporate well-being, paying particular attention to the work-life balance. Aware of the importance of a working environment that supports employees in practical ways, the Group has introduced numerous initiatives to promote the work-life balance, offering services, dedicated programmes and assistance pathways designed to respond to personal and family needs. Over time, the Group has defined specific policies for managing the impacts related to this area, in addition to collective agreements, the Code of Ethics and the Sustainability Policy of the Mediolanum Group. The main measures include agreements on smart working and the regulation of remote working, which reflect the Group’s commitment to ensuring flexibility and well-being for its employees. [S1-1 DP 19; 21; ESRS 2 MDR-P DP 65] IROs: Protection of the work-life balance and mental and physical wellbeing of Group employees Code of Ethics One of the key principles of the Code of Ethics (see ESRS G1 Business conduct, paragraph 4.1.1. Business culture, section The Group’s approach and policies for further details on the minimum reporting requirements of the Policies) is the integrity and dignity of the person (see ESRS S1 Own workforce, paragraph 3.1.2 Working conditions and human rights, section The Group’s approach and policies for further information on the principle of the integrity and dignity of the person).
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231 | Mediolanum Group - 2025 Annual Financial Report Smart Working and Teleworking Agreements (Italy) Content and objectives Banca Mediolanum has introduced agreements and regulations to facilitate flexible and smart working, ensuring operational flexibility without compromising productivity and security. In addition, to address health needs and promote an inclusive environment, the company has extended teleworking to employees with particular medical conditions, identified by the company physician. Scope of application All employees on fixed-term or permanent contracts can access smart working, including apprentices, by signing an individual agreement that can be renewed each year on expiry. The smart working agreement described above is considered valid and applicable to all Bank employees. For the Companies Flowe, Mediolanum Gestione Fondi, Prexta and Mediolanum Comunicazione, smart working is governed at a general level through specific corporate regulations and specific individual agreements signed by employees. Highest level of management responsible for implementation The highest level of management in the organisation of the undertaking responsible for the implementation of the Policy is the Human Resources Director. Regulations and reference standards Banca Mediolanum’s experimental smart working agreement is regulated by a specific experimental trade union agreement, signed between the Company and its trade union representatives, which governed organically - also as indicated by the national social partners in the ‘National Smart Working Protocol’ of 7 December 2021 and in accordance with the framework provisions on smart working provided for by Article 39 of the National Collective Bargaining Agreement of 19 December 2019, renewed by the Agreement of 23 November 2023 - the organisational and conduct rules that must be followed by employees who perform their work under ‘ordinary’ smart working arrangements pursuant to Law 81/2017 as amended. Method of dissemination The smart working agreement is made available to all interested parties in a dedicated section of the company intranet (HOMEdiolanum). At the same time, the individual smart working agreement is sent by email by the Human Resources Department to individual employees for them to sign if they wish. Agreement on the regulation of remote working (Spain) Content and objectives; Regulations and reference standards The Spanish Companies have entered into an agreement with the RLT (Representación Legal de los Trabajadores) to regulate the essential terms of the provision of remote services by the Company’s workers, in accordance with the requirements set out in Law 10/2021 of 9 July on remote working. Scope; Highest level of management responsible for implementation The agreement, approved by the Board of Directors and implemented by the Personas Area, applies to all people who work at Banco Mediolanum and who work remotely. Method of dissemination This document is published on the intranet and sent to all employees to be signed. E-Working Policy (Ireland) Content and objectives Since September 2020, the Irish Subsidiaries have implemented a remote working Policy, with the aim of establishing guidelines and best practices to enable staff in Ireland to work remotely.
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232 | Mediolanum Group - 2025 Annual Financial Report Scope of application The Policy applies to all employees of the Irish Group Companies, in line with the Policy itself. Highest level of management responsible for implementation The highest level of management responsible for administering the Policy is the Chief Executive Officer. Method of dissemination The Policy is available on internal corporate tools (such as Metric streem or the myMed-HR System). Actions [S1-4 DP 38 c] The Group actively promotes a work-life balance through flexible and smart working policies and agreements, with the aim of ensuring organisational flexibility and improving the quality of life of employees. In addition, the Group invests in structured corporate welfare programmes, which include benefits and services to support individual and family well-being. An integrated and responsible approach is adopted in the management of supplementary pensions and pension plans, in order to ensure long-term financial security. Finally, particular attention is paid to parenthood and family care, with initiatives aimed at promoting a sustainable work-life balance. The protection of mental and physical well-being, and the wellness of employees are crucial factors for the Group, which sees its role of looking after people as more broadly defined, according to a more conscious approach to corporate social responsibility. In addition, the Mediolanum Group not only ensures a healthy and safe working environment, but also promotes physical health by providing programmes and incentives to encourage a healthy lifestyle. The Group is paying closer attention to the quality of life in working environments and, in particular, to the relationship climate, by promoting motivation and professional development. [S1-4 DP 37; ESRS 2 MDR-A DP 68] IROs: Protection of the work-life balance and mental and physical wellbeing of Group employees Review and redefinition of teleworking principles In response to the specific health needs of employees and to facilitate their operability, besides promoting an inclusive and flexible working environment, the Company, as indicated above, has also extended the teleworking agreement to more employees with specific health conditions, as identified by the company physician. During 2024, therefore, in agreement with trade union representatives and with the direct involvement of the company physician, the principles and methods of the organisation and management of teleworking were reviewed and redefined. During 2025, the individual agreement for remote working was given to employees. This has enabled 17 new teleworking arrangements to be formalised, ensuring that tasks can be carried out in a flexible manner. Wellmed Plan For more than 20 years, the Italian Companies of the Mediolanum Group have been developing a supplementary corporate welfare initiative: the Wellmed Plan. The Plan is managed by the Human Resources Department, which has ownership of the processes. The Plan covers diverse areas, designed to meet the multiple needs of employees, both through initiatives and services, as well as monetary benefits. Flexible benefits are also available, allowing employees to replace a part of additional compensation with services dedicated to them and their families.
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233 | Mediolanum Group - 2025 Annual Financial Report Wellmed Wallet During 2025, the Italian Companies of the Mediolanum Group signed an agreement with AON for the management of an IT platform, through which employees can use a welfare credit that is paid by the Company annually. Employees have a welfare account to be used only to access the services available on the platform. The credit of the Wellmed Wallet welfare plan is ‘figurative’, and can be accessed during the year. For example, to support the social needs of employees and their families, the Group gives individuals signing Smart Working agreement a one-off increase in the Welfare Credit provided for in the Wellmed business plan of €250. Health prevention and protection initiatives In 2025, the Italian Group Companies, as part of a constant commitment to promoting and protecting the mental and physical well-being of their employees, implemented a series of initiatives aimed at raising awareness and promoting the topic of health care. In January 2025, Banca Mediolanum launched ‘Carol’, a digital primary care service for its employees and their family members. The service, fully supported by the Bank for primary care, was used by about 1,500 employees and 1,100 family members, with more than 6,650 services provided over the year, including 200 paediatric consultations. In the autumn of 2025, a free flu vaccination campaign was organised on the company campus, with some 670 employees taking part. Initiatives were also promoted in collaboration with ‘Lega Italiana per la Lotta contro i Tumori’ (Italian League for the Fight against Cancer), with approximately 650 participants overall. The campaign to prevent skin cancer was launched in the Spring, while the breast cancer prevention campaign began in September, with in-house diagnostic tests (ultrasound and mammography) for two separate targets: over 40 and under 39. In line with its commitment to prevention, thanks to the collaboration with the Health Centre ‘Consorzio Medico Il Sole’, a complete ultrasound screening was organised with immediate results, at no additional cost to employees. Approximately 500 people participated. In February and September 2025, in collaboration with Avis, a mobile blood unit was made available on campus, allowing employees to donate blood on site at the workplace. During the reporting you, various services and initiatives dedicated to health and well-being were offered: specialist osteopathy and nutrition services were made available to employees at preferential rates, and the Group joined the ‘Health Friendly Company’ programme, promoted by the ONDA Foundation, which included training videos, informational snippets and online publications focused on women’s health. To combat addiction to nicotine and electronic cigarettes, the ’Smetto di fumare’ stop smoking programme was launched, consisting of four webinars led by a psychologist and psychotherapist, with the opportunity for participant to explore their own situation through dedicated psychological counselling and a pulmonary check- up at reduced cost at the San Raffaele-Resnati Clinic. Finally, the gamification initiative ‘Ogni Movimento Conta’ (‘Every Movement Counts’) was launched, designed to promote physical activity and well-being within the Mediolanum community. Sporting activities were monitored based on calories burned and, upon reaching a total of five mln calories burned, an amount was donated to charity, transforming participants’ commitment into a concrete gesture of solidarity. Further initiatives to support the work-life balance In order to ensure and support the work-life balance for employees, in 2025, the Group provided the following services and initiatives at the Mediolanum Campus in Basiglio:
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234 | Mediolanum Group - 2025 Annual Financial Report a company day nursery: a facility for around 130 children of employees. The monthly fee payable by the employee is approximately half the amount actually payable: the other half is paid by Banca Mediolanum; a free tax return assistance service for Form 730. The service is provided under a business agreement with a major Tax Assistance Centre; a company transport service, for the route from the closest Milan metro stops to the Milano 3 City Campus and back. An average of 30 journeys per day are scheduled; a restaurant service, available in the facilities on the Campus. The Mediolanum Group has signed an agreement with a benefit corporation that is a leader in catering services, to provide a personalised offering in line with nutritional protocols and with a zero km supply of raw materials; an Amazon Lockers service. The Mediolanum Campus hosts a large Amazon Hub Locker to meet the needs of all employees; a driver’s licence renewal service. On Campus there are also other useful time-saving services, such as: a bakery and a food shop, a participating pharmacy, free fresh seasonal fruit, cultural initiatives, fitness courses and locker rooms for anyone wanting to participate in sports activities before or after working hours, and/or during lunch breaks. With the aim of promoting a work-life balance, attention has also been focused on parenting and support for families. During 2025, the Group promoted several initiatives, including: Futurely: a free digital platform for educational guidance, intended for the children of employees and including two alternative options: one pathway for children in high school who have to choose a university, and another pathway for children in middle school who have to choose a high school. Banca Mediolanum also supports the use of Futurely for 16 classes at the Calvino di Rozzano High School; ‘Family Caregiver Support|Ogni età ha voce’ (Family Caregiver Support |Every age has a voice), a programme designed to support those caring for a family member with specific critical issues. Nine podcasts are planned, with the first four scheduled for release in 2025 and the remainder in 2026, each lasting a maximum of 10 minutes so that they are easily and immediately accessible. There will also be a dedicated telephone number where employees can request psychological assistance or the help of a Care Manager who specialises in helping employees access local opportunities and services. All the tools offered are free and anonymous. During 2025, the project continued in collaboration with LIFEED, launched in 2021, designed to accompany professional transitions and support life changes, such as the beginning of parenthood. The initiative, through webinars, readings, cases for reflection and skills workshops, aims to enhance the experience of parenthood and moments of change, transforming them into opportunities for personal and professional growth. Analyses of work-related stress The Human Resources Department also supports the Health Safety Security & Environment Section, which, on behalf of the Employer, regularly carries out analyses of work-related stress, in order to monitor the mental and physical well-being of employees. See ESRS S1 Own Workforce, paragraph 3.1.3 Health and Safety, section ‘Actions’ section for further details.
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235 | Mediolanum Group - 2025 Annual Financial Report Collective health and term life insurance policy In addition to a health insurance plan for employees that protects them against major risks and the most serious health problems, in 2025 the Group maintained a collective term life insurance policy for all employees on permanent contracts and for apprentices, which provides for a supplementary benefit, paid to the spouse or cohabiting partner, children or, in the absence of these, the heirs of the employee. Supplementary pensions and pension schemes for employees Aware of the importance of building up a supplementary pension, especially in the context of longer working lives, the Mediolanum Group adopts an integrated and responsible approach to this issue, actively promoting employee participation in complementary pension schemes with favourable terms, which supplement the mandatory pension. The opportunities offered, based on internal agreements, include the possibility of allocating a part of the productivity bonus or a share of the welfare plan to supplementary pensions. In addition, through the internal advisory service ‘Supporters’, Mediolanum acts as a reliable partner, providing customised solutions that guarantee long-term financial security and stability. Supplementary pensions information campaign The Group constantly monitors its employees’ participation in supplementary pension plans and periodically communicates with them in order to increase their knowledge and emphasise the importance of making informed decisions. In particular, in 2025, an information campaign was launched for employees of the Group’s Italian Companies through video interviews with experts published on the company intranet. Welfare initiatives in Spanish companies With regard to Banco Mediolanum, in addition to the provisions of the collective bargaining agreement that regulates employment relationships with staff, there are also conciliation measures and special authorisations, such as, for example, accompaniment for parents to medical consultations and school interviews. Flu vaccination on a voluntary basis is regularly offered, and during 2025 Banco Mediolanum carried out initiatives related to the well-being and health of employees in sports, such as yoga lessons and paddle, football, volleyball and basketball tournaments. Finally, with the aim of providing psychological and emotional support to employees, the opportunity was given to attend a free session with a psychologist. Welfare Initiatives in Irish Companies For many years, the Group’s Irish companies have developed a range of supplementary corporate welfare initiatives, including both the provision of services and monetary and non-monetary benefits. These include, for example, preventive measures and private health and family-care assistance, supplementary pension schemes, life insurance, income protection benefits, a canteen service with a daily allowance, and numerous other services supporting employees’ overall well-being. These initiatives are accompanied by a regular campaign to promote well-being, which is open to all colleagues. In 2025, the programme included individual coaching sessions with an organisational psychologist and seminars on mental health, nutrition, and financial well-being. As for the protection of employees’ health, the Company provides all staff with fully subsidised health screening. In addition, in 2025, ‘CAPSULA’ was made available. This technologically advanced device provides a basic check-up in just a few minutes, analysing the main health indicators. The aim is to provide an immediate and non-invasive assessment of individual well-being, encouraging employees to take a proactive approach to caring for their health. [S1-4 DP 38 d]
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236 | Mediolanum Group - 2025 Annual Financial Report All the initiatives described above are monitored by verifying and analysing statistics and reports on take-up and satisfaction data on the services and activities offered. For example, the data on the take-up percentage of the individual smart working agreement, the turnover rate, the number of employees joining initiatives dedicated to protecting the work-life balance and their mental and physical well-being. The Human Resources Department provides all employees with engagement and/or satisfaction surveys, as well as quick surveys at the end of each initiative, in order to collect useful information to identify any aspects for attention and areas for improvement, as well as steer the definition of future activities and initiatives. [S1-4 DP 43] The Structures involved in managing impacts are the Human Resources Department and its organisational units, which interact on an integrated level, and include Human Resources Management and Development, Development Systems and Compensation, and Organisational Environment. The Human Resources Department also manages the above impacts in the foreign Companies. In particular, the Departamento de Personas for the Spanish Companies and Human Resources for the Irish Companies. Targets [S1-5 DP 46; ESRS 2 MDR-T DP 80] IROs: Protection of the work-life balance and mental and physical wellbeing of Group employees Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Joining the Smart Working contract % of employees participating in smart working > 90% 2030 Italy 2024 (99.5%) 99.7% Spain 2024 (99.0%) 99.0% The Group’s Italian and Spanish companies aim, on an annual basis and through the signing of Smart Working agreements, to keep the participation rate above 90%. Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Employee health prevention No. of annual campaigns ≥ 10 2030 Italy 2024 (11) 13 No. of annual campaigns ≥ 8 Spain 2024 (8) 12 No. of annual campaigns ≥ 5 Ireland 2024 (5) 5 The Mediolanum Group is committed to promoting and ensuring preventive health campaigns aimed at protecting its employees’ health.
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237 | Mediolanum Group - 2025 Annual Financial Report Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Volunteering in the social sphere % of employees who participate in volunteering initiatives ≥ 10% 2030 Ireland 2024 (6.3%) 10% The Irish Companies are committed to involving an increasing number of their employees in voluntary activities at chosen charities on an annual basis. [S1-5 DP 47 a] The process of setting objectives for the prevention of occupational health risks for employees is guided by the Group’s management, in line with the corporate strategy and a constant commitment to people’s well-being. Decisions are made based on an in-depth analysis of the health and well-being needs of the workforce, also conducted through engagement and/or satisfaction surveys administered to employees, in order to ensure targeted and genuinely useful initiatives. This approach is integrated with corporate welfare guidelines and industry best practices, ensuring consistency and quality in the proposed initiatives. Moreover, the objectives are defined taking into account the principles of social sustainability laid down in the Group Business Plan, because the health of employees is considered a fundamental value for the sustainable growth of the organisation. [S1-5 DP 47 b] Monitoring performance against objectives is managed internally by Group management and the relevant Functions, without the direct involvement of the Group’s own workforce or trade union representatives. However, results and progress are communicated transparently through periodic reports and dedicated information channels, in line with the principles of accountability and the standards established by the CSRD. [S1-5 DP 47 c] The Mediolanum Group has implemented a structured process to collect feedback and suggestions from the workforce, in order to identify lessons learnt and opportunities for improvement arising from company performance. For further details, see ESRS S1, paragraph 3.1.2 Working conditions and human rights, section ‘Targets’, DP 47 a; 47 b; 47 c. 3.1.5 Training and skills development [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Training and skills development Employee satisfaction thanks to appropriate training programmes, performance appraisal systems and career development plans Actual positive impact Own operations Medium term Harnessing the value of human capital, thanks to initiatives and activities that include aspects related to training and skills development Opportunities Own operations Medium term
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238 | Mediolanum Group - 2025 Annual Financial Report The Group’s approach and policies [S1-1 DP 19; 21; ESRS 2 MDR-P DP 65] For the Mediolanum Group, learning and training have always been fundamental. Staff follow pathways and training activities designed to encourage continual improvement, both professional and personal, with the aim of developing cross-cutting, specialised skills. The development of human capital is conceived as a lifelong career pathway, requiring structured, diversified and balanced training over time. Over the years, the Mediolanum Group has developed various Policies aimed at ensuring proper management of these impacts and opportunities. In addition to the Code of Ethics and the Sustainability Policy of the Mediolanum Group, which refer to its approach and general guidelines, the main policy for managing impacts and opportunities related to ‘Training and skills development’ are the Regulations on the process of training the Sales Network and employees. IROs: Employee satisfaction thanks to appropriate training programmes, performance appraisal systems and career development plans; Harnessing the value of human capital through initiatives and activities that include aspects related to training and skills development Code of Ethics One of the key principles of the Code of Ethics (see ESRS G1, Business conduct, paragraph 4.1.1. Business culture, section ‘The Group’s approach and policies’ for further details on the minimum reporting requirements of the Policies) is the value of human resources. The staff of the Mediolanum Group are an essential and indispensable part of the success of the business. For this reason, Mediolanum protects and promotes the value of human resources in order to improve and increase the assets and the competitiveness of the skills of each staff member. Mediolanum is committed to stimulating the capacity, the potential and the personal interests of its staff in order to achieve the corporate objectives. Regulations on the process of training the Sales Network and employees Content and objectives The Regulations on the process of training the Sales Network and employees set out the guiding principles, organisational architecture and interdependencies underlying the training process for the Sales Network and employees. ‘Training’ refers any training initiative, provided either in a standardised format (classroom courses, webinars and online courses) or by any other method deemed more suitable from time to time due to the nature of the content or the audience of learners (info-training events, corporate TV episodes, meetings, on- the-job training, etc.). This training process is an integral part of the professional growth strategy of the Network and the Bank’s internal organisational units, with the aim of increasing knowledge and skills, mitigating the risk of obsolescence and regulatory non-compliance, and the workforce’s employability. Scope of application The Policy covers all employees of the Mediolanum Group, including the Italian Subsidiaries of the Conglomerate. Periodic coordination and collaboration meetings are planned with the foreign Subsidiaries and with the Sales Network. Highest level of management responsible for implementation The Head of the Human Resources Training Section, together with the Head of Sales Network Training, are the reference for the Regulations on the process of training the Sales Network and employees.
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239 | Mediolanum Group - 2025 Annual Financial Report Regulations and reference standards The Regulations comply with current legislation, ensuring compliance with legislative and regulatory provisions in the banking, financial and insurance fields. The external reference legislation includes: Regulation (EU) 2016/679 on privacy; Directive 2014/65/EU (MiFID II); Directive (EU) 2016/97 on insurance distribution (IDD) and the ESMA Guidelines (ESMA/2015/1886) on the assessment of knowledge and competence. Relevant national legislation includes: Law 236/93 on company training for workers and the IVASS and Consob Regulations; Legislative Decree No.125/2019 on anti-money laundering; the Order of 18 June 2019 on the ‘Transparency of banking and financial transactions and services’ and Legislative Decree No. 231/01. Stakeholder involvement The Regulatory Training Line of the Network Training Section and the Human Resources Training Section carry out, at least once a year, an assessment test on a statistically significant sample of the Sales Network and the Head Office staff in scope, in order to collect data on the annual updating of the development and training needs of its Network and of Head Office employees. Method of dissemination The Regulations form part of the internal corporate regulations and are therefore available to all employees on the Mediolanum Group’s knowledge sharing platform (WeKnow). The Group’s foreign companies have also drawn up policies and documents similar to those of the Parent Company, for the management and support of ongoing staff training. Actions [S1-4 DP 38 c] The employees of the Mediolanum Group are a fundamental resource for the Company’s success, and the Bank therefore constantly invests in the development and well-being of its workforce. In order to ensure maximum satisfaction and enhance individual skills, Mediolanum has implemented a series of initiatives aimed at promoting professional growth and creating a working environment that can stimulate personal skills, potential and interests. Each year, the Group is committed to activating appropriate training programmes that meet the various professional needs, supporting each employee in the continual improvement of their skills. In parallel, performance appraisal systems enable individual progress to be monitored and potential development areas to be identified. Finally, through targeted succession plans, Mediolanum is committed to promoting opportunities for growth and career development within the organisation, so that every employee can reach his/her full potential, thereby contributing to the achievement of corporate objectives. [S1-4 DP 37; 40 b; ESRS 2 MDR-A DP 68] IROs: Employee satisfaction thanks to appropriate training programmes, performance appraisal systems and career development plans; Harnessing the value of human capital through initiatives and activities that include aspects related to training and skills development Training The training plan is defined and implemented to support the company’s strategic challenges by developing the Mediolanum Group’s human capital. It enriches knowledge and skills, strengthens the system of values and culture, and ultimately strives to provide the customer with ever-higher-quality service and high-level performance.
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240 | Mediolanum Group - 2025 Annual Financial Report In 2025, training activities for staff in Italy recorded further growth compared to the previous year, achieving the best ever result with over 130,000 student hours. The initiatives, carried out through a wide variety of methods (classroom training, webinars, online courses, workshops and external training), involved almost the entire corporate population. The number of training hours per capita for employees totalled 40, in addition to activities for stakeholders that, with different types of partnerships, use the Group’s expertise and support to contribute to the common objective of providing an excellent service to end customers, based on open-architecture knowledge-sharing methods. Taking these volumes into account, the total amount of training hours delivered in 2025 exceeded 200,000 student hours. The main initiatives included: Digital Transformation: the training programme to support the Digital Transformation was launched at the beginning of this year with the aim of supporting the Company in meeting the challenge of acquiring and developing digital skills, with both reskilling and upskilling pathways, to support performance in a context in which technology is constantly evolving. First and foremost, a digital awareness programme, ‘I am a mindful use’, was launched with the aim of promoting a responsible and thoughtful approach to change and the adoption of new technologies, involving more than 3,300 employees. In addition, the first individual organisational units were involved in a precise analysis of the digital readiness of their personnel, through digital skills assessment, and the collection of needs consistent with business objectives. Finally, another part of this training programme was developed: the workshop ‘Lead in digital: leading people not only technologies’, which created the opportunity to discuss with the first 60 managers the impacts of digital transformation on their role and on managing their teams, pooling practices, needs, fears and expectations. As not only digital transformation is concerned, but also a constantly evolving focus on leadership, this initiative marked the start of a Leadership Evolution programme that will involve all of Mediolanum’s management in the coming years; IT ACADEMY: in May 2025, the IT Academy project was launched, involving the recruitment of approximately 90 people, mainly STEM graduates 74, over three years, dedicated to project delivery (technical analysts and programmers), with the aim of enhancing the process of internalising strategic activities within the IT structure. To support this initiative, a 200-hour training programme was developed, consisting of 30 in-person classroom days with external trainers, involving two classes in total, comprising 29 new employees. Classroom lessons, focused on the main programming languages, were accompanied by 13 days of on- the-job training, during which new hires worked with senior colleagues to apply what they had learnt; ICT RISK & RESILIENCE EXPERT: in 2025, in collaboration with ABIFormazione, the ICT Risk & Resilience Expert course was also designed, for colleagues in the ICT, Risk Management, Internal Audit, Compliance, Organisation, Procurement and Outsourcing functions. This course, comprising 5 modules, is given by an external trainer, and also features internal case histories from the Bank’s management, with the aim of providing a general overview of the subject, further exploring the regulatory framework, with particular reference to the DORA, analysing the operational repercussions and promoting an information culture and risk culture; 74 STEM: Science, technology, engineering and mathematics. To be classified as a STEM employee, a worker must have a STEM-related qualification and apply those skills in their operational role. Positions include but are not limited to computer programmer, web developer, statistician, logistician, engineer, physicist and researcher/scientist. For Italy, the percentage of women employed in STEM roles as a proportion of the total STEM workforce is 30%.
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241 | Mediolanum Group - 2025 Annual Financial Report LEARNING DAYS: between 10 and 13 November 2025, the Learning & Values Days took place. These four days dedicated to the value of learning involved over 450 colleagues who, on a voluntary basis, participated in talks, workshops and training experiences within the framework of Mediolanum Corporate University, which has been providing training with a focus on corporate values for more than 15 years; Basics of project management : with a view to continually developing the skills essential for proper job performance, the course ‘Introduction to Project Management_the essential kit for managing a project’ was held, designed to give colleagues, without specific skills, the tools necessary to effectively manage the small projects that are often entrusted to them; Team building: in the reporting year, particular emphasis and space were dedicated to training initiatives focused on the development and concentration of group dynamics, with the aim of creating team building and teamwork activities within certain departments, placing a special emphasis on trust - which is essential for effective cooperation and team work; Mandatory training and Risk Culture: in 2025, the Group further strengthened its commitment to mandatory training, with the aim of promoting a corporate culture focused on transparency, fairness and customer protection, in line with the most recent legislative and regulatory provisions. The training was designed to meet both the ongoing training needs of the entire company workforce and the specific requirements of specialist roles. A key element of the 2025 training strategy was strengthening the organisation’s risk culture. The ‘Risk Culture’ course, which is for all employees, aimed to further explore the strategic role of risk culture in business decisions, promoting the understanding and application of the fundamental principles of risk management. Particular attention was paid to ECB guidelines and their impact on operational practices. All employees were also assigned courses aimed at raising awareness of issues such as transparency and proper conduct at work. Specifically: o the course on ‘Protecting Privacy in Banking’ provided practical tools for the safe handling of information; o the course ‘Transparency for the banking customer’ explored banking transparency in depth, which is fundamental for the protection of customers and the stability of the financial system; o the ‘Anti-Corruption’, ‘Market Abuse (Core)’ and ‘Personal Transactions’ modules reinforced the ethical and regulatory principles for preventing unlawful conduct and market manipulation; o the ‘DORA (Digital Operational Resilience Act)’ course, dedicated to new regulatory developments and tools for the digital resilience of financial entities; o lastly, there were the short sessions on the theme of ‘Digital Mindfulness’.
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242 | Mediolanum Group - 2025 Annual Financial Report In addition, for specialist roles, courses grouped into three main thematic areas were provided: customer protection and transparency in financial services: the courses on ‘Transparency in payment services’, ‘Transparency in consumer credit’ and ‘Transparency in real estate credit agreements’ examined the regulatory framework and customer rights at all stages of the contractual relationship, from the pre-contractual stage to the post-contractual stage, with the aim of ensuring a clear and protected relationship between the intermediary and the consumer; risk management and fraud prevention: the course on ‘unauthorised payment transactions’ provided the tools for recognising and managing fraud techniques, illustrating internal policies and reimbursement procedures according to the supervisory expectations of the Bank of Italy. The course ‘Market Abuse (Specific)’, on the other hand, investigated the legal and practical aspects related to insider trading, market manipulation and administrative responsibilities, with the analysis of cases and CONSOB orders; product governance and best practices: the courses on ‘Regulations and best practice in product offerings bundled with financing’ and ‘Product oversight governance (POG) in the insurance sector’ provided the principles and tools for product oversight, illustrating safeguards, protective measures and case studies in accordance with the guidance of the Bank of Italy and IVASS. In addition, the following periodic refresher courses were provided: updates on anti-money laundering, with meetings organised in conjunction with the AML Function dedicated to personnel more directly in contact with customers or otherwise involved in the process of reporting suspicious transactions, as well as anti-money laundering function staff; annual 30-hour IVASS/CONSOB update; the IVASS update is mandatory for personnel involved in insurance distribution, while the CONSOB update applies to staff engaged in advisory activities or the placement of financial products. In addition, advanced training programmes were offered, including the Mediolanum Certificate in Banking, Finance & Insurance, designed to support the professional development of middle management and talents. Finally, particular attention is paid to new hires, with a values‐based onboarding programme dedicated to them, called Mediolanum Journey. In addition they are assigned all mandatory core courses. These core courses, which cover issues such as the Code of Conduct, the administrative liability of entities, whistleblowing, privacy and other essential aspects of company compliance, are assigned when new hires join the company. In this way, each new employee can acquire in a timely manner the basic knowledge required to comply with the Group’s rules and values. The foreign Companies of the Mediolanum Group take a structured approach to training, in line with the framework of ongoing learning and development. Through the identification of required skills and any gaps at organisational and individual levels, training programmes are designed to raise employee skill levels, increasing engagement and satisfaction, and compliance with values. The Spanish Companies define the internal training plan on an annual basis, with the aim of aligning staff with the corporate culture, ensuring professionalism with regulatory and corporate training and improving quality and efficiency through technical skills. During 2025, various training programmes were started in Spain, including training on diversity and inclusion matters; language training; the training programme on Mediolanum’s values; specific leadership training; the mentoring programme and technical courses on MIFID, Power BI and Excel. In addition, courses on ‘Copilot’ and the new Accessibility Directive were launched.
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243 | Mediolanum Group - 2025 Annual Financial Report The Irish Group Companies continued to invest in technical training during the reporting period and promoted specialised courses such as CFA75, ACCA76, CIMA77, Python Programming and Sustainable Finance, with the aim of strengthening strategic expertise, corporate culture, retention and performance, ensuring better results for customers and organisation. In 2025, a comprehensive development programme was also launched in collaboration with a leading external organisation specialising in talent mapping and growth (Talent development programme). This initiative has helped map both performance and potential across all roles and will form the basis for a structured plan for 2026 to align talent with organisational needs. Through coaching, mentoring and continuous learning, people will be provided with the tools to reach their full potential, which is essential to deliver long-term value to customers and stakeholders. Moreover, the Irish companies, also in 2025, invested in young talent in order to train future leaders. During the year, the second edition of the Mediolanum Investment Academy (‘MIA’) was completed and the third edition was launched. This programme combines technical skills and strategic thinking through two years of immersive learning, supported by senior mentors, with the goal of transforming junior talent into future investment leaders. Development and Compensation Systems The Mediolanum Group has always paid close attention to the development and continual improvement of its people, adopting tools and initiatives aimed at bringing business needs closer to individual requirements. People development embodies our company values, puts people at the centre of everything and encourages satisfaction, retention and talent engagement. At the heart of this strategy are the performance management system, position weighting and the appraisal of potential. These processes involve the entire corporate population in dedicated professional development paths and aim to manage career progression, promotions, level advancement, internal mobility and succession planning objectively. The processes always ensure the absence of discrimination based on gender, age, ethnic origin, disability, language, political or sexual orientation, or religious belief. Performance Management is the set of processes and tools dedicated to managing, assessing and improving work performance. A distinctive element of the process is the direct involvement of people: from defining individual objectives to the finalisation of results, thanks to the Self Appraisal tool, which promotes accountability, transparency and continuous dialogue between employees and managers. Approximately 3,000 performance appraisal sessions were held during 2025. The Company also uses recurring Job Evaluation processes which, depending on the complexity, are carried out partly by in-house specialists and partly by external consultants. In 2025, Job Profile was launched - a major improvement in methodological efficiency with a view to the digital transformation of internal processes. This led to a reduction in appraisal turnaround times and a more effective involvement of the stakeholders in the process, resulting in a final increase in analysed positions. Around 60 positions were weighed in 2025 using this new process, and similar volumes are expected in 2026. Individual development assessments, conducted regularly by internal staff and accredited external consultants, are designed to identify aptitude and professional characteristics to guide development towards roles with a greater responsibility or that are better suited to the individual. Assessments measure personal traits, skills and competencies through role-play observations, group interactions, interviews, written tests, and online tests. The assessment focuses on the effectiveness and frequency of behaviours related to role-specific skills. The results support career and growth decisions, formalized in a development report and plan which the participant helps to produce. During 2025, 5 group assessments and 13 individual assessments were carried out, involving a total of 47 participants. 75 Chartered Financial Analyst. 76 Association of Chartered Certified Accountants. 77 Chartered Institute of Management Accountants.
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244 | Mediolanum Group - 2025 Annual Financial Report The platform to develop human capital skills is the ‘UPraisal’ hub, that accompanies people on skills development pathways with the aim of bringing out results, talent and capacity. UPraisal enables users to navigate through Mediolanum’s skills, read their definition, understand behavioural details and discover, above all, what training content is suggested, to bridge any gaps. Access is monitored using the analysis tools provided, which record the use of individual content. FEEDBACK4U For several years, Banca Mediolanum has implemented a system of continuous feedback as a strategic lever for employee development and the strengthening of corporate culture. In 2025, the Feedback4U tool, already featuring all feedback functionalities and used in assessment and professional development programmes, expanded its role, becoming a key player in initiatives aimed at fostering interfunctional collaboration, especially in contexts of organisational change. This evolution reflects the Group’s commitment to continually adopting innovative tools and methodologies, with the aim of promoting new approaches to people management and the enhancement of human capital. Integrating feedback into transformation processes not only supports transparency and sharing, but also helps build stronger connections between teams and functions, accelerating cultural alignment and adaptability. Succession Planning There has been an increasing focus on succession plans, refining their adoption, not only as a formal obligation but as an awareness of governance and the strategic management of this business process. Succession Planning is a tool to safeguard management stability in the medium‐ to long‐term, ensure good corporate governance and develop corporate talents. In accordance with supervisory regulations for banks, the current Plan represents the formalisation of the process that Banca Mediolanum has adopted, through an orderly succession to senior positions, in order to protect the Company from possible organisational weaknesses in critical roles that could have financial and/or reputational consequences. The Bank seeks to ensure timely substitution and support succession planning for those resources in the Company that hold senior positions and/or roles considered key for the Group. The process is structured differently depending on the role that is the subject of succession, always taking into account non-discriminatory elements in terms of diversity and inclusion. In 2025, the Succession Planning Policy was updated in order to bring it into line with the company’s organisational changes, taking into account that, in the meantime, internal and external regulations have not changed. Job Posting The internal job posting system works as a tool for professional development and as an internal recruitment channel, enabling all employees who apply to showcase their profiles, helping to promote the growth of resources, develop talent, enhance skills acquired and support business knowledge from an all-round perspective, as well as encourage job rotation, according to criteria focussed on transparency and meritocracy. In 2025, 19 advertisements were published, with 202 spontaneous applications. Finally, in the context of ongoing training and job rotation, a specific tool is available for new hires for the assignment of technical skills within the Customers Banking Centre and the Sales Support Centre (Front Office structure): ‘skill posting’. This tool consists of a process that enables: personal growth and increasing knowledge of the Bank’s business and customer service; understanding the approach underlying skill posting; making resources increasingly proactive and responsible in submitting personal applications; and transparently identifying deserving resources who are more aligned with the professional profiles sought internally.
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245 | Mediolanum Group - 2025 Annual Financial Report Foreign companies also promote a culture of growth and the exchange of feedback. In Ireland, performance is appraised either through an annual review or through the 30/30 ongoing appraisal system (i.e., 30 minutes every 30 days) to ensure it is in line with expectations. Banco Mediolanum uses an annual performance assessment system that requires a minimum of two meetings between each line manager and his or her staff. The process, coordinated by the Area de Personas, requires the compilation by the line manager of a qualitative and quantitative assessment sheet, which sets out the skills that the staff member should have in order to carry out his/her tasks. During 2025, analytical skills, technical skills relating to the relevant role in the Company, relational skills, and, lastly, attitude and positivity, in line with corporate values, were assessed. Banco Mediolanum offers various services and tools to support staff development. These include job posting - a development tool born from the desire to enable employees to make their CVs and aspirations known to the Company. The aim is to promote the professional development of individuals and employees’ abilities and skills. More than 9 job postings were created in 2025. [S1-4 DP 38 d] Periodically, the Mediolanum Group’s resources are listened to through the use of climate surveys to measure their level of satisfaction with training and development initiatives. #VociDiMediolanum was the latest internal opinion survey (climate survey), carried out at the end of 2024, thanks to the use of technological solutions that guaranteed anonymity in completing the questionnaire. The survey results were processed in the first quarter of 2025 and further focus groups were organised on topics considered particularly interesting. In addition, ‘hot’ satisfaction questionnaires are promptly administered at the end of training initiatives to assess the satisfaction of the participants and the effectiveness of the training. For 25 years, this investigative tool has been used cyclically to gauge the level of engagement and personal opinions on various aspects of working life. The aim is to subsequently identify actions that can increase employee welfare and promote a positive climate and motivation at work. The process involves measuring people’s perception and degree of engagement, with a view to promoting a responsible, proactive contribution to the Group’s objectives. The survey involved employees of the Mediolanum Group in Italy using an online questionnaire, which focused on listening to opinions on 13 survey topics and two open questions. People expressed their opinion, confirming the spirit of participation and openness to continual improvement that sets Mediolanum apart. Adherence to the initiative resulted in a voluntary participation level of the corporate population of 82.5%, in line with the expectation indices used by other national and international companies. In 2025, Banco Mediolanum also gave various surveys to employees to identify their level of satisfaction with certain training and development initiatives. At the end of several training initiatives, for example, on leadership, Copilot training, Diversity and Mentoring training, participants were asked to complete questionnaires to assess their level of satisfaction on the usefulness, content, duration and other aspects of the sessions, with the aim of identifying areas for improvement or enhancement. The main results of the surveys were positive, indicating that most participants were satisfied with the programmes. Regarding the Irish Group Companies, the external company Mazars was engaged with the aim of conducting a culture review (in January 2026) through a focus group. The review will verify whether the business climate reflects the Corporate Culture Policies’ aspirations and related internal procedures, following on from the previous year’s report. [S1-4 DP 43]
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246 | Mediolanum Group - 2025 Annual Financial Report In the Human Resources Department, the specific organisational units involved in the design and delivery of training activities (Human Resources Training) and the creation of assessment systems and tools and development plans (Development Systems and Compensation) operate, all in collaboration with the Human Resources Management and Development Division. The Human Resources Department also manages the above impacts in the foreign Companies. In particular, the Departamento de Personas for the Spanish Companies and Human Resources for the Irish Companies. Targets [S1-5 DP 46; ESRS 2 MDR-T DP 80] IROs: Harnessing the value of human capital, thanks to initiatives and activities that include aspects related to training and skills development Target Target KPI Target year Scope Year and baseline value Progress at 31/12/2025 Provision of training hours Hours of training per capita ≥ 40 hours 2030 Italy 2024 (31 hours) 44 hours Hours of training per capita > 50 hours Spain 2024 (70 hours) 57 hours Hours of training per capita > 50 hours Ireland 2024 (70 hours) 91 hours Each year, the Mediolanum Group aims to maintain the standard for training hours provided to employees (including compliance) with a view to continual professional and personal improvement. [S1-5 DP 47 a, 47 b, 47 c] The Mediolanum Group routinely consults its employees through climate surveys and questionnaires assessing training programmes, to measure their level of satisfaction, the usefulness of the content in relation to employees’ roles and to identify any areas for improvement (see S1 Own workforce; paragraph 3.1.5 Training and skills development, section ‘Actions’ for further details). For Banca Mediolanum, performance with respect to training objectives is monitored through the reports of the MedBrain portal, which provides data on training hours per capita. For the Group’s foreign companies, the monitoring is based on internal reports containing similar information. The results of the surveys and monitoring systems are used to draw useful lessons and guide updates to the training programmes, contributing to the continual improvement of training and skills development initiatives.
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247 | Mediolanum Group - 2025 Annual Financial Report 3.1.6 Equal treatment and opportunities for all [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Diversity Gender inequality in the overall workforce and, in particular, in senior positions and/or in corporate career development processes Actual negative impact Own operations Long term Gender equality and equal pay for equivalent work Gender pay gap for equal roles Potential negative impact Own operations Medium term Employment and inclusion of people with disabilities Failure to integrate workers with disabilities Potential negative impact Own operations Medium term Measures against violence and harassment in the workplace Insecurity of workers due to incidents of harassment and/or lack of measures to protect workers and/or awareness-raising initiatives Actual negative impact Own operations Short term The Group’s approach and policies For the Mediolanum Group, ensuring equal opportunities means recognising the value of diversity and promoting an inclusive working environment, where all individuals can best express their potential, regardless of gender, age, ethnicity, physical ability or cultural background. Through targeted Policies, defined below, the Group is committed to strengthening a fair organisational culture, in which meritocracy and inclusion promote a sense of belonging and collective responsibility. Over the years, the Mediolanum Group has developed various Policies designed to ensure the proper management of the above impacts. In addition to the Code of Ethics, the Policy for the Protection of Human Rights and the Mediolanum Group’s Sustainability Policy, which set out its approach and general guidelines, the main policies for managing impacts related to these areas are the Diversity and Inclusion Policy, the Mediolanum Group’s Policy for the Prevention of Sexual Harassment, the Employee Recruitment and Selection Policy and the Group’s Remuneration Policies. The following policies are adopted by foreign companies taking into account the specific national aspects of each company. [S1-1 DP 19; 21; ESRS 2 MDR-P DP 65] IROs: Gender inequality in the overall workforce and, in particular, senior positions and/or in corporate career development processes; Gender pay gap for equal roles; Failure to integrate workers with disabilities
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248 | Mediolanum Group - 2025 Annual Financial Report Mediolanum Group Diversity and Inclusion Policy Content and objectives The Policy, adopted in 2021 and updated in 2024, promotes the development of a corporate culture capable of valuing and including existing or potential diversity. Priority areas are gender, aging and generational diversity, cultures and ethnic backgrounds, and disability. The Policy sets out the roles and responsibilities of the various corporate functions and provides for constant monitoring, to ensure that initiatives are consistent with D&I principles. The main actors involved are identified, with a description of their respective roles, and it is specified that all Company Departments support and implement the defined principles. Scope of application The Policy applies directly to Banca Mediolanum and is sent to all Group companies for adoption by resolution of the Corporate Bodies, without prejudice to any local provisions. The Policy is addressed to and applies to the entire Mediolanum Group’s workforce, including both employees and the Family Banker network. Highest level of management responsible for implementation the Policy is approved by Banca Mediolanum’s Board of Directors, while the Chief Executive Officer is responsible for implementing its principles. The Diversity Manager is responsible for the preparation and updating within the HR Department. Regulations and reference standards The main legislative and regulatory references on diversity and inclusion used to draw up the document include: the Sustainable Development Goals (SDGs) of the United Nations 2030 Agenda; the Universal Declaration of Human Rights; the ABI Charter for ‘Women in the Bank’; the Declaration on Fundamental Principles and Rights at Work of the ILO and the OECD Guidelines for Multinational Enterprises. Stakeholder involvement The Bank is committed to ongoing dialogue on diversity and inclusion issues through partnerships with established, competent industry associations. Method of dissemination The Policy is available on the Bank’s website www.bancamediolanum.it in the section ’Sustainability’; in addition, the Policy has been distributed internally, in a specific circular, and through dedicated communications, and is available on the company intranet HOMEdiolanum, in the section ’Our Values’. Group remuneration policies Content and objectives Remuneration policies are based on the principles of recognising and enhancing talent and merit, protecting the dignity and physical and emotional balance of each person. The goal of these policies is to attract and retain appropriate professionals, as well as incentivise employee engagement and motivation for the improvement of business performance. Scope of application These remuneration policies are updated annually and also sent to the Subsidiaries, which adopt them on the basis of the characteristics specific to each of them and in accordance with the limits applicable to them, as provided for by the industry and/or State to which they belong, in force from time to time. They apply to the entire the Mediolanum Group’s own workforce: employees, directors and family bankers. Highest level of management responsible for implementation The corporate control functions of the Parent Company and the Subsidiaries collaborate and exchange all relevant information, in order to ensure that the remuneration policies are adequate in terms of the legislation and they function correctly. The Board of Directors of Banca Mediolanum develops and periodically reviews
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249 | Mediolanum Group - 2025 Annual Financial Report the Group’s incentive and remuneration policies with the support of the Remuneration Committee, and is responsible for their correct implementation. The policies, once drawn up, are submitted to the Bank’s General Shareholders’ Meeting for approval. Regulations and reference standards Remuneration policies are defined by the Parent Company in accordance with the provisions of the Bank of Italy relating to remuneration and incentive policies and practices (Title IV, Chapter 2, Section I of Circular No. 285) and are drawn up in accordance with the regulations and guidelines issued at national and international level for the sector, including Directive (EU) 2019/878, EBA 2021/04 Guidelines and Commission Delegated Regulation (EU) 2021/923. Stakeholder involvement The Group develops remuneration policies within the framework of sound governance, which involves the Remuneration Committee and the control functions on an ongoing basis, and promotes constant dialogue with all our Stakeholders, investors and proxy advisors in order to best implement their recommendations and instructions. Method of dissemination The report on the Remuneration Policy and remuneration paid will be made available for at least ten years on the Company’s website (www.bancamediolanum.it) in the section ‘Corporate governance’. Employee Recruitment and Selection Policy Content and objectives The Employee Recruitment and Selection Policy, updated in 2022, sets out the principles and rules that guide the selection process, ensuring fairness and respect for Diversity & Inclusion principles. Selection is based solely on the qualifications and skills required for the role, following specific guidelines for technical positions and for the acquisition of systems, software and services. The document sets out the guiding principles, organisational architecture and interdependencies that govern the various stages of the process of recruiting personnel external to the Mediolanum Group. Scope of application The Policy is directly applicable within Banca Mediolanum and its principles apply to all Italian Subsidiaries, as well as to their entire workforce. Highest level of management responsible for implementation The Policy is approved by the Board of Directors of Banca Mediolanum. On the basis of delegated powers and authorities, the Manager and/or the persons identified in the Policy decide whether or not to hire the candidate and define the contractual aspects. The Human Resources Department Manager also defines, in agreement with Senior Management, the annual staffing plan. The updating and review of the document is the responsibility of the Recruiting and Employer Branding Section of the Human Resources Department of Banca Mediolanum. Regulations and reference standards The Policy complies with the provisions of applicable national legislation, ensuring compliance with the relevant legislative and regulatory requirements in the countries in which the Group operates. Method of dissemination The Policy has been distributed internally in a specific circular and is available on the company intranet.
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250 | Mediolanum Group - 2025 Annual Financial Report IROs: Insecurity of workers due to incidents of harassment and/or lack of measures to protect workers and/or awareness-raising initiatives Mediolanum Group Sexual Harassment Prevention Policy Content and objectives The Policy for the Prevention of Sexual Harassment of the Mediolanum Group, the latest update of which was approved in 2023, defines the principles adopted by the Group in order to prevent, identify and combat all actions, implicit or explicit, attributable to harassment and sexually inappropriate behaviours, as well as defining actions that provide support to the persons who report them, protecting them from any retaliation. The principles of the Policy are shared by the entire corporate population and must, in particular, be supported by the heads of each corporate structure in order to ensure consistent behaviour. Scope of application The Policy applies to the entire Mediolanum Group’s own workforce. It applies to all organisational units of Banca Mediolanum and is sent to all companies belonging to the Mediolanum Group. It is aimed at all employees and the Family Banker network and applies both in corporate spaces and in external contexts related to professional activity (e.g. corporate events, business trips, meetings with customers), including interaction through information technologies. Highest level of management responsible for implementation The document is approved by the Board of Directors of Banca Mediolanum and the Diversity Manager is responsible for preparing and updating it. The Chief Executive Officer is responsible for implementing strategic guidelines in the area of sustainability, including commitments and guidelines relating to the value system. Regulations and reference standards The Policy complies with the provisions of applicable national legislation, ensuring compliance with the relevant legislative and regulatory requirements in the countries in which the Group operates. Method of dissemination The Policy has been disseminated internally through a specific circular and is available on the company intranet, HOMEdiolanum, in the ‘Our Values’ section. [S1-1 DP 24 a] All of the above Policies were adopted by the Mediolanum Group with the aim of promoting a fair and inclusive working environment, eliminating any form of discrimination. Through these Policies, the Group is committed to ensuring equal opportunities for all staff, enhancing diversity and fostering a corporate culture based on respect, integration and meritocracy. [S1-1 DP 24 b] The following grounds for discrimination are specifically addressed in the Policy: racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, political opinions, national ancestry or social background. [S1-1 DP 24 c] At an organisational and operational level, inclusion commitments are expressed in the consideration of the principles of diversity and inclusion at various times in people’s professional lives, and in particular in the various processes overseen by the Human Resources Department, including, for example: recruitment and selection, training activities, personal development pathways and talent enhancement, compensation systems, succession plans and communication initiatives for employees and for the Commercial Network. In addition, the Group has partnerships with leading specialist institutions, particularly in training, information and awareness-raising activities, in order to strengthen, increasingly, within the Group, a culture that is aware of and oriented towards the values of inclusion at all levels.
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251 | Mediolanum Group - 2025 Annual Financial Report Although the work of increasing awareness and internalisation of diversity is mainly carried out within the Company, the Group is also committed externally to speaking up for the key values necessary for the creation of free and inclusive spaces. In line with this, in the planning and production of events for the Family Bankers Network and for customers, Mediolanum is committed to promoting adequate gender representation in the selection of speakers. It therefore verifies, through the relevant Functions, that it can involve female speakers, as they are typically less represented in financial contexts, pursuing and in any case ensuring the primary criterion of competence in relation to the issues dealt with, in accordance with the principle of meritocracy. Similarly, in the initiatives and events organised by third parties in which the company managers participate, it undertakes to verify compliance with adequate gender representation approaches. [S1-1 DP 24 d] As reported in the Diversity and Inclusion Policy and in the Mediolanum Group’s Policy for the Prevention of Sexual Harassment, the principles referred to in the documents are implemented in the process regulations and/or in operating procedures, which provide a better definition of the tasks and operational and control activities underlying compliance with the requirements of the regulations. The Mediolanum Group also supports and promotes the values of diversity and inclusion through corporate and organisational mechanisms aimed at creating shared well-being, in line with the provisions of the Code of Ethics, the Mediolanum Group’s Policy for the Protection of Human Rights, the Mediolanum Group’s Sustainability Policy and the Group Diversity and Inclusion Manifesto. Actions [S1-4 DP 38 a] The Group adopts a systemic approach to prevent and mitigate negative impacts on the workforce, promoting an inclusive culture focused on valuing people. Actions are formalised in the Diversity and Inclusion Policy and embedded in HR processes throughout the professional life cycle. On an operational level, the Group: has incorporated and complies with the principles of D&I in key processes managed by the Human Resources Department; carries out training and awareness-raising activities in partnership with specialist institutions; monitors initiatives constantly through internal and external analyses, and through dedicated tools such as Valore D’s Inclusion Impact Index and reference benchmarks. [S1-4 DP 38 b] The Mediolanum Group, in considering the central value of the person, has been committed for years to enhancing diversity and equal opportunities in the workforce, following and promoting the principles of merit and competence, in accordance with the Group’s values. Since 2021, the guidance and overall oversight of programmes on the dimension of diversity has been provided by the Diversity Manager, who is tasked with guiding and fostering a culture consistent with the principles that are formalised in the Diversity and Inclusion Manifesto. With regard to gender diversity, in 2024 gender equality certification was obtained for all the Group’s Italian companies, in accordance with the standard UNI/PdR 125:2022, which defines guidelines for the gender equality management system and provides for the adoption and measurement of a set of key performance indicators (‘KPIs’) relating to gender equality policies. In accordance with the relevant standard for Gender Equality Certification, qualitative and quantitative parameters have been identified in the D&I Business Plan of the Italian Group, drawn up by the D&I Committee and approved by the Coordination and Strategic Development Committee, in its ESG configuration, relating to the areas indicated in regulations. The Certification was confirmed for all Italian Group companies in May 2025. From an operational point of view, the Group is raising awareness of the issues of diversity and inclusion, with a particular focus on gender equality, through training and awareness
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252 | Mediolanum Group - 2025 Annual Financial Report events periodically designed and implemented according to targets and topics. Among the main actions, Mediolanum organises opportunities for discussion and training programmes for managers and supervisors, to promote inclusive leadership and reduce gender inequality in senior positions. All staff in the Human Resources Department and employee representatives contribute to the organisation of the Diversity & Inclusion events described in the Mediolanum Group’s Diversity and Inclusion Policy and in the activities reported in ESRS S1-4 DP 37 in this section. Banco Mediolanum also has a Diversity Manager who promotes and develops initiatives consistent with its commitment to the themes of diversity and inclusion. In relation to incidents of harassment and the protection of workers, Banco Mediolanum has adopted a document, the ‘Protocol on the Prevention and Treatment of Harassment’, which aims to define how cases of psychological and sexual harassment are managed. The document is made available to all staff through the company intranet. [S1-4 DP 37; ESRS 2 MDR-A DP 68] IROs: Gender inequality in the overall workforce and, in particular, in senior positions and/or in corporate career development processes In 2025, in keeping with actions taken in the previous two years, in order to mitigate the numerical gender gap in senior positions and to disseminate a culture sensitive to the topics of diversity, inclusion and equity, Mediolanum has promoted various times for discussion and training dedicated to managers and officers. Final figures at the end of 2025 show that women make up 50.8% of the total in the Group’s Italian Companies, with 20.5% in management positions, 36.6% in junior management and 56.1% in clerical positions. This picture confirms the importance of continuing to invest in targeted initiatives, including: the ‘Leadership4change – focus D&I’ course, continuing from the previous year, dedicated to all resource managers, which reinforces an inclusive and aware approach to leadership that pays attention to diversity, particularly in terms of gender. 140 managers were involved in seven sessions. The objective is to progressively train all resource managers, targeting approximately 85% of relevant managers by the end of 2025; the development pathway ‘Women’s Empowerment and Leadership’, continuing from the previous year, dedicated to female managers, with the aim of strengthening leadership skills and enhancing strengths for optimum fulfilment of the leadership role. mentorship and training programmes in collaboration with Valore D and Women&Technologies through the ‘Women Empowerment Programme’ pathway. Making use of the collaboration with Value D and in continuity with previous years, some employees were enrolled on management development pathways, training modules that are developed during the year with the aim of promoting inclusive leadership styles. Overall, D&I training amounted to 2,643 hours. Elements of focus on diversity and inclusion are also included in the design of succession plans. The topic of gender inequality in senior positions and corporate development processes is also a priority for the Group’s Subsidiaries. In line with the Mediolanum Group’s Diversity and Inclusion Policy and the Diversity and Inclusion Manifesto, Mediolanum continues to track various aspects of diversity to follow its development and assess the outcomes of actions taken, with the aim of harnessing the value of the company’s human capital.
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253 | Mediolanum Group - 2025 Annual Financial Report Among the initiatives carried out in 2025, thanks also to external partnerships, Banca Mediolanum: confirmed its role as Supporter bank in the ‘D&I in Finance’ project, promoted by ABI and organised by ABIServizi. Banca Mediolanum is also a signatory to the ABI ‘Donne in banca’ (Women in the Bank) Charter and participates in the this Charter’s working group, established in 2022, with the aim of sharing practices, studies and research to support individual corporate entities; for years, the Bank has consolidated its commitment to Diversity and Inclusion ongoing partnerships with qualified associations and institutions. In particular, in 2025 its membership of the Marisa Bellisario Foundation was finalised. Its training commitment also continued in order to raise awareness among new hires of the consistency diversity values and commitment with the Group’s values, within the ‘Mediolanum Journey’ onboarding programme. In fact, a specific section of this programme was devoted to the themes of diversity and inclusion, with a particular focus on bias and stereotypes. During the onboarding, participants were introduced to the company’s D&I initiatives. Diversity & Inclusion principles are a part of all HR processes of the Mediolanum Group, guaranteeing a fair, respectful working environment, free of discrimination. In its recruitment activities, Mediolanum places respect for diversity and inclusion at the centre, ensuring a the working environment is fair, encourages participation and is free from discrimination, in line with the Group’s Policy. All announcements include a statement ensuring the fair treatment of candidates, according to the Diversity & Inclusion principles. During 2025, Banco Mediolanum also strengthened its commitment through mentoring programmes aimed at developing leadership skills and fostering the personal and professional growth of its staff and promoting training and networking initiatives dedicated to female personnel. At the same time, actions continued to raise awareness and promote diversity, encouraging participation in events and programmes such as Diversity Leading Company and Empowering Women’s Talent. Through a series of training initiatives, Banco Mediolanum also aimed to raise awareness of the values of inclusion, promoting the prevention of stereotypes, social stigmas and prejudices, the adoption of inclusive language and the sharing of successful examples. One of the initiatives promoted by the Irish Companies of the Group on the topic during 2025 was the annual event in collaboration with ‘100 Women in Finance’ intended for university and postgraduate students in the fields of investment, finance and STEM, offering them the opportunity to learn, through a training session at the Head Office, about the roles, duties and work carried out within a financial services company. The initiative was also implemented with the aim of promoting the corporate brand as an employer, in order to attract future talent. In addition, the Group’s Irish Companies participate in an inter-company and cross-sectoral mentorship programme. The one-year mentorship programme combines high-potential mid-level mentors with senior executive mentors to allow for professional and personal development. IROs: Gender pay gap for equal roles In this context, the Mediolanum Group is committed to reducing gender disparities, also working to close the gaps in all areas, including pay. In this context, as part of the annual governance cycle of the Parent Company, the Remuneration Committee and the Board of Directors perform a specific assessment of the gender pay gap in the Group, based on the analyses carried out by the Human Resources Department, with the support of an external provider. The analysis is conducted taking into account, at the individual level, the overall remuneration, role and responsibilities within the organisation and framework, as well as other objective and subjective elements that may form the basis for analysis. In accordance with the regulations (including the EBA Guidelines), the analysis activity was carried out
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254 | Mediolanum Group - 2025 Annual Financial Report by country and consists of three macro-areas: the average pay gap, which represents the gap between the average remuneration of women and the average remuneration of men; the unadjusted equal pay gap, which measures the gender pay gap for the same or equivalent work, calculated by comparing the pay gap for similar positions; and the adjusted equal pay gap, which, through a statistical regression model, aims to strip out (objective) non-discriminatory factors from the average pay gap. The issue of the pay gap is also a central priority for the foreign Subsidiaries, which are constantly committed to promoting fairness and inclusion within the organisation. IROs: Failure to integrate workers with disabilities Inclusion of disabled workers As defined by the Mediolanum Group’s Diversity and Inclusion Policy, the Group is committed to providing employment opportunities to people with motor, cognitive and sensory impairment. It develops initiatives that promote their integration and inclusion, providing roles that are suitable for their skills and needs and promoting conditions of well-being and support through an environment with appropriate physical but also behavioural characteristics. To confirm this, the Group has appointed two Disability Managers, who possess the specialist skills certified by the Metropolitan City, tasked with customising projects for people with disabilities and with resolving issues related to the working conditions of disabled employees. In 2025, based on the findings of the survey conducted in 2024, the Group carried out targeted educational initiatives dedicated to the management and inclusion of people with disabilities. Two distinct approaches were adopted: the first, focused on inclusive communication, totalled 324 hours of training; the second, focused on understanding the different characteristics of disabilities and on providing concrete tools for the day-to-day management of resources with disabilities, reached a total of 718 hours of training. Both approaches involved managers as well as teams of resources that are affected. An option of specific psychological support is also available, at the request of the person directly concerned, provided by a consultant who is an authorised and expert professional in the sector; Moreover, in collaboration with the company physician and through a protocol signed with the trade unions, the Group provides access, at the request of any employee with serious disabilities, to teleworking procedures to facilitate situations in which the type of individual problem makes it impossible or difficult to travel to and/or stay on company premises. The support and inclusion of people with disabilities is also a priority for the Group’s Subsidiaries, which are committed to promoting initiatives to encourage the full integration of staff. This aim is pursued through interventions on structural aspects and programmes dedicated to vocational training and development, often in collaboration with local authorities and foundations. The initiatives promoted by Banco Mediolanum during 2025 include: using the PorTalent Once portal to facilitate the placement of disabled candidates; partnering with the CEO for Diversity; working with the Adecco Foundation for the Disability Day campaign; collaborations with specialist centres such as Viajes 2000, Femarec and Multiple Sclerosis J M Charcot, Fundación Juan XXIII; Selid; Femfet; Fondació portolà; to promote the professional integration of people with disabilities.
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255 | Mediolanum Group - 2025 Annual Financial Report IROs: Insecurity of workers due to incidents of harassment and/or lack of measures to protect workers and/or awareness-raising initiatives Activities aimed at preventing situations of harassment As defined in the Mediolanum Group’s Policy for the Prevention of Sexual Harassment, respect for the person is one of the key values of the system adopted by the Mediolanum Group, which is committed to undertaking all forms of discrimination and to preventing, identifying and combating all actions, implicit or explicit, attributable to harassment and sexually inappropriate behaviour, as well as defining actions that provide support to the persons who report it, protecting them from any retaliation. In this regard, the Group has put in place a Policy for the prevention of sexual harassment with the aim of safeguarding its people and providing a working environment free from the risk of sexual harassment. Mediolanum has also adhered to the Protocol on the Prevention and Combating of Violence against Women and Domestic Violence, signed by ABI and the Minister for the Family, Birth Rate and Equal Opportunities. The aim is to help prevent and combat violence against women, and to promote training and information initiatives on the public and private tools available to support financial inclusion and the overcoming of gender-based differences. The development of a project related to economic violence was also launched in collaboration with the Adiconsum consumer association. The aim of the project is to raise awareness of this matter, which, although not specifically targeting the female population, is one of the initiatives referred to in the ABI Protocol on the Prevention and Combating of Violence against Women and Domestic Violence. The topics cover: budgeting, saving, investments and credit management. In order to protect its people and ensure a working environment free from the risk of sexual harassment, the Group is committed to actions that encourage a culture that is as respectful as possible of the person and prevent offensive behaviour and language. To this end, the Group’s 2025 harassment prevention awareness and training initiatives included: providing the entire corporate population with the ‘Preventing Sexual Harassment in the Workplace’ pill, accessed by 95% of employees, the aim of which was to disseminate awareness of the matter of harassment and to explain the contents of the Policy and any whistleblowing procedures; a cycle of five webinars on ‘Personal protection: knowledge and prevention of situations of violence against women’, which aimed to provide a practical knowledge and skills base to deal with potentially dangerous situations that might be experienced personally and/or as a witness. the launch of the ‘CosaConta’ project, on financial education, that aims to raise awareness of financial matters among the external community, also with a view to generational and gender inclusion. The aim is to make financial education widespread and accessible to all types of audiences, even with very diverse backgrounds and skills, through content such as pills, articles, videos and podcasts. On 25 November, the International Day for the Elimination of Violence against Women, an awareness-raising and communication campaign was launched, through a number of initiatives: a webinar in collaboration with Valore D entitled ’Digital gender-based violence: recognising, understanding, acting’. This round table addressed the issue of online violence as a phenomenon that reproduces gender dynamics already present offline. The main types and definitions were analysed, as well as the psychological and social risks arising from them, together with the critical aspects of AI- generated content. The importance of a clear and continuous culture of consent and the need for training programmes to prevent and combat the phenomenon were underlined;
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256 | Mediolanum Group - 2025 Annual Financial Report a ‘BmOnair’ radio episode (internal communication in a video format, designed to inform and engage employees on corporate issues, initiatives and values) dedicated to 25 November, in which some employees were interviewed, with the aim of raising awareness of these issues, also referencing the dissemination of the support number 1522; The red-orange illumination of the Group’s headquarters in Basiglio on the evening of 25 November, joining the UN Women campaign ‘UNiTE 2025 – Orange the World’; Communications on all the main social networks, in support of the awareness-raising initiative on the topic, promoted by ABI and the Foundation for financial education and savings, in liaison with the Department for Equal Opportunities of the Prime Minister’s Office. The Irish Companies and Spanish Companies are also committed to protecting the dignity of everybody working within the Company. In particular, they are committed to ensuring that the Company is free from any form of bullying or harassment at work, whether in the office or remotely, and that there is an atmosphere of respect, safety and equality in the workplace. [S1-4 DP 38 d] As also indicated in the Diversity and Inclusion Manifesto, Mediolanum is committed to monitoring the various aspects of diversity in order to verify its evolution and assess the results obtained through the actions taken from time to time, in order to enhance the wealth within the Company’s human capital. The Group, therefore, monitors and assesses the effectiveness of D&I actions through a structured approach that combines internal and external checks, quantitative and qualitative analyses, and market benchmarks. Internal measurement activities include: Gender Equality Certification under UNI/PdR 125:2022, which required a preliminary internal gap analysis phase, followed by a phase of reporting and formalisation of documents, practices and implementation plans for all parameters defined by the standard and for each Italian Company. For the purpose of Certification, a structured assessment is required, which the Group carries out annually with Bureau Veritas, involving, in addition to the directly affected areas of the Human Resources Department, various corporate structures and the direct participation of employee representatives, interviewed briefly by the auditors; the annual specific assessment by the Remuneration Committee and the Board of Directors of the Group’s gender pay gap, based on the analyses carried out by the Human Resources Department, with the support of an external provider, in order to monitor the Group’s performance and identify areas of potential intervention and internal project initiatives aimed at promoting gender diversity; periodic analysis of data on the working conditions of staff with disabilities by the Disability Managers and specialist disability-related structures. In detail, parameters including the following are analysed: the turnover rate, absenteeism and monitoring of the number of reports of any individual disadvantage, interpersonal relationships with managers and within the team, and the overall degree of personal satisfaction. The initiatives carried out are regularly monitored with periodic analyses of data and quantitative and qualitative parameters, such as: the number of participants in the training courses; the half-yearly monitoring of D&I training hours; and reporting on any reports of harassment, as defined in the reporting template included in the Mediolanum Group’ Policy for the prevention of sexual harassment. In addition, the Group uses specific indices that allow it to compare its KPIs with market benchmarks. These tools provide an objective and comparative view that is useful for identifying strengths and areas for improvement and for guiding future D&I strategies.
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257 | Mediolanum Group - 2025 Annual Financial Report The indices used include: the Inclusion Impact Index, developed by Valore D, with indicators based on international ESG sustainability standards, which returned an overall score of 78.9/100 for 2025, marking an improvement compared to 2024 and confirming the Group’s positioning above the market average, monitored by Valore D; the Bloomberg Gender Equality Index (GEI), an international index to assess corporate initiatives on gender inclusion and equality of listed companies, in which Mediolanum was included in 2023. In 2025, the monitoring of data collected by Bloomberg continued through the Gender Equality Scores, with a view to maintaining the standards achieved. [S1-4 DP 39] The process of identifying the necessary and appropriate actions to address impacts on the workforce is based on a structured and integrated approach that provides for constant monitoring of corporate activities and dynamics through tools such as surveys, the collection of feedback and data analysis. These tools identify critical touch points and assess the specific needs of staff, enabling the development and implementation of targeted planning initiatives. In addition, the Disability Managers, as well as the Human Resources Managers, act as a constant point of contact for the corporate population, ensuring ongoing involvement in the discussion with staff. [S1-4 DP 41] The Group integrates the principles of diversity, inclusion and respect in all its processes within its own workforce, continuously monitoring practices, and adopts specific policies and initiatives to prevent and manage any adverse impacts, with a particular focus on gender equality, inclusion of diversity and protection from harassment and discrimination. [S1-4 DP 43] The entire HR Department is involved in the management of diversity and inclusion matters for all the processes specific to each practice. In particular, the Diversity & Inclusion Committee was set up to support the Human Resources Director and the Diversity Manager by providing opinions and assessments for the benefit of the Group Coordination and Strategic Development Committee, in its ESG configuration, in order to ensure the effective adoption and application of the principles envisaged in the area of diversity. The Committee also proposes actions to support the development of an inclusive working environment and culture. It is assisted by an operational team, coordinated by the Diversity Manager and selected from the Human Resources Department, to propose and implement the relevant initiatives. The Development and Compensation Systems Office is specifically involved in the equal pay analysis. Other structures, including the Internal Audit Function, are also involved in managing any reports made through the Whistleblowing System.
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258 | Mediolanum Group - 2025 Annual Financial Report Targets The new 2026-2030 Sustainability Plan, in continuity with the previous plan, places great importance on D&I issues and, in particular, on the role of women within the Group’s companies. In this context, also in view of the improvements already evident in recent years, the existing objectives were reset and, where possible, expanded at perimeter level, so as to include the foreign Subsidiaries. [S1-5 DP 46; ESRS 2 MDR-T DP 80] IROs: Gender inequality in the overall workforce and, in particular, in senior positions and/or in corporate career development processes Target Target KPI Year target Scope Baseline year and value Progress at 31/12/2025 Senior women managers % of women Senior Managers - retention > 20% 2030 Italy 2024 (18.8%) 20.50% % of Women Senior Managers - > 30% Spain 2024 (36.21%) 37.40% % of women Senior Managers - retention >20% Ireland 2024 (23%) 20% The Group is committed to monitoring and encouraging, on an annual basis, the percentage of women in senior management positions. The defined percentage takes into account the specific contexts of each country and the professional categories present in the workforce. The previously applicable target was valid only within the Italian perimeter, while the current representation broadens this at Group level to highlight the importance of the issue for the Group. The target KPI was re-evaluated compared to the previous 2024 –2026 Sustainability Plan, to ensure consistency with realistically achievable improvement trajectories, which will be supported by a set of cross-cutting actions—including training, communication and awareness-raising activities.
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259 | Mediolanum Group - 2025 Annual Financial Report IROs: Gender pay gap for equal roles Group companies undertake, on a two-year basis, to maintain the gender pay gap for each role below the 5% threshold in comparison to each individual country. With respect to the 2025 financial year, an Equal Pay Gap (Adjusted) relating to total compensation was recorded at below 5%. With regard to the results of the analysis, with particular reference to the Italian perimeter, a trend in line with previous years was identified, and brought to the attention of the Committee and the Board of Directors. In particular, the following should be noted: a year-on-year decrease in the pay gap with regard to the Average Pay Gap both by base salary and by total compensation; an Adjusted Equal Pay Gap that remains well below the 3% threshold. In particular, regarding the Group’s Spanish Companies, the target aligns with indications in the context of the Equal Opportunities Plan, concerning the measurement of the ‘overall’ pay balance. 78 Compared to the previous 2024–2026 Sustainability Plan, the target KPI, previously called ‘Gender and/or pay disparity for the same work’, was renamed. Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Gender pay gap for equal roles – Equal pay gap (adjusted)78 Maintenance of the gender pay gap for the same role below the threshold of 5% 2030 Italy 2024 The female population has an average salary 1.8% lower than the male population in the same role <5% Spain 2024 The female population has an average salary 1.7% higher than the male population in the same role <5% Ireland 2024 The female population has an average salary 4.6% lower than the male population in the same role <5%
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260 | Mediolanum Group - 2025 Annual Financial Report IROs: Gender inequality in the overall workforce and, in particular, in senior positions and/or in corporate career development processes Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Gender balance in workforce composition % of women in the share of the total workforce - Maintaining a target range of 45-55% 2030 Italy 2024 51.1% 50.80% The Group’s Italian companies undertake to maintain, on an annual basis, an overall balance in the composition of the workforce, with a percentage of women between 45% and 55%. The target is in line with the provisions of the Gender Equality Certification, as well as with the objective set in the previous 2024-2026 Sustainability Plan. [S1-5 DP 47 a; 47 b; 47 c] With a view to taking into account the perspectives of its own workforce within the decision-making and impact management process, the Mediolanum Group establishes a relationship for ongoing dialogue and feedback with employees, through the Human Resources Department, using tools such as surveys aimed at exploring employees’ opinions. Monitoring takes place through the verification and analysis of statistics and reports that provide adherence and satisfaction data. In order to monitor satisfaction trends and the accessing of services, the Group periodically monitors developments by collecting feedback on all the initiatives implemented, such as, for example, webinars, training courses, the Mediolanum Journey onboarding pathway and the various initiatives targeted. Feedback is collected through questionnaires and direct discussions with the Diversity Manager. The Human Resources Department provides all employees with engagement and/or satisfaction surveys, as well as quick surveys, in order to collect information to analyse and obtain ideas for further aspects for attention, as well as directing the definition of future activities. 3.1.7 Other rights related to work (confidentiality) [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Other rights related to work (confidentiality) Breach of workers’ right to privacy due to data loss incidents Potential negative impact Own operations Short term The Group’s approach and policies The Mediolanum Group places a strong emphasis on the protection of personal and corporate data and safeguarding the rights of individuals, while meeting European regulatory standards, in particular the General Data Protection Regulation (GDPR). The key principles employed by the Group are accountability, privacy by design and by default, data minimisation and retention time limitation, ensuring that each stage of data processing is oriented towards the protection of data subjects. Over the years, the Group has implemented a number of Policies and tools to strengthen information security and confidentiality. These include the Code of Ethics and the Privacy Policy, which define guidelines for responsible data management, promoting transparency, correctness and legal compliance. [S1-1 DP 19; 21; ESRS 2 MDR-P DP 65]
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261 | Mediolanum Group - 2025 Annual Financial Report IROs: Breach of workers’ right to privacy due to data loss incidents Code of Ethics One of the key principles of the Code of Ethics (see ESRS G1, Business conduct, paragraph 4.1.1. Business culture, section ‘The Group’s approach and policies’ for further details on the minimum reporting requirements of the Policies) is confidentiality. Mediolanum ensures the right to confidentiality of information, including of its employees, guaranteeing through specific measures the right of each individual to manage his/her personal data completely independently. Privacy Policy For the Mediolanum Group, personal data protection has always been a fundamental issue, as ensuring the confidentiality and security of bank data, including personal data, represents an important milestone and considerable added value. The Privacy Policy (see ESRS S4, Consumers and end-users, paragraph 3.4.2. Confidentiality, section ‘The Group’s approach and policies’ for further details on the minimum reporting requirements of the Policy), which describes the privacy principles, defines the oversight of aspects relating to the processing of the personal data of data subjects (e.g. employees), in accordance with EU Regulation 2016/679 ‘GDPR’, the applicable national legislation and the orders issued by the Italian Data Protection Authority. Actions [S1-4 DP 37; ESRS 2 MDR-A DP 68] IROs: Breach of workers’ right to privacy due to data loss incidents For the Conglomerate Companies, training is provided in order to provide the basic privacy knowledge necessary for compliance with the requirements and controls. These measures consist in issuing mandatory online courses for all employees and contract staff of the Sales Network. Passing these courses requires completion of a test to ascertain that the concepts covered by the courses have been assimilated. In the Italian Companies, to ensure that all employees are aware of data protection regulations and know how to apply them correctly, the basic GDPR course for new hires continued along with as the course ‘Protecting privacy: concrete cases’, administered to the entire company population in previous year. During 2025, a new course was also released, ‘Protection of privacy in the Bank: the dissemination of information and tracking of transactions’, presented in an episode of BMONAIR in January 2025, followed by a letter addressed to each employee asking them to acknowledge having read it, with the aim of raising awareness and encouraging employees to adopt appropriate behaviour. During 2025, Banco Mediolanum provided new employees with an online course on personal data protection, adapted to the requirements of each functional area. An online cyber security refresher course was also offered to all personnel, covering the various strategies to prevent and defend against cyber-attacks. To support these activities, Banco Mediolanum shared 21 mini sessions on data protection and three course compliance reminders. Irish Group Companies also hold regular privacy training sessions for all staff and new hires via an online portal. All employees are required to pass a test, with a minimum success rate that is monitored. [S1-4 DP 38 a] Personal data protection is a central matter for the Group, which regards the confidentiality and security of bank data as a fundamental value. For this reason, the Human Resources Department collaborates with the Privacy Office to develop training interventions, such as mandatory online courses and refresher and awareness programmes, aimed at ensuring knowledge of the privacy regulations, integrating legal, operational, marketing and communication aspects, with a focus on the Companies, customers and employees. [S1-4 DP 38 d]
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262 | Mediolanum Group - 2025 Annual Financial Report The same methods as those used for consumers and end-users are employed to monitor and assess the effectiveness of the confidentiality measures relating to the Mediolanum Group’s workforce (see ESRS S4 Consumers and end-users; paragraph 3.4.2 ‘Confidentiality’, section ‘Actions’, DP 31 d, for further information). [S1-4 DP 39] With regard to the disclosures on the processes through which the Mediolanum Group identifies the actions necessary to manage negative impacts on confidentiality, it should be noted that the approach adopted for its workforce is similar to that used for consumers and end-users (see ESRS S4 Consumers and end-users; paragraph 3.4.2 ‘Confidentiality’, section ‘Actions’, DP 32, for further information). [S1-4 DP 41] With regard to the disclosures on the ways in which the Mediolanum Group ensures that its practices do not have negative impacts, it should be noted that the approach adopted for its own workforce is the same as that used for consumers and end-users (see ESRS S4 Consumers and end-users; paragraph 3.4.2 ‘Confidentiality’, section ‘Actions’, DP 34, for further information). [S1-4 DP 43] The Privacy Office, established within the Legal Affairs Division, performs and coordinates all the requirements of the privacy regulations for both Banca Mediolanum and some Companies in the Conglomerate. Among its activities, it oversees the privacy training provided to employees. The Human Resources Department supports the Privacy Office in activities relating to compliance with the provisions on privacy for employees and in accordance with the provisions established on the prohibition of remote monitoring of workers’ activities. It also supports the working group in the escalation process in the event of a breach of rules by employees. Targets [ESRS 2 MDR-T DP 72; 81 a; 81 b] IROs: Breach of workers’ right to privacy due to data loss incidents The Mediolanum Group has not defined specific objectives relating to the protection of the privacy of workers. However, the Group addresses the issue of confidentiality through the objectives relating to Consumers and End-Users; for further information, see ESRS S4-5 Consumers and end-users; paragraph 3.4.2 ‘Confidentiality’, section ‘Targets’, DP 40. 3.1.8 Processes for engaging with own workforce and workers’ representatives about impacts [S1-2 DP 27] The Mediolanum Group adopts an employee-centric focus, encouraging their active involvement in corporate processes through tools for resource management and development. To integrate the perspectives of the company’s own workforce into the decision-making process and impact assessment, the Company maintains constant dialogue through the Human Resources Department, using targeted surveys (quick, engagement and welfare surveys) to gather opinions and feedback. Mediolanum also guarantees transparent and continuous communication, ensuring employees are informed of and involved in company life thanks to the HOMEdiolanum portal, updated daily with Group content and news.
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263 | Mediolanum Group - 2025 Annual Financial Report The Group’s foreign Companies also engage their employees through the available institutional channels, in order to meet the needs and perspectives of the workers and to involve them in information and training processes. These include, in particular, the anonymous reporting channel and specific e-mail channels for communicating directly with departments responsible for the various areas (data protection, cybersecurity). Employees are trained and informed on how the reporting channel works, through mandatory internal training initiatives on the protection of personal data, compliance with the code of conduct and other topics related to these areas, as well as through periodic communications. [S1-2 DP 27 a] Engagement takes place both directly and indirectly through employee representatives. [S1-2 DP 27 b] Own Workforce engagement is maintained throughout the year and includes all Group employees. This is achieved, where necessary, through structured methods adopted during specific events and initiatives. Meetings with employee representatives are planned and scheduled during the year, or organised close to the expiry dates of current agreements. [S1-2 DP 27 c] The Function responsible for ensuring this engagement takes place is the Human Resources Department, which supervises internal communication and is assisted by all corporate functions involved for their areas of responsibility. [S1-2 DP 27 d] The Group operates in full compliance with all laws and regulations applicable in countries that adopt principles and regulations for the full protection of human rights. It applies national contracts applicable to the sector, with economic benefits that are higher on average than the contractual minimums and also with complementary company agreements. Particular importance is given to health and welfare cover, with benefits that are additional to those established by the general legislation in the countries in which it operates. [S1-2 DP 27 e] To confirm the importance of the role that employee engagement plays for Mediolanum, the Group has implemented a system of periodic surveys and regular meetings to assess the effectiveness of the engagement of its Own Workforce. [S1-2 DP 28] The Mediolanum Group demonstrates a constant focus on all employees, periodically assessing the needs and prospects of its own workforce, particularly with regard to the most vulnerable workers. On the subject of disability issues, two Disability Managers have been appointed to develop personalised projects and resolve problems related to working conditions. Considerable attention is also paid to a work-life balance, which is accompanied by initiatives aimed at parents, such as school guidance programmes for children, and support pathways for those caring for dependent family members. Many activities are also promoted by the Diversity & Inclusion Unit, confirming the Group’s commitment to an inclusive environment that is attentive to the needs of all. [S1-2 DP 27] With specific reference to health and safety, for the Italian Companies of the Mediolanum Group, the adoption of the integrated management system for workplace health and safety and the environment makes it possible to define the methods for managing the communication and consultation of the Mediolanum Group, and to ensure an efficient and constant flow of information between the various parties and relevant stakeholders. This is in line with the objective of promoting and disseminating throughout the organisation the culture of safety and the protection of the health of workers and the environment. The Group’s foreign Companies, in both Spain and Ireland, engage their employees through the available institutional channels, in order to meet the needs and perspectives of the workers and to involve them in information and training processes. In particular, this is achieved through the participation of trade union representatives in the Health and Safety Committee. [S1-2 DP 27 a; 27 b]
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264 | Mediolanum Group - 2025 Annual Financial Report For the Italian Companies of the Mediolanum Group, engagement takes place at various stages through communication, consultation and participation: communication: the processes established by the organisation involve the collection, updating and dissemination of information. They ensure that relevant information is provided, received and made understandable to all relevant workers and stakeholders; consultation: seeking opinions before taking decisions, including the involvement of Workplace Health and Safety and Environment Committees and employee representatives; participation: involvement in the decision-making process, including the Human Resources Department and the employee representatives. The primary channel for the engagement of employees on matters of workplace health and safety and the environment is the company intranet, where information on the relevant aspects of SSL and the Environment is provided to all employees, for example: health and safety organisation chart; a list of the names of preventative functions, including employee safety representatives; emergency response procedures; measures to be taken in the event of fire and other emergency situations; excerpt from the Health, Safety and Environment Policy; management system procedures. Banca Mediolanum informs its workers in the event of significant changes in the structures responsible for health and safety through the processes defined in the business model. Employees are also involved in all business processes through information, education (mandatory training and additional ‘mini training sessions’) and training, participation in corporate initiatives, and by periodically consulting their workers’ safety representatives. As regards Banco Mediolanum, participation takes place through information, consultation and active participation in the context of the Health and Safety Committee. The meetings of this Committee are held on a quarterly basis, although each of the parties may request extraordinary meetings if necessary. Subsequently, the assessments made and decisions adopted also apply to the branches of Mediolanum Gestione and Mediolanum Pensioni. For the Group’s Irish Companies, workers are periodically involved in information and training courses on risks present in activities and in the workplace and access health and safety information through the IT tools provided. [S1-2 DP 27 c] Responsibility for this process lies with the Head of the Health Safety Security & Environment (HSSE) Section, who is responsible for the Italian Companies and promotes coordination for the local implementation of the guidelines of the Parent Company of the Mediolanum Financial Conglomerate. In Spain, the Health and Safety Committee of Banco Mediolanum is responsible for ensuring that worker participation takes place and that the results of this participation are taken into account in the company’s decision-making processes. The Committee is composed of: three health and safety representatives (members of the company committee) representing employees; three people appointed by the company, from the Human Resources, Security and PRL and Corporate Services Departments. The role is not an exclusive function, but falls within the scope of the responsibilities assigned to the respective departmental positions. In Ireland, the Health & Safety Policy is also approved by the Board of Directors and the Chief Executive Officer is the person responsible for its implementation. [S1-2 DP 28]
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265 | Mediolanum Group - 2025 Annual Financial Report For the Group Companies, protection is ensured for vulnerable individuals with initiatives to support their employment, such as, by way of example and on the basis of the relevant national legislation, the company medical service and the possibility of working completely remotely. 3.1.9 Processes to remediate negative impacts and channels for own workers to raise concerns [S1-3 DP 32 a] To identify and manage any reports concerning actual and potential negative impacts on its Own Workforce, the Mediolanum Group establishes and promotes ongoing dialogue and feedback with employees through the Human Resources Department (and equivalent structures in foreign Subsidiaries), in particular with the relevant managers. The main tools and channels used include internal surveys aimed at gauging employee opinions, discussions with employee representatives and the whistleblowing channel. Specifically, the latter is a tool made available to all company staff for the formal management of reports through independent channels, where they can submit detailed reports of violations of the principles set out in Model 231 (the Compliance Programme specific to Italy), as well as other relevant national and European Union legislation, which they have become aware of due to their work or job functions performed. [S1-3 DP 32 b] For the areas envisaged in applicable regulations on whistleblowing, the Group has implemented a Whistleblowing System that ensures the receipt and management of complaints/concerns (with even the suspicion that they are justified), which is completely confidential, free of conflicts of interest on the part of the managers of the same, and protects against retaliatory measures. The reporting channels, with small differences relating to foreign Subsidiaries, comprise a paper form sent by post (also anonymously), a direct meeting with the Whistleblowing Manager, and the IT platform (written or verbal report). [S1-3 DP 32 c] The Internal Whistleblowing System provides for the possibility of receiving and managing complaints from staff on matters within the scope of the relevant legal framework (excluding complaints solely of a personal nature, an extra scope of whistleblowing legislation). [S1-3 DP 32 d] The disclosure of the internal regulations on the Whistleblowing System and its operating procedures, as well as the reporting channels activated, is made publicly available by the Group Companies on their websites (if these exist) and, for the workforce, also on the company intranet. [S1-3 DP 32 e] The Whistleblowing Manager, identified within the Internal Audit Function, or consisting of a collegiate body (in the case of the Spanish Subsidiaries) is responsible for the correct functioning of the Whistleblowing System. The Whistleblowing Manager is supported by the Whistleblowing Officers, usually identified within the Internal Audit Function, who are responsible for receiving, analysing and assessing the reports received. The Group’s Whistleblowing System has the characteristics described within the ‘criteria for the effectiveness of non-judicial grievance mechanisms’ defined in the United Nations Guiding Principles on Business and Human Rights. Internal and external reporting channels are made available to the various stakeholders in the internal regulations, which also indicate the procedures and timescales for managing reports received. This legislation is published in the company intranet sections and on websites, which potential whistleblowers may also access to make reports. Confidentiality and protection from retaliation ensure a safe environment for whistleblowers, while training courses for all persons at the Head Office allow stakeholders to access sources of information and expertise. [S1-3 DP 33]
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266 | Mediolanum Group - 2025 Annual Financial Report To date, no assessment/approval surveys on the whistleblowing channels are available. The Mediolanum Group prohibits retaliation, i.e. any behaviour, act or omission, even if only attempted or threatened, carried out as a result of the report, that causes or may cause unjust harm to the whistleblower, directly or indirectly (see ESRS G1 Business conduct, paragraph 4.1.2 Protection of whistleblowers, section ‘The Group’s approach and policies’, DP 10c for further details). In relation to Whistleblowing regulations and with the aim of promoting a corporate culture based on transparency, integrity and responsibility, the online course on ‘Whistleblowing: the internal reporting system’ continues to be given to new hires, raising awareness among all staff, and providing clear instructions on how to use the reporting channels provided by the Company. [S1-3 DP 32 a] With specific reference to occupational health and safety, the Group disseminates a culture geared towards safety and awareness of potential risks and their prevention. Any conduct contrary to these principles can be reported through different reporting mechanisms. In addition, the recipients of the Code of Ethics are required to refrain from any conduct that could, even only potentially, entail a breach of the principles and conduct set out in the Code, the implementation procedures or the legislation referred to, including with regard to safety and well-being in the workplace. Any breach of the principles and provisions contained in the Code of Ethics must be promptly reported through the appropriate channels established by the Company for the reporting of alleged non-compliance. [S1-3 DP 32 b] Workers can report any situations of danger concerning health and safety at work through an email notification to the Health Safety & Environment Section or by contacting the employee safety representative. Lastly, there is a process structured through the health monitoring procedure, through which workers can bring to the attention of the occupational medical service problems related to stress from work activities for corporate management. [S1-3 DP 32 c] As explained in the dedicated Policy, the Health Safety Security & Environment Sector periodically carries out risk assessment activities on the basis of the reports received. In Spain, the Human Resources Office maintains open channels of communication with all bank staff and provides communication channels for employees to address any concerns or needs. [S1-3 DP 32 d] The company intranet is the main means of disclosing internal regulations. [S1-3 DP 32 e] In managing matters relating to workplace health and safety, the Mediolanum Group takes an approach aimed at eliminating risk and, if this is not possible, maximum mitigation, and in any case based on its prevention. The Company identifies and assesses the risks to which the worker is potentially exposed and periodically carries out analyses to eliminate, where possible, the risks themselves, or in any case to minimise any impact they may have. Lastly, it periodically analyses the workplace health and safety needs and expectations of workers and Stakeholders, encouraging and soliciting their active participation. [S1-3 DP 33] The Group disseminates, makes available and readily accessible workplace health and safety documentation, including management documents, to the various actors (workers, customers/suppliers, supervisory authorities/bodies, etc.) based on the different levels of authorisation. The company has also put in place policies aimed at protecting individuals from retaliation (see ESRS G1 Business Conduct, paragraph 4.1.2 Protection of whistleblowers, section ‘The Group’s approach and policies’, DP 10c for further details).
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267 | Mediolanum Group - 2025 Annual Financial Report 3.1.10 Metrics Characteristics of the undertaking’s employees [S1-6 DP 50 a] Characteristics of the undertaking’s employees - number of employees by gender 79 UoM 2025 2024 Women Men Total Women Men Total Total number of employees No. 1,867 1,944 3,811 1,747 1,807 3,554 Characteristics of the undertaking’s employees - number of employees by country UoM 2025 2024 Total number of employees 80 No. 3,811 3,554 Italy No. 3,118 2,921 Spain No. 483 437 [S1-6 DP 50 b] Characteristics of the undertaking’s employees - number of employees by contract type and gender 81 UoM 2025 2024 Women Men Total Women Men Total Number of permanent employees No. 1,769 1,881 3,650 1,644 1,752 3,396 Number of fixed-term employees No. 50 62 112 61 53 114 Number of employees with variable hours No. 48 1 49 42 2 44 Total No. 1,867 1,944 3,811 1,747 1,807 3,554 [S1-6 DP 50 c] Employee turnover 82 UoM 2025 2024 Number of employees who left the undertaking No. 154 149 Voluntary No. 128 129 Due to redundancy No. 16 6 Due to retirement No. 8 11 Due to death in service No. 2 3 Total number of employees No. 3,811 3,554 Total employee turnover rate % 4.04 4.19 [S1-6 DP 50 f] 79 The figure includes all Group employees at 31.12.2025 (compared with the figure at 31.12.2024) and is expressed as the number of people. The columns for employees in the ‘Other’ and ‘Undisclosed’ categories are not shown in the table, as both are valued at zero. 80 The total number of employees includes all employees of the Group at 31.12.2025 (compared to the figure at 31.12.2024), including employees of the Irish and German Companies, which have not reached the representativeness threshold of 10% of the total number of employees. 81 The figures include all Group employees at 31.12.2025 (compared with the figure at 31.12.2024) and are expressed as the number of people. The columns for employees in the ‘Other’ and ‘Undisclosed’ categories are not shown in the table, as both are valued at zero. 82 The figures include all Group employees at 31.12.2025 (compared with the figure at 31.12.2024) and are expressed as the number of people.
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268 | Mediolanum Group - 2025 Annual Financial Report The most representative reference in the consolidated financial statements to the total number of employees is the figure relating to average employment (Notes – Part C –Information on the income statement – Item 190 Administrative expenses - Table 12.2). The basis for preparation is regulated by Bank of Italy Circular 262/2005, as subsequently updated, according to which the average number of employees also includes, in the ‘Other staff’ item, atypical employment contracts that are not included in the average number of employees determined in accordance with paragraph 50a). [S1-6 DP 50 d, 50 di, 50 dii] The figures shown in the tables, relating to the Group’s scope, are taken from the final financial statements without the use of estimates. The figures are expressed in terms of headcount and represent the situation at 31.12.2025. [S1-6 DP 50 e] The figures are in line with previous years and there were no significant fluctuations in the number of employees during the reporting period. At Group level, the use of temporary staff has been reduced and only happens in special circumstances, in particular for the replacement of temporarily absent staff or to manage peaks of activities, projects and specific needs. [ESRS 2 MDR-M DP 75] The metrics on the characteristics of the company’s employees (S1-6) are used as the basis for calculating the other quantitative workforce metrics to assess the Group’s performance in relation to the impacts, risks and opportunities inherent in the company’s own workforce. [ESRS 2 MDR-M DP 77 a] The number of employees by gender was broken down by dividing the number of employees for each gender declared by the total number of current employees. Similarly, the number of employees by country was broken down by dividing the number of employees in each country by the total number of current employees. The employee turnover rate was calculated as the ratio of the number of employees who left the workplace on a voluntary basis or due to redundancy, retirement or death in service to the total number of employees at the end of the reporting period. Collective bargaining coverage and social dialogue [S1-8 DP 60 a; 60 b; AR 70] 100% of the employees of Banca Mediolanum and Banco Mediolanum are covered by collective bargaining agreements. At Group level, also including the Irish and German Companies, where this form of bargaining is not provided for, the overall percentage is 94.49%.
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269 | Mediolanum Group - 2025 Annual Financial Report Collective bargaining coverage Social dialogue Coverage ratios Employees – EEA (for countries with > 50 employees representing >10% of total employees) Employees – Non-EEA (estimated for regions with >50 employees representing > 10% of total employees) Workplace representation (EEA only) (for countries with >50 employees representing >10% of total employees) 2025 2024 2025 2024 2025 2024 0-19% - - - - Italy Italy 20-39% - - - - - - 40-59% - - - - - - 60-79% - - - - - - 80-100% Italy/Spain Italy/Spain - - Spain Spain [S1-8 DP 63 a] The overall percentage of Group employees covered by employee representatives is 18.81%, up on the figure of 2024 (17.11%). Specifically, Banco Mediolanum has a coverage of 96.48%, in line with 2024 data, while for Banca Mediolanum the percentage is 8.03%, up on the figure of 2024% (6.40%). 83 . [S1-8 DP 63 b] Currently, no Mediolanum Group Companies have agreements in place with their employees for representation by corporate committees. [ESRS 2 MDR-M DP 75] The following metrics are used to assess the Group’s performance with respect to impacts, risks and opportunities relating to the topics of Own Workforce in relation to the IRO ‘Creation of a stable and secure working environment that ensures fair conditions in terms of employment, hours, wages, social dialogue and freedom of association, favouring the well-being and satisfaction of the Group’s employees’: the metrics cover collective bargaining and social dialogue. [ESRS 2 MDR-M DP 77 a] The percentage of total employees covered by collective bargaining agreements was calculated as the ratio of the number of employees covered by collective bargaining agreements to the total number of employees at the end of the reporting period. Similarly, the percentage of employees covered by employee representatives was calculated as the ratio of the number of employees covered by employee representatives to the total number of employees at the end of the reporting period. Diversity metrics [S1-9 DP 66 a ] Employees at Senior Management level by gender 84 2025 2024 UoM Women Men Total Women Men Total Employees at senior management level No. 16 60 76 13 62 75 Gender distribution of employees at senior management level % 21.05 78.95 100 17.33 82.67 100 [S1-9 AR 71] 83 The detail for the Irish and German Companies is not reported as they do not reach the representativeness threshold of 10% of the total number of employees. 84 The figures are expressed as the number of individuals at 31/12/2025 (compared to 31/12/2024). The columns for employees in the ‘Other’ and ‘Undisclosed’ categories are not shown in the table, as both are valued at zero.
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270 | Mediolanum Group - 2025 Annual Financial Report For the Parent Company, the category ‘Senior Management’ includes the Chief Executive Officer, the General Manager and their direct subordinates, including the Heads of the Control Functions. For the Spanish subsidiaries, this category corresponds to the CEO and Senior Managers. Senior managers are executives with key responsibilities for the company, reporting directly to the first level of the organisation, and other senior managers of critical functions that have an impact on the business. In Ireland, on the other hand, senior management is split between top-tier seniors, i.e. the CEO’s direct reports, and the category below the senior managers. [S1-9 DP 66 b] Age distribution of employees out of total number of employees85 UoM 2025 2024 Employees under 30 years old No. 470 412 % 12.33 11.59 Employees 30-50 years old No. 2,432 2,353 % 63.82 66.21 Employees over 50 years No. 909 789 % 23.85 22.20 [ESRS 2 MDR-M DP 75] The following metrics are used to assess the Group’s performance regarding impacts, risks and opportunities for its Own Workforce: the diversity metrics (S1-9) relating to the negative impact ‘Disparities in the presence of men and women in the overall workforce and, in particular, in senior positions and/or in the processes of professional growth in the company’. [ESRS 2 MDR-M DP 77 a] The calculation of the age distribution of employees out of the total number of employees was made by dividing the number of employees in the individual age brackets envisaged (under 30, between 30 and 50 and over 50) by the total number of active employees; the primary data used in the calculation refer to the number of persons employed at 31.12.2025. Adequate wages [S1-10 DP 69] For all the Italian and Spanish Companies, the salaries of permanent and fixed-term employees are equal to or higher than the minimums established by the CCNL applied and for the Irish Companies the legal minimums in force. The remuneration paid is also aligned with industry benchmarks for similar positions, seniority and years of experience. This is demonstrated by a comparison with industry research, which the Group regularly uses to ensure that wages are adequate and attractive in relation to the external labour market. [ESRS 2 MDR-M DP 75] No specific metrics are used, as reference is made to national collective bargaining and statutory provisions. [ESRS 2 MDR-M DP 77 a] All employees of the Mediolanum Group were considered in order to cover this regulatory request. 85 The figures are expressed as the number of individuals at 31/12/2025 (compared to 31/12/2024).
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271 | Mediolanum Group - 2025 Annual Financial Report Training and skills development metrics [S1-13 DP 83 a] Training and skills development metrics by gender UoM 2025 2024 Percentage of employees who participated in periodic performance and career development reviews % 92.60 92.35 Men % 93.11 92.09 Women % 92.07 92.62 Other % 0 0 Undisclosed % 0 0 Percentage of reviews in proportion to the number of reviews agreed by management % 100 100 [S1-13 DP 83 b] Average number of hours of training by gender86 UoM 2025 2024 Total number of training hours offered and completed by employees h 177,888.75 137,224.35 Men h 93,341.37 67,821.61 Women h 84,547.38 69,402.74 Other h 0 0 Undisclosed h 0 0 Average number of training hours per employee h 46.68 38.61 Men h 48.02 37.53 Women h 45.29 39.73 Other h 0 0 Undisclosed h 0 0 [ESRS 2 MDR-M DP 75] The following metrics are used to assess the Group’s performance with respect to the impacts, risks and opportunities concerning the topics of own workforce: training and development metrics (S1-13), with respect to the positive impact, ‘Employee satisfaction thanks to appropriate training programmes, performance appraisal systems and career development plans’; and the opportunity, ‘Enhancement of human capital through initiatives and activities that include aspects related to training and skills development’. [ESRS 2 MDR-M DP 77 a] The percentage of employees who participated in periodic performance and career development reviews was calculated as the ratio of the number of employees who participated in periodic performance and career development reviews to the total number of active employees at the end of the reporting period. Similarly, the average number of training hours per employee by gender was calculated as the ratio of the total number of training hours offered and completed by employees to the total number of employees at the end of the reporting period. 86 The figure includes all Group employees at 31.12.2025 (compared with the figure at 31.12.2024).
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272 | Mediolanum Group - 2025 Annual Financial Report Health and safety metrics [S1-14 DP 88 a] In 2025, like 2024, the percentage of employees and non-employees covered by the health and safety management system on the basis of legal requirements and (or) recognised standards or guidelines was 100%. [S1-14 DP 88 b] Like 2024, there were no occupational injuries or diseases during 2025 that caused the death of employees and non-employees or other Value Chain workers operating at Mediolanum Group sites. [S1-14 DP 88 c] Recordable accidents at work UoM 2025 2024 Number of recordable accidents at work No. 2 2 Employees No. 2 1 Non-employees No. 0 1 Rate of recordable accidents at work % 0.31 0.31 Employees % 0.34 0.18 Non-employees % 0.00 1.2 [ESRS 2 MDR-M DP 75] The above metrics are used to assess the Group’s performance with regard to the impacts, risks and opportunities relating to issues attributable to the health and safety of the Own Workforce, with regard to the potential impact ‘Harm to workers resulting from occupational accidents and diseases”. [ESRS 2 MDR-M DP 77 a] The rate of recordable accidents at work is calculated on the basis of all employees of the Mediolanum Group by dividing the number of recordable accidents at work by the number of hours worked, and multiplying the result by 1,000,000. The two reported accidents relate to cases that occurred outside the workplace while the workers were working remotely. Compensation metrics (pay gap and total compensation) [S1-16 DP 97 a] Gender pay gap UoM 2025 2024 Italy % 25.69 26.82 Spain % 17.44 26.02 Ireland % 33.11 40.04 [S1-16 DP 97 b] Total annual remuneration rate UoM 2025 2024 Italy % 44.58 36.72 Spain % 10.43 22.12 Ireland % 10.10 8.09 [S1-16 DP 97 c] With regard to the gender pay gap, it should be noted that the figure is constantly monitored by the corporate bodies of the Parent Company, both considering the average pay gap and considering the gender pay gap for equivalent work (equal pay gap), which is well below the ‘materiality’ threshold of 5%, with a further in-depth analysis resulting from the exclusion of objective factors underlying the gap (adjusted equal pay gap), below 3%. As indicated in the first section of the report on the Group’s Remuneration Policy and fees paid, the analyses carried out in 2025 do not show any particularly critical issues. [ESRS 2 MDR-M DP 75]
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273 | Mediolanum Group - 2025 Annual Financial Report The following metrics are used to assess the Group’s performance with respect to the impacts, risks and opportunities relating to Own Workforce: remuneration metrics (S1-16), with respect to the potential impact: ‘Gender pay gap for equal roles’. [ESRS 2 MDR-M DP 77 a] The gender pay gap was calculated by comparing the average gross hourly pay of male and female employees. In particular, the difference between the average gross hourly pay of men and women was determined, then compared with the average gross hourly pay of men. The result was then multiplied by 100, resulting in the percentage of the gender pay gap. The gender pay gap was calculated taking into account the following remuneration elements: the individual gross annual remuneration, with reference to the total fixed remuneration, and the variable remuneration actually paid to each person during the year for any reason. The overall remuneration thus determined at individual level was compared with the number of working hours stipulated in the employment agreement, to determine the ‘hourly pay’, the averages of which were then calculated by gender. Serious human rights incidents, complaints and impacts [S1-17 DP 103 a; 103 b; 103 c; 103 d] With regard to any incidents, complaints and severe Human Rights impacts, the Mediolanum Group notes that no breaches have been notified with regard to the workforce in the Group’s Italian, Irish and German Companies. During the year, Banco Mediolanum received a report and an internal investigation is under way to verify the existence of possible inappropriate conduct attributable to a discriminatory situation. An action plan has also been drawn up to prevent circumstances that violate a person’s dignity and to raise employees’ awareness. [S1-17 DP 104 a; 104 b] There were no severe Human Rights incidents related to the undertaking’s workforce during the reporting period. As a result, no fines or penalties were imposed, or damages awarded in respect of such incidents. [ESRS 2 MDR-M DP 75] The following metrics are used to evaluate the Group’s performance regarding impacts, risks and opportunities related to the Own Workforce. In particular, the metrics for incidents, complaints and severe human rights impacts (S1-17) are used to evaluate the Group’s potential impact: ‘Insecurity of workers due to incidents of harassment and/or lack of measures to protect workers and/or awareness-raising initiatives’. [ESRS 2 MDR-M DP 77 a] The above metrics are calculated on the basis of tracked reports using uniform criteria and communicated to the relevant departments. [ESRS 2 MDR-M DP 77 b] In relation to the social metrics indicated in previous sections, no external entities, other than the entity issuing the certificate of compliance, are involved in the data validation. Only the equal pay gap and average pay gap calculation was performed by an external, independent and internationally qualified consulting firm.
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274 | Mediolanum Group - 2025 Annual Financial Report 3.2 ESRS S2 Workers in the value chain 3.2.1 Material impacts, risks and opportunities and their interaction with strategy and business model [S2.SBM-3 DP 10 a] The impacts related to workers’ rights within the supply chain are a lever for guiding the Mediolanum Group’s business model towards higher standards of sustainability and responsibility. The inclusion of supplier selection and assessment criteria that integrate the analysis of the social and environmental impacts of the products and services provided, together with a guarantee of respect for the fundamental rights of workers, is a distinctive element to strengthen key controls in the area of governance, compliance and sustainability. This approach not only promotes respect for Human Rights and the protection of the health and safety of workers throughout the supply chain, but also reinforces the Group’s reputation as a promoter of responsible practices. Attention to these aspects can generate long-term value, mitigating operational and reputational risks and fostering trusted relationships with strategic Stakeholders. [S2.SBM-3 DP 11] Based on the double materiality assessment carried out, workers in the supply chain have been identified as persons in the value chain potentially exposed to significant impacts arising from the Group’s activities, including impacts directly related to its operations and the Value Chain. These workers therefore fall within the scope of the disclosure requirements under ESRS. [S2.SBM-3 DP 11 a] The main workers in the Value Chain subject to significant impacts are employees of the Group’s suppliers in Italy, the Group’s main market, and in other European countries, in particular Spain and Ireland. [S2.SBM-3 DP 11 ai-v] These workers mainly operate in the upstream Value Chain of the undertaking, mainly in relation to the following types of supply: professional services (e.g. advisory and legal services); IT services (e.g. software, hardware, infoproviders); management services (e.g. security, call centre, office supplies); facilities (e.g. cleaning, canteen); marketing and advertising (e.g., gadgets, advertising services); construction (e.g. renovations, office furnishings). [S2.SBM-3 DP 11 b] There are no geographical areas or specific goods for which there is a significant risk of child labour, forced or compulsory labour among workers in the Group’s Value Chain. In particular, as explained in the Policy for the Protection of Human Rights of the Mediolanum Group, the Group promotes respect for human rights along the supply chain, as well as the application of its sectoral policies and the Group Code of Conduct, which, inter alia, provide for measures related to the exercise of due diligence to prevent, mitigate and manage Human Rights impacts. In particular, the Code of Conduct calls on suppliers and their employees to adhere to the commitments described in the Policy, always respecting their management autonomy and following the best practices and procedures found according to the internal rules and regulations of purchasing. It also requires suppliers to ensure that fundamental Human Rights are respected in all activities and relationships along the supply chain, in compliance with the ILO Conventions, which implies a ban on labour exploitation, child labour, forced labour, human trafficking and discrimination. Suppliers must ensure the fair treatment of all workers, respecting union rights and promoting diversity and gender equality. [S2.SBM-3 DP 11 c]
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275 | Mediolanum Group - 2025 Annual Financial Report The potential negative impact identified as material by the double materiality assessment process refers exclusively to individual potential incidents concerning breaches of workers’ rights in the Value Chain (e.g. working hours and health and safety). The impact is considered potential, as there have been no incidents of this type in the Group’s Value Chain and, at present, there are no general or systemic negative impacts, also taking into account the characteristics of the sector. This impact is also adequately monitored, thanks to company policies that include checks and clauses on respect for fundamental rights. [S2.SBM-3 DP 10 b; 11 e; 12; 13] In the double materiality assessment, no material risks or opportunities were identified for the Mediolanum Group arising from impacts on workers in the Value Chain; furthermore, no specific categories of Value Chain workers were found to be more exposed to risks. 3.2.2 Suppliers [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Working conditions Violation of workers’ rights (job stability, working hours, adequate wages for a dignified life, social dialogue, freedom of association, work-life balance, health and safety, child labour, forced labour, etc.) in the Value Chain Potential negative impact Downstream value chain Medium term The Group’s approach and policies The Mediolanum Group regards supply chain management as a key element in ensuring sustainable supply, in which the focus on ethical, social and environmental values is fully integrated with the operational needs of the business. The selection and involvement of suppliers follows a structured approach, based on qualification processes and periodic assessment, which ensure compliance with high standards in terms of governance, sustainability and respect for Human Rights. This system is not limited to verifying the economic soundness of business partners, but also includes the adoption of measures to safeguard the health and safety of workers and reduce environmental impacts. In particular, this entails the integration of the principles of the ISO 20400 standard, which guides the Group towards a sustainable supply, requiring suppliers to demonstrate their ability to bring added value with sustainability criteria to the products and services offered. Over the years, the Mediolanum Group has developed various Group Policies intended to ensure the correct management of the impacts described above. In addition to the Mediolanum Group’s Code of Ethics and Sustainability Policy, which set out its approach and general guidelines, the main policies for managing impacts related to the rights of workers of suppliers are the Mediolanum Group’s Policy for the Protection of Human Rights, the Mediolanum Group’s Purchasing Policy and the Supplier Code of Conduct. [S2-1 DP 16; ESRS 2 MDR-P DP 65] IROs: Violation of workers’ rights (job stability, working hours, adequate wages for a dignified life, social dialogue, freedom of association, work-life balance, health and safety, child labour, forced labour, etc.) in the Value Chain
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276 | Mediolanum Group - 2025 Annual Financial Report Mediolanum Group Policy for the Protection of Human Rights In line with its corporate culture, the Mediolanum Group undertakes to respect and promote human rights (see ESRS S3 Affected Communities, paragraph 3.3.2 Economic, social and cultural rights of communities, section ‘The Group’s approach and policies for further details on the Mediolanum Group’s Policy for the Protection of Human Rights) as part of its activities and to prevent, with the aim of minimising, any breach directly caused by its actions. The relationship with suppliers is a fundamental commitment of the Group to its Stakeholder. In this context, the Group promotes respect for Human Rights throughout the supply chain, applying its sectoral policies and the Code of Conduct. These tools include due diligence measures to prevent, mitigate and manage potential impacts on Human Rights related to supplier activities. Supplier Code of Conduct of the Mediolanum Group Content and objectives The Mediolanum Group’s Supplier Code of Conduct establishes the rules of conduct to be adopted by suppliers in their commercial relations with the Group. The primary purpose of this document is to promote fair, transparent and sustainable business relationships with all business partners and to prevent and combat any form of corruption, conflict of interest or unlawful conduct, encouraging suppliers to adopt responsible practices towards the environment and human rights. Specific objectives include protecting the Group’s reputation, complying with applicable laws and regulations, promoting fair competition and enhancing a corporate culture based on integrity and social responsibility. Scope of application The document applies to all economic entities that establish commercial relations with Group Companies, recorded in the Official Suppliers’ Register held by each Group Company. Highest level of management responsible for implementation The Mediolanum Group’s Supplier Code of Conduct is approved by the Board of Directors of Banca Mediolanum and adopted by it; it is also sent to all the Companies belonging to the Mediolanum Group, so that, by resolution of their own corporate bodies, they can adopt their own Code of Conduct in accordance with the principles set out in this document. The Chief Executive Officer is responsible for implementing the principles and guidelines governed by the Code in question, which is subject to periodic review by the Parent Company ‘Procurement Division’. Regulations and reference standards The Mediolanum Group developed the Code taking into account the main European and international guidelines, such as, by way of example, the international guidelines defined by ISO 20400, the principles laid down in Model 231, the Anti-Corruption Policy and the Code of Ethics, and the international guidelines defined by the United Nations Global Compact, to which Banca Mediolanum has adhered since 2021, in which suppliers are encouraged to adopt practices that are responsible for the environment and human rights, thereby contributing to the creation of an ethical and sustainable supply chain. Method of dissemination Reading the Supplier Code of Conduct is a necessary requirement for establishing and maintaining commercial relations with the Mediolanum Group. Through the Supplier Code of Conduct, the Group shares the fundamental values and rules of conduct that suppliers must adopt when managing commercial relations with the Mediolanum Group. In addition, the Group expects its suppliers to adequately inform their employees and supply chain entities about the principles of the Code and that they should, in turn, comply with its contents.
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277 | Mediolanum Group - 2025 Annual Financial Report The Code of Conduct is made available through publication on the institutional website and is referred to in contractual clauses with suppliers that are requested to make a specific commitment to carry out their activity in accordance with the Code of Conduct. With regard to foreign subsidiaries, in 2025, Ireland and Spain implemented the Mediolanum Group’s Supplier Code of Conduct. Mediolanum Group’s Purchasing Policy Content and objectives The Mediolanum Group’s Purchasing Policy, with the latest update approved in early 2025, describes the principles adopted by Banca Mediolanum, in its capacity as Parent Company of the Mediolanum Banking Group, to optimise the management of purchasing processes and ensure adequate levels of control over the costs and quality of services provided by suppliers. With specific reference to sustainability matters, the Policy describes the process of qualification of the suppliers integrated over the years in order to assess the characteristics of the supply chain in relation to the social and environmental impacts of the products and services provided, while respecting and protecting Human Rights, through the integration and computerisation of ESG data. Scope of application This Policy is directly applicable within Mediolanum Bank and the Companies of the Financial Conglomerate. Highest level of management responsible for implementation The Procurement Division of Banca Mediolanum is responsible for updating and revising the Mediolanum Group’s Purchasing Policy. The Policy is approved by the Board of Directors of Banca Mediolanum and the Chief Executive Officer is responsible for implementing its principles and guidelines. Regulations and reference standards Banca Mediolanum developed its Purchasing Policy taking into account the main national, international and EU regulations, initiatives and agreements in force from time to time. Stakeholder involvement and dissemination methods Suppliers are actively engaged in ESG issues through the administration of a specific questionnaire that takes into account the suggestions of ISO 26000 ‘Guide to Social Responsibility’ and ISO 20400 ‘Sustainable Procurement’. The Group’s Spanish and Irish companies have transposed the Purchasing Policy, taking into account specific aspects of national legislation. [S2-1 DP 17; 18] The Group requires its suppliers to ensure respect for fundamental Human Rights in all activities and relations along the supply chain, including through compliance with the provisions of the ILO Convention. This includes the rejection of all forms of labour exploitation, precarious work, child labour, forced labour, human trafficking and discrimination, promoting safe, dignified and inclusive working conditions. Suppliers must ensure the fair treatment of all workers, respecting union rights and promoting diversity and gender equality. By way of example - and as also provided for in the Supplier Code of Conduct, this is required in the process for registration in the Official Register of Suppliers and in the standard contractual formats adopted by the Parent Company. [S2-1 DP 17 a] The areas of responsibility for suppliers are defined by the Group, which has always been committed to promoting a culture within its business that is compliant with current regulations, aligned with international best practices and able to ensure the satisfaction of its resources. This culture results in the pursuit of compliance with rules, privacy and ethics and is based on the value of the person, promoting behaviours based on consistency, transparency, fairness and mutual trust, in full compliance with the Group’s Code of Ethics. [S2-1 DP 17 b]
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278 | Mediolanum Group - 2025 Annual Financial Report The status of ‘full’ supplier of the Parent Company (suppliers with whom ongoing, recurrent, long-term and/or high value contracts and/or framework agreements have been signed), has been integrated, assessing the social and environmental impact of the supplier, including respect for and protection of human rights, through the integration and computerisation of ESG data. Suppliers are actively engaged in ESG issues through the administration of a specific questionnaire (see ESRS S2, paragraph 3.2.2 Suppliers, section ‘Actions’, DP 31 for further details on the ESG Questionnaire) that takes into account the suggestions of ISO 26000 ‘Guide to Social Responsibility’ and ISO 20400 ‘Sustainable Procurement’. In addition, with Service Providers considered strategic and ongoing, category managers organise periodic meetings with the aim of tracking supplier performance, as well as sharing the supplier’s development plans and innovation and evolution projects in the ESG area. In relation to foreign Subsidiaries, in Spain all major outsourcing service providers undergo an annual audit, which also includes an assessment of ESG criteria. For the evaluation of potential new suppliers, a full analysis covering ESG, financial, legal and reputational profiles has been carried out since July 2025. This process, supported by the Informa service, aims to ensure sustainability, transparency and risk mitigation along the supply chain. In Ireland, suppliers that come under the definition of ‘Value Chain Workers’ have been listed and given a specific ESG questionnaire as planned and amended based on local conditions. [S2-1 DP 17 c] At the time of the approval of the Supplier Code of Conduct, its acceptance was defined as a necessary requirement for the establishment and maintenance of commercial relations with the Mediolanum Group. In addition, based on the principles of this Code, suppliers are subject to an assessment, where applicable, to evaluate the adequacy of the safeguards and policies concerning data protection and privacy, in relation to the Bank’s internal values and standards. The Group, if it considers it necessary, may carry out checks and audits to monitor compliance with these principles, either directly or through third parties. In the event of any breach of the Code, the Group may take any contractual measures that it considers appropriate, including termination of the business relationship. [S2-1 DP 19] The Policy for the Protection of Human Rights and the Supplier Code of Conduct of the Mediolanum Group are based on main international guidelines, including the International Bill of Human Rights, ILO 87 Conventions and Fundamental Declarations, and the OECD Guidelines for Multinational Enterprises. During the reporting period, the Group did not receive any reports of violations of international principles, including the United Nations Guiding Principles on Business and Human Rights, the International Labour Organisation (ILO) Conventions and the OECD Guidelines, nor were any human rights violations identified in the upstream value chain. 87 In particular, the Declaration on Fundamental Principles and Rights at Work of the International Labour Organization (ILO) which promotes rights such as freedom of association, the elimination of forced labour, child labour and discrimination at work; and the ILO’s Tripartite Declaration of Principles concerning Multinational Enterprises, which is aimed at MNEs, governments, entrepreneurs and workers in areas such as employment, training, working and living conditions and industrial relations.
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279 | Mediolanum Group - 2025 Annual Financial Report Actions [S2-4 DP 32 a] The Mediolanum Group has adopted several initiatives to prevent negative impacts related to suppliers. In particular, for 2025, the main action plans implemented provide for: the supplier classification process; the supplier selection process. [S2-4 DP 31; 32 c; ESRS 2 MDR-A DP 68] IROs: Violation of workers’ rights (job stability, working hours, adequate wages for a dignified life, social dialogue, freedom of association, work-life balance, health and safety, child labour, forced labour, etc.) in the Value Chain Supplier classification process Through the Suppliers’ Register, the Procurement Division constantly monitors the requirements necessary to be in line with the assessment criteria, and has a portfolio of qualified references used for scouting activities. There are two types of classification for registration in the Official Suppliers’ Register: ‘full’ classification: this is for suppliers with which contracts and/or framework agreements are signed that are continuous, recurring, multi-annual and/or of high economic value, and is based on the collection, verification and assessment of information on different areas (financial, compliance, ESG, reputational). For foreign suppliers, a simplified procedure was activated that, in addition to the registration process, entails the acquisition of a Financial and Reputational Report, which includes a score calculated on the basis of information and data present in public sources from a Certified Supplier. ‘Light’ classification: this is for occasional suppliers, only required to register personal, administrative and tax data, and mainly refers to freelance professionals, suppliers with occasional collaborations and deals of low economic value that do not belong in the high-risk product categories. The Parent Company, with the aim of efficiently managing the corporate purchasing processes, ensuring the functionality and effectiveness of supply and to comply with the regulatory requirements on health and safety, has implemented the ‘full’ supplier qualification procedure over the years. The latter qualification consists of a number of activities aimed at collecting and verifying information concerning suppliers and also covers supplier due diligence to ensure compliance with specific regulations (for example, the DORA). The full supplier classification in the Register also enables assessment of the risk relating to the supplier in relation to the provisions in the areas of compliance, risk management, Legislative Decree No. 231/2001, Legislative Decree No.81/08, ESG and reputational risk. The four areas of action on which the Suppliers Register is based for evaluating sustainable purchases are as follows: environmental, through the analysis of an ESG report provided by a specialised information provider; social, through the collection, verification and periodic updating of the D.U.R.C. (Certificate of Social Security Compliance) and the insurance policy, as well as the collection of the documents necessary for the purposes of workplace safety provided for by Legislative Decree No. 81/08, with verification of the technical and professional suitability of the supplier and its resources; financial, with questionnaires (some for specific activities) with an indication of turnover, the dependency ratio, with references from other customers, collection of data from the reports of certified bodies, economic and financial screening and related analysis carried out by the ‘Loans’ Office to verify financial solidity; ethics, by means of reputational verification, protests and adverse events from certified data sources. In 2025, the assessment of ‘full’ suppliers continued, in line with the provisions of the Policies and Regulations.
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280 | Mediolanum Group - 2025 Annual Financial Report In Ireland, the Companies have also adopted a supplier qualification process consistent with the model and objectives pursued by the Parent Company, based on a multi-level system for gathering and verifying supplier information and for carrying out due diligence, aimed at assessing supplier risk. Through the Supplier Register, the Procurement function and the senior managers responsible for supplier relationships monitor the requirements necessary to be in line with the evaluation criteria. In 2025, the Supplier Code of Conduct was included in both the Procurement Policy and the standard contractual formats. Reading the Code is a necessary requirement for establishing and maintaining commercial relations with the Group. Vendor Rating Process & ESG Questionnaire The vendor rating process adopted by the Parent Company involves ‘strategic’ suppliers, which support the Italian Conglomerate in the sustainable development of business innovations and evolutions through a new engagement model. The ESG questionnaire, referred to above and completed by suppliers classified as ’full’, is a key tool to ensuring alignment with the company’s sustainability and innovation policies. This questionnaire incorporates the suggestions of both ISO 26000 ‘Guide to Social Responsibility’ and ISO 20400 ‘Sustainable Procurement’. By collecting detailed information and the supplier’s future commitments, the questionnaire makes it possible to: assess compliance with ESG regulations and standards, ensuring responsible environmental, social and governance practices; monitor the improvement objectives declared by the supplier, with particular attention to reducing environmental impact, protecting workers’ rights and the transparency of processes; promote sustainable innovation, facilitating the adoption of technologies and solutions that contribute to the ecological transition and competitiveness; support the company’s sustainability strategy, providing data useful for reporting and achieving the ESG targets defined by the organisation. The ESG questionnaire is a useful tool for evaluation and collaboration, aimed at selecting reliable partners focused on sustainable growth, in line with ethical principles and the challenges of the global market. In Ireland, the Vendor Rating process, launched in 2025, involves ‘strategic’ suppliers, that support Irish companies in the sustainable development of business innovations and evolutions through a new engagement model to share Mediolanum’s sustainability principles. This process takes place through regular meetings with suppliers and the internal customer to evaluate collaboration and the sales force. In particular, in 2025, meetings were held with strategic suppliers to share the principles and values of the Mediolanum Group and collect information on the supplier’s sustainability commitment. Supplier selection process The selection process currently implemented entails the assessment of suppliers in relation to ESG and financial performance. During the selection stage, in addition to the price of the asset or service acquired, the Parent Company also considers ethical aspects, anti-corruption, conflicts of interest, respect for property and intellectual property violations. Particular attention is also paid to the safeguarding of human and labour rights principles, anti-corruption and the protection of the environment. In accordance with the ISO 20400 standard, suppliers are required to demonstrate their ability to contribute added value through the integration of sustainability criteria as part of the product or service provided. In this area, a collaboration project was started with Bureau Veritas, a body recognised and accredited by the most important national and international organisations in inspection, conformity audit and certification services. The aim of the collaboration is to consolidate the matters covered by ISO 20400:2017, the first international standard on responsible procurement, which enables
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281 | Mediolanum Group - 2025 Annual Financial Report companies to make more informed decisions by introducing criteria and processes for evaluating suppliers, products and services based on their sustainability performance. In the tender stage, however, a screening model has been defined and extended to the sustainability criteria with information on the social and environmental impacts of the products and services provided. The responses to the tender are assessed and reported in the scoring model. In January 2025, the Procurement Division received the evaluation relating to the assessment carried out on ISO 20400:2017 by Bureau Veritas. The rating scale from 1 (minimum) to 3 (maximum) shows a significant improvement, placing us in the various sections in a rating range from 2.6 to 3.00. The Mediolanum Group’s Purchasing Policy has been updated to reflect the procedures for adopting the new internal and external regulations. With regard to the foreign Subsidiaries, Banco Mediolanum adopts a due diligence process for managing suppliers. In Spain, while not applying ISO 20400, good international practices are followed. For new main suppliers, specific consultations on sustainability information are conducted and an ESG report is requested. In addition, Banco uses an external service that provides a comprehensive assessment of suppliers, including financial, reputational and ESG aspects. As part of the analysis, documents are required to verify the supplier’s commitment to employee rights and sustainability, such as the Code of Ethics or Conduct, the Equality Plan and Environmental Policies. In Ireland, the supplier selection process follows criteria similar to those of the Parent Company, assessing suppliers against ESG criteria and financial performance. In addition to the price of the goods or services offered, ethical aspects, the prevention of corruption, conflicts of interest, and the protection of human rights and the environment are considered during the selection stage. In line with ISO 20400, suppliers must demonstrate their ability to integrate sustainability criteria into the products or the service offered. During the tender phase, a screening model is also defined, extended to sustainability criteria, with information on the social and environmental impacts of the products and services provided. [S2-4 DP 32 d] With a view to continual improvement, the Parent Company monitors and assesses the effectiveness of the actions described in the previous sections, mainly through the ISO 20400 certification process. In addition, the Group’s foreign companies have a due diligence process in place for the management of their suppliers, as well as periodic review processes. [S2-4 DP 33 a] The Parent Company adopts a structured approach to mitigate any material negative impacts in terms of violation of the rights of workers in the Value Chain. This process is divided into two main stages: contractual governance and dedicated contact persons: in the context of contractual agreements with suppliers, a solid governance activity is established. To this end, specific contact persons are identified who are responsible for monitoring and managing the collaboration with each supplier; periodic monitoring and discussion with suppliers: the category managers periodically organise a discussion with the contact persons of the strategic suppliers, in order to jointly examine the main matters involved in the collaboration, including matters of sustainability and Human Rights. The approach, also adopted in Ireland, is in line with the guidelines provided by ISO 20400, the international standard for sustainable procurement that addresses seven key matters, including protecting and respecting human rights.
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282 | Mediolanum Group - 2025 Annual Financial Report significant negative impacts related to the violation of workers’ rights. In the framework of contractual agreements with suppliers, robust governance is established, which includes the designation of specific contact points to monitor and manage the relationship with each supplier. As part of the control process, the existence of relevant documentation is verified in the supplier’s public channels (e.g. code of ethics and equality plan). In the event this information is not publicly available, the supplier is directly required to ensure transparency and compliance with social and labour standards. [S2-4 DP 33 b] In order to establish and maintain commercial relations with the Mediolanum Group, it is necessary to read the Supplier Code of Conduct, through which suppliers can adequately inform their employees and supply chain stakeholders of the principles of the Code so that they, in turn, comply with its contents. [S2-4 DP 33 c] The Group, if it considers it necessary, reserves the right to carry out checks and audits to monitor compliance with the principles defined herein, either directly or through third parties. As stated above, an audit is carried out annually at the Spanish Subsidiary on all the main providers of services classified as critical outsourced services. [S2-4 DP 35] In the event of any breach of the Code, the Group may take any contractual measures that it considers appropriate, including termination of the business relationship. For example, regarding the Spanish subsidiary, the contracts include termination clauses in the event of default. [S2-4 DP 36] In 2025, the Group was not notified of any breaches and consequently there were no high penalties and/or measures in the area of human rights connected to the upstream Value Chain. [S2-4 DP 38] The Parent Company’s Procurement Division oversees all the goods and services procurement activities necessary for the performance of the corporate activities. In particular, the Procurement Division includes the Contract Management Managerial Support Unit, which is also responsible for managing policies and initiatives relating to sustainable procurement. With regard to foreign Subsidiaries, in Spain, the Purchasing area is responsible for managing relations with suppliers of goods and services necessary for the development of the business. The review and validation of contracts are the responsibility of the Legal Consultancy Department, which ensures compliance with regulations and the correct formalisation of agreements; in Ireland, the Procurement Function oversees all purchasing activities for the goods and services necessary for the company’s operations. Targets IROs: Violation of workers’ rights (job stability, working hours, adequate wages for a dignified life, social dialogue, freedom of association, work-life balance, health and safety, child labour, forced labour, etc.) in the Value Chain [S2-5 DP 41; ESRS 2 MDR-T DP 80] Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Evaluation of suppliers with a focus on workers’ rights 100% of the suppliers analysed 2030 Group 2024 50% 50%88 88 Since the target was defined and approved at the end of 2025, there is no evidence of progress compared to the baseline year 2024. Any progress will be more evident in subsequent reporting.
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283 | Mediolanum Group - 2025 Annual Financial Report The Mediolanum Group intends assessing 100% of active suppliers, qualified in the supplier register in ‘full’ mode, with particular attention paid to workers’ rights, particularly in sectors considered to be high risk (e.g. security services, cleaning and facilities). [S2-5 DP 42 a] The process of defining the above objective was guided by the Procurement Division of the Parent Company, in line with the sustainability objectives of the Mediolanum Group. [S2-5 DP 42 b] Monitoring is carried out by acquiring the requested documentation proving the supplier’s commitment to respecting workers’ rights. On an annual basis, the percentage of suppliers assessed according to criteria relating to the protection of workers’ rights in services considered at risk will be monitored. [S2-5 DP 42 c] During the reporting period, there were no opportunities for direct dialogue with suppliers’ workers included in the indicator. 3.2.3 Processes for engaging with Value Chain workers about impacts [S2-2 DP 24] During Stakeholder Engagement carried out for 2025, the Mediolanum Group set up specific focus groups dedicated to the involvement of suppliers. However, no provision was made for the direct involvement of employees along the value chain. In May 2025, Banca Mediolanum organised a ‘Stakeholder Engagement’ event at the Palazzo Biandrà headquarters, involving the purchasing and sustainability managers of companies considered most strategic within a long-term partnership approach. On this occasion, the topics of sustainability and the procurement model for the Mediolanum Group were addressed, allowing ample opportunity for discussion among participants on sustainability priorities and future outlook, as well as on potential synergies within the high-value ESG supply chain. During 2025, the foreign Subsidiaries also set up specific focus groups dedicated to supplier involvement, where appropriate. 3.2.4 Processes to remediate negative impacts and channels for Value Chain workers to raise concerns [S2-3 DP 27 a] The Mediolanum Group has adopted an ‘Internal Reporting System’ (the so-called ‘Whistleblowing’) to allow the reporting of alleged infringements of the principles contained in Model 231, as well as other national and European Union legislation that require the adoption of reporting systems. To this end, both employees and third parties are entitled to make, through the channels provided and also represented on the websites of the Group Companies, reports detailing potential and/or actual violations of the regulations mentioned above, of which the whistleblower has become aware due to the functions performed. [S2-3 DP 27 b] With regard to workers in the supply chain, the Parent Company may request clarification or report a breach or suspected breach of the ‘Supplier Code of Conduct’ by the supplier or any person whose services it uses for the supply of goods or services by writing to: ufficioacquisti@pec.mediolanum.it. With regard to foreign Subsidiaries, at the Spanish companies of the Mediolanum Group, any violations or alleged violations of the principles contained in the Group’s rules of conduct, national legislation or European Union legislation may be reported through the channels and tools provided for by the Internal Whistleblowing Policy. In Ireland, if a violation of the MIFL and MIL Supplier Code of Conduct is identified or suspected, specific commitments are made to resolve the issue. [S2-3 DP 27 c]
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284 | Mediolanum Group - 2025 Annual Financial Report The Parent Company provides internal and external reporting channels. Similarly, foreign Subsidiaries have dedicated channels: Banco Mediolanum makes the reporting channels available through its website, accessible to all its stakeholders, while MIFL and MIL adopt both internal and external channels specifically dedicated to whistleblowers (See ESRS S1 Own workforce, paragraph 3.1.9 Processes to remedy negative impacts and channels that enable own workers to raise concerns, DP 32 d, for further details on whistleblowing channels). [S2-3 DP 27 d] The Internal Audit Function is responsible for the proper functioning of the ‘Internal Reporting System’. A Head is appointed to this Internal Reporting System (Whistleblowing System) and ‘Whistleblowing Officers’, responsible for receiving, analysing and assessing reports received, in compliance with applicable legislation and internal company regulations. (see ESRS S1 Own Workforce, paragraph 3.1.9 Processes to remedy negative impacts and channels that enable own workers to raise concerns, DP 32e, and ESRS G1 Business Conduct, paragraph 4.1.2 Protection of Whistleblowers for further details on procedures, control and monitoring methods regarding whistleblowing). In Spain, Banco Mediolanum has a procedure for analysing the data and cases reported and, in Ireland, any problems raised through the channels mentioned above are monitored and tracked by the Human Resources and Finance departments, as necessary. [S2-3 DP 28] The Procurement Division of the Parent Company requires that the ‘Supplier Code of Conduct’ be read during the stages of classification of the suppliers in the register and during the contract drafting stage. Reading the Code is a necessary requirement for establishing and maintaining commercial relations. In addition, in accordance with the above ‘Principles’, the Parent Company expects its suppliers to adequately inform their employees and supply chain entities about the Code principles and that they should comply with the Code principles. The Parent Company, if it considers it necessary, reserves the right to carry out checks and audits to monitor compliance with the defined principles, either directly or through third parties. In the event of violations of the Code, the Parent Company may take the contractual measures deemed most appropriate, including termination of the business relationship. For foreign subsidiaries, in Spain, the Supplier Code of Conduct is communicated to suppliers of recurring activities and is shared at the start of each new business relationship. In Ireland, MIFL and MIL have adopted the Code as an integral part of their Procurement Policy, providing for the possibility to take appropriate contractual measures, including the termination of the relationship in case of breach of the Code. On the other hand, to report a violation, or suspected violation, of the principles contained in Model 231, as well as other national or European Union legislative provisions requiring the adoption of reporting systems, pursuant to the Whistleblowing Systems Policy in force, it is possible to use the channels and means of transmission provided for by the relevant internal regulations, which can be viewed on the website of Banca Mediolanum and of the Group Companies concerned (see ESRS G1 Business conduct, paragraph 4.1.2 Protection of whistleblowers, section ‘The Group’s approach and policies’, DP 10c, for further details on the procedures for protecting whistleblowers).
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285 | Mediolanum Group - 2025 Annual Financial Report 3.3 ESRS S3 Affected communities 3.3.1 Material impacts, risks and opportunities and their interaction with strategy and business model [S3.SBM-3 DP 8 a] The impacts on affected communities where the Mediolanum Group operates are connected to one of the main dimensions that guide the Group’s social strategy, as enshrined in the Group’s Code of Ethics, through the principles of the ‘centrality of the person’ and ‘responsibility to the community’, which represents one of the four fundamental areas of responsibility on which the sustainability strategy is based. In 2001, as a sign of this commitment, the Mediolanum Foundation was set up with the aim of developing and supporting the Group’s main social activities. Since then, the Foundation has played a central role in implementing projects to promote community welfare, with a particular focus on the most vulnerable areas and the emerging needs of the social fabric. The community-related impacts, in the broader view of the Mediolanum Group’s ‘responsibility to the community’, help to direct the development of the strategy towards specific areas, such as financial inclusion and social credit objectives (see ESRS S4 Affected Communities, paragraph 3.4.4 Access to products and services, section ‘Targets’, for further details). This orientation is in line with the broader approach of the business, which views growth and economic development as an inclusive process that has to take into account the impacts generated on people and communities. [S3.SBM-3 DP 8 b] Responsibility to the community may also have a significant impact on the Group’s reputation. The positive effects generated by social initiatives are periodically monitored through Customer Satisfaction surveys, which make it possible to assess the degree of appreciation and trust of customers and the communities in which the Group operates. In addition to impacts, material opportunities are closely interlinked with the Group’s corporate strategy, as they are aligned with its commitment and the principles of ‘people-centricity’ and ‘responsibility towards the community’. In fact, indirectly, the positive effects generated through initiatives targeting the social dimension, financial eduction and support for culture may help to generate an increase in revenues for the Mediolanum Group (e.g. expansion of the customer pool/market share). [S3.SBM-3 DP 9] All of the affected communities that may be subject to material impacts caused by the undertaking, including those directly related to the own operations and the Value Chain of the undertaking, are included in the scope of the disclosure and have in fact been included in the double materiality assessment. [S3.SBM-3 DP 9 a; 9 b; 9 ai-iv] The type of community subject to material impacts caused by the undertaking, due to both its own operations and its upstream and downstream Value Chain, is a community living in the regions of the Group and where the Group operates, where the objective is to positively influence the socio-economic fabric through development, employment, innovation and services for local communities. The double materiality assessment process identified only positive impacts on these communities. [S3.SBM-3 DP 9 c] The Mediolanum Group has always been set apart by its social commitment, which includes support on the part of the Mediolanum EF Foundation for sociocultural and educational/training projects, initiatives, donations, sponsorship and long-term partnerships, both in the regions in which the Group operates and abroad, also thanks to the involvement of the Mediolanum EF Foundation. [S3.SBM-3 DP 9 d; DP 10]
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286 | Mediolanum Group - 2025 Annual Financial Report In the double materiality assessment with respect to affected communities, the Mediolanum Group did not identify any material risks or relevant negative impacts. The analysis, conducted considering the specific characteristics of local communities, regional contexts and the regulated, low-impact nature of the Group’s activities, did not reveal specific elements of vulnerability or exposure to significant social risks. Furthermore, the local communities with which the Group interacts do not have particular vulnerabilities. On the contrary, a significant opportunity was identified linked to strengthening the trust of communities where the Mediolanum Group operates, through financial education initiatives and support for culture, innovation and social or emergency causes. These initiatives contribute positively to the development of local communities and may, indirectly, generate growth opportunities for the Group. [S3.SBM-3 DP 11] The relevant opportunity identified, arising from impacts on affected communities, relates to the community as a whole and not to specific groups within it. 3.3.2 Economic, social and cultural rights of communities [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Economic, social and cultural rights of communities Socio-economic development of the communities present through the support of regional associations, solidarity, sports, cultural activities, etc. Actual positive impact Own operations and downstream Value Chain (distribution channels) Medium term Improvement of trust on the part of the communities in which the Mediolanum Group operates through initiatives for financial education and support for culture and innovation, or initiatives for emergency situations or directed at social causes, which may indirectly generate an increase in revenues for the Mediolanum Group (e.g. expansion of the pool of customers / market share). Opportunities Own operations and downstream Value Chain (distribution channels) Short term The Group’s approach and policies In line with its founding values, the Mediolanum Group makes a concrete commitment to supporting local communities through social and cultural inclusion projects, supporting human promotion and development activities. The focus on the affected communities translates into targeted initiatives, implemented both directly and through the Mediolanum EF Foundation, with the aim of generating a positive and lasting impact in the areas in which the Group is present. These measures range from assistance to vulnerable individuals, education, artistic and cultural promotion, to emergency activities in the context of humanitarian crises. The overall responsible vision, which integrates sustainability and innovation into support projects at both national and international level, confirms the Group’s commitment to enhancing communities and promoting constant dialogue with Stakeholders, with the aim of building a tangible and measurable impact over time.
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287 | Mediolanum Group - 2025 Annual Financial Report Over the years, the Mediolanum Group has developed various Policies aimed at ensuring the proper management of the above areas. In addition to the Code of Ethics and the Mediolanum Group’s Sustainability Policy, which set out its approach and general guidelines, the main policies for managing impacts and opportunities related to ‘region-related impacts’ are the Mediolanum Group’s Policy for the Protection of Human Rights, Banca Mediolanum’s Community Support Policy and the Charitable Donations Policy. [S3-1 DP 14; ESRS 2 MDR-P DP 65] IROs: The socio-economic development of the communities in which we operate through the support of regional associations, solidarity, sports, cultural activities, etc.; Improvement of trust on the part of the communities in which the Mediolanum Group operates through initiatives for financial education and support for culture and innovation, or initiatives for emergency situations or directed at social causes, which may indirectly generate an increase in revenues for the Mediolanum Group Community Support Policy of Banca Mediolanum Content and objectives Banca Mediolanum’s Community Support Policy, the latest update of which was approved in early 2025, outlines the fundamental principles for promoting shared well-being and support for the communities in which the Group operates. The general objectives of the Policy include the promotion of Mediolanum’s Mission, which is embodied in the construction of authentic, long-lasting relationships based on loyalty, commitment and transparency; in personalised advice, with effective solutions, attentive of the needs of the individual, capable of covering people throughout their entire lives; and in innovative and sustainable action. In order to achieve these objectives, the Parent Company conveys its own value system at every level of the organisation, with the ultimate aim of valuing the relationships established with the communities of which it is a part, committing to leave a positive, distinctive mark on them. Scope of application The Policy applies to all organisational units of Banca Mediolanum, including the Sales Network. Highest level of management responsible for implementation The Chief Executive Officer is responsible for implementing the principles and guidelines governed by the Policy in question, which is approved by the Board of Directors. The updating and review of the document is the responsibility of the Sustainability Office, within the Administration, Finance and Control Department. Regulations and reference standards The document refers to various international regulations and standards, including the Sustainable Development Goals (SDGs) of the United Nations 2030 Agenda. Stakeholder involvement The interests of Stakeholders are taken into account through the involvement of the various corporate actors responsible for relations with internal and external parties relevant to the Mediolanum Group. These include the Diversity Manager, the Human Resources Department, and the Diversity & Inclusion Commission. Method of dissemination The Policy is made available to stakeholders through the publication and dissemination of the document within the Mediolanum Group, as well as through publication on the Banca Mediolanum website.
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288 | Mediolanum Group - 2025 Annual Financial Report Charitable Donations Policy Content and objectives The Charitable Donations Policy, updated in 2023, outlines the Group’s long-standing commitment to developing a solid and sustainable business in the long term, generating added value for all Stakeholders, including through attention to and support for the development of the communities in which it operates. The Policy set out the principles, roles and responsibilities, and the areas envisaged for charitable donations. These payments may be made to natural persons, including customers, in situations of personal distress, to support solidarity initiatives, third-sector organisations or to other entities envisaged, as a form of charity. Political entities, trade unions and public authorities are excluded, except as approved by the Board of Directors. All instruments in which an economic interest of the Bank that provides them is evident are excluded from this Policy, such as: pricing exceptions granted to customers for commercial opportunities or in the case of specific service inefficiencies; complimentary products for customers and prospects; contributions to events in which the Bank has a commercial interest; initiatives to explicitly enhance the Bank’s brand; sums, services or other benefits in general provided to Family Bankers, employees or third parties for purposes other than remedying damages or events of a strictly personal nature; temporary or permanent preferential conditions on the offering of products and services, which are regulated in the context of promotional activities. Scope of application The Policy applies directly in Banca Mediolanum and is sent for adoption and application, in accordance with the principle of proportionality and taking into account applicable regulations and specific local situations, to the other Companies in the Conglomerate. The Subsidiaries are required to submit for prior examination by the Parent Company any charitable initiatives to be undertaken in derogation of the principles regulated in the Policy. The Parent Company, for initiatives that depart from the Policy’s principles, assesses the nature of the initiative and compliance with the principles of sound and prudent management and issues a binding opinion to the Subsidiary. If the Subsidiaries have specific characteristics or needs, they will provide information to the Parent Company on any exceptions to the process of adopting the guidelines at the local level. Highest level of management responsible for implementation The Chief Executive Officer is responsible for overseeing the implementation of the principles and guidelines in this Policy. The document is submitted for examination and approval by the Board of Directors, after consultation of the Risk Committee. The updating and periodic review of the document is the responsibility of the Sustainability Office, within the Administration, Finance and Control Department. Stakeholder involvement The interests of Stakeholders are taken into account through the involvement of various corporate actors responsible for relations with the internal and external stakeholders that are material for the Mediolanum Group, including the Technical Secretarial Team of the Chairman’s staff, the Charity and Donations Committee and the Commercial Network Department. Method of dissemination The document is made available to stakeholders through the publication and dissemination of the document within the Mediolanum Group, as well as through publication on the Banca Mediolanum website.
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289 | Mediolanum Group - 2025 Annual Financial Report Mediolanum Group Policy for the Protection of Human Rights Content and objectives The Policy for the protection of Human Rights of the Mediolanum Group outlines the Group’s commitment to the protection of human rights according to the highest international standards. The general objectives include the respect and promotion of human rights in own company operations, preventing or minimising any violation caused by the Group’s operations. Through this Policy, the Group is committed to maintaining moral integrity and equal opportunities, and prohibits discrimination based on political opinions, religion, race, nationality, age, gender, sexual orientation, state of health and other personal characteristics. Scope of application The Policy involves various categories of Stakeholders, including employees, Family Bankers, suppliers, customers and the communities in which the Group operates. It applies within the Mediolanum Group and is adopted by the other companies in the Conglomerate according to a principle of proportionality and taking into account applicable regulations and specific local aspects. Highest level of management responsible for implementation The Policy is approved by the Board of Directors and the Chief Executive Officer is responsible for implementing its principles and guidelines on respect for Human Rights within the Group. Regulations and reference standards The document refers to various international regulations and standards, including the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the Tripartite Declaration of Principles of the International Labour Organization and the OECD Guidelines for Multinational Enterprises. Method of dissemination The Policy is disseminated externally as a charter of values, so that stakeholders that have relationships with the business can know about and understand its purposes, and is made available to stakeholders through the publication and dissemination of the document within the Mediolanum Group, as well as through publication on the institutional website. [S3-1 DP 16] The Mediolanum Group’s Policy for the protection of Human Rights, approved in 2020 and last updated in 2025, outlines the commitment made Banca Mediolanum and the Group to protecting human rights according to the highest international standards, including, in particular, the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises. In this context, the Group has adopted processes and mechanisms aimed at monitoring compliance with these principles and preventing or mitigating any breaches caused by its actions. The Mediolanum Group is committed to ensuring the Policy’s effective implementation, monitoring its application on a regular basis and assessing the risk of breaches within the areas in which it operates. As part of its due diligence, the Group undertakes to evaluate in advance its counterparties’ Human Rights policies and practices before entering into any agreement, in line with the principles underlying its environmental and social policies. It also guarantees adequate resources to anticipate and mitigate risks, implementing the necessary corrective measures. [S3-1 DP 16 a] The Mediolanum Group undertakes to protect and promote human rights in the context of its economic and business activities and acts in order to prevent any violation directly caused by its actions, considering as a priority the direct or indirect impacts on people, in view of internationally recognised working standards, as well as local legislation in the countries in which the Group Companies operate. The areas of responsibility for communities are defined by the Group, which has always been committed to promoting a culture within its business environment that is compliant with current regulations, aligned with international best practices and able to ensure the satisfaction of its resources and the focus on its customers. [S3-1 DP 16 b]
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290 | Mediolanum Group - 2025 Annual Financial Report The Mediolanum Group encourages continuous and constructive dialogue with all communities concerned, with the aim of promptly identifying any critical issues and defining shared solutions. The Mediolanum Group’s Policy for the Protection of Human Rights is disseminated externally as a charter of values and rules of conduct promoted by Banca Mediolanum, so that stakeholders who have dealings with the Company can know about and understand its purposes. To this end, the Policy for the Protection of Human Rights is also published on the Banca Mediolanum website. [S3-1 DP 16 c] The Mediolanum Group takes concrete measures to prevent, mitigate and remedy any negative impacts on human rights. If violations of these rights were committed, they would be examined in accordance with internal procedures, legislation and agreements in force, with the possibility of taking disciplinary measures. The Group also undertakes to ensure that it has the necessary resources to identify and implement any corrective measures. The monitoring and gradual strengthening of human rights protection measures take place through a sustainability reporting system that includes the active engagement of stakeholders, the definition of objectives for improvement and the adoption of specific indicators to measure their effectiveness. [S3-1 DP 17] The Mediolanum Group’s Policy for the Protection of Human Rights, in line with the relevant international standards and regulations, demonstrates the Group’s commitment to respecting and promoting the rights of all Stakeholders, including the affected communities. No cases of non-compliance with international standards and regulations were identified during 2025; therefore, it was not necessary to adopt sanctions or enforce orders for violations in this area. Actions [S3-4 DP 31; 32 c; ESRS 2 MDR-A DP 68] IROs: The socio-economic development of the communities in which we operate through the support of regional associations, solidarity, sports, cultural activities, etc.; Improvement of trust on the part of the communities in which the Mediolanum Group operates through initiatives for financial education and support for culture and innovation, or initiatives for emergency situations or directed at social causes, which may indirectly generate an increase in revenues for the Mediolanum Group In continuity with previous years, in 2025 the Mediolanum Group implemented a series of actions with a specific focus on the socio-economic development of the communities in which it operates, aimed at generating positive impacts and pursuing the objectives set out in its Policies. These initiatives are designed to promote common well-being, including through support for regional associations that encourage solidarity, sports and cultural activities. The main actions taken are described below. Emergency Loans Banca Mediolanum and its Foundation, Fondazione Mediolanum EF, have confirmed their commitment, undertaken since 2009, which supports anti-usury foundations active in Italy with social projects focussed on providing financial assistance for the weakest sections of the population with problems of over-indebtedness and lack of access to banking (see ESRS S4-4, paragraph 3.4.4. Access to products and services, section ‘Actions’, DP 30, for further details).
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291 | Mediolanum Group - 2025 Annual Financial Report Conto accoglienza Through the ‘Conto Accoglienza’ (‘Welcome Account’) current account, reserved for customers with an Emergency Loan, Banca Mediolanum’s main aim is to support customers with debt and/or financial difficulties, forging relationships of trust. The account aims to increase social inclusion through a no-fee account and comprehensive banking services, to help manage daily needs, combined with a financial education programme. Collaborations with foundations and associations Banca Mediolanum has always been committed to developing a solid and sustainable business in the long term, creating added value for all Stakeholders and actively contributing to the development of the community in which it operates. This includes making donations for charitable purposes and supporting initiatives of collective interest. Collaborations with foundations and associations are a fundamental component of the Group’s social commitment, involving not only customers, but also employees, in support of projects of social importance. In confirmation of the Group’s commitment to providing practical support to local entities and contributing to the well-being of the community, the entire process of granting donations is overseen by the Charity and Donations Committee, which ensures full consistency with the principles and guidelines that the Bank is required to follow. In 2025, donations totalling €519,400 were made for social support initiatives, individuals in difficulty and Associations and Foundations. Contributions to initiatives in favour of the third sector (charitable donations) UoM 2025 Financial statement item Opex € 4,756,707.00 Explanatory note – ‘Administrative expenses: Other administrative expenses - Entertainment, gifts and donations expense’ In Spain, in 2025, Banco Mediolanum was engaged in the following collaborations: a collaboration with the ‘Una mela per la vita’ (‘An Apple for Life) foundation, for research on multiple sclerosis. In October, a solidarity action was organised promoted by the Multiple Sclerosis Foundation, the aim of which was to purchase apples for solidarity purposes. The funds raised were used to promote support, treatment, and research services related to this disease. The Bank purchased the apples, which were then made available to workers, accompanied by an explanation of their purpose and the allocation of the resources obtained; a collaboration with the ‘Enriqueta Villavecchia Paediatric Oncology’ Foundation for the delivery of charity roses for Sant Jordi Day. To mark the occasion, the Company collaborated with the foundation by purchasing the roses it promoted. The flowers were then distributed to staff, with the aim of allocating the funds raised to support and assist this foundation and its solidarity initiatives. In addition, the solidarity project of Banco Mediolanum ‘Mediolanum Aproxima’ also continued in 2025. This project was created in 2015 to support local non-profit organisations through the direct involvement of the Family Bankers and their customers. The aim is to encourage cooperation between local NGOs and people. In 2025, 141 solidarity initiatives were implemented, 141 NGOs were helped and 134 Family Bankers participated. Thanks to these initiatives, €2,060,006.00 was donated, thanks to the involvement of the Spanish delegation of Fondazione Mediolanum EF. In 2025, the ‘365 days of solidarity’ communication campaign took place at national and regional level with the media, to communicate the results of Banco Mediolanum’s social action.
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292 | Mediolanum Group - 2025 Annual Financial Report Over the years, the Irish Group Companies have developed partnerships with various associations and foundations. In 2025, a fundraising campaign supported by Mediolanum’s business partners raised €1 million for three charities, namely Coolmin Therapeutic Community (‘CTC’), Belvedere Youth Club (‘BYC’) and the Mediolanum South-West Inner City project (‘SWIC’). CTC provides rehabilitation programmes for people with alcohol and substance dependence, accompanies them through therapeutic and social reintegration pathways, and runs the only programme in Ireland for pregnant women or women with young children affected by addiction. The Irish Companies are supporting CTC’s expansion project to create a new mother and baby recovery centre in Limerick, replicating Ashleigh House’s successful 2024 model. BYC works on behalf of young people in Dublin’s north‐east area, promoting their personal development and active participation in the community. Mediolanum supports the organisation in launching an after-school programme dedicated to study support, certified courses, youth leadership programmes, and sports and music initiatives, with the aim of preventing social hardship and promoting the well-being and employability of young people. Finally, the SWIC project is a strategic initiative to promote social change in the south ‐west area of Dublin city centre, through sports, educational and wellbeing programmes. Mediolanum acts as sponsor and facilitator, supporting the charity The Liberties Community Project Company Limited by Guarantee, in collaboration with Sporting Liberties, to create an integrated programme to support the networks of Stakeholders involved in community development. Centesimi che contano (Cents that count) Banca Mediolanum offers customers participating in the initiative the option of donating the cents on their monthly current account balance, if in credit, to Fondazione Mediolanum EF. With the increase in service uptake, and the consequent increase in the amounts available, the Foundation undertakes to identify new beneficiaries among trusted associations that have demonstrated effectiveness in the implementation of the projects. This makes it possible to increase the positive impact of the service and to support more beneficiary associations. In 2025, alongside the three established associations – ‘Dynamo Camp’, ‘Centro Benedetta d’Intino’ and ‘Lega del Filo D’Oro’ –, a fourth organisation featured: Invictus Camp. The main actions of the service are implemented on an annual basis. Fundraising is done on a monthly basis, while the distribution of funds and reporting take place at the end of the calendar year. At 31 December 2025, donations totalled €1,084,023.59, an increase of 30% compared to 2024). This growth reflects the greater involvement of the Family Banker Network, supported by the actions of the Mediolanum Values Manager – which led to a 17.09% target product activation at the beginning of 2024 increasing to 20.51% at the end of the year – and the growing commitment of customers and the Bank to supporting charitable causes. This initiative is also implemented by Banco Mediolanum in Spain, where donations totalled €67,089.34 in 2025, thanks to the participation of 21,655 customers with an associated account (20,437 customers; 1,111 with Family Bankers, 107 at the central headquarters). Mediolanum with you Banca Mediolanum continued to collaborate with local associations, including through the ‘Mediolanum con Te’ project (formerly the ‘Mediolanum Insieme’ project). The objective of this project is to support non-profit entities in the region indicated by the Family Bankers, giving them visibility on the Bank’s website and promoting their initiatives, implemented at both local and regional level, through direct email marketing targeted at customers. A total of €150,000 was disbursed between 2021 and 2025, confirming the Bank’s commitment to supporting social and solidarity initiatives. In 2025, partnerships were launched with 8 new non-profit organisations working in areas such as social integration, work training, support for families in difficulty and protection of the rights of people with disabilities. Banca Mediolanum intends to continue its collaboration in 2026, with a view to consolidating the results achieved and further improving the impact of the initiatives.
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293 | Mediolanum Group - 2025 Annual Financial Report Social and cultural initiatives Banca Mediolanum’s commitment was also achieved through high-impact socio-cultural initiatives, with the aim of raising participants’ awareness of inclusive social issues. Three events to support the Community of San Patrignano were organised, with a total charitable donation of €30,000 from Banca Mediolanum. On the occasion of the Giro d’Italia, an inclusive bike ride was organised to support the Fondazione per la Ricerca sulla Fibrosi Cistica (Cystic Fibrosis Research Foundation), which was attended by a Paralympic athlete. Banca Mediolanum supported the event with a donation of €5,000. Furthermore, at the six stages of the Mediolanum Padel Cup, the Inclusive Padel initiative was held, during which Padel matches were played between players with and without disabilities. The format, designed by the Bionic People association, was supported by the Bank with a charitable donation of €10,000. Banca Mediolanum also organised a financial education tour, ‘Comprendi il denaro, Costruisci il tuo futuro’ (Understand Money, Build Your Future), which addressed key topics particularly relevant to our customers, with special attention paid to the needs of women. The initiative has enhanced the role of our FBOs as points of contact and a local presence for customers and prospects. 256,000 customers and prospects were involved in the five stages of the tour, with more than 600 attending. These events, conceived and supervised directly by the Group in collaboration with the associations involved, represent a concrete example of integration between solidarity and social development, highlighting Banca Mediolanum’s ongoing commitment to promoting social and cultural well-being, sustainability and inclusion and strengthening its role as an active and responsible partner in the communities in which it operates. Cause-related marketing Banca Mediolanum promotes Cause-Related Marketing initiatives, i.e. campaigns to raise social awareness in support of projects dedicated to children in disadvantaged conditions. The Bank contributes to these projects by waiving part of the subscription costs for specific products or by contributing a pre-established amount for products without subscription costs placed between 1 October and 31 December 2025. The amounts collected are donated to the beneficiary organisations selected by the Mediolanum Foundation. For 2025, Banca Mediolanum has selected the following products: current accounts, credit cards, sustainable investment funds and the Capitale Salute protection policy. The Mediolanum Foundation therefore contacts partners to launch the charitable project, define the beneficiaries, establish the action lines and monitor the reporting. At the end of the initiative, the funds pass through the Foundation’s account and are entirely allocated to the beneficiary entities. The entities identified for 2025 are Fondazione Città della Speranza Onlus, Albero dei Desideri ETS and Mission Bambini ETS, with the aim of supporting 1,105 sick children throughout Italy. During the year, €630,244 was disbursed, an increase of 16.43% compared to 2024. Fund-raising events The Mediolanum Group promotes fundraising initiatives to support projects aimed at minors in disadvantaged situations, in collaboration with non-profit organisations, through two types of events: Solidarity Events and Matching Events. The Solidarity Events, organised by the Family Bankers, involve raising funds for local non-profit entities with which they are in contact. The donations collected are doubled by the Mediolanum Foundation, according to specific criteria: donations above €2,000 are doubled, up to a maximum of €5,000 (the amount is defined by the Mediolanum Values Manager), while smaller donations under €2,000 are not doubled and only the amount actually collected is paid to the beneficiary. Each Region has an annual budget dedicated to these events,
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294 | Mediolanum Group - 2025 Annual Financial Report calculated based on the Region’s size relative to the total of Family Bankers 89. To start the procedure and schedule an event, the Family Banker concerned must contact the Mediolanum Values Manager of his/her Region, to see if the project meets the Foundation’s mission and check budget availability necessary to double the amount to be collected. In 2025, 113 projects were supported through this initiative, with a budget of €400,000, for which a total of €1,081,278.25 was disbursed. On the other hand, Matching Events provide direct support from the Mediolanum Foundation for projects aimed at minors in disadvantaged conditions, in collaboration with non-profit entities with which the Foundation is in direct contact, or reported by the Family Banker or Group Stakeholders. In this case as well, in accordance with the agreed budget, fundraising is doubled with a minimum of €5,000. A total budget of €1,300,000.00 was allocated for 2025, with a disbursement of €4,881,630.24 at 31 December. Mediolanum Social Impact The Mediolanum Group has adopted a structured approach to measuring and enhancing the impact generated by its social initiatives, developing a dedicated Framework for Social Impact. To ensure the correct development of data collection processes and the definition of framework KPIs, a monitoring system has been established involving the Group’s various internal contacts. Three distinct areas of action have been identified, namely: the community, including charitable donations, the Mediolanum Foundation, social initiatives carried out in Spain and Ireland, and initiatives promoted by social cooperatives; customers, including the Emergency Loan, the Special Care Loan and loans to Third-Sector Entities. employees and contract staff , including welfare programmes, initiatives carried out on Campus and non-mandatory training courses for employees and contract staff in Italy, Spain and Ireland. The most appropriate data collection method has been defined for each area, depending on the nature of the initiatives considered, where possible by leveraging existing processes to retrieve the information necessary to determine the KPIs. [S3-4 DP 32 d] In order to monitor and assess the effectiveness of actions and initiatives in favour of the affected communities, the Customer Satisfaction Survey is adopted, which explores this area by means of specific questions. In 2025, the development of the project launched in 2024 continued, aiming to create a social impact framework and to collect the results of the impact generated (see ESRS S3-4 Affected communities, paragraph 3.3.2 Economic, social and cultural rights of affected communities, section ‘Actions’, DP 31; 32 c – Mediolanum Social Impact, for further details). As far as the Group’s foreign companies are concerned, charities and foundations periodically provide information on the projects financed. Each year, a report is produced that highlights the positive impacts generated by the support received. In particular, in Spain, Banco Mediolanum requests formal reporting from the beneficiary entities on the use of the funds and they must present a certificate of the correct allocation of resources to the financed project, accompanied by documentary evidence. In Ireland, during the annual charity event, information about the supported activities and results is presented and shared. [S3-4 DP 34 b] The Mediolanum Group is also committed to improving the trust of the communities in which it operates, promoting financial education initiatives, support for culture and innovation, as well as measures for emergency situations or significant social causes. These initiatives not only strengthen ties with the local community and its citizens, but indirectly contribute to the Group’s sustainable growth, facilitating the expansion of its customer base and the increase in its market share, with a positive impact on both the social fabric and corporate performance. The main initiatives undertaken in 2025 are described below. 89 There are restrictions on the management of requests, i.e. each Family Banker can only request one event per year, and each beneficiary entity can only be supported with two events in the same year, presented by different Family Bankers.
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295 | Mediolanum Group - 2025 Annual Financial Report Financial education and cultural support The Group undertakes to pursue its commitment through projects aimed at disseminating financial subjects, aimed at both customers and potential new users. These projects are a pillar of Banca Mediolanum’s educational and relational approach, aimed at creating lasting value for people and communities. Initiatives for emergency situations or directed to social causes The Mediolanum Group carried out targeted actions to deal with emergency situations, strengthening its role as a responsible actor in promoting community well-being and sustainability for future generations. The initiatives undertaken included: natural disasters: in 2025, Banca Mediolanum was again close to the populations affected by natural disasters, undertaking actions that led to the disbursement of €51.200 for 18 households affected by flooding in Tuscany. In addition, Banca Mediolanum implemented a series of preferential measures aimed at providing concrete support to beneficiaries in difficult situations. These included the option of suspending mortgage and loan repayments for 12 months; preferential credit lines were activated; for mortgages and loans outstanding, a spread reduction (-1%) was offered for a period of 24 months; and for current accounts and term deposits, all costs were reduced to zero for a period of 24 months. global humanitarian emergencies: in order to address severe global humanitarian emergencies, the Group, through its collaboration with Fondazione Mediolanum, has undertaken concrete actions in collaboration with humanitarian organisations. In response to the emergency relief in Gaza, the Mediolanum Foundation launched a fundraising campaign in collaboration with Pro Terra Sancta to provide immediate aid, including food, blankets and clothes for displaced persons, as well as psychosocial support aimed at mitigating the consequences of the conflict. In general, the above measures were taken at the time of the occurrence of a specific emergency and demonstrate Banca Mediolanum’s ongoing commitment to supporting the affected communities and to providing concrete assistance during emergencies. Collaboration with the Fondazione Mediolanum EF Banca Mediolanum is a committed supporter of the Mediolanum Foundation in pursuing civic, solidarity and social goals. Fondazione Mediolanum, active at national and international level, decided to focus its interventions on assistance for disadvantaged children. The Foundation operates through the provision of aid for basic needs and the promotion of basic education and vocational training, contributing to the autonomy of children and to respect for the universal values of the individual. The Foundation’s work is based on a rigorous projects policy, which prioritises reliable, effective, and efficient partners to mitigate and address the hardship situations identified. The actions, which cover different areas, including assistance, research, education, rights and health, are planned and implemented with defined time horizons, monitoring the effectiveness of interventions and the achievement of objectives. Fundraising and the granting of contributions takes place within the calendar year, and are promoted through marketing campaigns and fundraising. In 2025, the Foundation funded several projects, a significant increase compared to 2024. Total contributions received and granted increased, demonstrating the effectiveness of fundraising campaigns and continued donor support. The main areas of action were as follows: fundraising: in 2025, Fondazione Mediolanum benefited from the contributions of the Mediolanum Financial Conglomerate, allowing it to finance projects for disadvantaged children totalling €3,110,057.36 (+1% compared to 2024). These contributions were allocated to both disbursement and management costs. A part of these contributions, in particular, derives from Cause Related Marketing initiatives, i.e. social positioning campaigns promoted by Banca Mediolanum, in support of projects for disadvantaged children totalling €630,244.00 (+16% compared to 2024) (see ESRS S3-4, paragraph 3.3.2 Economic, social and cultural rights of the community , section ‘Actions for affected communities’, DP 31 b; 32 c – Cause Related Marketing, for further details);
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296 | Mediolanum Group - 2025 Annual Financial Report In 2025, donations were also made by Mediolanum Comunicazione S.p.A. through specific promotional activities during significant periods of the year, such as Easter and Christmas, for a total of €26,700 (+21.36% compared to 2024). In addition, Banca Mediolanum’s customers were able to make donations through Mediolanum For You Rewarding, the programme that rewards their loyalty, allowing them to accumulate points to redeem prizes or enjoy selected experiences from a dedicated catalogue. Thanks to this initiative, the sum of €36,592.00 was donated in 2025 (+52% compared to 2024). In addition to the contribution from the Mediolanum Financial Conglomerate, funds were received by the Foundation from the Italian Revenue Agency, for ‘recognised Associations and Foundations – allocation of personal income tax donations’, totalling €243,614.31. This item includes €59,588.80 deriving from gross interest on the current account of the Mediolanum Foundation for 2025. Lastly, the fundraising activities involved a wide network of donors, including customers of Banca Mediolanum and Banco Mediolanum, Family Bankers, employees, executives, members of the Board of Directors, external private donors and businesses for a total sum of €7,597,008.49 euro). Overall, the total contributions received by the Foundation during 2025 amounted to €11,010,268.96 (+13% compared to 2024); grants: the Mediolanum Foundation operates as a grant-making body, financially supporting projects of other non-profit organisations, and has adopted a collaborative approach to achieve a common fundraising target, doubling the funds raised as a ‘bonus’ once the target is met. This model encourages donors and increases project visibility. During the year, the Fondazione Mediolanum financed 311 projects, disbursing €10,699,329.74. In addition, with regard to foreign subsidiaries, the local market is expected to be monitored in Ireland in order to identify any new charities to support. [S3-4 DP 36] No human rights violations were reported to the Group during 2025 and consequently no sanctions or measures in this area were imposed. [S3-4 DP 38] The Sustainability Office is the point of contact for the management of projects to support the community and to ensure that their implementation takes place in a manner consistent with the principles of the Banca Mediolanum Community Support Policy. In addition, where necessary, it assists other departments/offices involved in specific activities. At the Irish Subsidiaries, the Human Resources Office is involved in this area, while at the Spanish Subsidiaries, the Acción Social Office is involved. Targets [ESRS 2 MDR-T DP 72; 81 a; 81 b] The Mediolanum Group has not defined measurable and temporal objectives with respect to the areas relating to the affected communities. However, Banca Mediolanum’s objective relating to the Emergency Loan (see ESRS S4 Affected communities, paragraph 3.4.4 Access to products and services, section ‘Targets’, DP 40, for further details on the objective of the Mediolanum Group’s Emergency Loan), while formally coming under consumer- focussed targets, aims to generate a wider positive social impact. In particular, it supports the socio-economic development of communities and contributes to the fight against poverty and usury. Moreover, the effectiveness of the Banca Mediolanum Community Support Policy and the related actions are monitored by tracking the investments made in the community, according to formalised procedures for each individual support action. The Group uses a number of qualitative and quantitative indicators to assess progress, including: the value of disbursement and the number of people reached by social and cultural support initiatives; customer perception of the social commitment of the Mediolanum Group measured through the Customer Satisfaction survey;
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297 | Mediolanum Group - 2025 Annual Financial Report the number of projects financed by Fondazione Mediolanum EF and the monetary value of the contributions disbursed. Like the Parent Company, several quantitative indicators are presented and monitored at Banco Mediolanum to assess progress, including the number of projects financed as part of the ‘Mediolanum Aproxima’ project, the monetary value of donations for social and cultural support initiatives and the perception of customers of the Company’s social commitment. No objectives have been defined in Ireland; however, Companies participate in and support solidarity and cultural initiatives for local associations, in order to generate a positive social impact in the communities in which the Group operates. 3.3.3 Engaging with affected communities about impacts [S3-2 DP 21; 24] For the Mediolanum Group, the point of view of the affected communities is an important factor in the orientation of strategic choices, ensuring that the initiatives undertaken respond effectively to local needs and generate a positive and sustainable long-term impact. For this reason, opportunities for discussion and listening are periodically organised in the context of sustainability. Community engagement initiatives vary according to the Group’s needs. For example, in 2025, as part of the process of updating the materiality analysis, Banca Mediolanum launched a structured process of Stakeholder engagement, in order to include the point of view of the affected communities in the process of identifying and analysing material positive and negative impacts, whether current or potential, with the aim of guiding the Mediolanum EF Foundation’s activities and strategic decisions. Also in the context of the ‘Mediolanum Con Te’ project, the point of view of the affected communities is central to guiding the Bank’s decisions: this approach ensures that the needs and concerns of the communities are taken into account and that the actions taken are aligned with the expectations of stakeholders. As regards foreign subsidiaries, Banco Mediolanum, through the ‘Mediolanum Aproxima’ solidarity project, contributes to generating a positive and concrete impact in society and in the communities concerned. The project supports more than a hundred non-profit organisations based in Spain, helping them achieve their goals and carry out projects that improve the lives of hundreds of people. The Irish Companies, in line with the principles and ethics of the Mediolanum Group, geared to ensuring a positive and lasting social impact, engage in constant dialogue with supported charities. [S3-2 DP 21 a; 21 b; 22] The frequency of the engagement is ongoing and guaranteed to correspond to the Group’s strategic updates, to ensure continuous alignment between the Group’s activities and the needs expressed by the communities. The Group has set itself an objective of managing relations with all Stakeholders, including the interested communities, on an ongoing basis, through various engagement tools and continuous feedback mechanisms. The involvement of the affected communities is managed, depending on the circumstances and the region, either directly, through interviews and continuous feedback processes, including periodic surveys and the presence in the region of Family Bankers (e.g. as part of the process of updating the double materiality assessment and as part of the ‘Mediolanum Con Te’ project), or through the legitimate representatives of the communities themselves, who are informed and aware of their specific needs and circumstances. [S3-2 DP 21 c]
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298 | Mediolanum Group - 2025 Annual Financial Report In Italian Companies, engagement initiatives are overseen by the Administration, Finance and Control Department, sometimes with methodological support from academic institutions, research institutions and specialised organisations, in order to ensure a rigorous and structured approach to analysis, engagement and reporting. As for foreign subsidiaries, in Spain engagement initiatives are managed by Acción social, reporting to the Chief Executive Officer, and by Sostenibilidad & Proyectos de Negocio, reporting to the Management of the Organisation; in Ireland, these initiatives are supervised by the Sustainability Officer, supporting the Chief Executive Officer. [S3-2 DP 21 d] With regard to the Group’ Italian Companies, the effectiveness of community engagement is measured through the use of specific performance indicators, which allow the progress and results of the engagement process to be assessed. These indicators enable monitoring of the impact of the activities carried out and ensure that the objectives set are achieved, thus providing a solid basis for assessing and continuously improving the effectiveness of engagement. For Spanish companies, as described above, the charities and foundations they support issue a certificate of projects to which the funds received have been allocated. In addition, the Spanish delegation of the Mediolanum Foundation annually prepares a report that includes an analysis of the last three financial years of the beneficiary entities, in order to assess and verify their effectiveness and efficiency in managing he resources and aid received. Furthermore, the charities supported by the Irish Companies provide an annual report indicating the results achieved during the reporting year thanks to the support received.
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299 | Mediolanum Group - 2025 Annual Financial Report 3.4 ESRS S4 Consumers and end-users 3.4.1 Material impacts, risks and opportunities and their interaction with strategy and business model [S4.SBM-3 DP 9 a] The Mediolanum Group has always offered its customers a relationship based on freedom and human relations, placing them at the heart of its strategy and business model, through its resources, tools and services. The Mediolanum Group pursues the objective of building a solid and lasting relationship with customers through transparency in communications and the knowledge and skills developed to guide them in managing their assets. In addition, the commitment to the supply of products and services is based on the importance of ensuring a high level of satisfaction, through increasingly flexible and cutting-edge solutions that can completely fulfil all the needs of customers. The impacts related to ‘access to high-quality information’ therefore represent the maximum expression of the Mediolanum Group - the ‘Bank built around the customer’ - where the focus on protecting the main aspects of the customer’s life is fully integrated into the offering of products and services, through a holistic advisory model aimed at meeting the customer’s needs throughout the entire life cycle. The centrality of customers is also reflected in the provision of effective complaint reporting and management systems, which allow critical issues to be detected in a timely manner and the experience to be continuously improved. With regard to the impacts related to the ‘Social inclusion of customers’, the Group is committed, in the area of ‘Financial inclusion’, to the creation of dedicated products and services, the presence of Family Bankers/Financial Agents in the regions where the Group operates (both domestic and foreign), the issue of digital tools for the autonomous management of operations by the customer and the guarantee of ‘Responsible business practices’ with respect to the Group’s various internal and external Stakeholders. Lastly, the Group guarantees the confidentiality of customer data and transactions, ensuring data protection and compliance with legislation and regulations in the sale of financial products and services, including digital products and services. [S4.SBM-3 DP 9 b] The main risks identified in the double materiality assessment concern the potential negative impacts related to the confidentiality and potential theft of customer data, such as the IT risk of the breach of systems available to the customer, with risks related to the theft of customer data, and the impacts related to accessing products and services, such as the risks of distribution of banking, investment and insurance products/services that are not in line with the Group’s sustainability policy and/or with sustainability regulations. The main opportunities identified in the process of the double materiality assessment are linked to the positive impact generated in terms of financial inclusion, such as the increase in the Mediolanum Group’s market positioning towards non-profit/ social economy operator targets, and are linked to the positive impact arising from the centrality of the ‘person’ and from support in achieving the customer’s well-being objectives, such as gaining a greater market share thanks to initiatives that improve the level of personalisation of investment plans and customer protection. [S4.SBM-3 DP 10] All consumers and end-consumers that may be subject to material impacts on the part of the undertaking, including impacts directly related to own operations and the undertaking’s Value Chain, are included in the scope of the reporting and have effectively been included in the double materiality assessment. [S4.SBM-3 DP 10 a] The main consumers and/or end-users subject to material impacts are the Group’s customers in Italy, which is the Group’s main market, and in other European countries such as Spain. The Group’s products and services are separated into banking, credit and protection products and services as well as investment products and services. [S4.SBM-3 DP 10 ai-iv]
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300 | Mediolanum Group - 2025 Annual Financial Report The Group does not include products that are inherently harmful to people and/or increase the risk of chronic diseases. In addition, it undertakes to protect consumers and/or end-users of its products and/or services by preventing any negative impacts on their rights to privacy, personal data protection, freedom of expression and the principle of non-discrimination. Lastly, it ensures that information on products and services, including the financial services distributed, is accurate and easily accessible by means of specific dedicated disclosures. [S4.SBM-3 DP 10 b] The material negative impacts, which emerged in the context of the double materiality process, are connected to individual potential incidents such as Confidentiality (e.g., a violation of customers’ right to privacy due to a loss of confidential data and information) and responsible business practices (e.g., Purchasing decisions by consumers not aligned with their real needs, influenced by unfair, misleading or aggressive business practices, including greenwashing and social washing, relating to the products offered). [S4.SBM-3 DP 10 c] The material positive impacts, which emerged in the context of the double materiality process, across the Group’s entire clientele, being generalised and not limited to specific types of consumers and countries/regions (e.g., the protection of freedom of expression through the establishment of effective reporting/complaints systems, customer satisfaction through effective methods of engagement and listening to feedback, and contribution to customer financial education). On the other hand, the specific impact of facilitating access to credit relates in particular to certain target groups of customers (e.g., young people, vulnerable groups, etc.), and is more closely linked to the Group’s banking and credit products and services. [S4.SBM-3 DP 10 d] The risks associated with the impacts on consumers and/or end-users identified as material are the risks of aa distribution of banking, investment and insurance products/services that are not in line with the Group’s Sustainability Policy and/or with regulations on sustainability and risks associated with ‘confidentiality’, such as a breach of the systems available to the customer and theft of customer data. With regard to opportunities, the outcome of the double materiality process identified as material opportunities connected to the increase in the Mediolanum Group’s market positioning towards non-profit/social economy operator targets and the achievement of a greater market share thanks to initiatives that improve the level of personalisation of investment plans and customer protection. [S4.SBM-3 DP 11] The double materiality assessment identified two material negative impacts (breach of customers’ right to privacy due to a loss of confidential data and information); Purchasing decisions by consumers not aligned with their real needs, influenced by unfair, misleading or aggressive business practices, including greenwashing and social washing, relating to the products offered) which may expose consumers and end-users to greater risks. [S4.SBM-3 DP 12] As regards opportunities, the increase in the Mediolanum Group’s market positioning towards non-profit/social economy operator targets is connected to specific groups of customers such as third-sector entities, households in difficulty, dependent persons (Law 104/92) and female victims of violence.
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301 | Mediolanum Group - 2025 Annual Financial Report 3.4.2 Confidentiality [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Confidentiality Breach of customers’ right to privacy due to loss of data and confidential information Actual negative impact Downstream Value Chain (Banking, Protection, Asset/Investment Management) Short term IT risk of violation of the systems available to the customer, with risks related to the theft of customer data Risk Own operations Short/medium term The Group’s approach and policies The Mediolanum Group puts the protection of personal data at the centre of its commitment, highlighting an approach focused on protecting personal information and strengthening data security measures. The Group also undertakes targeted initiatives, on an ongoing basis, to ensure cybersecurity and the protection of personal data by investing in strategic plans and objectives aimed at strengthening its digital security infrastructure. To this end, numerous reference documents and policies for cybersecurity have been developed, as well as for the management of cybersecurity and data breach incidents. [S4-1 DP 15; ESRS 2 MDR-P DP 65] IROs: Violation of customers’ right to privacy due to loss of data and confidential information; IT risk of breach of the systems available to the customer, with risks related to theft of customer data Policy on IT Security of the Mediolanum Group Content and objectives The Mediolanum Group’s IT Security Policy, the latest update of which was approved in early 2025, defines the reference model for overseeing the IT security aspects of the Group. In particular, it aims to outline: the general principles and high-level rules of IT security on the use and management of the information system; the IT security macro-processes necessary to prevent, contain and react to threats to persons and corporate assets, in order to comply with national and international regulations; the objectives of the IT security management process expressed in terms of cyber risk protection and control requirements; guidelines for communication, training and awareness-raising activities for users; the roles and responsibilities of corporate bodies, governance structures and organisational units in the context of processes and activities related to IT security; the procedures for directing and coordinating the Companies of the Mediolanum Conglomerate in this context; a reference to internal rules regulating the consequences of any violation of the Policy by staff; a reference to the laws and other applicable external regulations on IT security and ICT resources;
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302 | Mediolanum Group - 2025 Annual Financial Report a reference to the general principles and guidelines for the security of the development of the application software; a reference to corporate regulations in terms of minimum security safeguards for third parties, outsourcing and the development and management of EUDA (end user developed applications) software. Scope of application The IT Security Policy of the Mediolanum Group applies directly within Banca Mediolanum, subject to the approval of the Board of Directors and, in the exercising of the management and coordination function that is the responsibility of the Parent Company, is sent to the Companies in the Mediolanum Financial Conglomerate, so that they can apply the principles and rules set out therein, on the basis of a principle of proportionality. Highest level of management responsible for implementation The Policy is reviewed and updated by the IT Security Governance Office, which forms part of the IT & Security Governance Section of the ICT Division and is approved by the Board of Directors of Banca Mediolanum. The Bank’s Chief Executive Officer, in its capacity as the body with management functions, approves the training and awareness plans on information security defined by the ICT Division in collaboration with the Human Resources Department. Regulations and reference standards The Policy refers to national and EU laws and regulations applicable in the area of IT security and draws on the recognised international standard NIST SP 800-53 – Security and Privacy Controls for Information Systems and Organizations. Method of dissemination The Policy is made available through publication on the company intranet to all employees of Banca Mediolanum and is communicated to the entities in the Conglomerate so that they can view and adapt it. No communication is made to customers due to the confidentiality of the information contained in the document. Policy on ICT Change Management of the Mediolanum Group Content and objectives The ICT Incident Management Policy of the Mediolanum Group, the latest update of which was approved in early 2025, formalises the principles defined by the Banca Mediolanum ICT Division for the ‘IT incident management’ process and describes the principles relating to the effective management of incidents on the ICT systems and applications under management with the aim of: preparing a rapid and efficient response to the occurrence of an incident at all stages (i.e. identification and classification, initial support and first-level diagnosis, analysis and diagnosis, resolution and restoration; validation of first-level oversight and closure of the incident) in accordance with the escalation procedures provided for in the Bank’s business continuity plan; ensuring the integrity, availability, confidentiality and authenticity of the services. Scope of application The Policy applies to Banca Mediolanum and the Group Companies; in exercising the management and coordination function that is the responsibility of the Parent Company, the Policy is also sent to the other Companies in the Mediolanum Financial Conglomerate, so that they apply the principles expressed therein on the basis of a principle of proportionality, insofar as they have been transposed in accordance with the relevant internal laws and any specific sectoral and/or local regulations. Highest level of management responsible for implementation The updating and review of the document is the responsibility of the IT User Support & Service Management Unit within the ICT Division of Banca Mediolanum; the document is approved by the Bank’s Board of Directors.
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303 | Mediolanum Group - 2025 Annual Financial Report Furthermore, the Chief Executive Officer has responsibility for the implementation of the guidelines decided in exercising his strategic oversight function. In particular, with regard to the Policy in question, he monitors the proper performance of the management and control processes of the ICT services and, in response to anomalies detected, takes appropriate corrective actions. Regulations and reference standards The Policy refers to the national and EU laws and regulations applicable to the management of ICT incidents and is based on the international standard ISO/IEC 27035 Information Technology, Security Techniques and Information Security Incidents. Method of dissemination The Policy is made available through publication on the company intranet to the employees of Banca Mediolanum and is communicated to the entities in the Group so that they can view it and transpose its content. No communication is made to customers due to the confidentiality of the information contained in the document. Privacy Policy Content and objectives The Privacy Policy provides a description of privacy principles. The Bank, through this Policy, provides the guidelines and identifies the requirements to be met in order to ensure that the processing of personal data is carried out in compliance with fundamental rights and freedoms, as well as the dignity of the person concerned, with particular reference to confidentiality, personal identity and the right to their protection. The principles in the Policy are implemented in process regulations, which set out the operating and control tasks and activities. Scope of application These principles are adopted by Banca Mediolanum, as a company of the Mediolanum Banking Group and the Parent Company of the Financial Conglomerate. Moreover, the Privacy Policy is sent for adoption, in accordance with a principle of proportionality and taking into account local regulations and specificities, to the Companies in the Conglomerate. The foreign Companies apply the Policy, unless local regulations have different and stricter requirements. Highest level of management responsible for implementation The Policy is approved by the Board of Directors of Banca Mediolanum and is updated by the Privacy Office, which operates within the Corporate, Legal Affairs and Litigation Department. In addition, the Data Controller, which coincides with the Board of Directors, is responsible for ensuring compliance with the legislation in question. Regulations and reference standards The Privacy Policy comes under the legal framework outlined in Regulation (EU) 2016/679 (the ‘GDPR’), applicable national legislation and orders issued by the Italian Data Protection Authority. Method of dissemination This document is published on the company intranet whenever it is updated, for all employees and contract staff of Banca Mediolanum, and is communicated to the Companies in the Group so that they can view it and transpose its content. Regulation on the process of managing and reporting personal data breaches Content and objectives The Regulation describes the operational criteria, the organisational architecture, the actions assigned to the relevant organisational units and the execution times to be met in the event of a personal data breach,
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304 | Mediolanum Group - 2025 Annual Financial Report according to the provisions of current legislation on the subject (Regulation (EU) 2016/679 on the protection of personal data) and consistent with the DORA (‘Digital Operational Resilience Act’). The purpose of this document is to ensure compliance with the obligations relating to the management of personal data in the event of security breaches in their processing involving, accidentally or unlawfully, the destruction, loss, modification, unauthorised disclosure or access to personal data transmitted, stored or otherwise processed. Scope of application The Regulation describes the various stages of the process of managing and reporting personal data breaches carried out by Banca Mediolanum S.p.A., including for the companies of the Mediolanum Group with which contracts are in place for the provision of corporate services (Mediolanum Gestione Fondi, Mediolanum Fiduciaria, Mediolanum Vita, Mediolanum Assicurazioni, Mediolanum Comunicazione and Prexta). Highest level of management responsible for implementation The document is updated by the Privacy Office, which operates within the Corporate, Legal Affairs and Litigation Department. Regulations and reference standards The Regulation is part of the legal framework outlined by Regulation (EU) 2016/679 (‘GDPR’) and Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience in the financial sector (DORA), as well as in compliance with national legislation in force. Method of dissemination The document is published, whenever updated, on the company intranet for all Banca Mediolanum employees and contract staff. Data Retention Policy Content and objectives The purpose of this document is to describe the storage times for the various types of personal data of which Banca Mediolanum S.p.A. is the Controller. These data are processed in accordance with the provisions of applicable legislation on the protection of personal data (Regulation (EU) 2016/679, the ‘GDPR’). The document applies to personal data processed by the Company and provides the necessary information for the deletion of such data according to the indicated retention period and to all third parties involved in the storage and deletion of personal data owned by the Company. Retention times are defined for the Company and apply to all organisational units of the Company in the scope of intervention. Scope of application The Data Retention Policy applies directly in Banca Mediolanum and is sent for adoption, in accordance with the principle of proportionality and taking into account applicable regulations and specific local situations, to the other Companies in the Conglomerate. Highest level of management responsible for implementation The Policy is approved by the Board of Directors of Banca Mediolanum and is maintained and updated by the Corporate, Legal Affairs and Litigation Department. Regulations and reference standards The document is classified under the Policies in the reference framework of internal regulations and comes under the legal framework outlined by Regulation (EU) 2016/679 (‘GDPR’) and by current national legislation.
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305 | Mediolanum Group - 2025 Annual Financial Report Policy on Vulnerability Management of the Mediolanum Group Content and objectives The Vulnerability Management Policy of the Mediolanum Group, the latest update of which was approved in early 2025, defines the reference model for managing vulnerabilities in order to govern the management principles in a comprehensive and organised way. In particular, it aims to: detect vulnerabilities that could be exploited by third-parties to impact the provision of services or the data they process; identify, plan, test and implement actions to resolve or mitigate vulnerabilities; have regular scans carried out by the Bank and all Subsidiaries (with a frequency and scope based on the classification and risk profile of the ICT assets being scanned) and updates to identify and manage any new vulnerabilities; regulate the detection of vulnerabilities in IT systems, which could be exploited by attackers; determine the severity of the vulnerabilities identified to establish priorities for intervention; identify the roles and responsibilities of corporate bodies, governance structures and organisational units in the context of processes and activities related to vulnerabilities; request the application of corrective measures to mitigate or eliminate vulnerabilities (e.g. updates, patches, reconfigurations, etc.); request the maintenance of a register of vulnerabilities and actions taken to resolve them, useful for compliance and for improving future security strategies. Scope of application The Vulnerability Policy of the Mediolanum Group applies directly within Banca Mediolanum, subject to the approval of the Board of Directors and, in the exercising of the management and coordination function that is the responsibility of the Parent Company, is sent to the Companies in the Mediolanum Financial Conglomerate, so that they can apply the principles and rules set out therein, on the basis of a principle of proportionality. Highest level of management responsible for implementation The Policy is reviewed and updated by the IT Security Governance Office, which forms part of the IT & Security Governance Section of the ICT Division and is approved by the Board of Directors of Banca Mediolanum. Regulations and reference standards The Policy refers to applicable national and EU legislation and regulations in the area of vulnerability, and is updated based on the application of the DORA and the related ‘Regulatory Technical Standards (RTS)’. Method of dissemination The Policy is made available through publication on the company intranet to all employees of Banca Mediolanum and is communicated to the entities in the Conglomerate so that they can view and adapt it. No communication is made to customers due to the confidentiality of the information contained in the document.
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306 | Mediolanum Group - 2025 Annual Financial Report Actions IROs: Violation of customers’ right to privacy due to loss of data and confidential information; IT risk of breach of the systems available to the customer, with risks related to theft of customer data [S4-4 DP 30; 31 a; ESRS 2 MDR-A DP 68] In 2025, the Mediolanum Group confirmed the specific guidelines for the oversight and protection of personal data to enable activities to be carried out in smart mode with respect to personal data protection, the correct use of company email and the use of company devices only through secure connections. The Privacy Office is responsible for overseeing privacy compliance, and in particular advises the corporate structures, also in the following activities: prepares, at Group level, the Data Processing Agreement (DPA) as a contractual addendum used as an annex to supply agreements that provide for the processing of personal data and consequently the qualification of the supplier of the data processor; handles regulatory alerts and activates the necessary processes for adaptation to the corporate functions; manages reports of personal data breaches; sends notifications to the Italian Data Protection Authority; draws up and updates privacy notices and consents; drafts and updates letters of authorisation for processing; handles the management of requests from data subjects concerning their own data; handles the management of requests relating to the Code of Conduct of ‘private’ central risks; oversees the privacy training provided to employees and contract staff of the Sales Network; handles the management of customer complaints relating to privacy; prepares the letters of appointment of system administrators and updates the list of system administrators; keeps the data processing log up to date; carries out the preliminary risk assessment and the data protection impact assessment (DPIA). Banco Mediolanum also carries out periodic reporting activity in Spain, keeping a register of reports on breaches and the supervision of corresponding mitigation measures. During 2025, monthly training briefs were held for Banco personnel and Family Bankers, with the aim of reinforcing key topics of interest. Inspiration was drawn both from cases that provided an opportunity to give staff more information and from regulatory updates on data protection. In addition, two in-person training sessions of about two hours were held for banking centre staff. Staff training is carried out every 2 years and will be repeated in 2026, (as was the case in 2024). However, when new staff are hired - both new Banco Mediolanum personnel and new Family Bankers receive mandatory training on data protection included in the onboarding process. Finally, with particular reference to Family Bankers, an update session was organised to consolidate the fundamental principles of data protection, explain the legal requirements and offer operational instructions for the correct processing of personal data when performing assigned functions. During 2025, the Mediolanum Group carried out various initiatives to strengthen the governance of IT risks related to breaches of customer-facing systems and potential thefts of customer data. For Banca Mediolanum, the following activities took place in Italy in 2025: Training sessions were held for employees and the sales network;
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307 | Mediolanum Group - 2025 Annual Financial Report the information/training section dedicated to IT security for customers on the Banca Mediolanum website was further developed; MFA (multi-factor authentication) was introduced for the Sales Network to access customer data; the use of Cleafy (a platform aimed at combating IT fraud) to safeguard customers’ operations was introduced; a first-level assessment was carried out with the aim of mapping and analysing the adequacy, completeness and maturity of the current processes, controls and safeguards relating to ‘Access Management’, with reference to both international industry standards (e.g. ISO 27001) and applicable privacy legislation. In Spain, Banco Mediolanum adopted the Parent Company’s approach to cybersecurity. Mandatory annual training is guaranteed for all staff and Family Bankers, alongside regular information briefings. Additionally, 100% of employees are trained in cybersecurity. In 2025, the first phishing simulation for employees was also carried out. The system implemented within the company operates in accordance with the requirements set out in the Security Policy, avoiding the risk of potential incidents. For Banca Mediolanum, the oversight of ICT and security risks is a strategic and essential element for the protection of customer, the Bank and the services provided in matters of confidentiality. A governance and oversight model for ICT and security risks has been implemented to guide strategy and protective measures, and to continuously strengthen the monitoring of ICT security controls and the risks arising from cybercrime, which is growing rapidly. These issues can compromise the customer experience, causing inconveniences, delays and possible loss of earnings. A lack of access to digital services can also generate frustration, damage customer confidence, and lead to complaints. At an operational level, a breach of confidentiality may also expose the organisation to sanctions by the Supervisory Authority. In addition, recurring data breach events can damage the Company’s reputation and have a lasting impact on customer relations and public perception, with possible long-term and significant financial consequences. In particular, the Risk Management Function monitors and controls ICT and Security Risks and ensures that these are identified, measured, assessed, managed, monitored, reported and maintained within the limits of the financial institution’s risk appetite. ICT and security risk management consists of the following main stages: ICT and security risk governance, the objective of which is to define and maintain an updated ICT and security risk management model, methodology, process and operating procedures, in relation to changes in the context, organisation and ICT strategies of the Company, changes in legislation and the evolution of technological risks on the financial market; ICT and security risk assessment, which aims to assess the level of risk to which IT resources are exposed, with varying frequency according to their criticality, and to implement appropriate measures to limit and manage ICT and security risk, where necessary; Monitoring and Reporting, the purpose of which is to continuously monitor the exposure to the risk of IT resources and to share reports on the outcome of the ICT and security risk assessment process with the Board of Directors and with the Responsible Users in accordance with applicable regulatory provisions. In the context of the Risk Appetite Framework, ICT and security risks are monitored through specific strategic ICT and security risk indicators. The Company’s ICT and security risk objective is set so as to ensure it has sufficient margins to operate under any conditions, including stress, within the maximum ICT risk that may be assumed. [S4-4 DP 33 a]
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308 | Mediolanum Group - 2025 Annual Financial Report During 2025, the ICT Department of Banca Mediolanum maintained a strong focus on ICT risk management and cybersecurity through the implementation of the following strategies: compliance with the programme in relation to the management of infrastructure obsolescence, which allowed the level of obsolescence to be reduced, in line with the RAF indicator; development of the vulnerability management process, by reviewing the prioritisation model using a risk- based approach, and starting activities to actively monitor sophisticated attack scenarios and conduct in-depth assessments in order to identify any mismatches or vulnerabilities in the Identity context (ref. Identity Protection & Prevention); enhanced data resilience through the completion of planned initiatives, including storage renewal, to ensure full replication of production data at the Disaster Recovery site and data protection through a segregated vault, ensuring immutability even in the event of ransomware attacks, and copying the backup to the Disaster Recovery site. In addition, the updating of the CRM-A technology stack is being completed; completing the extension of playbooks responding to security incidents, including cyber scenarios provided for by Business Continuity; starting up and managing the monitoring of mitigation actions which emerged following Level I assessment carried out between December 2024 and January 2025, to map and analyse the adequacy, completeness and maturity of current processes, controls and safeguards relating to ‘Access Management’, taking as a reference both international industry standards (e.g. ISO 27001) and applicable privacy legislation. In addition, during 2025, the Risk Management Function carried out the annual ICT and Security risk assessment campaign on Banca Mediolanum’s current ICT Assets, with an impact assessment against potential breaches of Confidentiality, Integrity, Availability and Authenticity, and an assessment of the effectiveness of the existing level of security safeguards. Banco Mediolanum, adopting the Parent Company’s approach, carries out a comprehensive risk analysis, in which various scenarios are assessed in order to identify potential threats that may affect both the organisation and customers. This process considers the impact and probability of each risk and makes it possible to define the necessary mitigation measures. [S4-4 DP 31 d] At Banca Mediolanum, the Privacy Controls Unit operates in the Corporate, Legal Affairs and Litigation Department, tasked with verifying the adequacy of and compliance with privacy legislation of business operations, as well as the correct functioning of personal data processing processes, in order to prevent, mitigate or remediate any risk of breaches of privacy rights. In this context, the Privacy Controls Unit carries out periodic checks based on the annual control plan agreed with the DPO (‘Data Protection Officer’), and the Board of Directors receives an annual report on the outcomes. In the Spanish companies, the reporting control system makes it possible to have 3 severity levels and to assess the main risk involved in incidents, carrying out an overall assessment and determining the necessary corrections. In 2025, the ‘Privacy Control Unit’ area was set up, with the aim of carrying out controls based on a sample of the various data processing carried out by Banco Mediolanum, Mediolanum Gestión and Mediolanum Pensiones. With regard to IT security, the processes governed by the ICT Department are the subject of internal audits planned by the Internal Audit Function, compliance audits planned by the Compliance Function and IT and security risk analysis activities carried out by the Risk Management Function. The scope of the audits carried out by the corporate Control Functions also includes measures regarding IT security processes.
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309 | Mediolanum Group - 2025 Annual Financial Report In Spain, to ensure the monitoring and effectiveness of the actions implemented, Banco Mediolanum has a structured internal audit system managed by its Internal Audit Department. An annual plan defines the processes to be reviewed and establishes specific controls, including those related to IT developments and cybersecurity. In addition, Banco Mediolanum is subject to external audits which include, among other things, the audit of the annual financial statements and accounts and the audit required to maintain ISO 27001 certification. [S4-4 DP 32 a] If an event occurs that involves, including accidentally or unlawfully, the destruction, the loss, modification, unauthorised disclosure of, or access to, the personal data processed, a process of management and reporting the event is initiated. This process is described in the specific Regulation on the process of managing and reporting personal data breaches, which is also applicable to the activities carried out by Banca Mediolanum for the Companies of the Financial Conglomerate, under specific service supply agreements. In Spain, like the Parent Company, a Procedure for notifying security breaches to the Spanish Data Protection Authority (AEPD) and to data subjects is published on the intranet. In addition, a report management process has been set up in which recorded reports are reviewed daily and, during monitoring, mitigation measures are proposed to remedy the incident and prevent their recurrence. [S4-4 DP 32 b] In the event of a data breach, without undue delay and, where possible, within 72 hours of becoming aware, the Group’s Italian and Spanish Companies, as controllers, are required to notify the Data Protection Authority of the breach. In addition, if the breach poses a high risk to the rights of persons, the controllers are required to notify all data subjects. [S4-4 DP 32 c] At the Group’s Italian Companies, the status of implementation/completion of the resolution and mitigation actions taken in the event of a data breach are periodically monitored and controlled by the DPO, who, potentially with the support of the Privacy Controls Unit, ascertains that the defined actions are managed according to the methods and timescales indicated, according to the Regulation on the process to manage and report personal data breaches. [S4-4 DP 31 b, 31 c, 34] The Mediolanum Group is responsible for maintaining, auditing and updating security measures, integrating the principles of data protection by design and by default. These actions are essential to prevent breaches and ensure the protection of personal data in compliance with the fundamental principles of the GDPR. In accordance with these principles, the Mediolanum Group must necessarily take into account in making decisions, including those of a commercial nature, any repercussions on the data subjects of any breach of privacy. In order to ensure a high level of competence in managing operational risks arising from the processing of personal data, privacy training is provided to employees and the Sales Network, organised by the Human Resources Training Office. In addition, more than 60 hours of training were dedicated to each member of the Privacy Office, in particular to the interpretative study of the legislation on the processing of personal data and the examination of the orders of the Data Protection Authority applicable to the practical cases under discussion. In Spain, security incidents that breach the security of personal information must be notified to the data protection authority Agencia Española de Protección de Datos within 72 hours of becoming aware of the incident. Incidents classed as personal data breaches were reported to the authority. In addition, there is an incident log, which is checked daily for the affected area.
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310 | Mediolanum Group - 2025 Annual Financial Report Banco Mediolanum also provides customers, in a clear and easily accessible manner, with information on the processing and management of their personal data. It should be noted that in contracts for opening accounts and subscribing to products, an initial privacy notice is attached, containing a link to the full privacy notice published on the Banco website. Emails and SMS are sent to customers to raise awareness of fraud and scams. Ad hoc communications are also included on the site and in the applications. [S4-4 DP 37] The resources assigned to monitor privacy compliance are as follows: the Privacy Office carries out and coordinates the obligations laid down by privacy legislation and provides advice to all company departments; the Data Protection Officer (DPO), introduced by Regulation (EU) 2016/679, in addition to overseeing the reference regulatory framework, is responsible for specialist advice, regulatory alerts and gap analysis, checks of the adequacy and functioning of corporate structures and processes in relation to the current regulatory framework and identification of any actions to mitigate compliance risk; The Privacy Control Unit, through second level controls, analyses the internal operating and control procedures put in place in the personal data processing processes and supports the DPO, at his/her request, in the context of the relevant oversight and monitoring activities. In accordance with the Group’s Regulations on Coordination and Guidance, with regard to the foreign Subsidiaries, the latter refer to the above-mentioned Offices of the Parent Company. In the area of IT security, the ICT Department includes the IT Security Sector, which, among other responsibilities, is tasked with responding to cyber threats that put the Bank at risk, assessing the security posture of suppliers, combating phishing campaigns, monitoring the presence of the Bank’s data on the dark web, managing infrastructure access, constantly improving processes and technologies used, and actively collaborating with various Banca Mediolanum offices, forwarding compromise indicators such as compromised cards, accounts, illicit social profiles and fraudulent IBANs. Furthermore, the Head of the ICT Division also acts as Chief Information Officer (‘CIO’) at Conglomerate level, and the Head of the IT & Security Governance Sector also acts as Chief Information Security Officer (‘CISO’) at Conglomerate level. In addition, the Board of Directors of Banca Mediolanum includes Members with IT expertise. This expertise comes from both the professional and educational background of the Board members and from the training activities proposed by the Board, which continue with induction activities, with particular reference to ICT and digital transformation issues. In particular, two Directors have specific IT skills, as a result of personal training and work experience. The expertise acquired covers topics related to the field of technological innovation. Specifically: one director is an expert in digital transformation, specialising in the use of cutting-edge technologies, including blockchain and generative artificial intelligence, as well as the integration of advanced digital solutions. The position also has proven experience in technological and process innovation; the other director has consolidated managerial skills in the field of technological innovation, proven by taking on positions of great responsibility within large companies. In Spain, on the other hand, the Operational Cybersecurity Office, in synergy with the SOC (‘Security Operations Center’), carries out similar activities envisaged by the Parent Company’s offices, monitoring Banco Mediolanum’s resources for any security breaches. [S4-4 DP 35] In 2025, there was no evidence of serious Human Rights problems or incidents.
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311 | Mediolanum Group - 2025 Annual Financial Report Targets [S4-5 DP 40; ESRS 2 MDR-T DP 80] IROs: IT risk of violation of the systems available to the customer, with risks related to the theft of customer data Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 End of Life/ End of Support ≤ 16% of EOL/EOS assets compared to total installed assets 2030 Italy 2024 18.40% 13.35% ≤ 5% EOL/EOS assets compared to total installed assets Spain 2024 0.10% 0.08% The indicator, within the area of the obsolescence risk of ICT assets, is designed to monitor infrastructure assets at end of life (EOL) or end of support (EOS), i.e. obsolete assets on which there is no extension of support. This indicator is calculated as the ratio of the number of EOL/EOS assets to the number of infrastructure assets installed. Since this is a RAF indicator with a Forward Looking logic, with a target to be achieved annually, in addition to the nature of the target, it may be reviewed annually as regards target threshold percentages. Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Management of security vulnerabilities ≤ 20% Critical vulnerabilities overdue vs. critical vulnerabilities detected 2030 Italy 2024 0.00% 0.00% Spain 2024 0.00% 0.00% The indicator measures on a monthly basis the percentage of vulnerabilities classified as critical and not resolved within the timescales established in the Policy on Vulnerability Management of the Parent Company. Also in this case, as this is an RAF indicator measured on a monthly basis, and considering the very nature of the objective, the threshold percentages may be reviewed annually. [S4-5 DP 41 a; 41 b; 41 c] As part of the Stakeholder engagement process (see ESRS 2 General disclosures, paragraph 1.1.3 Strategy, section ‘Interests and views of stakeholders’ for further details), customers were involved through one-to-one interviews, both to assess the topics covered by the double materiality analysis and to collect feedback and comments on the perception of adequacy and effectiveness of the measures adopted by the Group in managing the topic and, more generally, its commitment in the area of sustainability. Through direct discussions, the Group was able to gain a deeper understanding of customers’ viewpoints, better understand their expectations of the Group and identify possible areas for improvement. However, consumers and/or end-users were not directly involved in goal setting or monitoring performance against targets.
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312 | Mediolanum Group - 2025 Annual Financial Report 3.4.3 Access to (quality) information [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Access to (quality) information Customer satisfaction through effective engagement and listening to feedback Actual positive impact Downstream Value Chain (Banking, Protection, Asset Management/Investment) Long term Assurance of the quality and usability of the offering thanks to accessibility of information Actual positive impact Downstream Value Chain (Banking, Protection, Asset Management/Investment) Medium term The Group’s approach and policies The Mediolanum Group considers it a priority to ensure that its customers have simple and transparent access to high-quality information, recognising that this aspect represents a turning point for consolidating trust and improving the customer experience. The multi-channel approach, which integrates the physical support of Family Bankers with advanced digital tools such as mobile applications and the web portal, ensures the fast and intuitive use of all banking services provided, allowing users to access information in real time and with maximum clarity. Digital accessibility, in line with applicable regulations, commits the Bank to making digital channels a universal tool for accessing banking products and services. In this context, the Bank makes available to customers ‘Information on services that meet accessibility requirements’, which describes the level of accessibility of digital channels, in line with Legislative Decree 82/2022. In accordance with its Code of Ethics and Sustainability Policy, which set out its approach and general guidelines, the Mediolanum Group has developed Policies over the years for guaranteeing a correct management of impacts related to ‘access to high-quality information’, including the Code of Conduct and Policy on Customer Protection. [S4-1 DP 15; ESRS 2 MDR-P DP 65] IROs: Customer satisfaction through effective methods of engagement and listening to feedback; Guarantee of the quality and usability of the offering through accessible information Code of Conduct One of the areas governed by the Code of Ethics (see ESRS G1 Business conduct, paragraph 4.1.1. Business culture, section ‘The Group’s approach and policies’ for further details on the minimum reporting requirements of the Policies) is customer protection. In particular, the Code of Conduct specifies that, in relations with customers, the recipients of the Code shall base their conduct on the principles of transparency, loyalty, diligence and fairness, avoiding any conduct that may give rise to an abuse of the good faith or inexperience of the customer. The Mediolanum Group therefore considers it essential for relations with customers to be based on: full transparency and fairness, in order to enable the customer to understand the characteristics and value of all the products and services offered; offering products and services in line with the customer’s needs, expectations and interests; maintaining the high quality standards of its services and maximising customer satisfaction; avoiding the risk of falling into unfair commercial practices, i.e. aggressive or misleading sales practices, by providing information that does not correspond to the truth or may deceive current or potential customers about the characteristics of the products and services;
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313 | Mediolanum Group - 2025 Annual Financial Report promptly responding to and resolving complaints and grievances received, as they represent an opportunity for improvement in terms of customer satisfaction; independence from any form of condition, whether internal or external. The Spanish Companies of the Group and MIFL have transposed the Group Code with certain specific national aspects, adopting a Code in line with the Group Code. Policy on Customer Protection of the Mediolanum Group Content and objectives The objective of the Customer Protection Policy is to provide all Group structures with a clear description of the principles to follow to operate while complying fully with applicable regulations on customer protection and, more generally, with principles of transparency, diligence and fairness, that must steer the activities of financial intermediaries, the principles of accessibility, inclusion and personal and financial data protection, as well as the Mission and values of the Mediolanum Group. Compliance with these rules and principles in customer relations mitigates legal and reputational risks and enhances overall confidence in the system. The purpose of the document is therefore to help ensure that customers can make informed choices, in order to promote the establishment of correct and transparent relationships with Group Companies. During the year, the Banca Mediolanum Policy was also updated to introduce further customer protection measures, with specific provisions for the management of requests to have unauthorised payment transactions derecognised and for the treatment of unduly charged fees. Scope of application The Policy is directly applicable within all Companies belonging to the Mediolanum Group and its principles apply to all Group employees and contract staff. Spanish Companies also have their own document, ‘Customer Protection Guidelines’, aligned with the Group Policy. Highest level of management responsible for implementation The Policy is approved by the Board of Directors of the Parent Company Banca Mediolanum. The Parent Company Compliance Department is responsible for preparing and updating the Policy. Furthermore, the Chief Executive Officer is responsible for implementing the principles and guidelines governed by the Policy in question. Regulations and reference standards The Group continuously bases its strategic and operational decisions on the principle of full compliance with regulations. This principle underlies the way in which governance and leadership structures and management, commercial and control processes have been defined. In general and, therefore, regardless of the specific type of product and/or service in question, the information provided during any form of dialogue with customers must be expressed in a clear, understandable and accessible manner, taking due account of the level of financial literacy of the customers to whom they are addressed and, in general, the accessibility and transparency requirements stipulated by current legislation. Stakeholder involvement The interests of Stakeholders are taken into account through a process of indirect customer engagement, as well as through the implementation of safeguards and controls to intercept incorrect conduct and ensure that the information provided is clear, understandable and accessible.
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314 | Mediolanum Group - 2025 Annual Financial Report Actions [S4-4 DP 30; 31 c; ESRS 2 MDR-A DP 68] IROs: Customer satisfaction through effective engagement and listening to feedback In December 2025 and January 2026, in collaboration with the BVA-Doxa research institute, Banca Mediolanum carried out a market survey in Italy involving 1,782 ‘Prima Banca’ customers of Banca Mediolanum, in CAWI (Computer-Assisted Web Interviews with a structured questionnaire lasting approximately 20 minutes). At the same time, a similar sample was built on a Doxa panel interviewing customers of competitor banks. The reference market sample consists of 2,499 individuals interviewed about their ‘First Bank’. The findings show that the overall level of satisfaction remains high (average index 84/100), above the average of the benchmark market. ‘First Bank’ current account holder Banca Mediolanum ‘First Bank’ current account holder Total market Total Women Men Total Women Men Customer satisfaction index90 84 85.89 82.80 74.93 76.72 73.05 Overall satisfaction 84.38 86.66 82.92 71.73 76.96 73.29 Satisfaction compared with expectations 82.55 84.52 81.29 74.17 75.82 72.44 Satisfaction compared with other banks 85.36 84.30 84.30 75.71 77.91 73.46 Banco Mediolanum also carries out annual surveys to measure the general satisfaction of its customers both internally and by relying on a specialised company (Stiga) that also allows a comparison with the level of satisfaction of customers of other banking institutions. In 2025, 400 customers responded to the Stiga survey, showing a satisfaction of more than 8.5% At the end of each year, overall client satisfaction is measured during the year and specific surveys are also carried out on (i) customers who have not carried out transactions in the 6 months following the subscription, (ii) customers who have divested 50% or more of their assets under management and (iii) new customers. Moreover, the satisfaction and recommendability of the loan-granting process are measured. [S4-4 DP 31 d] The results of the surveys conducted are shared, both at Banca Mediolanum and Banco Mediolanum, with senior management and the various areas of responsibility. Any initiatives or actions taken in response to the results of the analyses are the responsibility of the respective areas of competence. Currently, for both Banca Mediolanum and Banco Mediolanum, a formalised process for the systematic monitoring of the actions undertaken has not yet been defined. [S4-4 DP 30; 31 c; ESRS 2 MDR-A DP 68] 90 Source: Customer Satisfaction Survey 2025, carried out in collaboration with the BVA-Doxa Institute Interviews in CAWI mode (online questionnaire) carried out in December 2025.
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315 | Mediolanum Group - 2025 Annual Financial Report IROs: Assurance of the quality and usability of the offering thanks to accessibility of information The Mediolanum Group is committed on a daily basis to seeking out products and services that prioritise the protection and centrality of people. The basis for improving the customer experience is therefore the constant search for innovation, quality and usability of the offering. In 2025, a major project initiative continued, having been launched in 2023, aimed at implementing accessibility on the digital channels used by customers, based on a new design system with a ‘mobile first’ approach that can also support the web channel. ‘Digital accessibility’ refers to the ability of information systems to provide services and information that can be used without discrimination, even by those who need assistive technologies due to functional limitations. This approach, as well as being compliant with the most recent regulations and best market practices on accessibility, is intended to offer an experience of using digital channels that is increasingly recognisable, consistent and inclusive, in line with Banca Mediolanum’s values. In particular, in view of the transposition of European legislation by Legislative Decree No. 82 of 28 June 2022, implementing Directive (EU) 2019/882 on the accessibility requirements for products and services, during 2025 Banca Mediolanum continued the adjustment process as provided for, in continuity with the provisions of the Stanca Law (Law 4 of 9 January 2004) on digital accessibility. In addition, during 2025 an accessibility project was also implemented on the Network Channels, with the aim of enabling customers to be aware of and have access to forms for signing contracts proposed by the Family Banker. In this regard, after an initial stage of analysis and rationalisation of the scope of intervention, started during 2023, the activities envisaged by the document accessibility project continued in 2025 to adapt the communication models made available to customers in digital mode. Given the wide range of documents and communications managed within Banca Mediolanum and by the Group Companies through various production and dissemination processes, it became necessary to identify many different solutions for adaptation to accessible modalities, initiating a progressive conversion and/or production plan which is continually updated. In addition, legislation with similar aims and required safeguards is in the process of being implemented (the so- called European Accessibility Act), also in the European Community. However, the EU legislature, probably aware of the significant economic, IT and operational impacts, considered it appropriate to provide for the entry into force of these provisions in the European Community by 28 June 2025. The activity of transposing the instructions of the EU regulations also concerns Banco Mediolanum, which, since 2023, has been working to develop all of its channels (including digital channels) aimed at the end-customer to this end. This initiative is of primary importance to the Group because, while it meets a need for regulatory compliance, it is part of the process outlined in the Sustainability Plan and represents an opportunity to reach certain groups of customers potentially interested in accessing the services offered by the Bank. Banca Mediolanum reported compliance with the regulations on its websites and mobile applications on 5 November 2022, in a first Accessibility Statement, which is updated annually 91, also providing for an adaptation roadmap for the adoption of the necessary measures to achieve full compliance of all digital touch points for customers. In this regard, the adjustment process defined by Banca Mediolanum is in line with the orientation of the other main banks. In fact, in 2025, the Bank also actively participated in the interbank task force established on these issues at the associative level. As part of this task force, ABI had the opportunity to report to the Authority on the significant complexities in implementation that characterise the banking sector. 91 The 2025 Accessibility Statement was published on 9 September 2025.
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316 | Mediolanum Group - 2025 Annual Financial Report Lastly, with the support of ABI, Banca Mediolanum set up a specific dialogue and discussion group with the main representative bodies of persons with functional limitations already involved in ABI working groups, including: UICI Onlus – Unione Italiana dei Ciechi e degli Ipovedenti (The Italian Union of Blind and Visually Impaired Persons); ENS – Ente Nazionale per la protezione e l’assistenza dei Sordi (National Body for the Protection and Assistance of Deaf Persons); FIABA Onlus – Fondo Italiano Abbattimento Barriere Architettoniche (Italian Fund for the Removal of Architectural Barriers) Fondazione LIA – LIA Foundation (Accessible Italian Books); Fondazione ASPHI Onlus – Associazione per lo sviluppo di Progetti Informatici a favore di persone con disabilità (Association for the Development of Computer Projects for People with Disabilities). In addition to establishing relations with these associations, since 2023 the Bank has endorsed the European Disability Charter, an agreement that renews every year and that entered into force in January 2024. This group was established in order to identify and correctly interpret people’s needs, in order to direct the Group’s projects towards the topics prioritised for these types of customers, also in order to intervene effectively to meet any related needs, thereby reducing any reputational risk and facilitating compliance with the regulations. During 2025, the alignment for access to the Group’s public sites was completed, with activities for the Consulenti Mediolanum and Family Banker sites, as well as the closure of the Mediolanum Fiduciaria and Mediolanum Corporate University sites, with a view to streamlining editorial content. In June 2025 the project was completed, allowing customers to request the closure of current accounts via digital channels (website and app). In addition, the process that digitised corporate and personal account opening forms was also completed and a digitalisation project is under way for legal entities as well. Banco Mediolanum committed to making its products and services accessible, in accordance with national legislation (Law 11/2023), which transposes Directive (EU) 2019/882 of the European Parliament and of the Council. The main initiatives for adapting accessibility were carried out on the following channels: Public websites; Private web area; Mobile application; Banking Center; ATM cards; Contractual and non-contractual communications.
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317 | Mediolanum Group - 2025 Annual Financial Report Due to the large number of assets and functionalities distributed across the various channels, a programme of activities was defined and implemented to start a progressive adaptation process, making significant improvements in terms of accessibility for customers by the date the regulations come into force. In addition, a solid plan was defined with the goal of completing the level of accessibility on all available channels for our customers. In Italy, the Customer Banking Centre provides qualified, extensive assistance in the form of information and/or practical measures for the Bank’s customers, via approximately 450 operators, assisted by two external partners. During 2025, the Customer Banking Center provided support to 831,923 customers by telephone or in writing (i.e. chat and/or email), obtaining a very high level of satisfaction for the service provided, in line with previous years, with an average score of 3.7 (scale of 1 to 4). [S4-4 DP 31 d] The effectiveness of actions and initiatives undertaken on credit products is tracked and assessed through a process that includes periodic monitoring aimed at verifying customer satisfaction, in full compliance with the POG (Product Oversight and Governance) regulations. In the case of Selfy PayTime, a specific survey was carried out one year after the launch of the product which showed a high level of approval, with positive satisfaction in 94% of cases. Thanks to these tools and practices, the Mediolanum Group ensures that the initiatives implemented are effective and that they continue to produce positive results for consumers, responding in a way appropriate for their needs and expectations. In general, regular checks are carried out on the products being placed, both through the production of dashboards and reports, subsequently shared internally, and through ‘official’ documents required by law (e.g. product governance) in which, due to critical issues or indicators deemed significant, detailed analyses are carried out and possible recovery actions are provided. At Banco Mediolanum, periodic monitoring is carried out on the progress of projects launched in 2025 in the area of Accessibility. The outcomes of the monitoring are then discussed with Company Management.
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318 | Mediolanum Group - 2025 Annual Financial Report Targets [S4-5 DP 40 a; ESRS 2 MDR-T DP 80] IROs: Customer satisfaction through effective engagement and listening to feedback Target Target KPI Target year Scope Baseline year and value Current progress Maintenance of the customer satisfaction index above the predefined threshold Maintenance of the customer satisfaction index between 83 and 85/100 2030 Italy 2024 84.90 84 Consolidation of the position among the top five banks in the Stiga Customer Satisfaction survey Ranked between 1st and 5th among Spanish banks (Stiga survey) 2030 Spain 1st place 1st place In view of the high level of satisfaction recorded in the Customer Satisfaction survey in 2024, the target for the next few years remains conservative, given the high score already obtained. The 2030 horizon represents a commitment to preserve a high and stable standard of quality, while taking into account the natural variations that may occur over the five-year period. The target reflects a commitment to ensuring continuity and stability in the customer experience, while highlighting the results achieved. Since 2019, Banco Mediolanum has participated in the Stiga survey on customer satisfaction, which assesses financial institutions operating in the Spanish market in terms of customer satisfaction and the level of customer engagement. The survey, conducted by an independent company across the industry, provides a common and comparable framework for measuring the satisfaction and customer experience of banks in Spain in a uniform way. [S4-5 DP 41 a, 41 b, 41 c] Both in Italy and Spain, customers are not directly involved in monitoring performance against targets. The Customer Satisfaction Survey is designed to listen to customers. Any initiatives or actions taken in response to the results of the analyses are the responsibility of the respective areas of competence. At present, there is no formalised process for monitoring the actions undertaken.
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319 | Mediolanum Group - 2025 Annual Financial Report 3.4.4 Access to products and services [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Access to products and services Contribution to customers’ financial education, generating a positive socio- economic impact in communities Actual positive impact Downstream value chain (Banking, Protection, Savings/ Investment Management) Long term Contribution to the dissemination of virtuous customer behaviour on ESG matters through awareness-raising and the promotion of sustainable products Actual positive impact Downstream Value Chain (Banking, Protection, Asset Management/Investment) Medium term Facilitating access to credit for specific customer targets (e.g. young people, female entrepreneurs, …) Actual positive impact Downstream Value Chain (Banking) Short term Increase in the Mediolanum Group’s market positioning towards non- profit/social economy operator targets Opportunities Downstream Value Chain (Banking) Medium term Risk of the distribution of banking, investment and insurance products/services not being in line with the Group’s sustainability policy and/or with the relevant sustainability regulations Risk Downstream Value Chain (Banking, Protection, Asset Management/Investment) Short/medium term The Group’s approach and policies The Mediolanum Group places the social inclusion of customers at the centre of its vision, including accessibility, quality and sustainability as guiding principles in the provision of products and services. The Group has implemented major social inclusion initiatives aimed at directly supporting households and individuals in order to ensure more widespread and sustainable access to credit through non-profit companies and dedicated programmes. The Group is also committed to conducting info-training activities outside the organisation designed to develop financial knowledge and skills and a safe and responsible approach to the world of finance. In addition to the Code of Ethics, the Code of Conduct and the Sustainability Policy, which set out its approach and general guidelines, the main policies for managing the impacts related to ‘access to products and services’ are the Banca Mediolanum Community Support Policy, the Product Sustainability Policy and the Financial Products Distribution Policy. [S4-1 DP 15; ESRS 2 MDR-P DP 65]
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320 | Mediolanum Group - 2025 Annual Financial Report IROs: Contribution to customers’ financial education, generating a positive socio-economic impact in communities The Group’s main policies on sustainability and business conduct set out specific commitments on financial inclusion, including the Mediolanum Group’s Sustainability Policy and the Code of Ethics (see ESRS G1 Business conduct, paragraph 4.1.1 Business culture, section ‘The Group’ approach and policies’ for further details on the minimum reporting requirements of the Policies). In particular, within the Code of Ethics, ‘responsibility’ with regard to the commitment to solidarity and to education and development projects is one of the key principles of the Group’s value system. Furthermore, within the Policy to support the Community of Banca Mediolanum (see ESRS S3 Affected communities, paragraph 3.3.2 Economic, social and cultural rights of affected communities, section ‘The Group’s approach and policies’ for further details on the minimum reporting requirements of the Policies), the Group is committed to facilitating financial inclusion and promoting information and training activities aimed at developing a safe and responsible approach to finance. The Group’s Spanish companies adopt the same policies as the Parent Company, in accordance with specific national aspects. IROs: Contribution to the dissemination of virtuous customer behaviour on ESG matters through awareness- raising and the promotion of sustainable products; Risk of the distribution of banking, investment and insurance products/services not in line with the sustainability policy of the Group and/or with sustainability regulations By defining the broader-ranging Mediolanum Group Sustainability Policy, Banca Mediolanum and Banco Mediolanum integrate the sustainability dimension of products into their processes through dedicated policies such as, but not limited to, the ‘Banca Mediolanum Product Sustainability Policy’, the ‘Banca Mediolanum Investment Advisory Services Policy and Distribution Strategy for Financial Instruments and Insurance Investment Products” and the ‘Política sobre la Estrategia de Distribución de los Productos Financieros/ Strategy Policy for the Distribution of Financial Products’ of Banco Mediolanum (see ESRS E1 Climate Change, paragraph 2.2.4 Financed GHG emissions-Investments, section ‘The Group’s approach and policies’ for further details on the minimum reporting requirements of the Policies). In particular, according to Banca Mediolanum’s ‘Product Sustainability Policy’, the Bank acts in such a way that environmental, social and governance factors are taken into account throughout its ‘production process’, i.e. from the conception and design stage, to creation and release, up to after-sales management, in which the customer uses the product/service. This is reflected, for example, in the following guidelines: paying attention to transparency and the clear communication of the product/service conditions in order to make customers’ choices as informed as possible; overseeing sales processes and the associated risks; increasing the range of sustainability-focused products over time. In addition, the distributors of the Bank and Banco Mediolanum are continuously monitored to ensure that the sustainability positioning of products maintains an adequate level of quality over time. The Mediolanum Group has also incorporated ESG principles into its internal credit regulations and Responsible Finance Policies regarding decision-making and operational processes, including the lending stage (see ESRS E1 Climate change, section 2.2.5 Financed GHG emissions-Credit, section ‘The Group’s Approach and Policies’ for further details). The Group’s Spanish companies adopt the same Policies as the Parent Company, in line with specific national aspects.
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321 | Mediolanum Group - 2025 Annual Financial Report IROs: Facilitating access to credit for specific customer targets (e.g. young people, female entrepreneurs, …); increase in the Mediolanum Group’s market positioning towards non-profit/social economy operator targets Financial inclusion is a key tool for improving economic stability, reducing inequality and promoting individual and collective well-being. With this awareness, the Group supports people in difficulty through the creation of dedicated products and services, as well as through the presence of Family Bankers on the ground and the availability of digital tools for customers’ self-management of their finances. The Group’s main policies on sustainability and business conduct outline specific commitments on financial inclusion, including the ‘Mediolanum Group’s Sustainability Policy’ and the ‘Code of Ethics’ (see ESRS G1 Business conduct, paragraph 4.1.1. Business culture, section ‘The Group’s approach and policies’ for further details on the minimum reporting requirements of the Policies). In particular, in the Code of Ethics, ‘Inclusion’ in decisions that affect relations with Stakeholders (including the choice of customers to serve) is one of the key principles of the Group’s system of values. Lastly, the ‘Product Sustainability Policy’ (see ESRS E1 Climate change; paragraph 2.2.4 Financed GHG emissions- Investments, section ‘The Group’s approach and policies’for further details on the minimum reporting requirements of the Policies) indicates the creation of inclusive and accessible products and services as a key guideline in taking into account environmental, social and governance factors throughout its ‘production process’. Actions IROs: Contribution to customers’ financial education, generating a positive socio-economic impact in communities [S4-4 DP 30; 31 c; ESRS 2 MDR-A DP 68] With regard to the impact linked to customer financial education, during the year the Group continued its commitment to various projects aimed at disseminating financial topics for existing and prospective customers. In particular, during 2025, the CosaConta project continued with the objectives of disseminating even more effectively the social value of financial education, enhancing the public’s knowledge and expertise of financial, insurance and welfare matters, offering content consistent with the Group’s identity and values, and of being more present and active in a context characterised by an increasing attention from the market, entities, institutions and trade associations. In addition, Family Bankers continued to receive concrete support through dedicated editorial content, designed to assist them in their day-to-day activities. For further details about CosaConta, see the dedicated section below (‘Blog’). In 2025, Banco Mediolanum also continued its commitment to the production of dedicated content for the blog CuálesSonTusMetas and for its social networks, with the aim of promoting and expanding the financial education and culture of customers and savers. In particular, during the year, 80 publications were posted on social networks, and 23 articles were published on financial education.
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322 | Mediolanum Group - 2025 Annual Financial Report Blogs The objective of the Mediolanum Group has always been to constantly release contributions and content on financial education in such a way as to share information with the public that is continually updated. Banca Mediolanum’s blog CosaConta continues to feature more technical and traditional articles alongside real stories of people, with the aim of conveying concepts and notions of financial education through concrete examples linked to life experiences. The involvement of the Bank’s people, both as a source of content and as active support for the development of narrative, continued and increased during the 12 months of 2025, including through the production of 2 video podcasts dedicated to this theme. In 2025, the digital hub cosaconta.bancamediolanum.it had 47 new pieces of content added (i.e. articles, podcast episodes, etc.) and was visited by 83,035 people. In March, a new training platform was also launched and, with the support of Mediolanum Corporate University, two new video courses were produced, freely available to visitors. A WhatsApp channel was launched in May with the aim of providing a simple tool to keep up with project updates. Building on last year, the contents were produced in collaboration with Fondazione per l’Educazione Finanziaria e al Risparmio (FEduF) of ABI and all activities were promoted through the Bank’s social media. Customer communications In 2025, Mediolanum Magazine, which is also for Selfy customers, with a total of 5,035,333 submissions, confirmed the multimedia configuration of previous years, maintaining sections dedicated to the blog CosaConta and the promotion of the Bank’s social channels. This consolidated communication tool was complemented by new initiatives linked to the financial education programme, which have expanded the points of contact with customers. Specifically: during the year, two articles from the blog CosaConta were included in World magazine, reserved for Black, Elite and Privilege clients, in print and digital formats; invitations to participate in the live streams of the financial education tour ‘Understand your money, build your future’ were sent to customers via email and push notifications; the launch of the Braccioli podcast was featured in the e-mail sent out with summer tips for customers; one of the recurring emails sent to customers about security included a reference to the Tranelli podcast; in the September and December account statements, the advertising section was dedicated to the CosaConta blog. Mediolanum Magazine continues to cover the main themes of economics and finance, current events, solidarity initiatives, technological innovation, and banking services. In 2025, the touchpoints related to financial education were increased and diversified compared to 2024. Events In addition to institutional events, involving our top managers, new formats for in-depth events on financial education topics were created, available on request from the Sales Network and dedicated to customers and prospects. [S4-4 DP 31 d] The results of Banca Mediolanum’s financial education activities, monitored by the Communication, Bank Marketing and Digital Channels Department, are tracked by means of analytics that measure how many people enjoy content on the digital platforms and in what way. In addition, market surveys (Doxa) are implemented in order to learn about consumers’ perceptions of the attention that the Mediolanum Group places on the specific issue of financial education. Banco also monitors the number of users per publication in order to assess the effectiveness of the content.
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323 | Mediolanum Group - 2025 Annual Financial Report IROs: Contribution to the dissemination of virtuous customer behaviour on ESG matters through awareness- raising and the promotion of sustainable products [S4-4 DP 30; 31 c; ESRS 2 MDR-A DP 68] With regard to the impact linked to the Group’s contribution to the spread of virtuous customer behaviour on ESG matters, during the year the Group’s commitment consisted of a combination of raising awareness and promoting sustainable products. Family Bankers are central to the dissemination of virtuous customer behaviour on ESG matters. In this regard, the Sales Network in Italy is offered, on a voluntary basis, a training course for EFPA (European Financial Planning Association) certification on ESG topics. In the reporting year, the number of Family Bankers in Italy with EFPA ESG certification was 307. In addition, events specifically related to sustainability matters were organised in the region in 2025, involving customers, Family Bankers and other persons interested in the matters addressed. The Sustainability section of Banca Mediolanum’s website, contained in the Corporate area of the website (https://www.bancamediolanum.it/corporate/sostenibilità), is an integrated communication tool that describes the Bank’s overall approach to sustainable development, with the aim of informing stakeholders and the public about initiatives relating to social, environmental and economic responsibility and promoting dialogue with communities. The main areas are corporate Policies, certifications, manifestos, initiatives and projects and reports, as well as the Consolidated Sustainability Report of the Mediolanum Group, providing a complete overview of the concrete actions undertaken and of Banca Mediolanum’s future commitments. Thanks to awareness-raising and the promotion of sustainable products, the divestment of the Maestro Circuit was an opportunity to provide customers with more functional and advanced e-money products. For this reason, in 2023 the Mediolanum debit card was launched on the Mastercard network, distributed to both new and existing customers. In addition, at the end of 2025, the digital-only version (without a physical counterpart) of the Mediolanum debit card on the Mastercard circuit, usable for online or in-store purchases via smartphone or smartwatch, was also introduced. The physical card can still be requested at a later time. With the introduction of the digital version of the debit card, new layouts were introduced for the physical debit card and any physical media for the digital debit card, made from 99% recycled PVC, a material that reduces CO2 emissions by 54% at the time of production of the payment card. Moreover, with accessibility in mind, the design features a rounded edge to for greater recognition. In addition, with the ongoing aim of integrating ESG values into customer relations, an initiative is in place to send the Bank’s best customers a gift on their birthday. The supply is renewed annually and selected on the basis of a quality product and its virtuous production chain, as well as any values conveyed by the related message, where present. In the tender for the award of the supply, the values shared with Banca Mediolanum, with particular attention paid to social and environmental sustainability, for example through the use of innovative and high-quality raw materials, may be indicated for every participating supplier. To create the packages, 100% Made in Italy artisan products are favoured, with the use of local raw materials and recyclable materials such as glass and paper, avoiding the use of plastic, or instead packaging is chosen that supports successful entrepreneurial projects. In 2025, in particular, the products of the following were also selected: a leading start-up, thus supporting companies founded by young entrepreneurs involved in research in the food sector; suppliers who contributed to charitable projects, donating a part of the proceeds to non-profit organisations.
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324 | Mediolanum Group - 2025 Annual Financial Report In Spain, Banco Mediolanum offers a range of financing products dedicated to the eco sector, such as the Freedom Green mortgage and Zero-emission loans, with more favourable interest rates as they are used to finance customers’ purchases of homes and vehicles with a higher energy efficiency. In addition, the Bank’s institutional website includes a section on sustainability, which describes in detail the Bank’s approach to ESG issues. Similarly, the Mediolanum Aproxima solidarity project and initiatives promoted by its collaborations with NGOs, with a description of their concrete impact, are presented in the ‘Social Action’ section of the website. Among these initiatives is ‘Ogni Centesimo Conta’, (Every Cent Counts), a programme that customers can join via their current accounts, in which they can automatically donate, at the end of each month, the cents remaining in their account—ranging from 1 to 99 cents—thereby contributing simply and continuously to the community. [S4-4 DP 31 d] The effectiveness of actions, both at Banca Mediolanum and Banco Mediolanum, is assessed in surveys and the results are shared with senior management and the relevant departments respectively. In addition, at the end of the reporting period, no formalised processes are defined for the continuous monitoring of the actions taken. IROs: Facilitating access to credit for specific customer targets (e.g. young people, female entrepreneurs, …) [S4-4 DP 30; 31 c; ESRS 2 MDR-A DP 68] The Group focuses its efforts on developing credit products for social purposes, aimed at ensuring real accessibility for specific customer targets (e.g. young people, female entrepreneurship, etc.). The Group’s offering at 31 December 2025 is as follows: the Mediolanum Young mortgage (Banca Mediolanum): the intended recipients of the Mutuo Mediolanum Young mortgage are young people under the age of 36, in order to encourage first-time buyers. The mortgage provides for a loan with a maximum LTV of up to 90% and an optional pre- amortisation period of two years, without the application of any increase and a progressive reduction of the spread applied, every five years, in case of regular payments. In addition, the Mediolanum Fondo di garanzia prima casa home-buyers guarantee for up to 100% the value of the property is added to this product, offering a state guarantee that often replaces the need for a private guarantor. The product is aimed mainly at young people under 36, couples and single-parent households with an ISEE (income level) of up to €40,000, guaranteeing them access to preferential rates and priority access to the fund. During 2025, €30.4 mln of the Mediolanum Young and Fondo di Garanzia Prima Casa products were disbursed, equal to 1.7% of total mortgages disbursed; the Mediolanum Special Care loan with preferential rates for dependent persons, to finance the costs of those who need assistance, care or special equipment. The purpose of this loan is to purchase goods or services to improve accessibility in daily life, such as mobility aids (wheelchairs or crutches), work to remove architectural barriers (e.g. the installation of ramps or environmental adaptations) or technological support devices (e.g. screen readers or hearing aids). Caregivers may also request a loan if it is intended to support the expenses of the dependent person. The initiative was launched in the last months of 2024, and 16 loans were granted during 2025, for a total of €360 thousand; memorandum of Understanding to favour credit repayment on the part of female victims of gender- based violence: on 24 November 2025, ABI, Fabi, First-Cisl, Fisac-Cgil, Uilca and Unisin signed meeting minutes extending until 25 November 2027 the Memorandum of Understanding to favour credit repayment on the part of female victims of gender-based violence. The aim of the Memorandum of Understanding is to support female victims of gender-based violence who are included in protection pathways, by providing the option of requesting a suspension of payment of the principal on mortgage loans and consumer loans, with the corresponding extension of the repayment plan, for a period of no more than 18 months. In 2025, Banca Mediolanum, always very focused on promoting support initiatives
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325 | Mediolanum Group - 2025 Annual Financial Report for people or families in difficulty, decided to renew its endorsement of the Protocol. Women on ‘protection pathway’” for gender-based violence, duly certified by the social services of their municipality of residence or anti-violence centres or refuges, can access the measures provided for in the Protocol. In addition, during 2025 confirmation was given for customers to be able to suspend up to 6 instalments over the life of the loan, with a maximum of 2 per year; this option can be taken from the second year (after the end of the initial period at a fixed promotional rate) and exclusively by customers who are up to date with their instalment payments. In 2025 the possibility of using the ‘skip the repayment’ option was also extended to mixed- rate mortgages. [S4-4 DP 31 d] The effectiveness of actions and initiatives undertaken on credit products is tracked and assessed through a process that includes periodic monitoring aimed at verifying customer satisfaction, in full compliance with the POG (Product Oversight and Governance) regulations. One key element in measuring the effectiveness of the initiatives is customer satisfaction questionnaires, regularly administered to customers taking out loans. These tools enable the gathering of feedback both on the actual satisfaction of the need for which the product was taken out and on the overall customer experience during the application process. For further information on Customer Satisfaction see ESRS S4 Consumers and end-users, paragraph 3.4.3 Access to quality information, section ‘Actions’. In Spain, monitoring is carried out through two complementary mechanisms: on the one hand, the register of requests for the deferral of repayments; on the other hand, the processing of periodic reports based on real data, in collaboration with the IT team, to define customer profiles and models of behaviour. IROs: Increase in the Mediolanum Group’s market positioning towards non-profit/social economy operator targets [S4-4 DP 30; 33 b; ESRS 2 MDR-A DP 68] Within the framework of the new 2026-2030 Business Plan, the Group aims to strengthen its market positioning, with a specific focus on the targets represented by non-profit and social economy operators. In order to pursue this opportunity, the relationship with customers operating in the third sector is an area in which the Bank has been working for years. Among the initiatives planned, the training course for Family Bankers ‘The value of consultancy for third sector organisations’ continued in 2025, in collaboration with Mediolanum Corporate University (MCU). This course is aimed at promoting services and products dedicated to this type of entity, with particular attention paid to credit solutions; in 2025, a further 63 Family Bankers completed the course. The training plan, which relies on specialised speakers in canon law, ecclesiastical asset administration and the non-profit sector, will continue in the coming years, becoming a permanent course in MCU’s educational offering. In addition, Banca Mediolanum pays particular attention to protecting the assets of ecclesiastical bodies, recognising the complexity of their economic and financial requirements and the need to collaborate with experienced professionals. The Bank is committed to offering expertise and personalised solutions through specifically trained internal financial advisors, with the support of experts from the same ecclesiastical bodies. The proposals include banking, investment and insurance services, with a particular focus on dedicated credit solutions and investment services, including distribution solutions that comply with the guidelines of the Italian Episcopal Conference, certified by Nummus.Info. In 2025, 77 consultants participated in webinars dedicated to Ecclesiastical Bodies, consolidating their expertise in advising these entities.
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326 | Mediolanum Group - 2025 Annual Financial Report The Technical Secretariat of the Chairman’s staff assists, with the support of the Wealth Management Department, the Family Bankers in meetings on national territory and continuously promotes, both through newsletters and in the dedicated community on the company intranet, products and services for the Family Bankers who have completed the specific training courses for third-sector entities and ecclesiastical bodies. Banca Mediolanum has developed dedicated solutions for Third-Sector Organisations that include loans for volunteer organisations, social promotion associations, philanthropic bodies and social enterprises (including social cooperatives), networks of associations and mutual aid companies, as well as non-profit organisation, and entities for civic, solidarity and social utility purposes, registered in the Single National Register of the Third Sector (Mediolanum Loans for the Non-Profit Sector) and a current account for these categories. In 2025, loans and exposures were granted to the non-profit sector totalling €1,395,000. With the aim of guaranteeing further and renewed support to families in need through the ‘Emergency Loan’, agreements with anti-usury foundations, which totalled 16 throughout Italy at 31 December 2025, were renewed and extended, both in terms of increased ceilings and geographical coverage. Since 2009, the Group has provided support to more than 900 people, thus confirming its concrete commitment to the community and the protection of fundamental rights. In particular, Banca Mediolanum, with the backing of the Mediolanum EF Foundation, supports numerous diocesan foundations associated with the Consulta Nazionale Antiusura ‘Giovanni Paolo II’ (the John Paul II National Anti-Usury Council), in agreements to grant funding in the form of social micro-credit, through the ‘Prestito di Soccorso’ (‘Emergency Loan’) project. The anti-usury foundations operate through the Caritas organisations of the various Dioceses, which in turn work with parish Listening Centres to gather information on families in need. Following the signing of the relevant agreements between anti-usury foundations, Banca Mediolanum and Fondazione Mediolanum EF, as a form of sponsorship, the Bank has undertaken to grant the foundations a revolving line of credit to be used to grant loans with repayment by instalments to persons in difficulty, at a rate of 1.25%, with Bank taking on the entire credit risk of the agreed loans. The Mediolanum EF Foundation has indicated that women with dependent children should be prioritised as beneficiaries of loans, in line with its mission. In 2025, 967 families were helped and the revolving ceiling provided amounted to €6,150,000, while the total amounts granted amounted to €9,094,423. Also during 2025, the agreement was extended to 1 new foundation and 5 funding ceilings were increased with foundations with which operations were already underway, for a total amount of €550,000; considering the predominantly regional nature of the anti-usury foundations, the Bank’s strategic development plan foresees the progressive coverage of all Italian regions where these foundations operate, through the signing of specific agreements. [S4-4 DP 35] No serious consumer and/or end-user-related human rights issues and incidents were reported during the year. [S4-4 DP 37] The Departments of the Italian companies responsible for managing the impacts and opportunities attributable to the theme ‘Access to products and services’ mentioned above are the Communication, Bank Marketing and Digital Channels Department, also in synergy with the Compliance function, the Sustainability Office of the Administration, Finance and Control Department and the Credit Department; the Credit, Banking and E-Money Product Development Office; the E-Business Market Intelligence Unit and the Market Research Office; also the Technical Secretarial team of the Chairman’s Staff, with specific reference to the actions connected with operators in the non-profit sector and the social economy. Similarly in Spain, these areas are monitored by Marketing Productos & Marketing Estratégico (Product and Strategic Marketing), Comunicación y Canales; (Institutional Communication and Media Relations); Dirección de Organización (Organisation) and Dirección Strategic Marketing & Business Development (Strategic Marketing & Business Development).
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327 | Mediolanum Group - 2025 Annual Financial Report IROs: Risk of the distribution of banking, investment and insurance products/services not being in line with the Group’s sustainability policy and/or with the relevant sustainability regulations [S4-4 DP 30; 33 a; ESRS 2 MDR-A DP 68] The Mediolanum Group has adopted specific policies aimed at promoting responsible finance, integrating and updating existing internal regulations to systematically include ESG issues, including during the lending stage. ESG integration in credit and investment processes is monitored periodically and continuously, with an analysis of deviations and transitions between risk classes. With regard to the risks associated with the distribution and monitoring of banking, investment and insurance products/services that are not in line with internal sustainability regulations or with the Sustainability Policy of the Mediolanum Group, the Italian and Spanish Compliance Functions, with regard to changes in the regulatory framework, carried out both ex ante assessments and ex post controls to oversee compliance risks, including ESG and climate-related risks, with specific regard to areas that affect customers or potential customers. For example, with investment products, customers were asked about their sustainability preferences to offer the most suitable options. With specific reference to the IRO in question, this risk is also mitigated by the current governance system, in terms of the authorisation process for new products, committees and internal regulations (Policies, procedures and process regulations), as well as the monitoring of the distribution data produced by the relevant functions. In particular, in relation to this risk, the Group has taken a number of measures: an Investments and Insurance ESG Committee, was set up in 2020 to support the Investment and Insurance Services Department; the ‘Banca Mediolanum’s Policy on investment advisory services and strategy for the distribution of financial instruments and insurance investment products’ and ’Política sobre la Estrategia de Distribución de los Productos Financieros’ (Policy on the Distribution Strategy of Financial Products) of Banco Mediolanum were produced. The Mediolanum Group has established the Investments and Insurance ESG Committee, which is tasked with providing support and advice in the analysis and monitoring at Conglomerate level of the ESG positioning of the offer, in the proposal of sustainable investment guidelines, methods for assessing ESG characteristics and any parameters that the offer has to comply with at Group level. The Committee ensures that the guidelines on Responsible Finance and initiatives to meet regulatory requirements are correctly adopted by the relevant companies of the Conglomerate concerned. In addition, through specific working groups, the Committee oversees the implementation of the guidelines and monitors their consistency. Banca Mediolanum and Banco Mediolanum, which provide customer advisory services (Financial Advisors), have introduced sustainability safeguards into their financial product distribution policies, specifying that ESG factors should be taken into account, both when selecting financial products and when preparing investment proposals. When selecting the offer, ESG risks are taken into account through the following measures, sometimes implemented with the support of third parties: the valuation of financial products; the valuation of management companies; consideration of the principal adverse impacts (PAI) on sustainability factors; ongoing monitoring of investment products. In the advisory process, ESG risks are taken into account through the following safeguards: the collection of customer sustainability preferences;
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328 | Mediolanum Group - 2025 Annual Financial Report consideration of the preferences expressed by customers when verifying the suitability of the investment proposal. These safeguards help to mitigate the risk of the distribution and monitoring of investment and insurance products and services that are not in line with the Mediolanum Group’s Sustainability Policy, ensuring an offering that is consistent with ESG principles. The scope of these activities includes all investment products offered to customers of Banca Mediolanum and Banco Mediolanum through the customer advisory service. In the lending sector, for mortgages for the purchase of a first home in energy-efficient properties (energy classes A+, A and B), there is an obligation to prepare a technical report on the property offered as collateral. This technical appraisal must include, in particular, information relating to energy data and the main physical risks to which the property may be exposed. During the disbursement stage, the maximum eligible percentage of the loan-to-value (LTV) –, an indicator used as a condition for granting the loan –, may exceed the limit of 80% and reach 90% of the LTV. With specific regard to pricing, the integration of ESG factors takes place by including the impacts of climate risk in the calculation of the cost of risk and, in particular, in the estimates of LGD applied to the entire retail mortgage portfolio. The product range also includes solutions with preferential economic conditions, granted upon meeting certain environmental criteria (these include the ‘Mutuo Eco+’ and ‘Mutuo Casa+’ mortgages and the ‘ECO+ Mobility’ and ‘Casa+’ loans). The same approach is also aimed at supporting companies that demonstrate a strong commitment to environmental, social and governance (ESG) issues. Financing transactions with counterparties that have economic activities with a strong environmental impact are generally prohibited and, in 2021, some ESG safeguards were introduced, based on the assessment of ESG factors in the corporate credit portfolio. In particular, when the loan is granted, all credit investigations relating to the corporate sector are accompanied by the counterparty’s ESG score. This score, provided through an infoprovider, shows a summary ‘ESG’ indicator and three specific indicators, one for each area of expertise: ‘Environment’, ‘Social’ and ‘Governance’. Targets [S4-5 DP 40; ESRS 2 MDR-T DP 80] IROs: Increase in the Mediolanum Group’s market positioning towards non-profit/social economy operator targets Banca Mediolanum has chosen to support the fight against poverty and usury through the ‘Prestito di Soccorso’ (‘Emergency Loan’), an initiative starting in 2009 which today involves 16 anti-usury Diocesan foundations located throughout Italy. The development of these initiatives is one of the strategic objectives of the Mediolanum Group’s Sustainability Programme in relation to support for the community. With respect to the objective set in the previous 2024-2026 Sustainability Plan, the target was slightly recalibrated to include, within the scope, only disbursements made through the Emergency Loan. Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Provision of Emergency Loans €15 mln in emergency loans 2030 Italy 2024 6.80 mln 2.07 mln in loans disbursed
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329 | Mediolanum Group - 2025 Annual Financial Report The emergency loans represent a significant initiative in the context of financial inclusion and combating usury, designed to support households throughout Italy who, due to the lack of adequate collateral, with negative evidence of the central risks, fail to access traditional credit channels and risk falling victim to usury. Active monitoring of emergency loans is ensured through a dedicated Power BI dashboard, updated monthly, which allows for the timely tracking of disbursements and asset positions. The data are consolidated in summary reports sent regularly to the partner anti-usury Foundations, in line with the reporting obligations established by the agreement governing the relationships. Operational oversight is provided by the Credit Quality Monitoring Office, which also coordinates with the sales network and foundations to manage cases/applications and analyse anomalies. IROs: Facilitating access to credit for specific customer targets (e.g. young people, female entrepreneurs, …) Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Disbursement of mortgages for customers under 36 €275 mln of disbursed through Under-36 mortgages 2030 Italy 2024 220.1 mln 2020-2024 (5 years) 30.40 mln disbursed Banca Mediolanum has set the target, to be achieved in the three-year period up to 2030, of promoting mortgages for customers under 36, who historically face greater difficulty accessing credit, with the placement of two dedicated mortgages: The Young Mortgage, with a lower spread schedule compared to the standard Mediolanum Loan, along with specific characteristics such as a 90% LTV, a 24-month pre-amortisation period and a discount of 15 bps every 5 years (maximum 45 bps in total), provided the instalments are paid regularly. €19.39 mln of these mortgages were disbursed in 2025; The Prima Casa Guarantee Fund mortgage, with a lower spread schedule than the standard Mediolanum mortgage and financing of up to 100% of the property’s value. In 2025, €11.01 mln of these mortgages were disbursed. Mortgages for customers under 36 are monitored annually through the Product Governance process. IROs: Contribution to customers’ financial education, generating a positive socio-economic impact in communities Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Publication of financial education content and people engagement 200 Published content reached 100.000 people 2030 Italy 2024 35 content items 7,439 people reached 93 content items published and 90,474 people reached 100 content items published 60,000 people reached Spain 2024 16 content items 15,800 people reached 23 content items published 16,300 people reached The objective of the Group Companies has always been to constantly release contributions and content on financial education in such a way as to share information with the public that is continually updated.
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330 | Mediolanum Group - 2025 Annual Financial Report IROs: Contribution to the dissemination of virtuous customer behaviour on ESG matters through awareness- raising and the promotion of sustainable products Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Engaging customers in ESG events Involvement of at least 5,000 customers each year 2030 Italy 2024 5,700 customers involved 6,000 customers involved Every year, to date, Banca Mediolanum has managed to involve more than 5,000 customers in events organised by the Head Office, both on matters of financial education and with the involvement of the Mediolanum EF Foundation. Accordingly, the Bank has undertaken to maintain a target of at least 5,000 customers until 2030, continuing to engage customers throughout Italy. [S4-5 DP 41 a; 41 b; 41 c] The Mediolanum Group did not directly involve consumers and/or end-users in defining targets, monitoring performance against targets, or identifying lessons learn or improvements deriving from corporate performance. However, customers a central strategic asset for the Group: their preferences and interests are always carefully considered. To this end, the Group listens to and analyses customers’ needs, including through the stakeholder engagement process carried out in 2025, which helps guide strategies and processes of continual improvement. 3.4.5 Responsible business practices [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Responsible business practices Purchasing decisions by consumers not aligned with their real needs, influenced by unfair, misleading or aggressive business practices, including greenwashing and social washing, relating to the products offered Potential negative impact Downstream Value Chain (Banking, Protection, Asset Management/Investment) Medium term Achieving a greater market share through initiatives to improve the degree of personalisation of investment plans and customer protection Opportunities Downstream Value Chain (Banking, Protection, Investment Management) Medium term
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331 | Mediolanum Group - 2025 Annual Financial Report The Group’s approach and policies Mediolanum was created as ‘The Bank built around the customer’ and has always placed the customer at the centre of its business model at Group level. Our strong desire to understand customer needs is based on the relationship between the customer and the Family Bankers, who, through their professionalism, support customers as they achieve their objectives. With the primary goal of the centrality of the person, relationship care and service excellence, the Group also develops its strategy, ensuring transparency, clarity of information and responsible business practices. In addition to the Code of Ethics, the Code of Conduct and the Customer Protection Guidelines of the Mediolanum Group, which set out its approach and general guidelines, the main policies applied by the Group to manage impacts related to ‘responsible business practices’ are the Policy on Transparent Banking and Financial Transactions and Services, the Policy for the Prevention and Management of the Risk of Non- Compliance with the Antitrust Regulations and Unfair Business Practices of the Mediolanum Group, the Policy for Managing Conflicts of Interest with Customers relating to the Distribution of Products and Services and the Policy for Managing Advertising Campaigns, Events and Advertising Materials. [ESRS S4-1 DP 15; ESRS 2 MDR-P DP 65] IROs: Achieving a greater market share through initiatives to improve the degree of personalisation of investment plans and customer protection The main Policies on customer protection (see ESRS S4 Consumers and end-users, paragraph 3.4.3 Access to quality information, section ‘The Group’ approach and policies’ for further details on the minimum reporting requirements of the ‘Policy on Customer Protection of the Mediolanum Group’), and on business conduct (see ESRS G1 Business conduct, paragraph 4.1.1 Business culture, section ‘The Group’ approach and policies’ for further details on the minimum reporting requirements of the Policies) set out specific commitments on customer protection and the centrality of the person. The Mediolanum Group puts its customers at the heart of its business model, dedicating personalised and unique advice to them, with effective solutions covering the different stages of people’s lives. As also highlighted in the Group’s Code of Ethics, the basis of a lasting relationship with the client is the identification of needs, as well as their satisfaction, through an innovative and constantly evolving offer of products and services. In addition, seeking the interests of customers requires precise and in-depth customer knowledge, which can be acquired through dialogue and listening, as well as the correct identification of the investor’s risk profile, which is a further aspect, also regulatory, that the Group considers very material. In this respect, since 2018, the evolution of the Banca Mediolanum distribution model has led to the integration of protection specialists for the placement of stand-alone products, and this approach was also extended to Banco Mediolanum, starting from 2020. This has fostered the spread of a culture of Protectionas an integral and founding element of wealth planning. Protection, especially from major risks, is, in fact, considered indispensable in order to safeguard the stability of the individual and households. The protection solutions offered follows the sales network’s advisory approach, in line with regulations on placing insurance products, based on an analysis of the protection needs of acquired and potential customers. In this regard, the offering is focused on protecting against the most significant risks, and provides a high degree of customisation in terms of cover, limits, duration and options for the free splitting of premiums. Customer commitment is therefore also reflected in the continual improvement of products and processes, and in expanding the offering where necessary. Protection, by its nature, incorporates a focus on sustainability. In fact, some of the cover offered contributes significantly to protecting people in vulnerable situations, from the death of a loved one who provided income (with the possibility to advance the benefit), to serious illnesses, disabilities caused by accident or disease, or a lack of self-sufficiency (including psychological support for caregivers). Other insurance solutions reimburse medical and healthcare costs, including cancer care costs, for the entire life of the insured.
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332 | Mediolanum Group - 2025 Annual Financial Report Banca Mediolanum’s interest in building an offering increasingly focused on protecting people and placing them at the centre is also confirmed by its introduction, since 2020, of an ESG score applied to non-financial products, including non-life insurance solutions. Measuring and reporting specific elements of the offering and processes encourages an increased awareness within the Group and an ever growing focus on responsible business practices. IROs: Purchasing decisions by consumers not aligned with their real needs, influenced by unfair, misleading or aggressive business practices, including greenwashing and social washing, relating to the products offered Policy on Transparent Banking and Financial Transactions and Services Content and objectives The provisions in the Policy on the transparency of banking and financial transactions and services apply to the banking and financial products offered at every stage of the Bank-customer relationship. In particular, the Policy aims to: frame the principles and rules of conduct to ensure the substantive, as well as formal, fulfilment of the applicable provisions; provide guidelines for the operational fulfilment of legal and regulatory obligations and internal provisions; define the roles and responsibilities of the main Functions involved in the activities of applying the rules on transparency, information flows between actors and the Board of Directors, responsibility for the document, the scope of application of the Policy and its recipients. Scope of application The provisions on transparency in this Policy apply to all banking and financial transactions and services offered by intermediaries, including outside branches (indirect sales channel) or through ‘remote communication techniques’, during all stages of the Bank-customer relationship. Highest level of management responsible for implementation The Policy is approved by the Board of Directors of Banca Mediolanum. The Chief Executive Officer is responsible for implementing the principles and guidelines governed by the Policy in question. Regulations and reference standards The rules on the transparency of banking and financial transactions and services are in addition to the regulatory sources of other areas of the law that regulate the subject of transparency and fair conduct towards customers, such as those relating to the offering of investment services, governed by the Consolidated Finance Act (TUF), or insurance products (Private Insurance Code) or the provisions contained in the Consumer Code. Method of dissemination The Policy is circulated and made available to the company through publication on corporate platforms. Policy for the Prevention and Management of the Risk of Non-Compliance with the Antitrust Regulations and Unfair Business Practices of the Mediolanum Group Content and objectives The Policy describes the principles for preventing and managing the risk of non-compliance with the antitrust regulations defined for the Mediolanum Group and aims to define, as for other compliance risks, the principles for preventing and mitigating the risk of incurring legal or administrative penalties, material financial losses or damage to reputation, as a result of violation of the obligations under competition protection laws (‘antitrust risk’) by Group Companies, and to strengthen governance on antitrust matters and promote a culture of competition. During 2025, the Compliance Function validated the update of the training course relating to Antitrust matters.
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333 | Mediolanum Group - 2025 Annual Financial Report Scope of application The document is directly applicable to all organisational units of the Group’s Companies. Highest level of management responsible for implementation The Policy is approved by the Board of Directors of the Parent Company Banca Mediolanum. The Chief Executive Officer is responsible for implementing the principles and guidelines governed by the Policy in question. Regulations and reference standards Through this Policy, the Mediolanum Group undertakes to comply with and implement the main antitrust regulations and guidelines based on the Treaty on the Functioning of the European Union (TFEU), which is applied in Italy through the Antitrust Law, and on the Directive on Unfair Commercial Practices, primarily transposed in Italy by the Consumer Code. They are issued by the main institutions of the European Union such as the Parliament and the Council of the European Union, the European Commission and the European Securities and Markets Authority (ESMA). Stakeholder involvement The interests of stakeholders are taken into account through a process of indirect customer engagement, as well as through the implementation of safeguards and controls to intercept incorrect conduct and ensure that the information provided is clear, understandable and accessible. Method of dissemination The Policy is made available on the company intranet. The Group’s Spanish companies and MIFL, with respect to the relevant IRO, have their own policy aligned with that of Banca Mediolanum, taking into account certain specific national aspects. Policy for Managing Conflicts of Interest with Customers relating to the Distribution of Products and Services Content and objectives The Group’s Italian Companies that distribute products have a Policy in place for managing conflicts of interest with customers relating to the distribution of products and services, in compliance with the principles set out in the Mediolanum Group’ policy for managing conflicts of interest, that describe and explain the guidelines adopted to identify, prevent or, where appropriate, manage situations of conflict of interest that may arise with the customer or between customers in the context of the intermediary’s activities. The principles set out in the Policy and the identification, management and monitoring processes established by them aim to ensure that a conflict of interest does not prejudice the interests of customers, shareholders or other Stakeholders, by identifying, preventing or managing conflicts. The document is monitored and, if necessary, updated normally on an annual basis, or whenever significant circumstances arise that require its amendment and/or supplementation, by the Compliance Function. Scope of application The policies for managing conflicts of interest with customers relating to the distribution of products and services are adopted by the Italian Group Companies that distribute products. Highest level of management responsible for implementation The principles defined in the Policies are approved by the Board of Directors of the relevant Companies. The Chief Executive Officer is responsible for implementing the principles and guidelines governed by the Policy in question. Regulations and reference standards The principles set out in the Policy are identified and applied to ensure compliance with European legislation on conflicts of interest, which, for Group companies that distribute banking products and services, mainly applies to product governance. With specific reference to the distribution of investment and insurance products, these principles are also laid down in the regulatory framework in MiFID II and in the Insurance Distribution Directive (IDD).
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334 | Mediolanum Group - 2025 Annual Financial Report Stakeholder involvement The Mediolanum Group places the customer at the heart of its business strategy, adopting all appropriate measures and tools to ensure that the development of its activities and the pursuit of its business objectives are congruous and work in synergy with the duty to act honestly, fairly and professionally, ensuring that the best interests of its customers are fulfilled. Method of dissemination The Policy is made available on the company intranet; in addition, for Banca Mediolanum, an excerpt of the document is made available on its website, at www.bancamediolanum.it, in the public section ‘Transparency’. The Group’s Spanish companies, with respect to the relevant IRO, have their own policy aligned with that of Banca Mediolanum, taking into account certain specific national aspects, which was updated during 2025. Policy for managing advertising campaigns, events and advertising materials Content and objectives The objective of the Policy is to provide guidelines to prevent and mitigate the risk of any breaches of the legislation on consumer protection and to support the organisational units concerned and the Sales Network in preparing advertising materials and organising information and promotional events for customers or potential customers of the Bank and the Group Companies concerned. The Policy includes, among others, specific principles to prevent greenwashing and social washing phenomena. It defines the characteristics recommended for proper communication regarding sustainability and the environment, while indicating examples of poor practices to be avoided in the promotion and advertising of products and services. Scope of application The Policy applies directly in Banca Mediolanum and is sent for adoption, in accordance with the principle of proportionality and taking into account local regulations and specific characteristics, to all Companies belonging to the Mediolanum Group. Highest level of management responsible for implementation The principles set out in the Policy are approved by the Board of Directors of Banca Mediolanum. The Chief Executive Officer is responsible for implementing the principles and guidelines governed by the Policy in question. Regulations and reference standards Banca Mediolanum has defined its Policy taking into account the main legislative and regulatory references on the subject, including, but not limited to, Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 (MIFID II), EU Directive 2016/97 of the European Parliament and of the Council on insurance distribution (IDD), the ESMA ‘Progress Report on Greenwashing’, the EBA ‘Progress report on greenwashing monitoring and supervision’ and EIOPA ‘ Advice to the European Commission on Greenwashing’. Stakeholder involvement Banca Mediolanum has always focused on matters of consumer protection, particularly aspects relating to the transparency of services and products and, more generally, to the correctness of the information provided in relation to the services and products offered by financial intermediaries to customers, in the context of both promotional and advertising activities and placement and distribution activities. The relevant rules are specifically defined with the aim of protecting customers from any conduct by intermediaries, which may not be based on principles of loyalty, fairness, diligence, clarity of information and transparency of conditions and costs. Method of dissemination The Policy is made available on the company intranet. The Group’s Spanish companies and MIFL, with respect to the relevant IRO, have their own policy aligned with that of Banca Mediolanum, taking into account certain specific national aspects.
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335 | Mediolanum Group - 2025 Annual Financial Report Actions IROs: Achieving a greater market share through initiatives to improve the degree of personalisation of investment plans and customer protection [S4-4 DP 30; 33 b; ESRS 2 MDR-A DP 68] In accordance with its vision, the Mediolanum Group is committed on a daily basis to seeking products and services that prioritise the protection and centrality of the person. The basis for improving the customer experience is the constant search for innovation, personalisation and safety. In 2024 a new working environment was released, Life Planning, which supports Family Bankers in analysing customer characteristics and recognising their life needs, with the aim of helping them find customised solutions consistent with customer-specific needs. The new environment was gradually released to Family Bankers, with a dedicated training course that continued throughout 2025. This is because Banca Mediolanum’s objective is to evolve the Network’s commercial approach towards advice that is more oriented towards the customer’s life goals. The personalised solutions offered with the support of Life Planning are based on the personal characteristics of customers, their life goals and their current and prospective financial situation. In fact, one essential characteristic of the Life Planning path is the monitoring over time of both solutions for the goals identified and, above all, the modification and evolution of these goals in relation to the life path of the customer. This creates a long-term relationship with the customer based on listening and mutual trust. Also on the corporate platform for the Family Banker network, BMedRed, Banco Mediolanum has a ‘Mis Metas’ application aimed at managing the life goals set by customers, which allows the most suitable products and services to be combined for the same customers. During 2024, the application was made available to customers, who can autonomously view, or introduce new goals, and, consequently, with the support of their Family Banker, assess their investments. In 2025, the ‘Mis Metas’ tool underwent technological developments, with features, among other things, allowing customers to view in their private app the goals managed by the Family Banker via the ‘Las Metas de Mis Clientes’ application on BMedRed. In addition, the shared objectives configuration feature was implemented, allowing multiple holders to view the same objective. [S4-4 DP 31 d] One key element in measuring the effectiveness of the initiatives is customer satisfaction questionnaires, regularly administered to customers taking out loans. These tools allow for feedback to be collected both on the actual satisfaction of the need for which the product/service was purchased, and on the overall customer experience (see ESRS S4, paragraph 3.4.3, Access to (quality) information, section ‘Actions’, DP 30; 31 c for further details on Customer Satisfaction questionnaires). In addition, for the Spanish Subsidiary, the adoption ‘Mis Metas’ by the sales network is monitored by the Strategic Marketing Department, through periodic reports that show usage both at an aggregate level and by area, structure, salesperson and other detailed levels. IROs: Purchasing decisions by consumers not aligned with their real needs, influenced by unfair, misleading or aggressive business practices, including greenwashing and social washing, relating to the products offered [S4-4 DP 30; 31 a; ESRS 2 MDR-A DP 68] During 2025, the Compliance Function of each Mediolanum Group company, as part of the oversight of the relevant regulations and with particular reference to changes in the regulatory framework, carried out both ex ante assessment and ex post control activities to oversee compliance risks, including those related to ESG matters, with specific regard to areas that affect customers or potential customers.
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336 | Mediolanum Group - 2025 Annual Financial Report In detail, the activities, for all types of risks monitored by the Function, are structured on the basis of the stages typical of the methodological framework of the Function: ex ante advisory support for the process owner structures in relation to areas and legislation directly overseen and relating to the distribution of products with potential impacts for customers or potential customers (e.g. greenwashing). In the context of product governance, the conformity of the product selection process is checked, before the products’ marketing, both for new and substantially modified products. In relation to ex post control activities on the same areas, the Compliance Function identifies any mitigation actions to overcome the shortcomings detected, including internal regulatory updates, new safeguards and controls, ICT integration, organisational reviews, training initiatives and strengthening line controls. It should be noted that, in order to enable adequate Group coordination on a continuous basis, the Parent Company’s Compliance Function carries out supervision and coordination activities in relation to the corresponding functions of the foreign Subsidiaries, identifying and preparing adequate information flows, so as to direct and share any information relevant to monitoring the risk of non-compliance with the regulations in scope, complying with local specificities. In addition, the Function has periodic interactions with the Insurance Group in order to exercise its guidance and coordination role at the conglomerate level and with the aim of gradually adopting a homogeneous, shared control methodology. Specifically with regard to the transparency and adequacy of the banking offering, within the Italian scope, the Bank’s Customer Protection Unit, within the Communication, Bank Marketing and Digital Channels Department, oversees and coordinates activities relating to the regulations in force on consumer protection and, more generally, to the principles of transparency, diligence and fairness that must characterise the activities of financial intermediaries. The Unit strengthened its collaboration with consumer associations through constructive dialogue and the sharing of initiatives and activities with customers. It also continued its relations with disabled associations and renewed the Bank’s membership of the European Disability Charter. The Banking Transparency Management Office and the Usury Management Office operate within the Customer Protection Unit. The Unit performs the activities of governance and supervision of the requirements and obligations established by applicable legislation. Banking Transparency is regulated by a rather complex regulatory framework. The main aims are the comparability of products through the use of comprehensive cost indicators and the standardisation and simplification of information documents in order to communicate transparently to the customer. The projects and measures currently under way in the area of Banking Transparency aim to strengthen oversight of the quality of the process of creating and reviewing information material and increasingly improving communication to customers, making it clearer, more complete and more accessible. Consistent with the oversight and transparency activities described, all companies in the Mediolanum Group operate according to principles of the transparency, fairness and completeness of information. In this context, the Compliance Functions provide oversight to ensure customers are informed about the essential elements of the contractual relationship and any changes thereto, mitigating legal and reputational risks and thus contributing to sound and prudent corporate management. In this context, the Compliance Functions are systematically involved in the customer complaints management and analysis process, and, during dedicated periodic meetings, examine the main types of complaint as a tool for monitoring compliance and operational risks, contributing to the identification and assessment of any critical issues regarding the fairness of commercial practices, transparency of information and adequacy of organisational and procedural safeguards. [S4-4 DP 31 d]
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337 | Mediolanum Group - 2025 Annual Financial Report The ex-post controls carried out by the Compliance Function, from which any mitigation actions may arise, and the progress of these, are reported periodically to the corporate bodies at least once a quarter, on the basis of a verification plan approved annually by the Board of Directors. [S4-4 DP 32 a] The Compliance Function identifies business processes that expose the Company to the main compliance risks specific verification measures are planned for these, taking into account any shortcomings that may have been found in the controls previously carried out and any new risks identified as a result of changes in the regulations and in the Company’s business. The process control model assesses the risk exposure of each activity that makes up the process, verifying existing safeguards and carrying out controls to determine their effectiveness and completeness in order to express an opinion on the compliance of the process with current regulations. [S4-4 DP 32 b] In particular, the Compliance Function carries out specialist advisory activities, for the purposes of the assessment of compliance risk, constant monitoring of the external regulatory environment (regulatory alerts), assessment of the impact of regulations (gap analysis) on corporate processes, adequacy checks (through the identification of proposed changes, including organisational and procedural changes, arising from gap analysis, assessments and opinions) and checks on the functioning of corporate structures and processes, with the aim of preventing any breach of mandatory or self-regulatory rules and monitoring the adoption of the proposed corrective measures. Specifically in the area of product governance, the Function carries out checks on new banking, insurance or investment products before they are marketed, and also in the case of sustainable changes, ensuring consistency over time with the requirements of applicable regulations on the distribution of sustainable products. The prevention of compliance risk is also linked to the timely detection of symptomatic signs of risky situations, which could involve direct or indirect damage that takes the form of sanctions or is economic or reputational in nature. For this reason, as part of the overall control and risk mitigation framework, the Compliance Function uses a specific set of indicators for the remote analysis and monitoring of operational behaviour with regard to certain regulatory areas. To this end, each month it collects, processes and analyses data relating to compliance risk factors: the key compliance indicators (KCIs), divided by regulatory area and type. The indicators collected are not necessarily the source of compliance risk, but are elements that, following appropriate investigations, could highlight anomalies, errors or malfunctions, or business trends that may entail the need to define further safeguards to mitigate compliance risk. The information deriving from the periodic analysis of the KCIs also helps to direct the ex-post control activities of the Function and to assess, during the year, the need to carry out specific investigations. In relation to verifications of the functioning of corporate structures and processes designed to prevent breaches of mandatory or self-regulatory rules, ‘mitigation’ actions are included, which are shared with the heads of the company structures concerned (owners), making use, where necessary, of the support of internal corporate structures. Mitigation actions provide for the definition of a timescale for their implementation and are regularly monitored by the Function, interacting, where necessary, with the owner of the action and with the organisational units responsible for the adaptation measures. The activities and oversight of the Compliance Function, as outlined for the Italian perimeter, are also on a par with the Spanish subsidiary, which operates under a Compliance framework harmonised with the same principles and processes. [S4-4 DP 32 c]
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338 | Mediolanum Group - 2025 Annual Financial Report At least once a year, the Compliance Function presents to the corporate bodies a report on the activities carried out in the previous year, which describes the advisory and control activities carried out, the results that were found, any weaknesses detected and any measures identified to remove them, as well as the activity plan for the following year. In addition, on a quarterly basis, it submits to the Risk Committee, where applicable, and to the Board of Directors, a periodic report on the activities carried out, with reference to both advisory and supervisory activities, with reference to the specific observation period. The reports are also made available to the Supervisory Authority (ECB) together with the minutes of the Board meetings. As for the Parent company, the Compliance Function in the Group’s Spanish companies submits an annual report to the Corporate Bodies on the previous year’s advisory and monitoring activities, as well as the plan for the following year. On an annual basis, with regard to the provision of investment services, it draws up a report for the Corporate Bodies detailing the results of controls carried out in this area, while on a quarterly basis it presents a periodic report to the Joint Audit and Risk Committee and to the Board of Directors on the activities carried out, the results obtained, the weaknesses identified, as well as the proposed mitigation actions. The reports are made available to the Supervisory Authorities. [S4-4 DP 34] Mediolanum’s focus on protecting the main aspects of our customers’ lives is fully integrated into its offer of products and services. In fact, the offering is designed and updated in line with the product governance principles defined by the reference regulations. In order to enable customers to relate to the financial world in the best possible way and foster an understanding of its main characteristics, Banca Mediolanum – with the support of the Customer Protection Unit – fully complies with the transparency requirements that serve to provide the necessary clarity of information. [S4-4 DP 37] The resources assigned to managing material impacts relating to ‘Purchasing decisions by consumers not aligned with their real needs, influenced by unfair, misleading or aggressive business practices, including greenwashing and social washing, relating to the products offered’ impact are mainly attributable to the organisational units that carry out the following activities: oversight of areas relating to the financial advisory services adequacy model adopted by the Bank and governance of the placement of all types of financial products offered to customers; monitoring of the requirements and obligations established by legislation on transparency, and the correct performance of the process and the related requirements in the area of Product Oversight and Governance (POG), including aspects relating to accessibility. To these are added the resources of the Compliance Function, for both the Italian and Spanish Companies, who have adequate knowledge of the regulations and the business model, as well as of the products. The Function is required to provide support to the corporate structures indicated above in the assessment of the risks of non- compliance with the rules, through specialist ex ante advisory activities as well as ex post control activities. As part of the product governance processes, the Function monitors and supervises the consistency, adequacy and effectiveness of the governance and control procedures for the products and services issued by the Bank throughout their life cycle, from creation to monitoring. To this end, the Function provides an ex ante conformity assessment for each new product or for each substantial change to existing products, whether banking, insurance or investment products, as well as ex post control activities. Activities related to products issued by third parties and marketed by the Bank are carried out solely within the distributor’s areas of responsibility. [S4-4 DP 35] No serious consumer and/or end-user-related human rights issues and incidents were reported during 2025.
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339 | Mediolanum Group - 2025 Annual Financial Report Targets [ESRS 2 MDR-T DP 72; 81 a; 81 b] IROs: Achieving a greater market share through initiatives to improve the degree of personalisation of investment plans and customer protection; Purchasing decisions by consumers not aligned with their real needs, influenced by unfair, misleading or aggressive business practices, including greenwashing and social washing, relating to the products offered No specific quantitative targets have been set for the two IROs in question to date. In particular, with regard to the opportunity ‘Achieving a greater market share through initiatives to improve the degree of personalisation of investment plans and customer protection’, the absence of quantitative objectives is due to the fact that the Life Planning platform represents an evolution of the relationship model between the customer and the Family Banker, and requires a gradual adoption process. Therefore, during 2025 the focus was primarily on training the Network and providing support for using the platform, together with monitoring carried out through: standard first-level reporting that monitors the accessing of the platform, the saved projects and the related areas of need analysed with the customer; second-level reporting by the analytical CRM structure, which adds more in-depth analysis to this monitoring. In particular, the main indicators used are: adoption indicators, aimed at determining, for each Family Banker, how many of the customers in target were subject to at least one interaction based on the Life Planning platform; business development indicators, aimed at understanding the effects of the new method on the development of the relationship and the consequent business KPIs in the various areas of need covered. With regard to the Mis Metas service, no quantitative targets have been set to date and, with a gradual increase in the use of the instrument by customers, monthly monitoring of data trends is carried out. With regard to the IRO ‘Purchasing decisions by consumers not aligned with their real needs, influenced by unfair, misleading or aggressive business practices, including greenwashing and social washing, relating to the products offered’, although no quantitative objectives have been set, the Compliance Function continuously oversees the compliance risk to which the company is exposed, with reference to the above issues (unfair, misleading and/or aggressive commercial practices, greenwashing or social washing of the products offered). To this end, it carries out the following activities: monitoring of regulatory changes and checking the adequacy and functioning of organisational safeguards (structures, processes, operating and commercial procedures) as well as the effective implementation of the suggested measures to prevent the risk of non-compliance with the rules; development and monitoring of specific risk indicators in order to detect any anomalies in the context of compliance risk (Key Compliance Indicator - KCI); in the context of product governance (POG), checks products before they are marketed, also in the case of substantial changes, with regard to the requirements established by the reference legislation for the distribution of sustainable products; ex post checks on the same areas, issuing any mitigation actions and informing the corporate bodies in the context of ordinary reporting activity. The activities carried out by the Compliance Functions of each Mediolanum Group company, in connection with the management of this IRO, constitute oversight, monitoring and business support. This nature does not allow for the definition of quantitative objectives, since the effectiveness of the activities is assessed mainly in qualitative terms and in compliance with regulatory and procedural safeguards.
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340 | Mediolanum Group - 2025 Annual Financial Report 3.4.6 Freedom of expression [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Freedom of expression Protection of customers’ freedom of expression through effective whistleblowing/complaint systems Actual positive impact Downstream value chain Short term The Group’s approach and policies The protection of customers’ freedom of expression is a significant issue for Mediolanum, which has gradually implemented structured systems through which they can submit any reports or complaints. The Mediolanum Group has defined specific policies aimed at ensuring proper and transparent handling of complaints. In addition to the Code of Conduct and the Policy on Customer Protection, which refer to the general principles protecting customers (see ESRS S4 Consumers and end-users, paragraph 3.4.3 Access to quality information, section ‘Actions’ for further details on the policies), the Group has adopted a Complaints Management Policy, which formalises the process and governs its operating procedures. [S4-1 DP 15; ESRS 2 MDR-P DP 65] IROs: Protection of customers’ freedom of expression through effective whistleblowing/complaint systems Policy on Complaints Management Content and objectives In compliance with regulatory provisions on banking, finance and insurance, the companies of the Mediolanum Group have adopted a structured process for managing complaints, formalised in the Complaints Management Policy, the latest updates of which were approved in 2025. In addition to ensuring legal compliance, the complaints management process aims to ensure customers have prompt and exhaustive feedback, to help overcome any critical issues that have emerged, and to promote the continual improvement of company services and processes. The control activities relating to the complaints management process consist of first-, second- and third-level controls (see ESRS S4 Consumers and end-users, paragraph 3.4.6 Freedom of expression, section ‘ Actions’, DP 31d for further details). The Banca Mediolanum Policy applies to complaints addressed to the Institution in its role as banking, financial, insurance and pension intermediary, including those relating to the conduct of employees and contract staff in insurance brokerage activities. Scope of application The Policy is directly applied by Banca Mediolanum and is sent to the Companies of the Mediolanum Banking Group to which the regulations contained in the Policy are applicable, so that they can adapt their internal regulations, based on the specific nature of each one, and on the proportionality criteria. The document is also sent to Mediolanum Vita, the Parent Company of the Mediolanum Insurance Group, so that, likewise, it can adapt the internal regulations of the Insurance Group with the same attention as mentioned above for the Banking Group. Similar procedures have been put in place for the Group’s non-Italian Companies to ensure the correct handling of any complaints received, and to provide regular reports to the Parent Company.
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341 | Mediolanum Group - 2025 Annual Financial Report Highest level of management responsible for implementation This document is approved by the Board of Directors of Banca Mediolanum. The updating and review of the Policy is the responsibility of the Disputes, ADR and Claims Section within the Corporate, Legal Affairs and Litigation Department. The Chief Executive Officer oversees the implementation of the strategic guidelines and risk governance policies defined by the Board of Directors and is responsible for adopting all necessary measures to ensure the consistency of the organisation and internal control systems with the guidelines defined, monitoring their compliance. Regulations and reference standards The main legislative and regulatory references on the handling of complaints used to prepare the document are the EBA/ESMA/EIOPA Guidelines ‘Guidelines for complaints-handling for the securities (ESMA) and banking (EBA) sectors’ of 27 May 2014; the EIOPA Guidelines on Complaints Handling by Insurance Intermediaries (EIOPA BoS-13/164 [T); ISVAP Regulation No.24 of 19 May 2008 as amended; the COVIP Resolution of 4 November 2010: ‘Instructions for the handling of complaints’; the Intermediaries’ Regulation adopted by CONSOB Resolution No.20307 of 15 February 2018 and the Order of the Bank of Italy of 29 July 2009 as amended, concerning the ‘Transparency of banking and financial transactions and services’. Banco Mediolanum adopts similar policies to the Parent Company, including the Complaints Management Policy (‘Política de gestión de las reclamaciones’). There are no material differences compared with Group policies, except where required by local regulations and the specific circumstances of the Subsidiary. Actions IROs: Protection of customers’ freedom of expression through effective whistleblowing/complaint systems [S4-4 DP 30; 31 c; ESRS 2 MDR-A DP 68] During 2025, the Complaints Office carried out periodic activities according to its responsibilities. Specifically: • the annual publication on the website, in the complaints section, of the report on complaints handling activities, which summarises the data and types of reports received by the undertaking, as well as their outcome and the main actions taken in response to the matters that arose; • the provision of periodic and ongoing training initiatives aimed at providing up-to-date knowledge of tasks, duties and new regulations relating to its duties. In particular, in 2025, the training plan included the following initiatives: o IVASS update; o three training sessions with the support of an external law firm; o five internal training meetings; • analysis of the reasons underlying the complaints to improve customer service and, where appropriate, launching improvement activities, in addition to monitoring those already launched. The results of the analyses are reported specifically to the corporate bodies.
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342 | Mediolanum Group - 2025 Annual Financial Report The analysis of complaints received as at 31 December 2025 took account of all complaints received in writing, by fax, letter, email, certified electronic mail (PEC), telegram or other permitted form, from customers or potential customers (prospects) of the Group, in relation to banking and investment services and insurance intermediation provided by the Group. During 2025, the Mediolanum Group received a total of 6,075 complaints, in line with the figure for 2024 (6,017): of these 5,957 were ‘processable’ and 118 ‘non-processable’ (i.e. complaints that do not identify the complainant or the product subject to the complaint), as they lack the essential information to be adequately handled. The number of ‘reopened’ complaints (i.e. for which customers did not consider the response received in the first instance to be satisfactory) was 614, up slightly compared to 2024 (572). The channel most used by customers to send complaints was certified email, used in around 45% of cases. Of the 6,075 complaints received overall, approximately 78% were addressed to Banca Mediolanum and Prexta. Banco Mediolanum, through the Customer Service function, handles the complaints and disputes that customers submit. The activity of this function is governed by the relevant Regulation, drawn up in accordance with the provisions of Order ECO/734/2004 of 11 March 2004. The Subsidiary complies with provisions in force on the handling of complaints, periodically collecting relevant information for the continual improvement of services provided to customers. In addition, in accordance with the provisions of Spanish Royal Decree-Law 1/2017 of 20 January 2017, concerning measures to be adopted for the protection of consumers to whom the ‘floor’ clause had been applied, Banco Mediolanum has drawn up a procedure for examining requests by customers for the return of sums paid, if not due, under the clause in question. The management and resolution of requests submitted are the responsibility of the Analysis Unit for Requests for the Application of Decree-Law 1/2017. ABF and ACF appeals In 2025, 118 appeals were received from the Banking and Financial Arbitrator (ABF), 83 of which related to Banca Mediolanum and 35 of which related to Prexta, for a total petitum of €1,432,544 (of which €1,403,422 related to Banca Mediolanum and €29,122 to Prexta). During the same period, 116 cases were resolved, including 72 related to Banca Mediolanum and 44 to Prexta. With regard to the Bank, rulings resulted in an outlay of €26,089, while for Prexta, 31 rulings resulted in an outlay of €11,327. In 2025, 18 appeals were also received from the Arbitrator for Financial Disputes ((CF) for a total petitum of €452,803. In the same period, 21 cases were finally settled, resulting in a total outlay for the company of €236,603. [S4-4 DP 31 d] Banca Mediolanum is constantly committed to meeting the deadlines established by the regulations, regularly monitoring them and, during 2025, no significant issues were found in this regard. Banco Mediolanum also complies with the provisions in force on the handling of complaints, periodically collecting relevant information for the continual improvement of services provided to customers. [S4-4 DP 35] In 2025, with regard to consumers and end-users, the Group’s Italian Companies were not notified of any breach and consequently no penalties and/or measures arose in the area of Human Rights. Banco Mediolanum, on the other hand, received a complaint relating to a violation of human rights affecting consumers and end-users. In particular, the customer reported that an operator did not address him using the correct gender, perceiving this as a violation of his rights. The complaint was successfully resolved, in accordance with the prescribed procedure. [S4-4 DP 37] The following Departments of Italian Companies are in charge of managing the impact ‘Protection of customers’ freedom of expression through effective whistleblowing/complaint systems’: Services, Operations & ICT Department Corporate, Legal Affairs and Litigation Department
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343 | Mediolanum Group - 2025 Annual Financial Report The handling of complaints and disputes in the Spanish companies is entrusted to the Servicio de Atención al Cliente office, which performs the same function as the Complaints Office in the Group’s Italian companies. In general, the considered is adequate in terms of number and professionalism. This professionalism is ensured over time, also due to continuing professional development, including, among other things, participation in annual training initiatives organised as part of the broader training offered to all staff. Staff employed in the relevant Offices are given specialist training to deal with matters relating to the specific activity carried out. Targets [ESRS 2 MDR-T DP 72, 81 a, 81 b] IROs: Protection of customers’ freedom of expression through effective whistleblowing/complaint systems Although it is not possible to define a quantitative objective due to the type of activity, the Group Companies aim to provide comprehensive responses and limit as far as possible the number of complaints ‘re-opened’ at the request of customers not satisfied with the feedback received, by taking action if anomalies are found that could have repercussions on customers, including those who do not submit the complaints. In addition, the Group Companies undertake to comply with the management times established by current legislation. Compliance with the deadlines established by law is regularly monitored and, in 2025, no significant phenomena were detected that should be reported in this regard. For each individual complaint, every possible useful action is taken to resolve the individual problem; in cases where this anomaly has an impact, even only a potential impact, on other positions, the necessary measures are taken. 3.4.7 Commitments related to the Protection of Human Rights Policy of the Mediolanum Group [S4-1 DP 16] In line with its corporate culture, the Mediolanum Group is committed to respecting and promoting human rights (see ESRS S1 Own Workforce, paragraph 3.1.6 Equal treatment and opportunities for all, section ‘Policies related to own workforce’, DP 19 for further details on the Policy for the Protection of Human Rights of the Mediolanum Group) as part of its activities and to preventing or otherwise minimising any breach directly caused by its actions. The Mediolanum Group’s Policy for the Protection of Human Rights defines the Group’s commitment to the protection of Human Rights according to the highest international standards, in particular the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and OECD Guidelines for Multinational Enterprises. [S4-1 DP 16 a] Relations with customers are one of the Group’s principles and commitments to its Stakeholders. In general – and, therefore, regardless of the specific type of product and/or service in question, – the information provided during any form of dialogue with customers must be expressed in a clear, understandable and accessible manner, taking due account of the level of financial literacy and digital skills of the customers to whom they are addressed and, in general, the accessibility and transparency requirements stipulated by current legislation. In particular, the Mediolanum Group is particularly careful to offer customers only products and/or services that meet their situation and requirements, facilitating their understanding of terms and conditions, benefits, risks and costs and avoiding any unjustified discrimination, all in accordance with the Group’s Code of Conduct. The Group promotes respect for Human Rights to its customers, as well as the application of its sectoral policies and the Code of Conduct, inter alia, which provide for measures related to the exercise of due diligence to prevent, mitigate and manage human rights impacts. [S4-1 DP 16 b; 16 c]
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344 | Mediolanum Group - 2025 Annual Financial Report For further details on the Mediolanum Group’s Policy for the Protection of Human Rights, see ESRS S3 Affected Communities, paragraph 3.3.2 Economic, social and cultural rights of communities, section ‘The Group’s approach and policies’, DP 16b; 16c; 17. [S4-1 DP 17] In the area of the protection of consumer and employee data, the Company protects Human Rights, in line with the commitments of the Mediolanum Group, formalised in the ‘Policy for the Protection of Human Rights’, defined in compliance with international regulations, and with its adherence to the UN Global Compact, a United Nations initiative. All cybersecurity policies are based on recognised international rules and standards (e.g. NIST SP 800- 53). To date, there have been no breaches of the Global Compact Principles regarding customers, confirming the Group’s commitment to ensuring compliance with the highest international standards. 3.4.8 Processes for engaging with consumers and end-users about impacts [S4-2 DP 20] The Mediolanum Group involves its customers in terms of actual and potential material impacts, both through the action of the Family Banker Network spread throughout the region and through a series of structured processes. These include the assessment of customer satisfaction and periodic customer experience surveys, carried out quarterly on specific topics. In addition, the Group monitors brand reputation through special surveys, organises events on the ground to strengthen direct dialogue, and uses social networks and direct communication tools such as MPM and direct mail to ensure continuous and targeted engagement. Customer satisfaction assessment On an annual basis, in both the Italian and Spanish regions, a customer satisfaction survey is carried out with the aim of analysing both overall customer satisfaction with the Mediolanum Group and satisfaction with certain detailed aspects (e.g. product satisfaction and clarity in communications) (see ESRS S4 Consumers and end- users, paragraph 3.4.3 Access to (quality) information, section ‘Actions’ for further details on the initiative). Regional events [S4-2 DP 20 b] Events are an important tool for Banca Mediolanum for customer relationships and dialogue – actual or potential – on both economic and financial matters, as well as on non-banking matters. In 2025, more than 3,000 events were held, either directly by the Head Office or through the regional Sales Network, involving more than 200,000 participants, in person or digitally. In addition, major national events were organised in person, with simultaneous direct streaming on all of the Bank’s social media channels. The following should be noted in particular: • the ‘La Musica del Cuore’ (‘Music of the Heart’) charity event held in November at the Duomo in Milan, in support of the ‘Insieme per il nuovo Buzzi’ (‘Together for the new Buzzi Hospital’) project of Fondazione Mediolanum, where guests were able to participate in fundraising in support of this project; • the ‘Dai forma al tuo Futuro’, (‘Shape Your Future’) tour, an event divided into various stages taking place throughout the country, the contents of which have been developed with a view to increasing and enriching clients’ financial literacy. Overall, some 800 thousand spectators were involved in these two events, including around 2,600 in person. In relation to Banco Mediolanum, 987 events were held in Spain in 2025, organised by the local Family Bankers, with the participation of more than 29,100 people. For its part, the Headquarters organised 53 privilege events with over 1,700 participants, held a market session with more than 1,000 attendees, and sponsored several music festivals. [S4-2 DP 20 a]
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345 | Mediolanum Group - 2025 Annual Financial Report Consumer engagement takes place directly with end-customers. [S4-2 DP 20 d] In order to monitor customer satisfaction with the events held in the region, a satisfaction questionnaire was submitted by telephone to the participants (on average 15% per event) in which feedback and any useful suggestions to guide the next initiatives were collected. [S4-2 DP 20 c] The Communication, Bank Marketing and Digital Channels Department is responsible for ensuring that the engagement takes place and that the results guide the undertaking’s approach. In Spain, this involvement is overseen by the Marketing area, Eventos y Fidelización, reporting to the Marketing, Communication and Channels Department, Dipartimento Marketing, Comunicación y Canales of Banco Mediolanum. ISO 20121 sustainable events [S4-2 DP 20 a] Over the years, the Mediolanum Group has established guidelines and procedures relating to the criteria of environmental, social and economic sustainability that must be taken into account at all stages of an event, providing a description of the principles adopted by Banca Mediolanum on the subject of sustainable management of events, according to the international standards defined by ISO 20121. Events with ISO 20121 reporting are generally aimed at the Sales Network, which represents customers and their interests; these events are organised with full management of the expenditure by the Events Organisation Office. [S4-2 DP 20 b] The frequency with which the Mediolanum Bank’s Sales Network is involved varies according to the planning arising from the commercial requirements dictated from time to time by the Commercial Network Department. [S4-4 DP 20 c] Within the Group, Senior Management for the Sustainable Events Management System (SGSE), supported by the Sustainability Office and the Head of the Communication, Bank Marketing and Digital Channels Department, guides decisions regarding the sustainability of events. In Spain, this involvement is overseen by the Marketing area, Eventos y Fidelización, reporting to the Marketing, Communication and Channels Department, Dipartimento Marketing, Comunicación y Canales of Banco Mediolanum. [S4-2 DP 20 d] For ISO 20121 Sustainable Events, questions were prepared to assess the effectiveness of the communication and involvement of the Sales Network at the National Convention, within the broader Event Survey. The effectiveness of actions is measured by ad hoc ex post reporting that assigns a score for each item analysed in the three categories (social, environmental and economic sustainability) in question. The overall result shows very high scores, thanks to a strong focus on choices that favour local suppliers with a consequent reduction in environmental impact and a positive impact on communities. Overall, the other items analysed (e.g. Stakeholders’ needs, food recovery, inclusivity, total exclusion of discrimination, well-being of resources) have also had positive results. In 2025, in continuation of the activities of previous years and in the light of the objectives received from the Review of Sustainable Management of Events, the Production & Services Office, in collaboration with the Sustainability Office, analysed, from the point of view of sustainability, at a qualitative level, 163 events, comprising: • 45 events in digital mode only; • 10 hybrid events; • 108 in-person events.
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346 | Mediolanum Group - 2025 Annual Financial Report Promotional campaigns [S4-2 DP 20 b] In 2025, the Banca Mediolanum Campaign Management Office launched multiple commercial campaigns, maintaining a constant flow of communications to customers and prospects, further exploiting the multi-channel approach and increasing the level of personalisation of targets and content to ensure greater consistency with the customer’s profile and needs. A total of 81,960,655 commercial communications were handled during the year. With respect to institutional and regulatory communications, a total of 44,996,236 documents were handled. During the year, several commercial campaigns were carried out with a priority focus on matters related to environmental and social sustainability, as well as solidarity. Specifically: • in support of Fondazione Mediolanum EF, in order to encourage subscriptions to the ‘ Centesimi che contano’ (Cents that count) service for Banca Mediolanum, commercial communications were made by email, banner, website and application, aimed at raising customers’ awareness of the service and inviting them to support beneficiary projects such as Dynamo Camp. The Cause Related Marketing campaign was also structured. In addition to an information banner on the entire customer base, an email was also sent out to thank customers who subscribed to a current account, card, health insurance or investment fund product in the October –December quarter. In synergy with Fondazione Mediolanum EF, the Bank in fact donated a sum to charity for each target product subscribed in the quarter indicated; • during the year, several commercial initiatives were implemented to promote products protecting against damage and to raise awareness of the importance of protection in household financial planning. The contents were aimed at protecting people’s health and safety from the most significant risks; • several campaigns were carried out during 2025 to mitigate the risk of fraud, addressing major security issues including: the family emergency scam, investment scams, fraudulent payment drives and quishing. Furthermore, the content provided by Certfin has been disseminated and the key concepts on fundamental rules to protect against scams, cyber fraud and telephone fraud have been renewed a number of times. To ensure the widespread dissemination of information, various communication channels were used, including emails, banners, layer app postlogins, the ‘Security’ section of the website, which describes the different types of fraud and scams perpetrated against customers (e.g. phishing, spoofing, etc.) and how these can be used by fraudsters in combination, to be more effective, as well as a monthly presence in the newsletter sent to all customers; • in terms of environmental sustainability, the communication campaign promoted by Mediolanum Assicurazioni and Mediolanum Vita continued during the first half of 2025, to raise awareness among customers of the digitisation of communications on their policies and with the aim of continuing in 2026. [S4-2 DP 20 a] Consumer engagement takes place directly with end-customers. [S4-2 DP 20 c] The Communication, Bank Marketing and Digital Channels Department is responsible for ensuring that the engagement takes place and that the results guide the undertaking’s approach. In Spain, this involvement is overseen by the Marketing area, Eventos y Fidelización, reporting to the Marketing, Communication and Channels Department, Dipartimento Marketing, Comunicación y Canales of Banco Mediolanum. [S4-2 DP 20 d]
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347 | Mediolanum Group - 2025 Annual Financial Report The effectiveness of customer engagement in commercial campaigns is measured by trends in product and service adherence, comparing pre- and post-initiative results that are necessarily related to the delivered content. In the Spanish subsidiary, an online survey is carried out to monitor customers’ satisfaction with their participation in privilege events, where they provide their evaluations of the event organisation, as well as comments and/or suggestions. Social networks [S4-2 DP 20 b] The Group’s presence on the main social networks (e.g. Facebook, Instagram, LinkedIn, X, TikTok) provides for the native possibility of the platforms to receive publicly visible comments and private messages from unidentified users. Although these channels do not represent a caring touchpoint included in those formally provided to customers, their potential relevance from a reputational point of view and the opportunity to listen to the opinions of users mean that these forms of interaction should be managed, constantly monitored and increased. This takes place as defined by the Process Regulation - Oversight of Social Media Channels; in particular, there is provision for taking responsibility for comments and messages that represent a form of request for information or assistance or a complaint, managed where possible at the first level (therefore directly by the Digital Marketing Office) or escalated to other offices competent for the subject matter covered in the conversation. In 2025, around 417 caring requests were handled, compared with more than 5,100 comments and 5,700 mentions and direct messages. [S4-2 DP 20 a] Consumer engagement takes place directly with end-customers. [S4-2 DP 20 c] The Communication, Bank Marketing and Digital Channels Department is responsible for ensuring that the engagement takes place and that the results guide the undertaking’s approach. In Spain, this involvement is overseen by the Marketing area, Eventos y Fidelización, reporting to the Marketing, Communication and Channels Department, Dipartimento Marketing, Comunicación y Canales of Banco Mediolanum. [S4-2 DP 21] In order to gain a better understanding of the customers’ point of view, in 2025, Banca Mediolanum’s collaborative relationship with consumer associations was strengthened through constructive dialogue and the sharing of initiatives and activities with customers. Similarly, the Bank continued its relations with Associations for the disabled. In Spain, 2025 was marked by Banco Mediolanum’s efforts to adapt its channels to accessibility requirements. To this end, it was assisted by external consultants, to identify the needs of segments of society particularly sensitive to this issue.
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348 | Mediolanum Group - 2025 Annual Financial Report 3.4.9 Processes to remediate negative impacts and channels for consumers and end- users to raise concerns [S4-3 DP 25 a] In accordance with applicable legislation, the Mediolanum Group has adopted a structured and codified process for handling complaints, while at the same time providing comprehensive responses, aware that full customer satisfaction, as well as being a priority element of its strategy, is an important factor for developing and spreading a good corporate image within the market. Complaints are constantly monitored to identify any critical areas related to the products, services and operational processes. If elements are identified that may influence the characteristics of products and services, or the correctness and transparency of the procedures adopted, corrective actions and improvement measures are promptly initiated. The number of substantiated complaints is very limited and, each year, only a small number of complaints require specific action. [S4-3 DP 25 b] Customers who believe that they have not received a level of service appropriate to their expectations may contact Banca Mediolanum free of charge through the Customer Banking Centre or their Financial Advisor, indicating the reasons for this dissatisfaction and suggesting possible remedies. If it has not been possible, for any reason, to overcome the differences, the customer may address a complaint directly to the Complaints Office, whose contact details are provided in the relevant section, ‘Complaints, appeals (ABF/ACF/AAS) and settlements’, on the Bank’s website and in the contractual material. The Complaints Office (in Spain, Servicio de Atención al cliente) is exclusively responsible for handling complaints received. When sending definitive responses to customers, it uses language that is simple and easy to understand, based on the fair treatment of the customer, with a view to ensuring proper and timely handling of the complaint. According to the complaints management procedures, activities performed for customers by the staff responsible for handling complaints are free of charge. Additional channels made available by the undertaking and dedicated to customers are available to raise any concerns, including social media and the free helpline. Channels made available through participation in third- party mechanisms, with reference to Italian Group Companies, include the Il Sole24Ore offices. With regard to the Spanish Subsidiary, if customers are not satisfied with the reply provided, they may contact the complaints services of the Bank of Spain, the Comisión Nacional del Mercado de Valores or the Dirección General de Seguros y Fondos de Pensiones, depending on the subject matter of the complaint. [S4-3 DP 25 c; 25 d] The Group Companies report on their websites, providing adequate information on the home page, in customer guides, in contractual files and in information sheets the most material information concerning the handling of complaints, information on how they were presented to the undertaking, the response time required by law and the corporate department responsible for examining complaints with the relevant contact details. The complaints management procedure records the essential elements of each complaint received, together with any measures taken on behalf of the customer to resolve the problem. Each complaint received, also classified according to the service/product provided, is assigned a numerical code enabling its unique and progressive identification on an annual basis. The Complaints Offices of the Companies (for example the Servicio de Atención al cliente in Spain) are also responsible for highlighting, during the management of complaints received, any recurrent or systemic problems and the need for certain actions to mitigate the risk and/or improve the processes or procedures adopted, emerging from an analysis of the cases managed, involving, where necessary, the second-level Corporate Functions and some organisational structures involved in the issue in question, such as, the Organisation and Project Management Division and the Customer Protection Unit in Italy.
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349 | Mediolanum Group - 2025 Annual Financial Report Specific organisational structures therefore draw up the necessary information and periodic reports on complaints, including for the Board of Directors and the control functions/bodies. The annual report on the control and monitoring of issues is also incorporated by the Compliance Function in its yearly review, highlighting any areas of concern identified during the year under review, such as procedural, organisational and behavioural shortcomings described above. The Compliance Function, as part of its overall control plan, also carries out periodic checks on the complaints management process, with particular reference to identifying any procedural, organisational and behavioural shortcomings, issuing specific mitigation actions to be implemented by the process owner within the company. During 2025, the progress of the mitigation initiatives launched in previous years and not yet completed was monitored, and improvement initiatives aimed at optimising operating and customer service processes were supervised. For further information on the overall complaint handling situation in the year 2025 of the Parent Company, Banca Mediolanum, please visit: https://www.bancamediolanum.it/informazioni-al-cliente/reclami- ricorso-conciliazione. At Banco Mediolanum, a procedure dedicated to analysing data relating to complaints and disputes has been established, which defines the mechanisms for controlling and monitoring the reported issues, ensuring effective and continual analysis of data extracted from both complaints and disputes. In addition, the procedure describes the Departments involved in the monitoring process, the relevant stages, as well as the information flows that must be shared with the Company’s management bodies. [S4-3 DP 26] The procedures for submitting complaints are widely communicated to customers on several channels (for example websites, information sheets, Banking Centre, through the Family Bankers). During 2025, the Group Companies handled the following number of complaints: Banca Mediolanum S.p.A.: 3,523; Prexta S.p.A.: 1,216; Mediolanum Gestione Fondi S.G.R. p.A.: 6; Mediolanum Assicurazioni S.p.A.: 121; Mediolanum International Life dac – Italian branch: 26; Mediolanum Vita S.p.A.: 265; Flowe S.p.A. SB: 143; Banco Mediolanum S.A: 705; Mediolanum International Funds LTD: 3. The Code of Ethics provides concrete responses from its stakeholders, including its customers, and provides that the recipients of the Code of Ethics shall refrain from any conduct that may, even only potentially, involve a breach of the principles and rules contained in the document, the implementation procedures or the regulations referred to, implicitly providing for the protection of anyone who makes a report to this effect (including customers). In Spain, channels similar to those of Italian companies are also available, through which complaints can be lodged. Furthermore, protection against retaliation for those who use, where appropriate, such channels is governed by the Whistleblowing Policy. [S4-3 DP 25 a] With specific reference to the safeguarding and protection of personal data, when a breach is likely to present a high risk to the rights and freedoms of natural persons, the controller is obliged to report the breach to the data subject, describing the nature of the breach and providing recommendations for mitigating any negative effects, and is also required to notify the event to the Data Protection Authority.
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350 | Mediolanum Group - 2025 Annual Financial Report The controller is not obliged to notify the data subject and the Data Protection Authority if the data has been pseudonymised or encrypted, or if it considers that it has taken appropriate measures to avert high risks to the data subject, unless it assesses otherwise, considering the actual circumstances. [S4-3 DP 25 d] As regards personal data protection, in order to provide the continual monitoring of requests and applications made to Group Companies, the Privacy Office has a dedicated email address that is continually monitored by its staff. In any case, data subjects receive a specific privacy policy, describing their rights and how to exercise them, as well as the channels available to them.
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351 | Mediolanum Group - 2025 Annual Financial Report 4. Governance information 4.1 ESRS G1 Business conduct 4.1.1 Corporate culture [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Corporate culture Dissemination of fairness and ethics among employees and to the market Actual positive impact Own operations Medium term Disbursement of loans to companies implementing ESG-compliant practices and behaviours Actual positive impact Downstream Value Chain (Asset Management/Investment; Banking) Short term Improvement in the reputation of the Mediolanum Group through maintenance and/or improvement of rating scores and ESG indices Opportunities Own operations Short term Risk linked to failure to control compliance with internal and external rules, due to failure to manage rules related to the exercise of banking and brokerage activities, the management of conflicts of interest and protection of consumers, including from the phenomenon of greenwashing. Risk Own operations Medium term Risk of non-compliance with the principles of transparency, truthfulness and completeness in the process of dialogue with the regulators with which the Function/business interfaces Risk Own operations Medium/long term Inadequate consideration of scenario variables, sustainability priorities and stakeholder expectations in strategic planning, decision-making and operational processes Risk Own operations Medium/long term Risk of non-compliance with obligations/deadlines established by legislation on sustainability in the area of investments Risk Own operations Medium/long term Risk of developing products that are not in line with the Group’s Sustainability Policy Risk Own operations Short/medium term
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352 | Mediolanum Group - 2025 Annual Financial Report The Group’s approach and policies [G1-1 DP 9] The Mediolanum Group’s business culture is based on a set of values and practices that reflect a constant commitment to ethics, transparency and social responsibility. This approach is rooted in a robust and structured governance system defined by the Code of Ethics, the Code of Conduct and the Organisation, Management and Control Model adopted pursuant to Legislative Decree No. 231/2001. In terms of governance, the Internal Control System plays a crucial role in ensuring that the Group operates in compliance with current regulations and with defined strategic objectives. This system is supported by an organisational structure that has clearly defined roles and responsibilities aimed at monitoring and mitigating operational and reputational risks. Over the years, the Mediolanum Group has developed various Group Policies aimed at ensuring the proper management of the impacts, risks and opportunities described above. In addition to the policies already mentioned, and the Mediolanum Group’s Policy for the Protection of Human Rights, which set out its approach and general guidelines, the management of impacts, risks and opportunities related to business culture is based on a structured set of corporate policies which include the Sustainability Policy, the Risk Culture Policy, the ESG Risk Management Policy, the Responsible Investment Policies and the Policy on Combating the Financing of Companies Producing Anti-personnel Mines, Cluster Munitions and Sub-munitions. [G1-1 DP 7; ESRS 2 MDR-P DP 65] IROs: Dissemination of fairness and ethics among employees and towards the market; Risk linked to failure to control compliance with internal and external rules, due to failure to manage rules related to the exercise of banking and brokerage activities, the management of conflicts of interest and protection of consumers, including from the phenomenon of greenwashing; Risk of non-compliance with the principles of transparency, truthfulness and completeness in the process of dialogue with the regulators with which the Function/business interfaces Code of Ethics Content and objectives The Code of Ethics provides concrete responses to its stakeholders by setting out precise commitments, in terms of values, principles and rules of conduct, for the different areas of engagement. In order to ensure the effective application of the Code of Ethics, the Mediolanum Group has established specific channels for reporting presumed non-compliance with the document, which can be sent, also anonymously, to the email address codiceetico@mediolanum.it. Scope of application The Code of Ethics is an internal reference with which all Companies belonging to the Group are required to comply: it standardises the conduct of Directors, Statutory Auditors, management, employees, members of the Group’s sales networks, contract staff and suppliers, within their remit, and those who operate in the Group’s interest. Highest level of management responsible for implementation The Code of Ethics is approved by the Board of Directors of Banca Mediolanum. Responsibility for updating the Code, managing any reports of breaches, responses to clarifications about its application, and coordinating training initiatives are assigned to the Risks Committee of Banca Mediolanum S.p.A., which may also make use of other Group structures for these purposes. Furthermore, the Chief Executive Officer is responsible for the correct implementation of the strategic guidelines, as well as the principles set out by the Code.
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353 | Mediolanum Group - 2025 Annual Financial Report Regulations and reference standards The Mediolanum Group developed its Code of Ethics taking into account the main national regulations, including, but not limited to, Legislative Decree No. 231 of 8 June 2001 and Legislative Decree No. 81 of 9 April 2008, the ‘Consolidated Law on Workplace Health and Safety’. Stakeholder engagement The Code of Ethics, which is the result of a process of consultation and active participation involving the various stakeholders, is designed to disseminate the ethical values that the Group seeks to recognise in itself, and to provide concrete responses to its stakeholders, by indicating specific commitments to them in terms of principles of conduct and control in the various modes of interaction with the company. In a relationship of reciprocity, stakeholders are required to commit to the values established in the Code. Method of dissemination The Code of Ethics and its updates are made known to all recipients (internal and external) through appropriate communication and dissemination, as well as on the website, accessible to all, and on the company intranets. The Code of Ethics is delivered to the members of the corporate bodies, employees or contract staff, suppliers and consultancy firms, at the time of their appointment or recruitment or at the commencement of the relationship, respectively. The Group is engaged in specific internal training and customer communications campaigns to promote awareness of and compliance with the Code, in order to create a shared understanding of the values and principles it contains. Group Code of Conduct Content and objectives The Code of Conduct, in accordance with the Code of Ethics, describes the principles and behaviours expected of the members of the Administrative Bodies, employees, the Sales Network and contract staff of the Companies of the Mediolanum Financial Conglomerate. Compliance with the Code is ensured by a system of internal controls that is structured on several levels. Control activities are planned according to the methodologies in use at each business unit and regularly target areas with the greatest corporate risk. The results of control activities and any disciplinary actions are periodically reported to the Board of Directors, at least once a year. Scope of application The Code is sent to all the companies belonging to the Mediolanum Group, which adopt it by resolution of their Corporate Bodies, ensuring consistency with the principles in the Code and adapting it to specific local and regulatory aspects. In fact, in this context, the Group’s Spanish and Irish companies have adopted their own Code of Conduct aligned with that of the Parent Company, taking into account certain national characteristics. Highest level of management responsible for implementation The Chief Executive Officer is responsible for implementing the principles and guidelines governed by the Code in question, which is approved by the Board of Directors of Banca Mediolanum. Regulations and reference standards The document is part of the Group’s broader risk culture framework and is also aligned with the principles on which the ‘Code of Ethics’ and the ‘Code of Ethics and Conduct’ prepared by Assoreti are based. The Code is drawn up to guide day-to-day activities and evaluates decisions consistent with the ethical rules, company values and applicable legislation, incorporating legal and supervisory provisions, the relevant collective bargaining agreements, codes and category regulations where they exist and individual contracts, and creating, together with other regulations adopted for the purposes of the Group and individual Companies, a single regulatory framework.
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354 | Mediolanum Group - 2025 Annual Financial Report Stakeholder engagement The interests of stakeholders are taken into account through a process of indirect customer involvement, as well as through the implementation of safeguards and controls to intercept incorrect conduct and ensure that the information provided is clear, understandable and accessible. Method of dissemination The Code is made available to all recipients and new parties who enter into relations with the Group and is published on the company intranet. Compliance with the Code is an integral part of contractual obligations, and updates are communicated through dedicated channels. The provisions of the Code are also the subject of training, with a particular focus on new hires. Incentive Management and Monitoring Policy Content and objectives The Policy defines the principles and procedures adopted by Banca Mediolanum to identify, manage and monitor incentives related to investment services and the distribution of insurance products, ensuring that their payment and receipt take place legitimately in accordance with applicable legislation. Scope of application Mediolanum Group Companies that receive or pay incentives have their own policy for their management, aligned with Banca Mediolanum’s guidelines, according to their specific characteristics. Highest level of management responsible for implementation The Policy has been approved by the Board of Directors of Banca Mediolanum. Furthermore, the Chief Executive Officer issues instructions for implementing the guidelines governed by the Policy, in accordance with the guidance from the Board of Directors. Regulations and reference standards The Policy implements the main regulations and guidelines on Inducements issued in recent years by major international and national authorities such as the European Commission, the European Securities and Markets Authority (‘ESMA’) and the European Insurance and Occupational Pensions Authority (‘EIOPA’). Stakeholder engagement The interests of stakeholders are taken into account through a structured process for verifying the lawfulness of inducements paid and received, as well as through ex ante and ex post disclosure to customers, for investment transactions. Method of dissemination The Policy is brought to the attention of all its recipients and is made available on the company intranet. Policy on the Management of Conflicts of Interest of the Mediolanum Group Content and objectives In 2025 the Group adopted a Conflicts of Interest Management Policy, hierarchically superior to the existing conflicts of interest policies of the individual Group companies. The aim was to establish consolidated guidelines for the correct identification of circumstances that may generate an actual or potential conflict of interest (COI), based on the current regulatory framework and best market practices, and to guide corporate behaviour towards a common approach to their management. Scope of application The Policy is disseminated to all Companies in the Mediolanum Group, so that by resolution of their own Corporate Bodies they may adopt the Group principles contained in it, without prejudice to any specific provisions of local jurisdictions and their respective Supervisory Authorities.
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355 | Mediolanum Group - 2025 Annual Financial Report Highest level of management responsible for implementation The Mediolanum Group’s Policy is approved by the Board of Directors of Banca Mediolanum. The Chief Executive Officer plays a guiding and supervisory role in the activities of disseminating the principles defined for the oversight of conflicts of interest within the Group, in order to allow the Subsidiaries to operate in accordance with the Group principles and guidelines. Regulations and reference standards The principles in the Policy are identified and applied in order to comply with European legislation on conflicts of interest. Stakeholder engagement The interests of stakeholders are taken into account and protected through the adoption of safeguards and the implementation of controls to detect and neutralise the negative effects arising from a conflict of interest situation. Method of dissemination The Policy is made available on the company intranet. Policy on Risk Culture of the Mediolanum Group Content and objectives The sound and prudent management of banking and financial activity and the adequate and timely management of the risks arising from it fall within the fundamental and shared values of the Mediolanum Group, which bases its action on compliance with rules, professional ethics and the value of the person, promoting behaviours inspired by consistency, transparency, fairness and mutual trust, in full compliance with the Code of Ethics and Code of Conduct. The Mediolanum Group has adopted its own Risk Culture Policy, which defines the Risk Culture Framework, the related principles, roles and responsibilities of the Corporate Bodies, Control Functions and the organisational structures involved. Provision is made for annual reporting to the Corporate Bodies on the activities carried out, along with annual monitoring to assess any adjustments to the Framework in response to changes in the corporate and environmental context, thereby fostering the dissemination of a risk culture at all levels of the organisation. During 2025, the first annual report on risk culture was brought to the attention of the Risk Committee and the Board of Directors of Banca Mediolanum at its meetings of 24 and 27 March 2025 respectively, containing indicators of both a qualitative and quantitative nature that illustrate the level of dissemination of the risk culture within the Bank. Scope of application The Policy is sent to all the companies belonging to the Mediolanum Group, which adopt it by resolution of their Corporate Bodies, ensuring consistency with the principles in the Code and adapting it to specific local and regulatory aspects. The Spanish companies and Mediolanum International Funds have their own policy in line with that of the Group. Highest level of management responsible for implementation The Chief Executive Officer is responsible for implementing the principles and guidelines governed by the Policy in question, which is approved by the Board of Directors of Banca Mediolanum. Regulations and reference standards The Policy implements the main regulations and guidelines on risk culture and internal governance issued in recent years by major international authorities such as the European Commission, the European Central Bank, the European Banking Authority and the Bank for International Settlements.
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356 | Mediolanum Group - 2025 Annual Financial Report Stakeholder engagement The interests of stakeholders are taken into account through a process of directly and indirectly involving customers. In addition, safeguards and controls are implemented to intercept improper conduct and ensure that all recipients are adequately made aware of the risk culture characterising banking and financial activity, in order to operate in accordance with corporate values, professional ethics and applicable regulations. Method of dissemination The Policy is made available on the company intranet. In addition, during the reporting period, the Head of the Compliance Function was speaker in specific training modules on the dissemination of the Risk & Compliance Culture held for new hires of Head Office and the Sales Network, and also held lectures at leading Universities. Finally, the Compliance Function prepared and provided an online course on Risk Culture for all Mediolanum Group personnel, which will become mandatory for new employees. Organisation, Management and Control Model pursuant to Legislative Decree No. 231/2001 of Banca Mediolanum Content and objectives The Group has specific organisational models in place pursuant to the regulations for which models are provided for exemption from liability in the event of the commission of offences in the interest of the entities themselves. Like the other Italian Group Companies, the Bank has adopted an Organisation, Management and Control Model pursuant to Legislative Decree No. 231/2001, which was not modified or updated during 2025. Control of the effectiveness of and compliance with the Model is overseen by specific corporate bodies. For Italian companies, this function is performed by the Supervisory Body, whose members are the members of the Board of Statutory Auditors. Scope of application The organisational models are intended for persons that work for Group Companies, regardless of the relationship they have with the Companies, whether they hold positions of representation, administration or management of the Company, or whether they are managed or overseen by one of the above persons. The models also apply to the members of the Sales Networks, but are limited to the activities that they perform and that can be classed as directly related to the operating cycle of the Company for which they work. Control safeguards are provided for suppliers and external professionals. However, since they are separate from the Organisation and have decision-making and organisational autonomy, they are not among the recipients of the models. Highest level of management responsible for implementation The Boards of Directors are responsible for approving the organisation, management and control models by means of a specific resolution and for implementing them by assessing and approving the actions necessary for the implementation of the fundamental elements. In order to identify these actions, the Management Bodies make use of the support of the Bodies with supervisory tasks on specific regulations. Regulations and reference standards The models are prepared in accordance with regulatory instructions and the guidelines drawn up by the trade associations, which provide instructions for the adoption of organisation and management models suitable for the prevention of offences. The models are developed taking into account the specific nature of the Companies’ organisational structures, with the aim of implementing a system suitable to ensure the prevention of offences and compliance with the rules in force, while also responding to the needs of internal Stakeholders.
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357 | Mediolanum Group - 2025 Annual Financial Report Method of dissemination The models are brought to the attention of the recipients through the appropriate channels for the dissemination of internal regulations. Furthermore, extracts of the models are available on the institutional websites of the Companies. IROs: Inadequate consideration of scenario variables, sustainability priorities and stakeholder expectations in strategic planning and decision-making and operational processes; Reputational improvement of the Mediolanum Group through maintenance and/or improvement of rating scores and ESG indices Mediolanum Group Sustainability Policy Content and objectives The document sets out the Group’s sustainability principles and related governance, integrating sustainability into the corporate values in order to develop a solid and sustainable business in the long term. The Policy defines the strategic guidelines and sets out the principles for managing ESG risks (Legislative Decree No. 125/2024), promotes a culture of sustainability, facilitates non-financial reporting and strengthens stakeholder engagement. Scope of application The Policy applies to all organisational units of Banca Mediolanum and the Sales Network and is sent to all Group Companies for transposition that adopt it taking into account specific local and regulatory aspects. Highest level of management responsible for implementation The Chief Executive Officer of the Parent Company implements the strategic guidelines in the area of sustainability, defined by the Board of Directors of Banca Mediolanum, which is responsible for approving the Policy and defining the guidelines in the area of sustainability. Regulations and reference standards The document refers to various international regulations and standards, including the Paris Agreement on Climate Change, the United Nations (UN) 2030 Agenda for Sustainable Development, UNEP FI – Principles for Responsible Banking (PRB), the United Nations Global Compact (UNGC), the Universal Declaration of Human Rights, the OECD Guidelines, Directive 2022/2464 of the European Parliament and of the Council (CSRD), Commission Delegated Regulation (EU) 2023/2772, Regulation (EU) 2020/852 of the European Parliament and of the Council, Regulation (EU) 2019/2088 of the European Parliament and of the Council, the ECB Guide on climate-related and environmental risks – Supervisory expectations relating to risk management and disclosure, the EBA Guidelines on Loan Origination and Monitoring and the European Action Plan for Sustainable Finance. Stakeholder engagement The interests of Stakeholders are taken into account through a process of directly and indirectly involving them. The Mediolanum Group has launched a Stakeholder management process aimed at involving all internal and external stakeholders in defining the sustainability strategy, in line with the founding philosophy of the Group, which puts people at the heart of its operations. The results of the Stakeholder engagement process contribute to defining and updating the double materiality analysis and, consequently, the sustainability strategy, which is formalised in the Sustainability Policy. Method of dissemination The Policy is disseminated through publication in the Sustainability section of the Banca Mediolanum official website, in order to ensure transparency and accessibility.
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358 | Mediolanum Group - 2025 Annual Financial Report IROs: Disbursement of loans to companies implementing ESG-compliant practices and behaviours; Product development risk not in line with the Group’s Sustainability Policy; Risk of non-compliance with obligations/deadlines established by legislation on sustainability in the area of investments ESG Risk Management Policy of the Mediolanum Group In order to address the risk of product development not in line with the Mediolanum Group’s Sustainability Policy, all Mediolanum Group companies implemented the Mediolanum Group’s ESG Risk Management Policy (see ESRS E1 Climate change, paragraph 2.2.4 Financed GHG emissions – Investments, section ‘The Group’s approach and policies’, DP 24, for further details on the ESG risk management policy and the related MDR-Ps). Responsible Investment Policies Since 2021, the Group Companies, which operate as financial market participants (FMPs), have had specific Responsible Investment Policies in place. These policies provide that, as part of the investment process, ESG criteria are taken into account in the selection of economic instruments and activities in which to invest and in the selection of financial partners, third-party management companies, which support it in investment activity (see ESRS E1 Climate change, paragraph 2.2.4 Financed GHG emissions – Investments, section ‘The Group’s approach and policies’ Policies, DP 24, for further details on the Responsible Investment policies and related MDR-P). Policy on Combating the Financing of Companies Producing Anti-Personnel Mines, Cluster Munitions and Sub-munitions of the Mediolanum Group Content and objectives The Policy describes the key principles and safeguards to ensure compliance with the prohibition on financing provided for by the legislation, with regard to both the primary and secondary markets, including OTC markets, also in relation to transactions undertaken independently by Group customers. The Policy provides for an exclusion list, updated quarterly, identifying the manufacturing companies to which granting loans is prohibited. Scope of application The Policy is applicable to the entire Mediolanum Group, excluding instrumental Subsidiaries such as Pi Servizi Spa and Mediolanum Comunicazione Spa. The Spanish Companies and MIFL have their own policy of preventing the financing of companies producing anti-personnel mines, munitions and cluster sub-munitions, in line with that of the Group. Highest level of management responsible for implementation The Mediolanum Group’s Policy is approved by the Board of Directors of the Parent Company Banca Mediolanum. The Chief Executive Officer is also responsible for providing guidelines for the implementation of the management process to combat the financing of companies producing anti-personnel mines, munitions and cluster sub-munitions, in accordance with the guidelines established by the Board of Directors. Regulations and reference standards With the Policy, the Mediolanum Group undertakes to comply with and implement the regulations described below and, in particular, the requirements of Italian Law No. 220 of 2021, which, in implementation of the Ottawa Convention and the Oslo Convention, introduced a total ban on the financing of Companies carrying out activities of construction, production, development, assembly, repair, preservation, employment, use, warehousing, storage, holding, promotion, sale, distribution, import, export, transfer or transport of anti- personnel mines, cluster munitions and sub-munitions of any nature or composition, or parts thereof.
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359 | Mediolanum Group - 2025 Annual Financial Report Furthermore, with particular regard to the Italian scope, the Supervisory Instructions of the Bank of Italy, Consob, COVIP, IVASS and MEF of 26 July 2024 provide clarifications and timely instructions to enable intermediaries to effectively prepare safeguards in order to ensure compliance with the prohibition established in the said law. Method of dissemination The Policy is made available on the company intranet. [G1-1 DP 10 a] In line with the Supervisory provisions, the Group has implemented an internal control system, structured over several levels and defined as a set of rules, procedures and organisational structures designed to allow for an adequate process of identifying, measuring, managing and monitoring the main risks. The internal control system is divided into several levels, comprising: line controls (‘first-level controls’): these are designed to ensure that transactions are executed properly. These controls are performed by the same operating units (e.g. hierarchical, systematic and spot checks), and by units dedicated exclusively to control tasks that report to the heads of the operating units (the controls are performed in the back office). Where possible, they are incorporated into IT procedures. According to this configuration, the operational structures are primarily responsible for the risk management process. In the course of their day-to-day operations, these structures are required to identify, measure or assess, monitor, mitigate and report the risks arising from ordinary business, in accordance with the risk management process. These structures must also comply with the operating limits assigned to them, in accordance with the risk objectives and procedures governing the risk management process; risk and compliance controls (‘second-level controls’), which ensure compliance with the operating limits assigned to the various functions, the correct implementation of the risk management process and the compliance of the company’s operations with regulations, including self-regulation. internal audit (‘third-level controls’): aimed at identifying breaches of procedures and regulations and periodically assessing the completeness, adequacy, functionality (in terms of efficiency and effectiveness) and reliability of the internal control system and the information system, at predetermined intervals in relation to the nature and intensity of the risks. The Subsidiaries, both Italian and foreign, implement the Policies defined at Group level with adaptations deriving from specific or local regulations. In addition, the Mediolanum Group has adopted a ‘Whistleblowing System’ to enable, inter alia, the reporting of alleged violations of the principles contained in Model 231 (specific to Italy), as well as other national and European Union legislative provisions that require the adoption of reporting systems. To this end, both employees and third parties (within the scope of the relevant legislation) are entitled to make, through the channels provided and also represented on the websites of the Group Companies, reports detailing potential and/or actual violations of the regulations mentioned above, of which the whistleblower has become aware due to the functions performed. For further details, see ESRS S4, paragraph 4.1.2 Protection of whistleblowers, section ‘The Group’s approach and policies’. [G1-1 DP 10 e] The following requirements apply at Group level to the methods of transmitting information/data/news: periodic and event information flows must be sent to the corporate bodies to which supervisory duties are assigned by the corporate structures concerned using methods defined by those bodies; reports of evidence or suspicion of any breach of the Models for the prevention of offences, the general principles and the principles enshrined in the Code of Ethics, by the corporate structures or other recipients of the Models, are required to contact institutions through the whistleblowing channels, including through specific IT systems;
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360 | Mediolanum Group - 2025 Annual Financial Report The corporate bodies responsible for supervising the regulations concerning the liability of entities for the commission of offences are required to act in such a way as to protect the reporting persons referred to in the previous points from any form of retaliation, discrimination or penalisation or any consequence arising from the reports, ensuring the confidentiality of their identity, without prejudice to the legal obligations and the protection of the rights of the Company or of third parties; any reports received are carefully assessed and the advisability of consequent actions is considered, listening, if necessary, to the reporting person and/or the person responsible for the alleged breach. [G1-1 DP 10 g] During 2025, the Mediolanum Group planned and provided various training initiatives to support personal growth and the dissemination of a shared corporate culture, which involved all employees as well as members of the Sales Network, if present. The Group companies mainly held training courses for new employees and ad hoc ongoing training for both office staff and the Sales Network. In this regard, the Compliance Functions supported the relevant Department in planning and organising training activities for the various organisational units, deciding on the content of training plans for employees, contract staff and the Sales Network, and establishing information and training initiatives for the benefit of the Board of Directors and Senior Management on matters relating to corporate conduct. In Ireland, all staff annually complete mandatory online training on ethics and conduct issues. In addition, Fitness & Probity (F&P) training requirements for IAF (Individual Responsibility Framework) and SEAR (Senior Management Responsibility Regime) are met through courses offered in person and via the Intuition platform. In Spain, ‘Criminal Compliance and Code of Ethics’ training is mandatory and is provided every two years to all employees, to the Commercial Network and to the Board of Directors. The last edition of this training took place in 2024 and will therefore be offered again in 2026. For further information on training, see ESRS G1-1, paragraph 4.1.1 Business culture and paragraph 4.1.2 Protection of whistleblowers, section ‘Actions’. For the purposes of implementing the Organisation, Management and Control Models for the prevention of unlawful acts, the corporate bodies with supervisory duties ensure that an adequate pathway is in place for informing and training the recipients. The purpose of training plans is to raise awareness of legislation and the organisational models, and in particular to adequately support those involved in ‘sensitive’ activities. For this purpose, mandatory training courses were structured with a final test, also extended to the Sales Networks. For the Group’s Italian Companies, the training on the ‘administrative liability of entities’ was updated in 2024. Training courses for personnel and contract staff are reviewed at regular intervals to incorporate both the amendments made by the legislature to the subject referred to in Legislative Decree No. 231/2001, and to propose cases of particular interest based on the most relevant case law. As there were no legislative changes requiring a training update for the recipients of Model 231, no new training modules were held in 2025.
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361 | Mediolanum Group - 2025 Annual Financial Report Actions [ESRS 2 MDR-A DP 68] There are many areas of responsibility in the area of corporate culture. The actions taken in relation to the main IROs identified are described below. IROs: Dissemination of fairness and ethics among employees and to the market Code of Ethics training The Mediolanum Group actively promotes a culture based on integrity and ethics, both within the organisation and in its dealings with the market. This commitment takes the form of disseminating company principles and values and defining actions to strengthen a solid corporate culture. In order to promote its full application, the Code of Ethics may be the subject of specific internal training and communication campaigns to customers or other interested parties, including by email or in the permitted ways deemed most appropriate from time to time. In 2025, Banco Mediolanum provided a training course on the Code of Ethics and its principles, for a total of 550 hours for all employees. IAF Standards of Conduct in Irish Companies In Irish companies, requirements for integration and mutual respect have been defined, adopting common and also additional standards of conduct. In particular, the IAF Standards of Conduct define three levels: Standards of Business Conduct – applied to employees, who are required to comply with the Code of Business Ethics in line with the Standards of Business Conduct defined in the IAF Standards of Conduct; Common Standards of Conduct – all holders of CF (Controlled Functions) and PCF (Pre-approved Controlled Functions) roles must comply with the Common Standards of Conduct introduced, to define a set of unambiguous standards of conduct expected by the Central Bank for executives operating in financial services; Additional Standards of Conduct – the senior managers in PCF roles and other positions with significant influence over the conduct of the Company must comply with the Additional Standards of Conduct. IROs: Inadequate consideration of scenario variables, sustainability priorities and stakeholder expectations in strategic planning, decision-making and operational processes Stakeholder engagement The Mediolanum Group organises structured dialogue and listening sessions with its stakeholders on sustainability issues considered priorities, with the aim of integrating their expectations into the Group’s strategic planning, and its decision-making and operational processes (see ESRS 2 General disclosures; paragraph 1.1.3 Strategy, section ‘Interests and views of stakeholders’ for further details). IROs: Disbursement of loans to companies implementing ESG-compliant practices and behaviours; Product development risk not in line with the Group’s Sustainability Policy; Risk of non-compliance with the principles of transparency, truthfulness and completeness in the process of dialogue with the regulators with which the Function/business interfaces
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362 | Mediolanum Group - 2025 Annual Financial Report Actions for the disbursement of loans to companies implementing ESG-compliant practices and behaviours In the credit segment, the Group has adopted ESG safeguards since 2021, that provide for the assessment of corporate counterparties through an ESG score developed by CRIF, ranging from 1 (maximum sustainability) to 5 (lowest level of sustainability), as a summary indicator of the company’s environmental, social and governance profile. The calculation methodology adopted by CRIF, updated at the end of 2024, through the introduction of a new ESG scoring model, which replaces the previous fragmented approach with a single, aggregated system. This evolution has allowed for: a more complete and coherent representation of the level of sustainability of companies; greater effectiveness in the selection of counterparties; a strengthening of the commitment to the sustainable transition, in line with strategic and regulatory directives. The new ESG indicator is therefore a key tool for guiding investment and partnership decisions, ensuring transparency, accountability and compliance with international reporting standards. The actions taken have been extended to all counterparties incorporated in any legal form, domiciled in Italy or abroad. The actions of integrating sustainability factors into the investment and financing process described, such as, by way of example, monitoring and due diligence activities, are carried out periodically and continuously over time. Information flows to ensure that the management body has full oversight of organisational safeguards and to verify compliance with the prohibition on financing companies producing anti-personnel mines, cluster munitions and sub-munitions The Bank and the Companies covered by the Policy on Combating the Financing of Companies Producing Anti- personnel Mines, Cluster Munitions and Sub-munitions of the Mediolanum Group (see ESRS G1 Business conduct, paragraph 4.1.1 Business culture, section ‘The Group’s approach and policies’, DP 7, for further details on the policy and minimum reporting requirements) have adequate information flows, aimed at ensuring that the management body with strategic oversight functions is fully aware of and governed by the organisational controls adopted to verify compliance with the prohibition on financing, as well as timely knowledge of any breaches of the prohibition. In this regard, the Control Functions of the Bank and its subsidiaries establish appropriate information flows to the structures responsible for first-level controls, thus ensuring timely reporting of the activity carried out in the respective periodic reports. Similarly, the Control Functions of the Subsidiaries to which the Policy applies maintain timely information flows to the corresponding Control Functions of the Bank. Since any form of financial support to the producer companies is considered prohibited, the Bank and its Subsidiaries continuously adopt control procedures for both the risk capital and the debt capital of the producer companies, monitoring operations performed on both the primary and secondary markets. IROs: Risk of non-compliance with the principles of transparency, truthfulness and completeness in the process of dialogue with the regulators with which the Function/business interfaces Transparency of relations with the Supervisory and Control Authorities The persons responsible for relations with the Supervisory Authorities are required to conduct themselves with the utmost propriety, integrity and independence in carrying out the activities for which they are responsible, in accordance with the provisions of the Group’s Code of Conduct. The Group is committed to maintaining an
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363 | Mediolanum Group - 2025 Annual Financial Report open and transparent relationship with the Supervisory Authorities and to fostering trust-based cooperation. Failure to comply with this principle could lead to regulatory sanctions, reputational damage and/or substantial economic sanctions. Also in the year under review, the Compliance Function managed relations with national Supervisory Authorities and trade associations for matters directly within its responsibility, operating in accordance with the principles of transparency, truthfulness and completeness. In particular, it was responsible for centralised control of the correct management of communications (requests) from these national authorities, directing them to the relevant corporate structures and monitoring response times, where provided for. The centralised management of the Supervisory Bodies involves the following activities: the receipt of communications sent by the various national authorities; recording requests and directing them to the correct corporate structures for the relevant processing and monitoring compliance with the deadlines for the sending of any response on the part of the relevant owner; interactions with the Litigation and ADR Office in support of internal activities relating to the decisions of the Banking and Financial Ombudsman and the Arbitrator for Financial Disputes, taking into account the decisions for the purposes of compliance with the rules of company processes and procedures; the use of evidence from requests and from the Supervisory Authorities in the context of specialist advisory services, with reference to the regulations overseen by these Authorities. The actions implemented come under the scope of the Code of Conduct (see ESRS G1-1 Business conduct, paragraph 4.1.1 Business culture, section ‘The Group’s approach and policies’, DP 7; ESRS 2 MDR-P DP 65 The Compliance Function is responsible for monitoring national Supervisory requests on an ongoing basis throughout the year. IROs: Risk of non-compliance with obligations/deadlines established by legislation on sustainability in the area of investments Ex ante and ex post activities of the Compliance Function With specific reference to the risk of non-compliance with the obligations/deadlines established by sustainability legislation, the individual Compliance Functions of the Group, in line with a risk-based approach, carry out both ex ante and ex post supervisory activities to safeguard against the risk linked to sustainability matters, with particular regard to the areas that affect customers or potential customers. In detail, the ESG Compliance Functions, in line with the provisions for the other risk categories they oversee, carry out the following activities: monitoring regulatory developments and consequent alerting activities on ESG issues that affect business processes across the organisation, including (Climate Change); providing ex ante advisory support to the structures that own the Bank’s processes for areas and regulations not directly covered by the Risk Management Function and relating to the distribution of products with possible impacts on customers or potential customers (e.g. greenwashing). In the context of product governance systems, products are also checked before they are marketed, also with regard to the requirements established by the reference legislation for the distribution of sustainable products. The Functions carry out ex post control activities on the same areas/regulations as described in the ex ante activity, highlighting any mitigation actions and providing information to the corporate bodies as part of the Function’s ordinary reporting activity. IROs: Risk linked to failure to control compliance with internal and external rules, due to failure to manage rules related to the exercise of banking and brokerage activities, the management of conflicts of interest and protection of consumers, including from the phenomenon of greenwashing.
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364 | Mediolanum Group - 2025 Annual Financial Report Mapping of activities carried out and/or planned in 2025 and attributable to the Risk Culture Policy framework During 2025, the Parent Company completed the project launched the previous year, aimed at defining the Risk Culture framework within the Mediolanum Group’s Risk Culture Policy, mapping the activities carried out and/or planned in 2024 and attributable to this framework and completing the roadmap for the evolutionary actions planned to strengthen it. In 2025 the main actions implemented to mitigate risks and disseminate the corporate culture mainly related to: the definition of training courses for Head Office and Sales Network staff; the implementation of an annual reporting process for the Board of Directors and the Risk Committee, with the aim of representing the level of dissemination of the risk culture within the Company, based on a set of quantitative indicators to which the Control Functions, the Human Resources Department and the other Departments involved in various ways in the framework contribute; The distribution of a Risk Culture Survey to all Head Office employees and a sample of the Sales Network, aimed at gauging the level of knowledge and awareness of the principles of risk culture, both generally and in the context of day-to-day professional activities; the survey results were presented to the Board of Directors in June 2025 and revealed a very positive perception of risk culture and a high level of dissemination within the Group. Notwithstanding the positive outcome of the Survey, some suggestions for further development were identified to further strengthen the Mediolanum Group’s Risk Culture framework; the provision of a specific online training course on Risk Culture to all employees of the Head Office, the Sales Network and foreign Subsidiaries, which also takes account of the survey results when addressing specific issues. In addition, situations of conflict of interest relating to the distribution of products and services were identified and managed during the year. Where these measures are not sufficient, in the context of the provision of investment services or the distribution of insurance products, including investment products, customers are adequately informed of the existence of the conflict, so they may make informed decisions. Ultimately, the distributing company may decide not to provide the service. With regard to consumer protection, preventive measures were defined, through specific guidelines, to reduce the risk of any breaches of legislation in force. These guidelines support the various organisational units of Group companies in the adoption of good practices (with a particular focus on greenwashing), i.e. behaviour to be avoided during promotional events and the advertising of products and services. Information relating to the actions taken to manage the above matters is reported annually to the Board of Directors in the context of the Annual Report provided by the Compliance Function. The scope of the actions implemented corresponds to the scope of application of the Mediolanum Group’s Risk Culture Policy (see ESRS G1-1, paragraph 4.1.1 Business Culture, section ‘The Group’s approach and policies”, DP 7; ESRS 2 MDR-P DP 65 for further details). Evolutionary actions within the Parent Company’s Risk Culture Framework were completed, while the annual reporting process continued on an ongoing basis. Similarly, measures for the identification, prevention and management of conflicts of interest, as well as consumer protection measures, including those relating to greenwashing risk, continued to be applied on an ordinary basis. IROs: Improvement in the reputation of the Mediolanum Group through maintenance and/or improvement of rating scores and ESG indices
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365 | Mediolanum Group - 2025 Annual Financial Report Management of ESG ratings In 2025, in line with the Mediolanum Group’s Sustainability Policy on the management of ratings and ESG indices, with a view to greater transparency on ESG matters, and in the light of the importance given to sustainability performance assessments by Stakeholders, investors and others, the Group responsibly chose to measure business decisions, analysing all the impacts (economic and non-economic) that they determine for each ESG factor. These decisions were subsequently made public by international sustainability rating agencies. The ratings are assigned at the end of a process of analysing and evaluating ESG policies and performance and are a valid tool for the Group’s Stakeholders, offering summary, independent and comparable information on the performance and level achieved by the Group in non-financial areas related to governance, ethics and integrity, social and the environment. Targets IROs: Disbursement of loans to companies implementing ESG-compliant practices and behaviours [ESRS 2 MDR-T DP 80] Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Credit to Sustainable Enterprises 95% of loans granted to companies with a CRIF ESG score <592 2030 Italy 2024 96.96% 96.09% In line with the above description of the use of the CRIF ESG score for the assessment of corporate counterparties, the Group set the target of allocating more than 95% of financing to companies with a score below 5. This target was updated following the methodological revision introduced by CRIF at the end of 2024, which led to the adoption of a single, aggregated scoring model to represent companies’ sustainability more comprehensively. This methodological evolution has also allowed for a greater effectiveness in the selection of counterparties and reinforces the commitment to a sustainable transition, in line with national and international strategic and regulatory directives. For further information on Actions concerning the disbursement of loans to companies implementing ESG-compliant practices and behaviours, see ESRS G1-1, paragraph 4.1.1 Business culture, section ‘Actions’, MDR-A DP 68. 92 CRIF produces a score that measures the level of sustainability of companies on a scale from 1 to 5, where 1 indicates the highest level of sustainability and 5 the lowest level.
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366 | Mediolanum Group - 2025 Annual Financial Report 4.1.2 Protection of whistleblowers [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Protection of whistleblowers Presence of whistleblowing procedures and protection of whistleblowers Actual positive impact Own operations Short term The Group’s approach and policies The subject of whistleblowing is addressed by the Mediolanum Group in a context of increasing regulatory complexity and transparency requirements. The whistleblowing system enables employees and third parties to report breaches safely, with protection of their identity and protection against any form of retaliation. Managed by the Internal Audit Function and overseen by the Supervisory Body for areas in their responsibility, the process ensures that reports are treated with confidentiality and regulatory compliance. This approach not only strengthens internal trust, but also strengthens the Group’s commitment to transparent and sustainable management, helping to prevent unlawful conduct and protect Stakeholders. [G1-1 DP 7; ESRS 2 MDR-P DP 65] IROs: Presence of whistleblowing procedures and protection of whistleblowers Whistleblowing Policy Content and objectives The Parent Company’s Policy, the last update of which was approved in 2024 and is currently being revised, aims to describe the principles of the model defined in order to enable ‘whistleblowers’ to report potential and/or actual violations of the principles contained in Model 231 (specific to Italy), as well as national or European Union legislation and other legislation that requires the adoption of reporting systems. The adopted whistleblowing system provides specific, autonomous and independent channels and procedures dedicated to receiving and managing reports that ensure confidentiality, independence of assessment, traceability, protection of the whistleblower against possible retaliation, and safeguarding the confidentiality of the report’s content and the identity of both the whistleblower and the person reported. Reports may include, but are not limited to, significant unlawful conduct pursuant to Legislative Decree 231/2001, violations of banking, financial, anti-money laundering, antitrust, market abuse and EU legislation, as well as internal code violations. Scope of application The Policy applies to a wide range of parties – employees, contract staff, Family Bankers, consultants, suppliers, shareholders and other individuals – including during the pre-contractual stage or after the termination of the contractual relationship. Personal or commercial alerts are excluded. The Parent Company’s document applies directly within the Bank. The Policy is sent to the Companies belonging to the Mediolanum Group to which the legislation applies, so that they can adapt their own internal regulations, according to the specific characteristics of each Company and on the basis of the proportionality criteria. The following are excluded from the scope of reports: disputes, claims or demands of a personal nature relating exclusively to individual employment relationships or relationships with hierarchically superior persons or with colleagues. In relation to the latter, reference must be made to the applicable regulations and practices at the local level; and reports of matters of a purely commercial nature. Highest level of management responsible for implementation The Board of Directors approves the Policy and appoints the Whistleblowing Manager who, in the case of the Italian and Irish Companies, is identified within the Internal Audit Function, while in the case of the Spanish
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367 | Mediolanum Group - 2025 Annual Financial Report Subsidiaries, it consists of a collegiate body made up of the Heads of the Internal Audit and Compliance Functions. The Whistleblowing Manager is responsible for implementing the reporting system and sends the information on an ad hoc basis for more serious breaches in addition to periodic reporting (at least once a year). Proposals to update the document are the responsibility of the said Whistleblowing Manager, with the support of the competent structures for any impacts relating to operating and corporate processes. Regulations and reference standards As the Parent Company, Banca Mediolanum developed a Whistleblowing Policy pursuant to Legislative Decree No. 24/2023 and its Annex 1, implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and laying down provisions on the protection of persons reporting breaches of national regulatory provisions. The Bank transmits the relevant Policy to the Companies within the Group, so that they adapt their internal regulations according to their specific characteristics and proportionality criteria. Method of dissemination Finally, information on the use of the internal and external channel with particular regard to the conditions for making reports, on the competent persons entrusted with the management of reports, as well as the procedures are made available. The Companies of the Group publish this information in a specific section of the website of the Companies of the Group (where present), as well as on the corporate intranet. This information is also made accessible to persons who, although not attending the workplace, are entitled to submit a report. [G1-1 DP 10 c] The Group has adopted specific procedures, including IT procedures, to enable whistleblowing. Dedicated initiatives are planned to ensure the training and dissemination of knowledge among recipients for access to the channels provided. These ensure confidentiality in whistleblowing management, as well as forms of protection for the informant. Sanction systems are in place, to be applied if retaliation occurs against whistleblowers or if confidentiality measures are breached. Whistleblowers benefit from protection measures provided that they have had reasonable grounds to believe that the information reported was true at the time of the report and that the information fell within the scope of the rules. In addition, the protection measures also apply: to facilitators, i.e. natural persons who assist the whistleblower in the reporting process, and who operate within the same working environment and whose assistance must be kept confidential (e.g. the facilitator may be a colleague from an office other than that of the whistleblower who assists the latter in the reporting process on a confidential basis, i.e. without disclosing the information disclosed. The facilitator may be a colleague who also qualifies as a trade union member if he/she assists the whistleblower in his/her name and on his/her behalf, without using the trade union acronym); persons in the same working environment as the whistleblower who operate, or have operated in the past, in the same working environment as the whistleblower (e.g. colleagues, former colleagues, contract staff) and are connected to them through a stable affective relationship or family tie up to the fourth degree; work colleagues of the whistleblower who work in the same working environment and who have a normal and current relationship with that person; and corporate entities of the whistleblower or for which that person works, as well as entities operating in the same working environment as the aforementioned persons. The Mediolanum Group prohibits retaliation, i.e. any behaviour, act or omission, even if only attempted or threatened, carried out as a result of the report, that causes or may cause unjust harm to the whistleblower, directly or indirectly. Whistleblowers who believe that they have suffered discrimination/retaliation inform the external parties appointed (e.g. ANAC for Italy), which will carry out the investigations that the country’s law assigns to them and may impose a sanction on the person responsible. If the whistleblower declares that he/she has suffered retaliation/harm, the burden of proving that such conduct or actions are justified due to reasons unrelated to the report lies with the person who carried them out. The latter is therefore required to demonstrate
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368 | Mediolanum Group - 2025 Annual Financial Report that the measures taken against the whistleblower are in no way linked to the report. The retaliatory acts are null and void. A whistleblower who has been dismissed as a result of the report or complaint has the right to be reinstated to his/her position. In addition, the activities of receiving and analysing the report are recorded, tracked, monitored and managed, taking into account the principles of impartiality and confidentiality, also with respect for the dignity of the worker, the regulations in force at the local level regarding the protection of personal data and employment, and the contractual regulations of the sector. The persons responsible for receiving, reviewing and assessing reports are identified to ensure that they are not hierarchically or functionally subject to any report, are not themselves the persons allegedly responsible for the breach and do not have a potential interest related to the report. Specific training is provided on the Whistleblowing System for everybody at the Head Office and in the Commercial Network. [G1-1 DP 10 e] As part of the management of Whistleblowing Reports, the Mediolanum Group has defined an independent and confidential investigation process within the Whistleblowing Policy, which, if necessary, also allows the involvement of Corporate Structures for the purposes of the investigation. Actions [ESRS 2 MDR-A DP 68] IROs: Presence of whistleblowing procedures and protection of whistleblowers Whistleblowing training course The Mediolanum Group provides appropriate whistleblowing training through the provision of a specific training course for all employees. This course aims to provide information on the main regulatory requirements, the protective procedures activated and the operating procedures of the corporate whistleblowing system, and includes a final test. The course is updated whenever necessary due to organisational changes and/or legislative amendments. In particular, the Group’s Italian Companies will update the training course, following the ongoing review of the Policy document. In 2025, as no updates were made to the Policy in question, no training courses were provided. In Spanish companies, mandatory training on the ‘Code of conduct and risk culture’ was given in 2025, and a section on the reporting system and whistleblower protection was included. The training was attended by the staff and the commercial network. In addition, during the reporting year, three awareness-raising communications regarding reporting channels and the law on the protection of whistleblowers were sent to the same recipients. Similarly, in the reporting year, the Irish companies provided the mandatory training course on the subject to the entire workforce. Targets [ESRS 2 MDR-T 72; 81 a; 81 b] IROs: Presence of whistleblowing procedures and protection of whistleblowers No targets relating to the Whistleblowing System were identified, as they were not applicable to the scope of the Internal Reporting System. In compliance with current regulations, the Mediolanum Group undertakes, in any case, to provide reporting channels and to ensure the proper functioning of the process for managing Internal Reports. As provided for in the Policy, which regulates the internal reporting system, the Whistleblowing Manager prepares an annual report on the proper functioning of the internal alert procedure, as well as on the results of the continual monitoring of the channels and the handling of reports received. This report is approved by the corporate bodies and made available to the Company’s staff within the Internal Audit Function.
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369 | Mediolanum Group - 2025 Annual Financial Report 4.1.3 Supplier relationship management, including payment practices [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Supplier relationship management, including payment practices Improvement of suppliers’ ESG performance by means of selection criteria that take into account social and environmental aspects Actual positive impact Downstream value chain Medium term Developing a relationship of fairness and mutual trust with suppliers and adherence to payment practices Actual positive impact Downstream value chain Medium term The Group’s approach and policies Managing relations with suppliers is essential to ensure a system based on transparency, sustainability and social responsibility. The Mediolanum Group selects its suppliers on the basis of quality, ethics and compliance criteria and environmental and social standards, promoting long-term relationships based on trust. Responsible management also involves timely and transparent payment practices, which ensure balance in business relationships and support the financial soundness of partners. The Mediolanum Group pays particular attention to the timeliness of payments, aware of the impact that any delays may have, especially on small and medium- sized suppliers. In this respect, the Bank undertakes to comply with agreed timescales, contributing to a sustainable and responsible supply chain, in line with the Group’s values. [G1-1 DP 7; ESRS 2 MDR-P DP 65] IROs: Improvement of suppliers’ ESG performance by means of selection criteria that take into account social and environmental aspects Over the years, the Group has developed several Policies with the aim of integrating ESG criteria into the process for the selection, assessment and engagement of suppliers. The various policies include the Mediolanum Group Supplier Code of Conduct and Purchasing Policy (see ESRS S2 Workers in the Value Chain, paragraph 3.2.2 Suppliers, section ‘The Group’s approach and policies’, DP 16 for further details on the two policies). IROs: Developing a relationship of fairness and mutual trust with suppliers and adherence to payment practices The Parent Company adopts a specific procedure that formalises expenditure management. This procedure describes, for this scope of reference, the actors and their roles and responsibilities, the control points, the IT tools used and any reports produced. The Administration, Accounting and Financial Reporting Division, through the Active and Passive Invoicing Office, oversees all activities related to the registration and payment of supplier invoices in accordance with the contractual agreements signed by the Company. To ensure compliance with the agreed payment deadlines, the process is fully computerised and involves the automatic execution of payments twice a month. If contractual agreements provide for payment terms that differ from the standard, the Active and Passive Invoicing Office enters a manual payment mandate to meet the invoice deadline. The foreign Subsidiaries adopt dedicated operating procedures, calibrated to the specific aspects of each entity, in order to ensure the effective management of invoices, particularly in relation to the authorisation, accounting and payment stages. In Spain, the policy provides for the formalisation of the administrative procedure that regulates activities for the correct management of incoming invoices, in particular as regards their authorisation, registration in the accounts and
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370 | Mediolanum Group - 2025 Annual Financial Report payment. The procedure also includes a description of the systems and controls that enable monitoring and mitigation of the risks associated with the process. In order to improve relations with suppliers, Banco Mediolanum works actively to reduce payment times to suppliers as far as possible, in particular by speeding up the digitalisation of invoices received through an IT tool. In addition, it helps improve the invoice approval processes, making them more streamlined and straightforward, and ensuring a prompt response from the final approver, thus greatly shortening payment times and favouring a good client–supplier relationship. Finally, in Ireland, the ACC023 procedure is adopted, a payment approval process approved by the Board of Directors, which defines the persons authorised to validate payments, including those intended for suppliers. This procedure sets payment deadlines to ensure that all payments are made in an efficient and timely manner. Actions [G1-2 DP 15 a] Due to the importance of the issue relating to responsible procurement policies, the Mediolanum Group has developed specific policies over the years and improved its supplier assessment criteria by including an analysis of the social and environmental impacts of the products and services provided (see ESRS S2 Workers in the Value Chain, for further details on Policies, Actions and Objectives for workers in the Value Chain). [G1-2 DP 15 b] For Italian Companies of the Group, the ‘full’ supplier selection process also takes into account the assessment of ESG and financial performance (see ESRS S2 Workers in the value chain, paragraph 3.2.2 Suppliers, section ‘Actions’ - DP 32 a, for further details on how Mediolanum Group takes into account social and environmental criteria for the selection of its suppliers). The foreign Subsidiaries have initiated a process of alignment with the Parent Company’s practices. In particular, the Spanish companies have a specialised provider that supplies information on the sustainability of new suppliers and existing strategic suppliers. This external service (i.e. INFORMA - Dun & Bradstreet) provides comprehensive reports that include ESG, financial, legal and reputational aspects, allowing the identification of potential risks in the value chain. Finally, Irish companies are planning the inclusion of an optional ESG rating prior to the launch of a proposal to provide services.
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371 | Mediolanum Group - 2025 Annual Financial Report Targets IROs: Improvement of suppliers’ ESG performance by means of selection criteria that take into account social and environmental aspects [ESRS 2 MDR-T 80] Target Target KPI Target year Scope Baseline year and value Progress at 31/12/2025 Integration of ESG criteria into the specifications of new tenders or contracts Percentage of suppliers assessed who apply ESG criteria in new tenders or contracts ≥ 50% 2030 Group 2024 15% of newly signed tenders or contracts 15%93 The Mediolanum Group has targeted the integration of ESG criteria in its specifications for 50% of new tenders or contracts by 2030. The achievement of this objective will be monitored annually, verifying the percentage of tenders and contracts that actually integrate ESG requirements. 4.1.4 Bribery and corruption [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Active and passive corruption Damage to the market and the community caused by money laundering Potential negative impact Own Operations and Downstream Value Chain (Distribution Channels) Short term Damage to the market and the community caused by corruption Potential negative impact Own Operations and Downstream Value Chain (Distribution Channels) Short term The Group’s approach and policies Corporate conduct is one of the key aspects of maintaining trust in the markets and among Stakeholders, and is particularly relevant in the context of combating bribery and corruption. At Mediolanum, the management of this area reflects an approach based on a solid internal control system and a rigorous organisational model aimed at preventing unlawful conduct. Anti-corruption, both public and private, is an integral part of corporate policies, in line with national regulations and international conventions. The Group prohibits any attempt to provide or accept benefits that do not conform to market practices, by adopting internal procedures to monitor and manage the risks associated with such activities. This system is supported by a corporate culture that places ethics and integrity at the heart of business and institutional relationships, creating an environment that significantly reduces the risk of corrupt behaviour and enhances transparency. These measures not only protect against potential legal implications, but strengthen the Bank’s reputation as a responsible player in the economic landscape. Moreover, the scrupulous management of payment practices, regulated by precise internal regulations, is an additional protective factor, ensuring that every transaction complies with the highest standards of fairness and lawfulness. [G1-1 DP 7; ESRS 2 MDR-P DP 65] 93 Since the target was defined and approved at the end of 2025, there is no evidence of progress compared to the baseline year 2024. Any progress will be more evident in subsequent reporting.
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372 | Mediolanum Group - 2025 Annual Financial Report Over the years, the Group has developed policies dedicated to managing the impacts related to active and passive corruption and money laundering risk, i.e. the Anti-Corruption Policy of the Mediolanum Group and the Policy on Anti-Money Laundering and Combating Terrorist Financing of Banca Mediolanum. IROs: Damage to the market and the community caused by corruption Policy on Anti-Corruption of the Mediolanum Group Content and objectives The Anti-Corruption Policy of the Mediolanum Group was approved by the Board of Directors of Banca Mediolanum on 12 December 2024. The Group promotes a culture of zero tolerance, according to which corruption is never allowed, and is committed to combating it in all its forms. The Policy identifies the main corporate activities that, by their nature, are more exposed to the risk of corruption, and defines the principles to be followed in order to prevent corruption. The Group adopts a structured anti-corruption programme implemented across all companies, aimed at preventing corruption risks. The programme provides mechanisms for the internal reporting of possible cases of corruption through the whistleblowing channel. Scope of application The Policy applies to all members of the Management Bodies, employees, persons in the Sales Networks authorised to sell via the indirect sales channel and Group contract staff, and is sent to all Companies belonging to the Mediolanum Group, for their adoption, without prejudice to any specific provisions of local jurisdictions and their respective Supervisory Authorities. The Group’s Spanish and Irish Companies have a Policy, aligned with the Mediolanum Group’s Policy, to promote a corporate culture compliant with applicable regulations, aligned with best market practices and focused on customers. Highest level of management responsible for implementation The Parent Company’s Board of Directors defines the Group’s anti-corruption policies, creates and disseminates the culture of corruption risk management within the Group, oversees the required conduct and raises awareness about compliance with the standards of conduct described in the Policy. Furthermore, the Chief Executive Officer issues instructions for implementing the process for the management of corruption, in accordance with the guidance from the Board of Directors. Regulations and reference standards The Policy is in line with the principles of the Global Compact promoted by the United Nations, and with the EBA Guidelines on internal governance of 2 July 2021 (EBA/GL/2021/05). Stakeholder engagement The interests of Stakeholders are taken into account through a process of indirect customer engagement, as well as through the implementation of safeguards and controls to intercept incorrect conduct and ensure that the information provided is clear, understandable and accessible. Method of dissemination The Policy is made public on the company intranet and, in addition, must be made available to external stakeholders to i) inform them of the anti -corruption principles adopted by the Mediolanum Group and ii) expressly request that they adhere to the fundamental values of integrity, transparency and responsibility as defined by the Group. Therefore, the Parent Company publishes the Policy on the institutional website, in order to guarantee that external parties concerned have knowledge and understanding of the Policy’s rules.
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373 | Mediolanum Group - 2025 Annual Financial Report IROs: Damage to the market and the community caused by money laundering Policy on Anti-Money Laundering and Combating Terrorist Financing of the Mediolanum Group Content and objectives In accordance with provisions in force, at its meeting of 8 May 2025, the Board of Directors of Banca Mediolanum approved the Mediolanum Group’s Policy on Anti-Money Laundering and Combating Terrorist Financing, in addition to the existing Banca Mediolanum Policy. The Policy is in fact aimed at preventing Group companies from being involved, also without being aware, in money laundering or terrorist financing. The documents set out the organisational structures, governance rules and Group guidelines for combating money laundering, establishing procedures, controls, roles and responsibilities, as well as principles for managing high-risk customers. Scope of application The Policy is aimed at Group staff, including Family Bankers. Highest level of management responsible for implementation The Group Policy is approved by the Board of Directors of Banca Mediolanum and is sent for transposition, in accordance with the principle of proportionality and taking into account local regulations and specificities, to the Strategic Supervisory Bodies of the Companies/corporate bodies belonging to the Group. The Chief Executive Officer defines the Policy submitted for the approval of the Board of Directors and oversees its implementation. The Anti-Money Laundering Officer monitors the adequacy and proportionality of the Policy over time, taking into account the characteristics of the Company and the risks to which it is exposed. The Anti-Money Laundering Function assists with the updating and periodic review of these Policies. Regulations and reference standards Through the implementation of the Policy, the Group Companies undertake to ensure compliance with specific EU and national regulations in this area, as well as with the secondary regulations issued by the competent national authorities, which implement the more general recommendations of the Financial Action Task Force (FATF), which is the main international coordinating body in this area. Method of dissemination The Policy is made available to stakeholders through the publication and dissemination of the document within the Mediolanum Group, as well as through publication on the Banca Mediolanum website. [G1-1 DP 10 e] In order to quickly, independently and objectively investigate incidents concerning the undertaking’s conduct, for corruption cases, the Group has adopted an Anti-Corruption Programme, a structured and complete tool, involving all the Companies of the Group. The programme provides for a reporting mechanism whereby, in the event of the detection of information likely to suggest the possible existence of corruption, the internal structures are required to trigger the whistleblowing reporting process. In addition to the Anti-Corruption Programme, Banca Mediolanum prepared a Regulation during 2025 for the management and tracking of corporate gifts and hospitality. The Regulation describes the Bank’s approach to identifying circumstances that generate or may generate a potential act of corruption, and defines the procedures and measures for the prevention, detection, communication, assessment and management of such situations. In addition, during 2025, reporting was prepared on the monitoring of possible breaches of the Code of Conduct for the Risks Committee and the Board of Directors. The Spanish companies of the Group and MIFL also adopted an Anti-Corruption Programme in line with the Mediolanum Group’s programme. [G1-1 DP 10 h]
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374 | Mediolanum Group - 2025 Annual Financial Report The Special Section of the Organisation, Management and Control Model, which corresponds to Model 231 in Italy, includes specific Protocols containing principles of conduct and control for the prevention of risks of corruption. The Protocols are detailed for activities where this risk is potentially present: relations with the public administration and public supervisory authorities, cases in which public entities assume the status of customers/investors, staff recruitment processes, relations with suppliers and dispute management have been taken into account. The Group companies, through their own Policy, which incorporates the principles on Anti-corruption, have identified the organisational areas which, based on their business and the nature of the activities carried out, are most exposed to the risk of corruption. By way of example, for the Group’s Italian companies, these include functions involved in the oversight of gifts and hospitality, the engagement of third parties, the processes for selecting and managing personnel and the commercial network, credit granting and recovery activities, relations with public officials and authorities, as well as the administration of disputes and complaints. With respect to the Spanish Companies, various business areas considered to be particularly exposed to the risk of corruption have also been identified. These include: activities related to corporate gifts and hospitality, involving functions such as Acción Social, the Communication and Commercial Department; ‘facilitation’ payments, which represent a risk mainly in the context of corporate purchases and services, which concern the Compras y Servicios Corporativo Area; sponsorships and donations managed by the Acción Social Office and the Marketing and Events Teams; mergers, acquisitions and significant investments, as well as the management and sale of assets, under the responsibility of the Chief Financial Officer’s Department; procedures for assigning mandates or consultancy contracts to third parties, which involve the Purchasing Functions, Regulatory Governance and the Commercial and Marketing Department; activities related to job offers, such as hiring, internships and promotions, involving the Personas Department and Commercial Department; the granting, management and recovery of loans, together with the underwriting of products, entrusted to the Loans Department; Relations with public officials, authorities and public bodies require particular vigilance and involve several departments, including Administration, Compliance, Risk Management, Legal, Tax and Customer Service; relations with political parties, handled by the Acción Social and Purchasing Office, and dispute resolution, both judicial and through alternative methods, which come under the responsibilities of the legal area and customer service. Finally, Irish companies do not specifically identify the business areas most at risk of active or passive corruption and for this reason, as an example, training in this area is provided to all, regardless of their role and responsibilities.
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375 | Mediolanum Group - 2025 Annual Financial Report Actions [ESRS 2 MDR-A DP 68] IROs: Damage to the market and the community caused by corruption The Mediolanum Group has adopted various initiatives in relation to anti-corruption and anti-money laundering. In particular, for 2025, the main action plans implemented provide for: with regard to the implementation of organisational models and policies for the prevention of offences, periodic controls, examination and analysis of operating processes are carried out, in order to prevent, among other risks, cases of corruption. Similar safeguards are in place for the implementation of the Code of Ethics and the Code of Conduct; the structures responsible for conduct-related cases that could present corruption profiles may be alerted through specific reporting channels; in the area of anti-corruption, training courses are delivered to recipients. Case studies, the sanctions provided for and the main regulatory references in the area of public and private corruption are addressed during these courses. Recipients persons are also informed of the organisational safeguards provided for by the procedures and Policies in force. During 2025, the Group Companies updated and provided recipients with specific training. In 2025, the exemption models for certain Companies from ‘corporate administrative liability’ were also updated and adjusted. The competent corporate bodies approved them in order to transpose into them the offences governed by law, with respect to the previous versions of the models and the organisational changes that have taken place in the meantime. The updated documents were adequately disseminated, through publication company databases in which corporate documentation is available to employees and contract staff. IROs: Damage to the market and the community caused by money laundering In 2025, the Anti-Money Laundering Function of each Group company duly performed its activities, overseeing the evolution of the reference regulatory framework, providing support and advice to the various business areas for the purposes of correct application of the legislation and ensuring the delivery of the scheduled training and continuing professional development plan for employees and contract staff of the sales network, where provided for. Checks were carried out on the correct functioning of the first-level safeguards, at the same time fulfilling the obligations of active collaboration by analysing reports of possible suspicious transactions originating from the Sales Network, where provided for, from the operational structures and from transaction monitoring systems, for the purposes of possible submission to the suspicious transactions reporting manager of each company for the relevant assessments. Specifically with regard to the main project initiatives undertaken by the Parent Company, post go live monitoring of the new GIANOS® 4D v. 5.9 software is under way, in agreement with the supplier. The purpose is to ascertain the correct and complete population of all expected information, as well as enable the activation of some new parameters relating to the presence of any negative evidence from customers, which may be reflected in the more restrictive way that certain rules determine the thresholds used to identify anomalous behaviour. In accordance with the instructions issued by the Supervisory Authority, in order specific actions were taken to rationalise and refine the transaction monitoring system as a whole, taking action in several areas. This will further increase the effectiveness and efficiency of the process of identifying anomalous transactions. The Anti-Money Laundering Function of the Parent Company has also launched, with the support of a specialised law firm, a gap analysis of Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist
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376 | Mediolanum Group - 2025 Annual Financial Report financing, adopted as part of the European anti-money laundering regulatory package (‘AML Package’). The purpose of the analysis is to highlight any deviations from applicable legislation and the internal organisational and procedural structure, with the aim of defining the corrective or adjustment actions necessary to ensure full compliance with the new regulatory framework. The Function also worked with a specialist consulting firm to perform the assessment (the so-called sanction risk assessment), provided for in the EBA Guidelines ‘on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures’ , with the aim of identifying and assessing any vulnerabilities in the controls in use. The training plan represents a cyclical and recurring process that takes place on an annual basis. The plan for disseminating the Policy to the Group’s Stakeholders is implemented whenever the Policy is updated. The Anti- Money Laundering Function of the Group Companies, coordinated by the Human Resources Training Sector, plans permanent training and professional development programmes for Personnel and the Sales Network. Specific training programmes are also implemented for staff belonging to the Anti-Money Laundering Function. Specific Board induction sessions are also organised, during which the corporate bodies are updated on the main changes and evolution in the regulatory environment. In addition, in Spain, in 2025, mandatory training was provided on PBC/FT (Prevención del Blanqueo de Capitales y Financiamiento del Terrorismo – Prevention of Money Laundering and Terrorist Financing) to employees and new recruits, and was complemented by numerous webinars, seminars and specialised workshops aimed at various corporate functions, including senior management, to gain further insights into regulatory, operational and innovative aspects of the prevention of money laundering and terrorist financing. In addition, for the Irish companies, an Anti-Money Laundering and Counter-Terrorist Financing oversight programme for suppliers, an annual test plan (CDD – Customer Due Diligence, ECDD – Enhanced Customer Due Diligence, transaction monitoring and screening) and targeted reviews of high-risk customers and PEP were implemented, to ensure constant alignment with the Parent Company. [G1-3 DP 18 a] The organisation, management and control models implemented to prevent the ‘Administrative liability of entities’ are aimed at combating corruption in an effective way, in order to promote the social and economic development of an organised community of people. Corrupt practices have a negative impact on the relationship of trust that must be maintained at all levels, both with public institutions and among the economic operators themselves, and create a system that distorts the positive effects of a market economy oriented towards the protection of the interests and fundamental rights of the community. The Mediolanum Group’s Anti-Corruption Policy establishes that, in the context of specific risk management, with reference to both corruption risk and reputational risks associated with breaches of these rules, the material processes are identified and monitored by the individual corporate areas of the Bank within the scope of its specific activities through a system of controls mainly provided for the implementation of the Organisation, Management and Control Model pursuant to Legislative Decree No. 231/2001. Another level of detail to prevent corruption risks was obtained through a specific assessment of the risks of offences and the organisational safeguards present in corporate processes through specific ‘231 risk assessments’. Using this method, the following are identified: organisational units, methods of potential perpetration of offences, ‘231-risk’ factors and control points maintained by the second-level control functions, which are considered effective in mitigating the risks related to the ‘administrative liability of entities’. The corporate bodies responsible for supervising the above models are periodically updated on the results of these controls. Specific information flows were also created to inform the Supervisory Body of cases in which employees, contract staff or Senior Management are involved in the initiation of investigations or proceedings for the liability provided for by Legislative Decree No. 231/2001, which may directly or indirectly concern the Companies. Furthermore, in order to prevent and combat corruption effectively, the Mediolanum Group, in the
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377 | Mediolanum Group - 2025 Annual Financial Report context of its Anti-Corruption Policy, has adopted an Anti-Corruption Programme, a structured and complete tool that involves all the Group Companies. The programme is based on four principles: internal regulations; staff training; controls and organisational framework; recording and archiving of transactions. The Subsidiaries, both Italian and foreign, implement the Policies defined at Group level with adaptations deriving from specific or local regulations. [G1-3 DP 18 b] For the Italian Companies, pursuant to Legislative Decree No. 231/2001, an internal body is identified, vested with autonomous powers of initiative and control (Article 6, paragraph 1(b), which must be entrusted with the task of supervising the functioning, effectiveness and observance of the Model and ensuring that it is constantly and promptly updated. In view of the specific nature of its tasks and the Company’s organisational structure, the powers and responsibilities of the Supervisory Body are granted to a collegial body consisting of members with proven professionalism and experience, identified as the members of the Board of Statutory Auditors. The duties of the Supervisory Body are therefore performed by the Board of Statutory Auditors in accordance with the combined reading of both the Decree and the banking supervisory regulations. The above structure is guaranteed the characteristics of autonomy, independence, professionalism and continuity of action that the Decree requires for this delicate function. The Board of Directors appoints the Supervisory Body by means of a specific Board resolution. The Administrative Body is also responsible for periodically assessing the adequacy of the Supervisory Body in terms of organisational structure and powers conferred, making the amendments and/or additions deemed necessary by Board resolution. The Supervisory Body, in a specific document notified to the Board of Directors, sets out its operating rules and the procedures for managing the necessary information flows that it will be required to receive and send. For Spanish companies, in accordance with the Criminal Code, an internal body responsible for compliance with criminal law is established. The Ethics Committee performs this role for the Group’s Spanish companies and, as such, is responsible for applying the internal model on criminal compliance and for monitoring non-compliance with the principles of the Code of Ethics at these companies. The Criminal Compliance Model is a comprehensive system for the prevention, detection and management of criminal risks. In addition to preventing the perpetration of offences by the organisation or its members, it serves to reduce the company’s criminal liability, protect its reputation, promote an ethical culture and ensure compliance with the law in the current legal framework. Key components of the model include: the identification and assessment of requirements the definition of policies and procedures; continuous staff training; monitoring and control systems; mechanisms for reporting and managing violations. In addition, the Ethics Committee relies on the support of the Ethics Committee’s Technical Office (OTCE), a body that supports the Ethics Committee and the Whistleblowing Internal Information System, and that reports functionally to them. As a support body to the Ethics Committee, the OTCE is responsible for managing day-to- day operations related to the Criminal Compliance Model and for coordinating the control actions that must be carried out by the managers of each of the Group’s areas. [G1-3 DP 18 c]
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378 | Mediolanum Group - 2025 Annual Financial Report For the Italian Companies, the Supervisory Body reports annually, by means of a specific report, to the Board of Directors in order to disclose the work done during the year and the results achieved, as well as any need to update Model 231. If necessary, the Supervisory Body may submit information ‘by event’ to the Board of Directors, if it considers that a breach of Model 231 or risk behaviours is taking place in the context of ‘corporate administrative liability’. The Subsidiaries, both Italian and foreign, implement the Policies defined at Group level with adaptations deriving from specific or local regulations. In Spain, the Ethics Committee presents an annual report to the Boards of Directors on its activities, outlining the actions carried out during the previous financial year. In addition, the Ethics Committee submits reports to the Boards of Directors whenever deemed necessary, for example when it considers it appropriate to update the internal Criminal Compliance model or to report any serious incidents relating to this model. [G1-3 DP 20] The Boards of Directors of the various Companies of the Mediolanum Group are involved in the process of approving documentation to oversee the matter of anti-corruption, and therefore become aware of management practices on the subject. Model 231 is published in the database of corporate procedures, which can be accessed by employees and contract staff, as they are recipients vis-a-vis the internal regulations. An excerpt of the Model is also made available to third parties through the Bank’s website, where there is a section dedicated to the Supervisory Body. The commitment to compliance with Model 231 is expressly referred to in clauses in contracts with suppliers and in agency mandates relating to relations between the Bank and members of the Sales Network. As regards the Anti-Corruption Policy of the Mediolanum Group, after being approved by the relevant Boards of Directors, it will be published on the Companies’ official websites, to guarantee external parties concerned a knowledge and understanding of the Policy’s rules. Similarly, at the Spanish and Irish subsidiaries, following approval by the respective Boards of Directors and publication on the company intranets, the policies will be disseminated and, in specific cases, employees asked to acknowledge receipt of the documents. [G1-3 DP 21 a] The administrative liability regime provided for in the Decree and the adoption of Model 231 by the Bank are a system to which there must be a consistent and effective response in the operational conduct of the recipients of the Model. In this regard, it is essential to provide information and training aimed at facilitating the dissemination of what is established by the Decree and the Model adopted, so that knowledge of the matter and compliance with the rules that derive from it are an integral part of the professional culture of each employee. This activity involves the Board of Directors, Senior Management and executive personnel of the Company. For the purposes of implementing the Model, information and training for the recipients of the Model is coordinated and updated by the Supervisory Body with the support of the 231 Unit. The training process on ‘corporate administrative liability’ is constantly monitored by the Supervisory Body, through information flows and meetings with the corporate structures responsible for training staff and members of the Sales Network. In Spain, anti-corruption training is integrated into the Criminal Compliance, Code of Conduct and Code of Ethics programmes and is given to all personnel, the Sales Network and the Directors. In Ireland, policies on these issues apply to all staff, including contract staff and fixed-term employees, who must complete the relevant online training provided each year. [G1-3 DP 21 b] Banca Mediolanum and Banco Mediolanum identify and assess the functions most exposed to the risk of corruption. Specific anti-corruption training is provided for these functions. The Irish Group Companies, although they do not identify the functions most at risk of corruption, provide anti-corruption training to all employees. [G1-3 21 c]
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379 | Mediolanum Group - 2025 Annual Financial Report For the Group’s Italian Companies, company representatives receive special training sessions on various subjects relating to banking and regulation. Periodically, Legislative Decree 231/2001 is focussed on, which covers risks related to corruption offences. As for Banco Mediolanum, in keeping with the training described in the previous sections and in addition to the specific two-year training for Directors (last conducted in 2024), a session on risk culture was also held during 2025 for the Board of Directors and the Company’s Executives. For Irish companies, an annual Board self‐assessment is held, which replaces specific anti-corruption training courses. Targets [ESRS 2 MDR-T 72; 81 a; 81 b] No quantitative targets have been set for the prevention of active and passive corruption, as the approach adopted is mainly qualitative and preventive in nature. The Mediolanum Group carries out all activities necessary to promote the dissemination of company values, which are also laid down in internal policies, and to ensure constant oversight through careful monitoring by relevant company functions (see ESRS G1 Business conduct, paragraph 4.1.4 Active and passive corruption, sections ‘The Group’s approach and policies’; ‘Actions’ for further details). 4.1.5 Metrics Confirmed incidents of bribery and corruption [G1-4 DP 24 a; 24 b] No incidents occurred during 2025 that could be classed as incidents of corruption that involved the Group, whether directly or indirectly; therefore, it was not necessary to take specific action to manage such situations. [ESRS 2 MDR-M DP 75] Metrics relating to corruption and bribery are used to assess performance in relation to the impact ‘Damage to the market and community due to incidents of bribery’. [ESRS 2 MDR-M DP 77 a] The collection of data relating to any violations of anti-bribery and anti-corruption laws takes place through a platform made available to the Corporate Functions, which directly manage legal proceedings. [ESRS 2 MDR-M 77 b] The data related to any violations of the anti-bribery and anti-corruption laws are not validated by an external entity other than the entity issuing the certificate of compliance for data validation. Payment practices [G1-6 DP 33 a] For the Mediolanum Group, the average time taken to pay an invoice, from its due date to the date of actual payment, is: 5 days for the Group’s Italian Companies; 12 days for Banco Mediolanum; 21.96 days for the Group’s Irish Companies. [G1-6 DP 33 b] In Italy, the standard payment terms to suppliers are generally between 30 and 120 days from the invoice date; payments made within the standard payment terms amount to approximately 90% of the total94. 94 The standard payment terms for suppliers of the Italian Companies of the Mediolanum Group vary according to contractual agreements, which may be 30, 60, 90 or 120 days from the date of invoice or the end of the month in which the invoice is issued. Any payments with different conditions, such as payment on receipt of the invoice, while not falling within the standard terms, are nevertheless contractually defined.
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380 | Mediolanum Group - 2025 Annual Financial Report In Spain, the standard payment terms to suppliers are 30 days from the invoice date (60 days in the case of a specific agreement between the parties); payments made within the standard payment terms amount to approximately 90% of the total. In Ireland, the standard payment terms to suppliers are 30 days from the invoice date; payments made within the standard payment terms amount to approximately 90% of the total. The table below shows the average percentage of payments aligned with the standard payment conditions established by Banca Mediolanum. The percentage was calculated by aggregating data from Italy, Spain and Ireland: Overview of payment practices UoM 2025 2024 Total number of payments made No. 60,780 40,790 Number of payments aligned with the standard payment conditions No. 54,642 36,917 Percentage of payments aligned with the standard payment conditions % 89.90 90.51 [G1-6 DP 33 c] No Mediolanum Group Companies have legal proceedings pending due to delays in payments to suppliers; therefore, the total value of legal proceedings relating to payments to suppliers is zero. [G1-6 DP 33 d; ESRS 2 MDR-M DP 77 a] The calculation of the average time taken to pay an invoice from the due date to the actual payment date was made on all the invoices accounted for and paid during the reporting year. The average time, in days, to pay an invoice was calculated by applying the arithmetic mean of the days between the due date of the invoice and the actual date of payment of each individual invoice accounted for and paid in the year 2025. [ESRS 2 MDR-M DP 75] Metrics related to payment practices are used to evaluate performance against the following impact: ‘Developing a relationship of fairness and mutual trust with suppliers and adherence to payment practices’. [ESRS 2 MDR-M DP 77 b] In relation to payment practices metrics, no external entities, other than the entity issuing the certificate of compliance, are involved for data validation.
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381 | Mediolanum Group - 2025 Annual Financial Report 5. Entity-specific disclosures 5.1 Management of the distribution network The Mediolanum Group reports disclosures related to the management of the distribution network as specific topics of the entity in the social disclosures. As specified in the request for disclosures on the value chain (see ESRS 2 SBM-1), the Group’s distribution activity is located in the downstream Value Chain, developed on three specific channels for the purposes of providing advice to its customers: the network of Family Bankers (‘FB’) in Italy and Spain, comprising a total of over 6,500 individuals; Prexta agents in Italy. As of 31 December 2025, the model has had two operational centres (Rome and Milan), with the headquarters in Basiglio (Milan), and 58 agents in financial services (assisted by 558 contract staff); digital channels, mainly apps and the website. As required by specific disclosure requirements (see ESRS 1 AR 2), significant information is presented with reference to the areas of governance, strategy, impact management and risks and opportunities, as well as metrics and objectives. 5.1.1 Governance The Family Banker is a professional that represents the connection point between Banca Mediolanum and the customer. The Family Banker Network in Italy and Spain focuses on offering a personalised financial service. Its members act as independent consultants specialising in financial planning, asset management and the design of solutions tailored to customers’ needs. The Family Bankers have an independent contractual relationship with the Bank, which allows them to independently manage the assigned customer portfolio, within the set of controls put in place by the Bank, providing them with support in key aspects such as continual training, thus ensuring the quality of the service offered. Prexta, a subsidiary of the Mediolanum Group, also makes use of an extensive Distribution Network composed of financial agents duly registered in the Register of Financial Agents, in accordance with applicable legislation, under a single-mandate agency contract. The Prexta Sales Network is dedicated to the promotion and placement of credit consumer products (especially salary-backed loans and personal loans), and insurance products, with the latter as a supplement to salary- backed loans, and brokered on behalf of partner Companies. Prexta’s Sales Network therefore operates within the Mediolanum Group, contributing to the achievement of corporate objectives through a business model consistent with the Group’s guidelines. This synergy allows Prexta to maintain the appropriate degree of operational autonomy, while remaining in line with the Group’s principles and strategies. 5.1.2 Strategy Human relations are the principle on which the Mediolanum Group bases its relationship with the customer. The Family Banker is a key figure in the model and implements the values of the Mediolanum Group, strengthening the relationship of trust with customers and their families and becoming a point of reference in their lives. As part of the 2026-2030 Sustainability Plan, the Mediolanum Group has planned the development of the Sales Network through the Mediolanum Next programme, an initiative aimed at students about to graduate as well as recent graduates in economic and scientific, legal and political subjects who demonstrate a genuine interest in financial consulting, professional ambition and a strong entrepreneurial spirit. Using a structured approach,
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382 | Mediolanum Group - 2025 Annual Financial Report Banca Mediolanum allows young people to enter its commercial network in the role of Banker Consultant, enabling them to work with experts, ensuring adequate training and financial autonomy from the outset. The programme is in fact a privileged channel of access to the banking sector, offering specialist training and professional growth prospects (see the sections ‘Actions’ and ‘Targets’ of this chapter for further details). In addition, the network of Family Bankers in Italy and Spain actively contributes to the Group’s social commitment to communities through a role of support and communication of the initiatives undertaken in the region. For example, the ‘Mediolanum con te’ project allows Family Bankers to report non-profit entities in the region with which they have a connection, with the aim of supporting them financially (see ESRS S3 Affected Communities, paragraph 3.3.2 Economic, social and cultural rights of communities, section ‘Actions’ for further information). Finally, the Family Bankers are central to the dissemination of virtuous behaviour in customers on ESG matters. In this regard, the Sales Network in Italy is offered, on a voluntary basis, a training course for EFPA certification at the ESG level. In addition, training pills on the subject of sustainability are periodically delivered both in Italy and in Spain, and are constantly assigned to the new Family Bankers, in order to ensure a constant level of knowledge on the topic. In line with the Mediolanum Group’s sustainability strategy, Prexta also incorporates ESG principles into its corporate evolution, adopting an approach geared towards creating value for all Stakeholders and taking initiatives aimed at promoting sustainability in both the short and long term. The main lines of action and certifications obtained are as follows: Digitisation of credit granting processes: Prexta has for some time been implementing fully digital processes in the operating procedures for granting credit, in the context of both salary-backed loans and personal loans. The use by the Agent Network of this paperless technology is well and consistently above 95%, with a clear reduction in the environmental impact, including the reduction in CO2 emissions, thanks to the elimination of paper documentation; Accessibility Project: In line with the methodological approach adopted by the parent company, Prexta is gradually adjusting its channels to make them accessible, prioritising those with greater exposure, visibility and impact on customers: public websites, documents and communications. Projects are in progress and will lead over time to achieving progressive results; Support for Fragile and Vulnerable Groups o European Disability Charter: In 2025, Prexta renewed its endorsement of the Memorandum of Understanding between ABI and the Council of Ministers - Department for Policies for Persons with Disabilities, in order to offer holders of the European Disability Card preferential interest rate conditions on Prexta personal loans; o The Memorandum of Understanding to encourage the reimbursement of loans by women victims of gender-based violence: pending official confirmation by ABI on the extension of initiatives supporting women victims of violence, Prexta has expressed it is willing to renew its endorsement of the Memorandum of Understanding with ABI and the trade unions, thereby strengthening its commitment to supporting women enrolled in protection programmes. The initiative provides for the possibility of suspending the payment of the principal on personal loans for a maximum of 18 months, with a corresponding extension of the repayment plan. This reflects Prexta’s commitment to building a sustainable business model with a long-term focus, that combines technological innovation, social inclusion and attention to the environment, in line with the principles and values of the Mediolanum Group. As part of the double materiality process, the Mediolanum Group identified impacts and opportunities related to the management of the Distribution Network, with specific reference to the Family Banker network in Italy and Spain, in the light of size materiality, widespread presence in the region and centrality within the business model.
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383 | Mediolanum Group - 2025 Annual Financial Report 5.1.3 Impact, risk and opportunity management [SBM-3 DP 48 a] IRO description IRO category Connection with Value Chain Prevailing time horizon Family Banker satisfaction thanks to appropriate training programmes, performance appraisal systems and career development plans Actual positive impact Downstream Value Chain (Distribution Channels) Medium term Ensuring the job stability and the well- being at work of the Group’s Family Bankers Actual positive impact Downstream Value Chain (Distribution Channels) Medium term Insecurity among family bankers due to incidents of harassment and/or discrimination (gender, sexual orientation, religion, etc.) Potential negative impact Downstream Value Chain (Distribution Channels) Short term Improved attraction and retention of talent, involvement and productivity thanks to the valorisation of the Mediolanum Group’s Family Bankers Opportunities Downstream Value Chain (Distribution Channels) Medium term 5.1.4 Policies [ESRS 2 MDR-P DP 65] IROs: Family Banker satisfaction thanks to appropriate training programmes, performance appraisal systems and professional development plans; Improvement in talent attraction and retention, engagement and productivity thanks to the promotion of the Mediolanum Group’s Family Bankers Regulations on the process of training the Sales Network and Employees of Banca Mediolanum The regulations on the process of training the Sales Network and Employees of Banca Mediolanum are designed to develop and grow the various professionals within the Bank. The Network Training Sector, within the Network Governance, Training, Quality and Regional Services Department, is responsible for the entire training process aimed at the Banca Mediolanum Sales Network and, specifically: an analysis of the training requirements expressed by the Commercial Network Department and the other corporate departments, in collaboration with the Training, Learning & Empowerment Unit; the design and delivery of training activities, including in- depth education and training programmes activities relating to the offering and services of the Bank; the identification of trainers/speakers, selected from a pool of faculty speakers and leading third- party training companies; the delivery to the identified target of the planned activities, after identifying the dates and spaces (physical and digital) suitable for the purpose; verification of the knowledge acquired by administering, where provided for, an end-of- course test, on completion of which a training certificate is issued; monitoring of the training provided, with particular attention to the presence of learners, the accessing of courses, the quality of the materials used and the speakers providing the training.
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384 | Mediolanum Group - 2025 Annual Financial Report For further information on the minimum reporting requirements on the Regulations on the process of training the Sales Network and Employees of Banca Mediolanum see ESRS S1 Own Workforce, paragraph 3.1.5 Training and skills development, section ‘The Group’s approach and policies’. Regulation on the process for recruiting, selecting and monitoring Banker Consultants Content and objectives Banca Mediolanum has adopted a specific regulation to describe the various stages of the recruitment, selection, onboarding and monitoring process of Banker Consultants, within the Next Programme of Banca Mediolanum S.p.A. The Policy aims to promote access to the profession, ensure high professional and ethical standards and continuity and quality of service to customers. Continual performance- monitoring processes, as well as professional relationships, are envisaged. Scope of application The Regulation is addressed to the Sales Network of the Parent Company Banca Mediolanum. Highest level of management responsible for implementation Responsibility for implementing the policy lies with the Department for the Governance of Networks, Training, Quality and Territorial Services, with the involvement of the Managerial Support Unit for Territorial Services and the Regional Managers. Regulations and reference standards The policy is implemented in compliance with sector regulations, the requirements of OCF (the Italian Supervisory Body for Financial Advisors) and main internal references such as, but not limited to, the Code of Ethics and Code of Conduct of the Mediolanum Group. Stakeholder engagement The interests of the main Stakeholders, in particular prospective and current advisors, senior Family Bankers and customers, are considered in the definition and application of the Regulation. IROs: Ensuring the job stability and the well-being at work of the Group’s Family Bankers; Insecurity among family bankers due to incidents of harassment and/or discrimination (gender, sexual orientation, religion, etc.) Over time, the Mediolanum Group has defined a structured set of policies aimed at ensuring proper management of the impacts related to respect for labour rights, diversity and inclusion and, more generally, corporate culture. In addition to the Code of Ethics and the Sustainability Policy, the main safeguards include the Diversity and Inclusion Policy, the Internal Whistleblowing Policy, the Sexual Harassment Prevention Policy and the Human Rights Protection Policy. The Mediolanum Group’s Diversity and Inclusion Policy (see ESRS S1 Own workforce, paragraph 3.1.6 Equal treatment and opportunities for all, section ‘The Group’s approach and policies’, for further details on the minimum reporting requirements ) also applies to the Group’s Sales Network. With regard to the impact connected to the job stability and the well-being at work of the Family Bankers, the Policy specifies the Group’s commitment to promoting the continuous inclusion of young people and their professional development through programmes also aimed at the Family Bankers’ Network. At the same time, through the Employability & Empowerment Centre programmes, the Group guides the reskilling of all generations on the basis of the evolution of required skills. However, regarding areas related to discrimination, the Policy sets out specific principles and commitments, with reference to the valorisation of each person’s specific characteristics, including in relation to the Sales Network.
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385 | Mediolanum Group - 2025 Annual Financial Report The Policy on Internal Whistleblowing Systems (see ESRS G1 Business Conduct, paragraph 4.1.1 Business Culture, section ‘The Group’s approach and policies’, for further details on the minimum reporting requirements) extends the status of reporting person to Sales Network contract staff with an agency agreement (Family Bankers), recognising the possibility for them to report any potential or actual violations identified in performing their duties through the established channels. 5.1.5 Actions [ESRS 2 MDR-A DP 68] IROs: Family Banker satisfaction thanks to appropriate training programmes, performance appraisal systems and professional development plans; Improvement in talent attraction and retention, engagement and productivity thanks to the promotion of the Mediolanum Group’s Family Bankers Actions on training and professional development, with reference to the Sales Network in Italy, are planned and delivered through Mediolanum Corporate University(MCU), the educational institution created by Banca Mediolanum in 2009. In performing its function, Mediolanum Corporate University adopts an integrated model of teaching methods and tools to make learning more effective and practical, according to a lifelong learning approach that accompanies Family Bankers in their professional and personal growth over time. In 2025, Banca Mediolanum implemented various training initiatives through MCU. The main actions are listed below: Family Banker Academy: a training course designed to generate, enhance and structure awareness of the role of the Family Banker, enhancing technical and behavioural skills from the first months of activity, in order to achieve qualification as soon as possible. The Family Banker Academy is a course divided into three different stages (Smart, Advanced and Excellence), which takes place over three years, starting with the Family Banker’s entry into Banca Mediolanum; Executive Master’s in Banking Consulting (EMBC): a six-month specialist training course dedicated to young recent graduates who wish to become Financial Advisors. In 2025, seven classes were formed, each with a maximum capacity of 50 aspiring Banker Consultants; Mediolanum Innovative Training: ongoing business training for the entire network of Family Bankers, with two events per month lasting around three hours, on market scenarios, business strategies, products and services; Life Planning: training dedicated to all Family Bankers with the aim of enriching the commercial narrative, through the use of the new Life Planning advisory platform, through theoretical moments, the sharing of concrete experiences and group work on significant case histories. To this end, numerous in-person and remote sessions have been carried out and online training media have been produced, with the launch of operational laboratories, which will continue throughout 2026; EFPA certification : training courses dedicated to obtaining EFPA ( European Financial Planning Association) certification at EIP 95, EFA 96, EFP 97 and EIS 98 specialist levels. The first editions of the programmes for the new EFD and EFPS specialist certification were also launched in 2025. During the year, a total of 182 Family Bankers and Banker Consultants were involved in the training programmes (+52% compared to 2024); 95 European Investment Practitioner. 96 European Financial Advisor. 97 European Financial Planner. 98 European Insurance Specialist.
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386 | Mediolanum Group - 2025 Annual Financial Report Mediolanum Aurora – the training initiative ‘Dodici decimi: nuove lenti per i progetti finanziari femminili’ (‘Perfect eyesight: a new perspective for women’s financial projects’) dedicated to exploring current issues, such as financial education, inclusion and empowerment, enhancing the central role of women in society. The programme also includes an online community (‘Aurora Community’), for Family Bankers who attended the training course, which is activated starting from the first classroom session, to provide continuity for the training which began in-person. It is a space for discussion and awareness-raising, networking and inspiration. A dedicated editorial plan publishes new content on financial awareness and inclusion each week, collected in a SharePoint archive accessible to all community members. In addition, event formats have been developed to explore the above topics. Events can be requested by the Sales Network for customers and prospects and may be organised as single events or as more structured training pathways, within women’s associations and/or organisations, with the aim of highlighting successful experiences of women; IVASS and CONSOB training for certification and maintenance: mandatory regulatory pathways aimed at both obtaining and maintaining certification in the respective professional registers. In 2025, seven professional refresher courses were delivered, with access monitored, totalling 30 hours of training, as required by applicable legislation. In addition, a 60-hour initial professional training course is being provided for new Family Bankers for registration in the IVASS Intermediaries Register. Training in Artificial Intelligence: MCU has also begun to explore the use of artificial intelligence in the processes and day-to-day advisory activity of financial advisers. For this purpose, an initial awareness- raising initiative has been prepared on the potential and risks of using AI tools, consisting of a corporate TV broadcast and an online course; The Mediolanum Next Training Programme is a training programme divided into two main stages: o an Executive Master’s; o On-the-job support. The Executive Master’s is a scholarship for a six-month training course at Mediolanum Corporate University. This initial module aims to provide solid technical and behavioural skills, supporting participants in the preparation for OCF and IVASS certification and facilitating a deeper understanding of Banca Mediolanum’s operational dynamics. At the end of this programme, participants are authorised to act as Banker Consultants and undertake a mentoring scheme spanning several years. This stage, based on the co-management of the customer portfolio, aims to support and develop clientele and provides a competitive remuneration system. The Mediolanum model is based on a strong collaboration between Family Bankers in the local area and the Bank’s head office, ensuring the tools and resources necessary to operate at the highest levels in the asset advisory sector. In general, the training is intended for all the Italian geographical areas in which the Banca Mediolanum Financial Advisors Network is present, with an offering that includes both digital training that can be accessed from anywhere (i.e. online courses and webinars), and a training offering delivered directly in the various regional offices distributed throughout Italy, as well as in classrooms on the MCU Campus at the Head Office in Basiglio (Milan). The training is aimed at all stakeholder groups (i.e. Family Bankers, Managers and Faculty Speakers) and covers the entire career path, from onboarding to the development of specific skills.
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387 | Mediolanum Group - 2025 Annual Financial Report In 2025, MCU continued to monitor and improve its training initiatives through tools to assess the quality of the service provided, including administering satisfaction questionnaires and analysing the correlations between training initiatives and business data. In addition, dashboards were developed to analyse the various levels of training assessment, for most of the courses being delivered. These analyses, combined with the constant recording of the training needs expressed by the Family Banker Network, and the requirements of the Commercial Network Department, allow MCU to take action in a timely and effective manner on any training gaps or even to anticipate problems relating to regulatory, technical, commercial, behavioural and tool use matters. In 2025, total training up of the Sales Network accounted for 892,607 hours (distributed as follows: classroom training 101,149 hours; webinars 357,983 hours; online courses 433,473 hours), an increase of 27.34% compared to the previous year. In addition to the tools already available for communication and use of the training offer, the following are available on the intranet portal for the Family Bankers: FormaMente: a broad ‘showcase’ of the main courses and pathways to support the Family Bankers in all stage of their professional growth, both as advisory professionals and as managers. Each course is described in a detailed sheet with information on the content, teaching, professional targets, delivery methods and thematic areas concerned; MedBrain: training platform (i.e. Learning Management System) containing the courses profiled for the specific availability of individual users who can access the courses and how much they are accessed, both on a voluntary basis and on a mandatory basis, with tracking of access and tests for certification, collected according to SCORM standards. In 2025, continuing the approach to strengthen communication on the training activities of MCU, a section called ‘YoUniversity’ was introduced in the monthly newsletter, which Banca Mediolanum sends to the Family Bankers. This section promotes dedicated focus and support tools (i.e. articles, informative and educational videos, podcasts, interviews, etc.), and gives visibility to events, meetings and activities carried out in MCU, keeping the Network updated on corporate topics of interest. Banco Mediolanum is aware that the Family Bankers play an essential role in financial planning, asset management and the design of solutions adapted to the needs of customers and their families. For this reason, Family Bankers receive comprehensive training covering all the technical aspects and skills necessary to perform their role to the best of their ability. In 2025, the following training activities were held for all Family Bankers: Empodérate programme dedicated to lower-income FB; Workshops and Webinars dedicated to topics such as financial planning, portfolio segmentation, taxation, family and inheritance law); Extension of the catalogue of online courses available to the Network (ExplicaMED, Marca Personale, etc.); Supervisor-specific courses. To measure the degree of satisfaction of FBs, surveys are carried out periodically, at the end of the training activities (sometimes after each individual session, other times at the end of the programme, after several sessions), in which the Family Bankers assess the quality of the training received, the applicability of the knowledge acquired to their professional activity and the trainers who held the sessions.
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388 | Mediolanum Group - 2025 Annual Financial Report IROs: Ensuring the job stability and the well-being at work of the Group’s Family Bankers; Insecurity among family bankers due to incidents of harassment and/or discrimination (gender, sexual orientation, religion, etc.) The principles of diversity and inclusion are shared and supported by the management of the Commercial Network. Communication initiatives towards employees and the Commercial Network continued in 2025. Furthermore, although awareness-raising and the internalisation of diversity mainly takes place within the Group, these key values are also conveyed externally, in order to create free and inclusive spaces (for example, in the planning and production of events aimed at the Family Bankers Network and customers, Mediolanum promotes adequate gender representation in the choice of speakers). In fact, in 2025, the figures from the previous year were analysed and some experimental actions were carried out in order to refine our activities in 2026. In this regard, in the context of the sustainability plan, Network Training has been tasked with designing a training course to raise the awareness of the entire Network of issues related to the evolution of gender equality, to be delivered during 2025-2026. The Diversity and Inclusion Policy appoints a Diversity Officer for the Agent Network, tasked with overseeing compliance with the Policy and monitoring the development of initiatives in the Officer’s areas of responsibility. It should also be noted that the remuneration of the Network is proportional to the activity carried out, thus excluding any possible disparity in treatment. As regards the management and prevention of sexual harassment, the network has a policy and a dedicated procedure for handling complaints. Finally, in 2025, both a mandatory code of conduct course and a new online course on unconscious bias related to diversity and inclusion were organised in Spain for Family Bankers. 5.1.6 Targets [ESRS 2 MDR-T DP 80] IROs: Improved attraction and retention of talent, involvement and productivity thanks to the valorisation of the Mediolanum Group’s Family Bankers NEXT Project Target Target KPI Year target Scope Baseline year and value Progress at 31/12/2025 Ensure a constant flow of new entrants qualifying as Banker Consultants within the Sales Network 1413 Active Banker Consultants within the target year (2030) 2030 Italy 2024 (379 Banker Consultants) 590 Banker Consultants The target represents Banca Mediolanum’s intention to develop and expand the Sales Network, facilitating the access of young graduates to the profession of Financial Advisor, ensuring adequate training and financial autonomy from the outset, and also enabling generational transfer. IROs: Family Banker satisfaction thanks to appropriate training programmes, performance appraisal systems and career development plans
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389 | Mediolanum Group - 2025 Annual Financial Report Training Target Target KPI Year target Scope Baseline year and value Progress at 31/12/2025 Completion of 60 hours of annual professional training received by Family Bankers Percentage of Family Bankers who complete at least 60 hours of professional training per year ≥80% 2030 Italy 2024 > 80% 94.33% Spain 2024 > 80% 99% The target underlines the importance Banca Mediolanum and Banco Mediolanum attach to continual professional development, to ensure that every professional is adequately supported in their development journey, maintaining high standards of competence and service quality. 5.1.7 Metrics [ESRS 2 MDR-M DP 75] The following are the specific metrics used to assess performance and effectiveness with specific reference to the impacts linked to ensuring job stability and well-being at work for Family Bankers and opportunities related to the improvement of talent attraction and retention, involvement and productivity thanks to the development of the Mediolanum Group’s Family Bankers. The Family Banker network in Italy is spread throughout the country, offering an extensive presence that is close to customer requirements. Overall, there are 255 Family Banker Offices, 254 traditional offices and 3 branches. In Spain, also, the Family Banker network is spread across the country, with a total of 83 offices. Office distribution by region - Italy 2025 2024 Family Banker Office Traditional offices Branches Total offices Family Banker Office Traditional offices Branches Total offices Abruzzo 7 9 0 16 6 8 0 14 Basilicata 0 2 0 2 0 2 0 2 Calabria 3 10 0 13 3 10 0 13 Campania 2 17 0 19 2 17 0 19 Emilia- Romagna 31 22 0 53 34 21 0 55 Friuli-Venezia Giulia 7 8 0 15 6 8 0 14 Lazio 19 12 1 32 19 12 1 32 Liguria 4 5 0 9 4 5 0 9 Lombardy 41 28 2 71 41 26 2 69 Marche 14 3 0 17 15 3 0 18 Molise 4 1 0 5 4 1 0 5 Piedmont 16 19 0 35 16 18 0 34 Apulia 5 7 0 12 5 6 0 11 Sardinia 2 3 0 5 2 3 0 5
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390 | Mediolanum Group - 2025 Annual Financial Report Sicily 17 38 0 55 17 38 0 55 Tuscany 26 13 0 39 26 12 0 38 Trentino-South Tyrol 6 7 0 13 6 7 0 13 Umbria 5 7 0 12 5 6 0 11 Valle d’Aosta 2 0 0 2 2 0 0 2 Veneto 44 43 0 87 41 45 0 86 Total offices 255 254 3 512 254 248 3 505 Office distribution by region - Spain 2025 2024 Total offices Total offices Andalucía-Extremadura 11 10 Cataluña-Aragón-Islas 22 21 Comunidad Valenciana-Castilla Mancha-Murcia 18 19 Galicia-Asturias 19 18 Madrid-Castilla León 3 5 País Vasco-Navarra-La Rioja-Cantabria 10 10 Total offices 83 83 The following tables show the breakdown of Family Bankers by professional category, making a distinction between Advisors – including Financial Advisors and Banker Consultants, who perform exclusively commercial activities – and Managers, who combine commercial activities with managerial responsibilities. The data are further broken down by gender. Breakdown of Family Bankers by role and gender - Italy 2025 2024 Men Women Total Men Women Total Managers 658 49 707 593 43 636 Consultants 3,393 1,048 4,441 3,225 940 4,165 Total 4,051 1,097 5,148 3,818 983 4,801 Breakdown of Family Bankers by role and gender - Spain 2025 2024 Men Women Total Men Women Total Managers 261 74 335 272 81 353 Consultants 885 430 1,315 852 409 1,261 Total 1,146 504 1,650 1,124 490 1,614
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391 | Mediolanum Group - 2025 Annual Financial Report It should be noted that, in the table showing the breakdown of Family Bankers by role and gender in Spain, the data from 2024 relating to the total number of managers and advisors, as well as the related men/women split were reformulated, to make them comparable to 2025 data. In particular, the new methodology adopted considered Supervisors as Managers and no longer as Advisors. Finally, a significant figure demonstrating the commitment of the Network of Advisors to gain specialist skills to meet the challenges related to sustainable investments and to respond effectively to the growing needs of customers in terms of sustainability is the number of Family Bankers in Italy who obtained EFPA ESG certification (307 in the reporting year). [ESRS 2 MDR-M DP 77 a; 77 b] The Mediolanum Group actively involved the competent corporate structures in the information collection process. The data reported above was taken from internal management systems. In relation to the metrics, no external entities, other than the entity issuing the certificate of compliance, were involved in the data validation.
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392 | Mediolanum Group - 2025 Annual Financial Report OTHER INFORMATION Impairment testing - Goodwill The goodwill recorded in the consolidated financial statements, already present in the previous year, referred to the Spain and Italy “cash generating units” (CGUs). In particular, as in previous years, impairment testing at the level of the consolidated financial statements was performed on the following CGUs: Spain CGU: the goodwill allocated to the CGU includes goodwill relating to Banco Mediolanum of €102.8 million; CGU Italy: the total goodwill allocated to the CGU amounted to €22.7 million; The assistance of an independent expert was requested for impairment testing for the period ended 31 December 2025. Valuations were therefore made on the basis of estimated future cash flows and up-to-date projections, using methodology criteria from those proposed by the prevailing doctrine and used in professional practice that were deemed most suitable for the purpose and applicable to the case in question, taking into account the recommendations of the relevant accounting standards. The impairment process was specifically approved by the Board. The report produced by the independent expert and adopted by the Bank states that, in the light of the results obtained, no write-down is necessary. For the sake of completeness, it should be noted that, with respect to the Italy CGU, recoverability was verified, as a practical expedient, by referring to fair value, i.e. the market capitalisation of the Banca Mediolanum stock, as was also done in 2024. Shareholding in the German subsidiary August Lenz Following the start of the liquidation process, at 31 December 2025, the costs incurred by the company to meet disposal costs were €1.3 million. These were absorbed by the provision for risk and charges, with €8.8 million remaining at 31 December 2025, which is consistent with the hypothetical scenarios.
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393 | Mediolanum Group - 2025 Annual Financial Report Tax dispute With reference to the Mutual Agreement Procedure pursuant to Convention No. 90/436/EEC of 23 July 1990 on the elimination of double taxation in connection with the adjustment of profits of associated enterprises, and Article 24 of the Convention between Italy and Ireland for the avoidance of double taxation and the prevention of income tax evasion, already referred to in the 2024 Consolidated Annual Financial Report and in the previous periodic report, we report as follows. Following the closure, in 2024, of the 2017 and 2018 tax years by means of a tax assessment for Banca Mediolanum S.p.A. and Mediolanum Vita S.p.A., during 2025 the Companies began a negotiation with the Italian Revenue Agency in relation to subsequent tax periods, taking into account the imminent expiry dates for 2019 and the continuation of mutual agreement procedures (BAPA/MAP) relating to the 2019-2023 periods. On July 2025, Banca Mediolanum S.p.A., Mediolanum Vita S.p.A. and the Italian Revenue Agency signed a settlement agreement for the 2019-2022 tax periods, based on the same criteria already adopted in the agreements concluded in April 2024 and December 2024, which in turn were based on the results of the mutual agreement procedures between the competent Italian and Irish authorities. This agreement provides, also for the periods 2019-2022: a retrocession rate on management fees to Banca Mediolanum S.p.A. and Mediolanum Vita S.p.A. of 59.65%; a retrocession rate on performance fees to Banca Mediolanum S.p.A. of 7.70%, without prejudice to the non-recognition of the retrocession of performance fees for Mediolanum Vita S.p.A. Following the signing of the above agreement, on 7 August 2025, Banca Mediolanum S.p.A. and Mediolanum Vita S.p.A. submitted an application for a mutual agreement procedure to the competent Italian and Irish authorities, pursuant to EU tax dispute resolution legislation (Directive (EU) 2017/1852), in order to eliminate the double taxation arising from the adjustments agreed for the 2019-2022 tax periods. It should also be noted that on 22 December 2025, the competent Irish authority informed the companies concerned of the outcome of the mutual agreement procedures relating to intra-group transactions between the Irish entity and Mediolanum Vita S.p.A. for the tax periods 2010-2017. The agreement reached by the competent Italian and Irish authorities provides for the recognition, for these periods, of an arm’s length retrocession rate on of management fees of 59.65%, in line with the agreements already concluded and therefore of the accrual of the related tax credit by the Irish Group company. In light of the developments described and on the basis of the information currently available, the Group has updated its estimates, without recognising any further significant economic effects beyond those recorded in previous years.
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394 | Mediolanum Group - 2025 Annual Financial Report Tax developments Judgment of the Court of Justice in regard to IRAP Judgment 599 of 1 August 2025 has its origin in an initiative of the bank which, for the years 2012 to 2024, submitted applications to the Italian Revenue Agency to obtain the reimbursement of IRAP paid on 50% of the dividends received from foreign subsidiaries resident in the European Union. These applications challenged the unlawfulness of paragraph 1 of Article 6 of Legislative Decree No. 446 of 1997, which ordered the inclusion in the IRAP taxable base of 50% of the dividends received from foreign subsidiaries, as this provision violated the prohibition on taxing dividends distributed to parent companies resident in an EU State by subsidiaries resident in other EU States by a percentage exceeding 5% of their amount established in Article 4 of Directive 2011/96/EU of 30 November 2011 (the so-called Parent-Subsidiary Directive). In some cases, in response to the Italian Revenue Agency’s refusal to reimburse, the bank has lodged appeals at every level, requesting to refer the examination of the dispute, for a preliminary ruling, to the EU Court of Justice, i.e. to the EU court competent to judge on the compatibility of the national laws of the Member States with EU law. The Court accepted the bank’s argument by declaring in Judgment No. 599 of 1 August 2025 that subjecting Community dividends to a 50% IRAP tax rate was incompatible with the Parent-Subsidiary Directive. Since the Community judgment expressed a principle of direct application in national law, on the occasion of the enactment of Law No. 199 of 30 December 2025 (2026 Budget Law), the Italian Government amended the provision with effect from the 2025 tax period, establishing that intra-EU dividends received, inter alia, by banks that comply with the conditions of the Parent-Subsidiary Directive do not contribute to forming the IRAP taxable base at the rate of 95% of their amount instead of the 50% provided for in the previously applicable regime. Furthermore, for previous tax periods, the 2026 Budget Law recognised the right to reimbursement of the portion of higher IRAP calculated on the part exceeding 5% of the dividends received provided that an application to that effect is submitted. In light of the above, Banca Mediolanum, having already submitted applications for previous years starting from 2012, recorded a benefit of approximately €140.1 million in the separate and consolidated financial statements for the year ended 31 December 2025. It should also be noted that in 2025, the new regime was taken into account for the purposes of estimating the tax due on accrued dividends received from foreign subsidiaries. Disclosure in terms of “Tax on excess profits” The so-called “excess-profits tax” was introduced by Article 26, paragraph 2, of Legislative Decree No. 104/2023, which provides for an extraordinary tax determined by applying a rate of 40% to the amount of the net interest income, item 30 in the income statement, drawn up in the formats approved by the Bank of Italy, for the year prior to that under way on 1 January 2024, which exceeds by at least 10% the same margin in the year prior to that under way on 1 January 2022. When converting Legislative Decree No. 104/2023 into Law No. 136/2023, a clause was inserted into Article 26 (5-bis) according to which banks can avoid payment by allocating an amount of no less than two and a half times the “excess-profit tax” to a non-distributable reserve in order to strengthen their assets. Banca Mediolanum exercised this right when preparing the separate and consolidated financial statements for the year ended 31 December 2023, creating a non-distributable reserve of €67.4 million.
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395 | Mediolanum Group - 2025 Annual Financial Report Article 1, paragraphs 68-73, of the 2026 Budget Law, Law No. 199/2025, allows banks to render this reserve distributable, through the payment in 2026 of an extraordinary release/franking contribution equal to 27.5% of the reserve at 31 December 2025, or by paying, in the following years 2027, 2028, an extraordinary contribution equal to 33% of the reserve at 31 December of the previous year, without payment of interest. A legal presumption was also introduced, which provided that, with effect from the 2029 financial year, in the case of distribution of profits, including advances on dividends, or reserves, regardless of the shareholders’ meeting resolution, it is assumed that the reserve in which the 2.5 times the “excess-profit tax” has been set aside is distributed first. In accordance with the above, for the purposes of preparing the separate and consolidated financial statements for the year ended 31 December 2025, Banca Mediolanum has set aside €18.5 million as an extraordinary contribution, equal to 27.5% of the reserve already set up and recognised with other equity reserves as a contra entry. The amount set aside will be paid within the deadline applicable to the income tax balance for this year. Pillar Two disclosure It should be noted that the Mediolanum Group applied the temporary exemption provided for in the amendment to IAS 12 Revised, issued by the International Accounting Standards Board (IASB) on 23 May 2023, concerning the recognition and related disclosure to be provided in the consolidated financial statements of deferred tax assets and liabilities deriving from the application of the minimum level of tax (Global Minimum Tax) provided for by Directive (EU) No. 2022/2523 of 14 December 2022 (the “Directive”), within the framework of the Model of Global Anti-Base Erosion Rules (Pillar Two). In this regard, on 28 December 2023, Legislative Decree No. 209 of 27 December 2023, implementing the international tax reform, was published in the Official Gazette, which entered into force on 29 December 2023, containing the Italian provisions relating to Pillar Two, effective 1 January 2024. According to this legislation, the parent entity of a multinational group (and the intermediate participants) located in the Italian State are (will) eventually be required to pay a minimum top-up tax (“imposta minima integrativa” or “IIR”) on the profits accrued by its subsidiaries in States with an effective tax rate lower than 15% (“Minimum Tax Rate”) unless the individual States in which the subsidiaries operate have adopted the national minimum tax (“Qualified Domestic Minimum Top-up Tax” or “QDMTT”). The said tax may, depending on its characteristics, be deducted from the minimum supplementary IIR tax or result in its non-application to the countries in question. On the basis of its current composition, in addition to Italy, the Mediolanum Group operates (i) in Spain, through its subsidiary, Banco Mediolanum, and (ii) in Ireland, through subsidiaries Mediolanum International Funds and Mediolanum International Life. Spain implemented the Pillar Two provisions as well as a national minimum tax QDMTT scheme through Law No. 7 of 20 December 2024, which is applicable as of 1 January 2024. Ireland has also transposed the Pillar Two legislation into its own legislation through the Finance (No. 2) Act 2023 Section 94 of 15 May 2024, also effective from 1 January 2024, and the implementation of the QDMTT. In light of analysis carried out, the Group has identified Ireland and Italy as jurisdictions which, at present and on the basis of the preliminary assessments made, do not benefit from the temporary exemption known as “transitional safe harbour” (“TSH”). The analysis also showed that the Irish jurisdiction alone is subject to additional local taxation, applied through the Qdmtt. Accordingly, the Group recognised an additional supplementary tax charge in the financial statements for the year ended 31 December 2025 of approximately €20.1 million. With regard to the Italian jurisdiction, although the conditions for the TSH temporary exemption have not been met, no information has come to light that makes it necessary to recognise additional taxes in the financial statements.
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396 | Mediolanum Group - 2025 Annual Financial Report Guarantee Fund for Life Insurance Policies With regard to the contribution for the Life Insurance Fund, as already reported in 2024, the Group made provision as defined by the Fund’s Provisional Management Committee, which, pending the publication of the Articles of Association, has provided for confirmation of the calculation methods used in 2024. On the basis of this notice, therefore, the total amount recorded by the Group is €19.8 million (€16.2 million at 31 December 2024). Stamp duty on life insurance policies As already reported in the financial statements as at 31 December 2024, please note that the 2025 Budget Law (Law No. 207/2024) introduced a change to the method of payment of stamp duty on life insurance policies of classes III and V. In particular, the provision in question provides for the annual payment of stamp duty, it being understood that the amount will be calculated and allocated to the insured as a reduction in the service provided at the expiry or surrender of the policy. A transitional regime was then established, according to which the stamp duty calculated for each year for which the tax is due until 31 December 2024 was and will be paid: - 50% by 30.06.2025; - 20% by 30.06.2026; - 20% by 30.06.2027; - the remaining 10% by 30.06.2028. In particular, with regard to the above, in June 2025 the Group’s Life insurance companies proceeded to pay the instalment scheduled for the 2025 financial year which totalled €108.5 million. With reference to the accounting treatment arising from the above regulatory change, for insurance contracts valued in accordance with IFRS 17, as already done in the previous year, account was taken of the expected outlay forecasts for the payment of tax and the recovery of this tax from policyholders at the time of contract closure in accordance with the contractual provisions and technical assumptions already adopted for the purpose of projecting technical flows. With regard to the accounting treatment of the portion of the advance paid for products classified in accordance with IFRS 9, a receivable of €59.3 million was recognised, deriving from the right of the companies in question to recover the tax paid in advance from policyholders at the expiry or surrender of the policies. In this regard, in light of the guidelines issued by the supervisory authorities (Joint Bank of Italy, Consob and IVASS Document No. 10), the Group recognised a negative effect on the income statement of €13.5 million, representing the time value effect deriving from the expected average time of collection of the discounted receivable, given the nature of the asset, using a risk-free rate (free risk curve Eiopa).
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397 | Mediolanum Group - 2025 Annual Financial Report Information on the sale of Mediobanca shares The Board of Directors of Banca Mediolanum and Mediolanum Vita, at its meeting of 30 June 2025, approved the sale of the equity investment held in Mediobanca, amounting to a total of 29.1 million shares. The sale was completed through an accelerated bookbuilding procedure (the “Placement”) reserved to institutional investors, announced at the close of the market on 30 June 2025. The placement involved the purchase of shares by 77 different counterparties at a price of €18.85 per share, for a gross consideration of €548.4 million. The trade date of the Placement was 1 July 2025 and the settlement was completed on 3 July 2025. The security was classified as financial assets measured at fair value with an impact on comprehensive income as of 1 January 2020. Transaction costs of €5.0 million were charged to the income statement. Report on the transfer of the investment in MIFL to the subsidiary Banco Mediolanum It should be recalled that at the Board meeting on 8 May, a further contribution of 2.46% of the share capital of Mediolanum International Funds Ltd. (“MIF”) was approved to the Spanish subsidiary Banco Mediolanum SA, which already holds 4.54%. Following completion of the required obligations, the operation was completed with effect from 30 July 2025. SIGNIFICANT EVENTS AFTER THE REPORTING DATE In 2026, Banca Mediolanum successfully completed the issue of a Senior Preferred Bond maturing in 5 years (January 2031) and first call date in January 2030) for a total amount of €500 million and a coupon of 3.125%. The issue, dedicated exclusively to investors, was carried out under the Euro Medium-Term Note 1 billion programme dated October 2025. The rating expected is BBB+, in line with the issuer’s rating from S&P Global Ratings. It should also be noted that on 22 January, Banca Mediolanum also exercised the early redemption option on the “Green Senior Preferred Green Bond issued in November 2022”, amounting to €300 million. Apart from the foregoing, no other events occurred after 31 December 2025 that could have a material impact on the Company’s financial position and result of operations.
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398 | Mediolanum Group - 2025 Annual Financial Report BUSINESS OUTLOOK In the coming months, the global economy should continue to benefit from the cumulative effects of the monetary policy decisions already taken and the gradual implementation of expansionary fiscal policies. This is particularly the case in the United States, where the recent tax package (the One Big Beautiful Bill Act) is expected to start unfolding in the first part of the year, but also for Europe, with its infrastructure and defence investment plans, and for Japan, where fiscal stimulus remains an important supporting factor for growth. For bonds, the environment continues to be characterised by “higher for longer” yields, especially on the long part of the curves. In an environment of still resilient economic growth, credit spreads remain contained and do not signal significant tensions. This framework creates favourable conditions for bond investments with a medium-term horizon, with a view to carry. In addition to income generation, fixed income has also returned to a portfolio stabilisation role in equity volatility phases, reaffirming its dual contribution in terms of return and diversification. On the equity side, supportive factors remain numerous: not only overall accommodative monetary and fiscal policies, but also earnings growth which continues to be revised upwards. This is accompanied by a gradual expansion of participation in upward trends, both geographically (no longer limited to the United States) and sectoral (no longer exclusively focused on technology). While maintaining the pull of structural megatrends – with Artificial Intelligence in the spotlight – the market picture therefore appears more “democratic”. A lower concentration of yields could be a healthy development, paving the way for a more balanced dynamic in the medium term. The hype linked to Artificial Intelligence appears to be gradually fading, partly due to the maturing of the sub- fund. This is not a negative signal, but rather a more realistic and pragmatic development, which could result in a smaller relative boost to the technology sector. It will therefore be important to monitor which sectors will be able to pick up the baton, leading to an orderly sector rotation. In this context, episodes of volatility remain possible, but with the underlying scenario still constructive, well-structured diversification remains the most effective choice. Against this backdrop, the Banca Mediolanum Group confirms that it has adopted an integrated customer service strategy as a critical success factor for achieving a growing level of customer satisfaction and loyalty, with the aim of increasing new customer acquisition and the share of wallet of existing customers. Moreover, the diversified business model is capable of producing positive results in a variety of market conditions. Banca Mediolanum has a market share of the financial assets held by Italian households of 3.4% (Q3 2025 – Mediolanum processing of Prometeia data). The Group will therefore continue to pursue its strategy based mainly on organic growth both by improving its position in the competitive environment and by improving the quality of services offered and the efficiency of processes. In this regard, mention should be made of the initiatives aimed at strengthening the Family Banker network (the so-called NEXT Project) through the creation of a new generation of professionals - Banker Consultants – that will allow an additional level of improvement of service by Senior Private Bankers and Wealth Advisors, the “Grandi Patrimoni” initiative aimed at offering a top-level advisory service capable of addressing complex needs with a strategic, personalised and long-term approach and the Digital Transformation initiatives implemented by the Group.
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399 | Mediolanum Group - 2025 Annual Financial Report Therefore, in light of the macroeconomic scenario, considering the risks typical of the sector in question, and barring the occurrence of exceptional events that could lead to a significant deterioration of the current situation (not within the Directors’ and Management’s control and currently not foreseeable), a positive business performance is expected for 2026. Basiglio, 12 March 2026 For and on behalf of the Board of Directors The Chief Executive Officer Massimo Antonio Doris
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400 | Mediolanum Group - 2025 Annual Financial Report CONSOLIDATED FINANCIAL STATEMENTS
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401 | Mediolanum Group - 2025 Annual Financial Report STATEMENT OF FINANCIAL POSITION Asset items €/thousand 31/12/2025 31/12/2024 10. Cash and cash equivalents 161,823 684,440 20. Financial assets at fair value through profit or loss 48,154,374 42,531,431 a) financial assets held for trading 393,945 416,218 b) financial assets designated at fair value 47,554,066 41,904,095 c) other financial assets mandatorily measured at fair value 206,363 211,118 30. Financial assets measured at fair value through other comprehensive income 1,786,629 2,305,833 40. Financial assets measured at amortised cost 36,961,812 37,863,887 a) loans to banks 1,159,383 811,382 b) loans to customers 35,802,429 37,052,505 80. Insurance assets 76,651 70,997 b) reinsurance cessions that are classified as assets 76,651 70,997 90. Tangible assets 203,975 209,693 100. Intangible assets 220,878 212,914 of which: - goodwill 125,625 125,625 110. Tax assets 1,008,087 834,297 a) current 820,809 664,392 b) prepaid 187,278 169,905 120. Non-current assets and disposal groups - 823 130. Other assets 1,364,031 1,439,957 TOTAL ASSETS 89,938,260 86,154,272
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402 | Mediolanum Group - 2025 Annual Financial Report Liabilities and shareholders’ equity €/thousand 31/12/2025 31/12/2024 10. Financial liabilities measured at amortised cost 33,077,523 35,555,496 a) payables to banks 630,185 717,433 b) payables to customers 32,133,213 34,524,434 c) debt securities in issue 314,125 313,629 20. Financial liabilities held for trading - 3 30. Financial liabilities designated at fair value 21,808,900 18,740,436 60. Tax liabilities 427,783 410,923 a) current 338,259 307,087 b) deferred 89,524 103,836 80. Other liabilities 1,265,063 1,263,085 90. Employee severance benefits 11,868 12,228 100. Provisions for risk and charges 397,474 342,336 a) commitments and guarantees given 1,513 930 b) pensions and similar obligations 78 105 c) other provisions for risk and charges 395,883 341,301 110. Insurance liabilities 28,455,288 25,804,045 a) insurance contracts written that are classified as liabilities 28,455,288 25,804,045 120. Valuation reserves 8,809 119,833 150. Reserves 3,141,767 2,526,734 155. Interim dividends (443,529) (272,832) 160. Issue premiums 9,277 9,082 170. Capital 600,700 600,688 180. Treasury shares (-) (60,571) (77,414) 200. Profit (loss) for the year (+/-) 1,237,908 1,119,629 TOTAL LIABILITIES AND SHAREHOLDERS’ EQUITY 89,938,260 86,154,272 Basiglio, 12 March 2026 For and on behalf of the Board of Directors The Chief Executive Officer Massimo Antonio Doris
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403 | Mediolanum Group - 2025 Annual Financial Report INCOME STATEMENT €/thousand 31/12/2025 31/12/2024 10. Interest income and similar income 1,247,510 1,464,258 of which: interest income calculated using the effective interest method 1,150,033 1,361,831 20. Interest expense and similar expenses (368,914) (589,333) 30. Net interest income 878,596 874,925 40. Commission income 2,478,726 2,350,217 50. Commission expenses (996,516) (883,132) 60. Net commission income 1,482,210 1,467,085 70. Dividends and similar income 21,995 36,125 80. Net gains (losses) from trading 21,261 8,794 90. Net gains (losses) from hedging - 10 100. Gains (losses) from disposal or repurchase of: 1,592 304 a) financial assets measured at amortised cost 1,522 5 b) financial assets measured at fair value through other comprehensive income 70 299 110. Net gain (loss) from other financial assets and liabilities at fair value through profit or loss 879,894 2,689,820 a) financial assets and liabilities designated at fair value 872,817 2,682,486 b) other financial assets mandatorily measured at fair value 7,077 7,334 120. Operating income 3,285,548 5,077,063 130. Credit-risk induced net value adjustments/write-backs relating to: (26,290) (30,628) a) financial assets measured at amortised cost (26,627) (31,437) b) financial assets measured at fair value through other comprehensive income 337 809 150. Net gain (loss) from financial operations 3,259,258 5,046,435 160. Result of insurance services 224,383 192,095 a) insurance revenues deriving from insurance contracts written 504,357 441,959 b) costs of insurance services deriving from insurance contracts written (272,551) (236,060) c) insurance revenues deriving from reinsurance cessions 32,604 26,913 d) costs of insurance services deriving from reinsurance cessions (40,027) (40,717) 170. Balance of revenues and financial costs relating to insurance management (1,113,027) (2,883,237) a) net financial costs/revenues relating to insurance contracts written (1,113,569) (2,883,382) b) net financial revenues/costs relating to reinsurance cessions 542 145 180. Net gain (loss) from financial and insurance operations 2,370,614 2,355,293 190. Administrative expenses: (804,797) (789,914) a) staff costs (349,467) (328,727) b) other administrative expenses (455,330) (461,187) 200. Net provisions for risk and charges (85,241) (64,367) a) commitments and guarantees given (583) 560 b) other net provisions (84,658) (64,927) 210. Net value adjustments/write-backs of tangible assets (22,578) (24,146) 220. Net value adjustments/write-backs of intangible assets (29,703) (35,091) 230. Other operating income/expenses (6) 6,794 240. Operating costs (942,325) (906,724) 280. Gains (losses) on disposal of investments 1,368 2,125 290. Net income from continuing operations before tax 1,429,657 1,450,694 300. Taxes on income from continuing operations (191,749) (331,065) 310. Net income from continuing operations after tax 1,237,908 1,119,629 330. Profit (Loss) for the year 1,237,908 1,119,629 350. Profit (loss) for the year attributable to the parent company 1,237,908 1,119,629 Basiglio, 12 March 2026 For and on behalf of the Board of Directors The Chief Executive Officer Massimo Antonio Doris
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404 | Mediolanum Group - 2025 Annual Financial Report STATEMENT OF COMPREHENSIVE INCOME €/thousand 31/12/2025 31/12/2024 10. Profit (loss) for the year 1,237,908 1,119,629 Other income net of taxes without reversal to the income statement 132,414 78,856 20. Equity securities designated at fair value through other comprehensive income 131,493 78,231 70. Defined benefit plans 921 625 Other income net of taxes with reversal to the income statement 2,750 1,662 150. Financial assets (other than equity securities) measured at fair value through other comprehensive income 1,312 15,272 180. Financial revenues or costs relating to insurance contracts written 821 (13,197) 190. Financial revenues or costs relating to reinsurance cessions 617 (413) 200. Total other income net of taxes 135,164 80,518 210. Comprehensive income (Item 10+200) 1,373,072 1,200,147 220. Consolidated comprehensive income attributable to minority interests 230. Consolidated comprehensive income attributable to the Parent Company 1,373,072 1,200,147 Item 20 “Equity securities designated at fair value with an impact on comprehensive income” mainly relates to the sale of the interest held in Mediobanca S.p.A., completed on 3 July 2025, for an amount of €548.4 million. In particular, for the purposes of recognition of the sale transaction, the item included a positive change in the fair value of the security recorded during 2025 until the time of sale (with a positive sign) of €131.4 million, net of the tax effect. Basiglio, 12 March 2026 For and on behalf of the Board of Directors The Chief Executive Officer Massimo Antonio Doris
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405 | Mediolanum Group - 2025 Annual Financial Report STATEMENT OF CHANGES IN SHAREHOLDERS’ EQUITY AT 31 DECEMBER 2025 €/thousand Allocation of previous year’s result Changes during the year Shareholders’ equity at 31/12/2025 Changes in reserves Transactions on shareholders’ equity Comprehensive income at 31/12/2025 Balances at 31/12/2024 Change in opening balances Balances at 01/01/2025 Reserves Dividends and other destinations Issue of new shares Share buybacks Extraordinary dividend distribution Change in equity instruments Derivatives on treasury shares Stock options and performance shares Capital: - ordinary shares 600,688 - 600,688 - - - 12 - - - - - - 600,700 - other shares - - - - - - - - - - - - - - Issue premiums 9,082 - 9,082 - - - 195 - - - - - - 9,277 Reserves: - earnings 2,445,472 - 2,445,472 381,106 - 246,188 - - - - - - - 3,072,766 - other 81,262 - 81,262 - - (21,960) - - - - - 9,699 - 69,001 Valuation reserves 119,833 - 119,833 - - (246,188) - - - - - - 135,164 8,809 Equity instruments - - - - - - - - - - - - - - Interim dividends (272,832) - (272,832) - 272,832 - - - (443,529) - - - - (443,529) Treasury shares (77,414) - (77,414) - - - 16,843 - - - - - - (60,571) Net profit (loss) for the year 1,119,629 - 1,119,629 (381,106) (738,523) - - - - - - - 1,237,908 1,237,908 Shareholders’ equity attributable to the Group 4,025,720 - 4,025,720 - (465,691) (21,960) 17,050 - (443,529) - - 9,699 1,373,072 4,494,361 Shareholders’ equity attributable to minorities - - - - - - - - - - - - - - The change in the valuation reserve corresponding to the column “Overall profitability at 31/12/2025” is mainly attributable to the sale of the interest held in Mediobanca S.p.A. completed on 3 July 2025 for an equivalent value of €548.4 million. In particular, for the purposes of recognition of the sale transaction, the following were represented: i) the positive change in the fair value of the security recorded during 2025 until the time of sale, equal to €131.4 million net of the tax effect, in the column “Overall profitability at 31/12/2025”; ii) the transfer to the profit reserve of the accumulated valuation reserve with respect to the initial recognition value, equal to €246.2 million net of the tax effect, in the column “Changes in reserves”. With regard to the “Tax on excess profits”, see the Report on Operations Basiglio, 12 March 2026 For and on behalf of the Board of Directors The Chief Executive Officer Massimo Antonio Doris
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406 | Mediolanum Group - 2025 Annual Financial Report STATEMENT OF CHANGES IN SHAREHOLDERS’ EQUITY AT 31 DECEMBER 2024 €/thousand Allocation of previous year’s result Changes during the year Shareholders’ equity at 31/12/2024 Changes in reserves Transactions on shareholders’ equity Comprehensive income at 31/12/2024 Balances at 31/12/2023 Change in opening balances Balances at 01/01/2024 Reserves Dividends and other destinations Issue of new shares Share buybacks Extraordinary dividend distribution Change in equity instruments Derivatives on treasury shares Stock options and performance shares Capital: - ordinary shares 600,564 - 600,564 - - - 124 - - - - - - 600,688 - other shares - - - - - - - - - - - - - Issue premiums 7,035 - 7,035 - - - 2,047 - - - - - - 9,082 Reserves: - - - - - - - - - - - earnings 2,143,371 - 2,143,371 302,101 - - - - - - - - - 2,445,472 - other 69,885 - 69,885 - - 1,342 - - - - - 10,035 - 81,262 Valuation reserves 39,315 - 39,315 - - - - - - - - - 80,518 119,833 Equity instruments - - - - - - - - - - - - - - Interim dividends (207,519) - (207,519) - 207,519 - - - (272,832) - - - - (272,832) Treasury shares (19,781) - (19,781) - - - 8,294 (65,927) - - - - - (77,414) Net profit (loss) for the year 821,870 - 821,870 (302,101) (519,769) - - - - - - - 1,119,629 1,119,629 Shareholders’ equity attributable to the Group 3,454,740 - 3,454,740 - (312,250) 1,342 10,465 (65,927) (272,832) - - 10,035 1,200,147 4,025,720 Shareholders’ equity attributable to minorities - - - - - - - - - - - - - - Basiglio, 12 March 2026 For and on behalf of the Board of Directors The Chief Executive Officer Massimo Antonio Doris
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407 | Mediolanum Group - 2025 Annual Financial Report CONSOLIDATED STATEMENT OF CASH FLOWS Indirect method €/thousand 31/12/2025 31/12/2024 A. OPERATING ACTIVITIES 1. Management 1,245,628 1,504,060 - profit (loss) for the year (+/-) 1,237,908 1,119,629 - capital gains (losses) on financial assets held for trading and on other assets/liabilities at fair value through profit or loss (-/+) (897,505) (2,401,140) - capital gains (losses) on hedging activities (-/+) - (121) - credit-risk induced net value adjustments/write-backs (+/-) 26,290 30,628 - net value adjustments/write-backs of tangible and intangible assets (+/-) 52,281 59,237 - net provisions for risk and charges and other costs/revenues (+/-) 85,241 64,367 - net revenues and costs of insurance contracts written and reinsurance cessions (-/+) 888,644 2,691,142 - unpaid taxes, duties and tax credits (+/-) (156,930) (69,717) - other adjustments (+/-) 9,699 10,035 2. Cash generated by/utilised for financial assets (2,218,967) (3,455,073) - financial assets held for trading 23,737 582,606 - financial assets designated at fair value (3,803,793) (2,733,186) - other assets mandatorily measured at fair value 11,775 2,557 - financial assets measured at fair value through other comprehensive income 653,267 (177,138) - financial assets measured at amortised cost 875,448 (975,072) - other assets 20,599 (154,840) 3. Cash generated by/utilised for financial liabilities (395,201) 2,397,952 - financial liabilities measured at amortised cost (2,451,377) 303,191 - financial liabilities held for trading (3) (8,455) - financial liabilities designated at fair value 2,111,307 1,943,041 - other liabilities (55,128) 160,175 4. Cash generated by/utilised for insurance contracts written and reinsurance cessions 1,758,383 705,247 - insurance contracts written that are classified as liabilities/assets (+/-) 1,770,301 712,089 - reinsurance cessions that are classified as assets/liabilities (+/-) (11,918) (6,842) Net cash generated by/utilised for operating activities 389,843 1,152,186 B. INVESTMENT ACTIVITIES 1. Cash generated by 23,142 40,958 - dividends received on equity investments 21,995 36,125 - sales of tangible assets 1,147 4,833 2. Cash utilised for (43,479) (56,479) - purchases of tangible assets (7,766) (15,558) - purchases of intangible assets (35,713) (40,921) Net cash generated by/utilised for investment activities (20,337) (15,521) C. FINANCING ACTIVITIES - issues/purchases of treasury shares 16,843 (57,633) - issues/purchases of equity instruments 207 2,171 - dividend distribution and other purposes (909,173) (584,897) Net cash generated by/utilised for financing activities (892,123) (640,359) NET CASH GENERATED/UTILISED DURING THE YEAR (522,617) 496,306 Legend: ( + ) generated ( - ) utilised
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408 | Mediolanum Group - 2025 Annual Financial Report RECONCILIATION TABLE €/thousand 31/12/2025 31/12/2024 Line items Cash and cash equivalents at beginning of year 684,440 188,134 Total net cash generated/utilised during the year (522,617) 496,306 Cash and cash equivalents: effect of changes in exchange rates Cash and cash equivalents at end of year 161,823 684,440 Basiglio, 12 March 2026 For and on behalf of the Board of Directors The Chief Executive Officer Massimo Antonio Doris
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409 | Mediolanum Group - 2025 Annual Financial Report NOTES TO THE FINANCIAL STATEMENTS
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410 | Mediolanum Group - 2025 Annual Financial Report NOTES TO THE FINANCIAL STATEMENTS The Notes to the financial statements are divided into the following parts: Part A - Accounting policies Part B - Information on the consolidated statement of financial position Part C - Information on the consolidated income statement Part D - Consolidated comprehensive income Part E - Information on risks and the relative hedging policies Part F - Information on consolidated capital Part G - Business combinations involving businesses or business units Part H - Related party transactions Part I - Share-based payment agreements Part L - Segment reporting Part M - Lease reporting PART A – ACCOUNTING POLICIES A.1 – GENERAL PART SECTION 1 – Declaration of compliance with international accounting standards The consolidated financial statements of the Mediolanum Group at 31 December 2025 have been compiled in application of Legislative Decree No. 38 of 28 February 2005, in accordance with the IFRS accounting standards issued by the International Accounting Standards Board and the related interpretations of the International Financial Reporting Interpretations Committee (IFRIC) and adopted by the European Union, as set forth in Regulation (EU) No. 1606 of 19 July 2002 and subsequent updates. The Mediolanum Group, in accordance with the provisions of Legislative Decree No. 142 of 30 May 2005, is a financial conglomerate primarily engaged in banking. These financial statements of the Mediolanum Group for the year ended 31 December 2025 have been prepared on the basis of the “Instructions for the preparation of the financial statements of banks and financial parent companies of banking groups” issued by the Bank of Italy, in the exercise of the powers established by Article 9 of Legislative Decree 38/2005 with Circular 262 of 22 December 2005, as subsequently updated. These instructions set out in a binding manner the formats of the financial statements and the methods for compiling them, as well as the contents of the notes. The IFRS accounting standards issued by the International Accounting Standards Board endorsed and in force as at 31 December 2025 (including the SIC and IFRIC interpretative documents) were applied in compiling the Financial Statements.
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411 | Mediolanum Group - 2025 Annual Financial Report SECTION 2 – General basis of preparation The consolidated financial statements consist of the statement of financial position, income statement, statement of comprehensive income, statement of changes in shareholders’ equity, statement of cash flows and notes to the financial statements. They are also accompanied by a directors’ Report on Operations. In accordance with the provisions of Article 5 of Legislative Decree No. 38 of 28 February 2005, the consolidated financial statements have been compiled using the euro as the reporting currency. The amounts shown in the financial statements and the figures shown in the tables in the notes are expressed in thousands of euro, unless otherwise indicated. The accounting policies used to compile these consolidated financial statements, with reference to the phases of classification, recognition, measurement and derecognition of assets and liabilities, as well as the methods of recognising revenues and costs and the consolidation criteria, are consistent with those used to prepare the consolidated financial statements as of 31 December 2024 of the Banca Mediolanum Group. See the section “A2 – Part relating to the main balance sheet items” below for more details. The financial statements and notes include figures for the period under review as well as comparative data at 31 December 2024. The consolidated financial statements have been compiled in accordance with the following general principles: The Directors of Banca Mediolanum S.p.A. believe that they may reasonably expect that the Company, as well as the companies belonging to the Group in question, will continue to operate as a going concern for the foreseeable future, and therefore the consolidated financial statements for 2025 have been prepared on a going concern basis. They also specify that they have not found any cause for doubt regarding the going concern principle in the Group’s financial position or operating performance; accrual basis accounting: the financial statements have been prepared according to the accrual principle; relevance and aggregation: the balance sheet and income statement consist of items, sub-items and further details. The formats comply with those defined by the Bank of Italy in Circular 262 of 22 December 2005, as subsequently updated. New items may be added to these formats if their content is not attributable to any of the items already covered by the formats and only if they consist of significant amounts. The balance sheet, income statement and statement of comprehensive income do not include accounts with zero amounts, either for the year to which the financial statements refer or for the previous year; presentation: the classification of balance sheet items is constant over the years, unless there are changes that may occur as a result of a new standard or interpretation that require an amendment for which specific information is provided in the notes. For each balance sheet and income statement account, comparative information relating to the previous year is provided, unless an accounting standard or interpretation does not allow it or provides otherwise; prevalence of substance over form: operations and other events are recognised and represented in accordance with their substance and economic reality.
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412 | Mediolanum Group - 2025 Annual Financial Report CONTENTS OF THE CONSOLIDATED FINANCIAL STATEMENTS Consolidated statement of financial position and income statement The statement of financial position and the income statement consist of items, sub-items and more detailed information (the “of which” within items and sub-items). With respect to the formats defined by the Bank of Italy, items with zero amounts have not been presented, either for the year to which the financial statements relate or for the previous year. In the income statement, revenues are indicated with no sign, whereas costs are shown in parentheses. Consolidated statement of comprehensive income The statement of comprehensive income consists of items that show the changes in the value of the assets recorded during the year as balancing items of the valuation reserves, net of the relevant tax effect. Negative amounts are presented in parentheses. Consolidated statement of changes in shareholders’ equity The table shows the breakdown of and changes in the shareholders’ equity accounts during the reporting year and the previous year, broken down into share capital, capital reserves, earnings reserves and reserves from the valuation of assets or liabilities in the statement of financial position and the income statement. No equity instruments other than ordinary and savings shares were issued. Consolidated statement of cash flows The statement of cash flows for the reporting year and the previous year has been prepared using the indirect method, whereby cash flows from operating activities are represented by the net result for the year adjusted for the effects of non-monetary transactions. Cash flows are divided between operating activities, investment activities and financing activities. The table shows the flows generated during the year with no sign, while utilised flows are shown in parentheses. Contents of the notes to the financial statements The notes include the information required by the international accounting standards and Circular 262/2005 of the Bank of Italy, as subsequently updated. With respect to the formats defined by the Bank of Italy, the headings of the sections relating to financial statement items with zero amounts have not been presented, for either the year to which the financial statements relate or for the previous year. In the tables relating to the income statement items, revenues are indicated with no sign, whereas costs are shown in parentheses.
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413 | Mediolanum Group - 2025 Annual Financial Report SECTION 3 – Scope and methods of consolidation The consolidated financial statements include Banca Mediolanum S.p.A. and its direct or indirect subsidiaries, pursuant to IFRS 10. The control requirement, as defined by the standard, underpins the consolidation of all types of entities and occurs when at the same time an investor: has the power to decide on the entity’s significant activities; is exposed to or benefits from variable returns arising from their relationship with the entity; has the ability to exert their power to influence the amount of their returns (link between power and returns). IFRS 10 therefore establishes that in order to hold control, investors must have the ability to direct the entity’s significant activities, as a result of a legal right or simply de facto, and also be exposed to the variability of results that arise from that power. The inclusion of the majority of voting rights exercisable at the ordinary shareholders’ meeting is determined within the scope of the Group’s wholly owned subsidiaries, without exclusion when there is de jure control. The following table shows the equity investments included in the scope of consolidation: 1. List of equity investments in Group companies owned directly by Banca Mediolanum S.p.A., included in the consolidation on a line-by-line basis: Company Share capital (€/thousand) Ownership % Registered office/Operational HQ Type of relationship* Business Mediolanum Vita S.p.A. 207,720 100.00% Basiglio 1 Life insurance Mediolanum Comunicazione S.p.A. 775 100.00% Basiglio 1 Audiovisual production PI Servizi S.p.A. 517 100.00% Basiglio 1 Real estate activity Mediolanum International Life dac 1,395 100.00% Dublin 1 Life insurance Mediolanum Assicurazioni S.p.A. 25,800 100.00% Basiglio 1 Non-life insurance Mediolanum Gestione Fondi SGR p.A. 5,165 100.00% Basiglio 1 Mutual fund management Mediolanum International Funds Ltd** 165 93.00% Dublin 1 Mutual fund management Mediolanum Fiduciaria S.p.A. 240 100.00% Basiglio 1 Trust management Prexta S.p.A. 2,040 100.00% Basiglio 1 Financial intermediation FloWe S.p.A. – SB 10,000 100.00% Basiglio 1 Payment services August Lenz & Co. AG*** 20,000 100.00% Munich 1 Residual assets Banco Mediolanum S.A. 86,032 100.00% Valencia/Barcelona 1 Banking (*) Type of relationship: 1 = majority of voting rights at the ordinary shareholders’ meeting 2 = dominant influence at the ordinary shareholders’ meeting 3 = agreements with other shareholders 4 = other forms of control 5 = single management pursuant to Article 39(1) of “Legislative Decree 136/2015” 6 = single management pursuant to Article 39(2) of “Legislative Decree 136/2015” (**) The remaining 7% interest is held indirectly by Banca Mediolanum through Banco Mediolanum. During the third quarter of 2025, Banca Mediolanum transferred to the Spanish subsidiary Banco Mediolanum S.A. an equity investment of 2.46% in the share capital of the Irish subsidiary Mediolanum International Funds LTD, represented by 4,064 fully paid-up shares, through a non-monetary contribution to equity (without any change in the share capital), which is non-refundable and freely available. (***) The German subsidiary reissued its banking licence on 7 November 2022.
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414 | Mediolanum Group - 2025 Annual Financial Report 2. List of equity investments in Group companies owned indirectly by Banca Mediolanum S.p.A., through Banco Mediolanum S.A., included in the consolidation on a line-by-line basis: Company Share capital Ownership % Registered office/Operational HQ Type of relationship* Business (€/thousand) Mediolanum Gestión S.A. S.G.I.I.C. 2,506 99.999% Barcelona 1 Mutual fund management Fibanc S.A. 301 100.00% Barcelona 1 Financial advice Mediolanum Pensiones S.A. S.G.F.P. 902 99.999% Barcelona 1 Pension fund management Mediolanum International Funds Ltd 165 7.00% Dublin 1 Mutual fund management (*) Type of relationship: 1 = majority of voting rights at the ordinary shareholders’ meeting 2 = dominant influence at the ordinary shareholders’ meeting 3 = agreements with other shareholders 4 = other forms of control 5 = single management pursuant to Article 39(1) of “Legislative Decree 136/2015” 6 = single management pursuant to Article 39(2) of “Legislative Decree 136/2015” Consolidation methods Equity investments in subsidiaries are consolidated on a line-by-line basis. Line-by-line consolidation Full consolidation is the line-by-line inclusion of the aggregates of the subsidiaries’ statements of financial position and income statements. Once the shares of the net assets and profit attributable to minority shareholders have been allocated to them under a designated item, where applicable, the value of the investment is written off against the residual value of the subsidiary’s equity. The differences resulting from this transaction, if positive, are recognised – after any allocation to the assets or liabilities of the subsidiary – as goodwill under intangible assets. Negative differences on the date of initial consolidation are taken to the income statement. Assets, liabilities, income and expenses between consolidated companies are fully eliminated. The subsidiaries are consolidated as of the date on which control is acquired, according to the purchase method, and cease to be consolidated when the situation of control no longer exists. To prepare the consolidated financial statements for the year ended 31 December 2025, all the exclusively controlled subsidiaries prepared a balance sheet and income statement in accordance with the Group’s accounting principles.
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415 | Mediolanum Group - 2025 Annual Financial Report Significant valuations and assumptions for determining the scope of consolidation A summary of the main assessments performed in determining the scope of consolidation is provided below. The Mediolanum Group does not believe that it controls the “Unit Linked” internal insurance funds (of which it holds 100% of the outstanding units) and the promoted funds (investment, real estate and SICAVs) because not all the conditions provided by IFRS 10 are simultaneously met. With regard to the unit-linked funds, the Mediolanum Group believes that: it does not exercise full power over the unit-linked entity as it is limited by the requirements of the fund regulations in terms of asset allocation and management policies; it is not significantly exposed to the variable returns of the investee entity. In fact, the gains or losses relating to the valuation of assets in the unit-linked funds are fully attributed to policyholders through the change in the relevant liabilities, with the only change still attributable to the Group being the related impact on commissions (impact related to the variability of the flows of the entity and assessed as insignificant). With regard to the funds, the Mediolanum Group believes that: it does not own the majority of the outstanding units and does not bear their investment risk (e.g. unit funds holding units in managed funds the risk of which is borne by policyholders); it does not exercise full power over the investee entity (the funds) as it is limited by the requirements of the fund regulations in terms of asset allocation and management policies; it is not significantly exposed to the variable returns of the investee entity as it does not hold, or holds only marginal units of the funds, or holds units the risk of which it does not bear. The exposure to changes in the value of the funds, i.e. gains or losses relating to the valuation of the assets, is attributable to the investors, while the Group remains solely responsible for the change in the related impact on commissions. In particular, the Group is exposed to the risk of fluctuations in entry fees and premium loading related to inflow performance, management fees relating to assets under management and incentive fees associated with the performance of the funds under management, as well as operational, compliance and reputational risks typical of the sector in which the Group operates. Business Combinations Business combinations are accounted for using the purchase method. No business combinations took place during 2025
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416 | Mediolanum Group - 2025 Annual Financial Report SECTION 4 – Events after the reporting date In 2026, Banca Mediolanum successfully completed the issue of a Senior Preferred Bond maturing in 5 years (January 2031) and first call date in January 2030) for a total amount of €500 million and a coupon of 3.125%. The issue, dedicated exclusively to investors, was carried out under the Euro Medium-Term Note 1 billion programme dated October 2025. The rating expected is BBB+, in line with the issuer’s rating from S&P Global Ratings. It should also be noted that on 22 January, Banca Mediolanum also exercised the early redemption option on the “Green Senior Preferred Green Bond issued in November 2022”, amounting to €300 million. Apart from the foregoing, no events occurred after 31 December 2025 that could have a material impact on the Group’s financial position and results of operations. SECTION 5 – Other aspects Use of estimates These consolidated financial statements entailed the use of complex valuations and estimates which had an impact on the assets, liabilities, costs and revenues recognised and on the identification and quantification of potential assets and liabilities. The production of such estimates involved the use of the available information and the adoption of subjective assessments, also based on historical experience, which was used to make reasonable assumptions for the recognition of events during the year. By their nature, the estimates and assumptions used may vary from one year to the next and, it cannot be ruled out that in subsequent years the values recognised in the financial statements may also vary significantly as a result of changes in the subjective assessments used. If there are more significant uncertainties and/or activities subject to measurement of particular materiality, the valuation is supported by external experts. The main circumstances in which subjective assessments are most required are: the quantification of impairment losses on loans, equity investments and other financial assets in general; the use of valuation models to recognise the fair value of financial instruments not listed on active markets; assessment of the appropriateness of the value of goodwill and other tangible and intangible assets; The quantification of staff provisions and provisions for other risk and charges; the estimate of tax liabilities and the assessment of the related risk of an unfavourable outcome; estimates and assumptions regarding the recoverability of deferred tax assets; the non-financial assumptions (e.g. demographic assumptions related to the prospective mortality of the insured population, expected evolution of claims) and financial assumptions (deriving from the possible evolution of the financial markets) used to value insurance products in accordance with IFRS 17 an estimate of the parameters used to discount the activity to customers related to the payment of stamp duty on life policies, in particular with reference to the risk-free rate and the average duration of policies. For some of the cases listed above, the main factors that are estimated by the Group and therefore are involved in determining the carrying value of assets and liabilities may be identified. It should be noted that:
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417 | Mediolanum Group - 2025 Annual Financial Report for allocation to the three credit risk stages provided for by IFRS 9 of receivables and debt securities classified among financial assets at amortised cost and financial assets measured at fair value, with an impact on comprehensive income and calculation of the relevant expected losses, the main estimates concern: either determination of the parameters for a significant increase in credit risk, based essentially on models for measuring the probability of default (PD) at the origination of financial assets and the reporting date; the inclusion of forward-looking factors, including macroeconomic factors, for the determination of the PD and LGD “lifetime”; or determination of the probability of the sale of impaired financial assets; for the determination of the fair value of financial instruments not listed on active markets, if it is necessary to use parameters that cannot be inferred from the market, the main estimates concern trends in future financial flows (or income flows, in the case of shares), possibly contingent on future events, as well as the level of certain input parameters not listed on active markets; for the determination of the estimates of future cash flows from non-performing loans, certain elements are taken into account: expected recovery times, the presumed realisable value of any guarantees and the costs that are expected to be incurred for recovery of the credit exposure; for the determination of the value in use of intangible assets with an indefinite useful life in relation to the cash generating units (CGUs) of which the Group is composed, separate and appropriately discounted estimates are made of future cash flows in the analytical forecast period and the flows used to determine the “terminal value” generated by the CGU. The cost of capital is included among the items assessed; for appraisals of real estate, rents, sale prices, discount rates and capitalisation rates are estimated; for the quantification of provisions for risk and charges– where possible – the estimate process includes the amount of the disbursements required to fulfil the obligations, as well as the relative probability and timing of their occurrence; for the determination of the items relating to deferred taxation, the probability of actual future tax liability (taxable temporary differences) is estimated, along with the degree of reasonable certainty – if any – of future taxable amounts at the time tax deductibility applies (deductible temporary differences and tax losses carried forward); with reference to the insurance companies included in the consolidation, information on the main methodological options and estimates used to determine the insurance contracts and the release of the contractual margin, for consistency of treatment, is provided in the Accounting Policies A.2 – part relating to the main balance sheet items under Insurance Assets and Liabilities, where the methodologies used to define the discount rates, to adjust for non-financial risk and to estimate the future cash flows required to fulfil the insurance contracts are illustrated, among others with regard to discounting the asset to customers associated with the payment of stamp duty on life policies classified as financial instruments and treated as financial liabilities, applying IFRS 9, the main estimates relate to determining the risk-free discount rate and the average duration of policies; the asset, as it is non-interest-bearing, is initially recognised at the value of the payment made and, where the effect is significant, the difference between the carrying amount and the present value, attributable to the financial charge implicit in the discounting, is charged to the income statement. The directors periodically monitor the estimates and assessments made on the basis of historical performance, the current macroeconomic and geopolitical environment and other factors considered to be reasonable. Due to the uncertainty inherent in these financial statement items, the actual values may differ from estimates made due to unexpected factors not known at the time the estimates were produced.
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418 | Mediolanum Group - 2025 Annual Financial Report A.2 – PART RELATING TO THE MAIN BALANCE SHEET ITEMS Accounting principles The accounting policies used to prepare these consolidated half-year financial statements, with reference to the phases of classification, recognition, measurement and derecognition of financial assets and liabilities, as well as the methods of recognising revenues and costs and the consolidation criteria, are consistent with those used to prepare the consolidated financial statements for 2024 of the Banca Mediolanum Group. The following are described below: IFRS accounting standards, amendments and interpretations applicable as of 1 January 2025; the IFRS and IFRIC accounting standards, amendments and interpretations endorsed by the European Union not yet mandatorily applicable that had not been adopted early by the Group as at 31 December 2025; the IFRS accounting standards, amendments and interpretations not yet endorsed by the European Union. IFRS accounting standards, amendments and interpretations applicable as of 1 January 2025 The following table shows the new international accounting standards or amendments to accounting standards that came into force in 2025. Title of document issued by the IASB Date of publication of the IASB document Number and date of EU approval regulation Date of effect Date of publication in the OJEU Impossibility of change (Amendments to IAS 21) 15 August 2023 (EU) 2024/2862 12 November 2024 1 January 2025 13 November 2024 In terms of new accounting requirements applicable from 1 January 2025, the following is reported: Amendments to IAS 21 – impossibility of change; The amendments to IAS 21 clarify (i) when one currency is considered exchangeable in another currency and (ii) how to determine the spot exchange rate when exchangeability is absent, as well as the related supplementary information. The Group assessed the applicability of the amendments and, on the basis of current exposures, no material impacts on the consolidated financial statements were identified, as it is not significantly exposed to restricted currencies that prevent conversion into other currencies.
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419 | Mediolanum Group - 2025 Annual Financial Report IFRS and IFRIC accounting standards, amendments and interpretations endorsed by the European Union not yet mandatorily applicable that had not been adopted early by the Group as at 31 December 2025 As at 31 December 2025, the following IFRS/IFRIC accounting standards, amendments and interpretations, approved by the European Union, are not yet mandatorily applicable and have not been adopted in advance by the Group. Accounting standards or amendments Date of IASB publication Number and date of EU approval regulation Date of effect Date of publication in the OJEU Nature-dependent electricity contracts (Amendments to IFRS 9 and IFRS 7) 18 December 2024 (EU) 2025/1266 30 June 2025 1 January 2026 1 July 2025 Amendments to the classification and measurement of financial instruments (Amendments to IFRS 9 and IFRS 7) 30 May 2024 (EU) 2025/1047 27 May 2025 1 January 2026 28 May 2025 Annual Improvements to IFRS Accounting Standards Cycle – Volume 11 (Amendments to IAS 7 and IFRS 1, 7, 9, 10) 18 July 2024 (EU) 2025/1331 9 July 2025 1 January 2026 10 July 2025 Nature-dependent electricity contracts (IFRS 9 and IFRS 7): aim to help entities better communicate the financial and economic effects of nature-dependent electricity contracts, often structured as electricity purchase and sale agreements. In particular, they introduce clarifications for the application of own-use exemption, allow for specific simplifications forhedge accounting and introduce new supplementary information on the related economic-financial effects and on future cash flows. Amendments to the classification and measurement of financial instruments (IFRS 9 and IFRS 7): clarify certain aspects of initial recognition/elimination of accounting (including an option for certain payments through electronic systems), provide additional guidance on the SPPI test for instruments with contingent clauses/features (incl. linked to ESG objectives), non-recourse and contractually linked instruments, and introduce new disclosures (notably on equity FVTOCI and instruments with contingent cash flow). Annual Improvements Cycle – Volume 11 (IFRS 1, IFRS 7, IFRS 9, IFRS 10 and IAS 7): makes minor amendments aimed at clarifying and aligning certain existing requirements. The Group has launched impact analyses with reference to its operations and, on the basis of the information currently available, does not foresee any significant effects on the consolidated financial statements; any impacts are expected, mainly, on the information perimeter and on the application/procedural aspects related to the new disclosure requests.
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420 | Mediolanum Group - 2025 Annual Financial Report IFRS accounting standards, amendments and interpretations not yet endorsed by the European Union The Agenda Decisions of the IFRS Interpretations Committee published in 2025 are set out below. Such decisions do not constitute an accounting standard that can be endorsed by the EU, but include explanatory material relevant to the consistent application of IFRS and are considered in the definition/updating of accounting policies, where applicable. The changes and the Agenda Decisions have been analysed and, on the basis of available information and the nature of the Group’s operations, no significant impact is expected on the consolidated financial statements. The following “Agenda decisions” were also submitted by IFRIC to the IASB during 2025 and for which the finalisation process is under way: • Embedded Prepayment Option (IFRS 9 Financial Instruments); • Determining and Accounting for Transaction Costs (IFRS 9 Financial Instruments); Accounting standards and impacts ‘Final agenda decisions’ Date of approval of the IASB IAS 7 – regarding the classification in the statement of cash flows of payments made to margins on contracts on commodities/derivatives that are centrally cleared because in certain markets in which derivatives are traded, the entity that manages the market requests the payment of sums of money to guarantee the performance of the contract and these sums deposited vary according to the change in the fair value of the derivative. These are sums of money paid as collateral for the derivative which do not relate to the settlement of the derivative itself. Classification of cash flows related to variation margin calls on ‘collateralised-to- market’ contracts February 2025 IFRS 9/IFRS 17 - concerning the accounting treatment of guarantees issued to other investee entities. These are guarantees on the basis of which the entity undertakes to make payments to a bank, customer or other type of counterparty if the investee company defaults on its obligations Guarantees issued on obligations of other entities April 2025 IFRS 15 – which addresses the issue of the accounting of tuition fees and specifically how to reflect the progressive recognition of revenues taking into account that for a certain time period university tuition is suspended. Recognition of revenue from tuition fees April 2025 IAS 38 - relating to the recognition of expenses for research and development activities related to environmental issues Recognition of intangible assets from climate-related expenditure April 2025 IAS 29 - which looked at how to apply IAS 29 to identify when an economy becomes hyper-inflationary, assessing whether and how to consider indicators required by the rule. Assessing indicators of hyperinflationary economies July 2025
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421 | Mediolanum Group - 2025 Annual Financial Report • Updates to Committee’s agenda decisions for IFRS 18 Presentation and Disclosure in Financial Statements. Finally, the following table shows the new international accounting standards and amendments to accounting standards that have not yet been endorsed by the European Union but will be effective in the future. Accounting standards or amendments Date of IASB publication Date of effect IFRS 18 Presentation and Disclosure in Financial Statements 9 April 2024 1 January 2027 IFRS 19 - Subsidiaries without Public Accountability: Disclosures 9 May 2024 1 January 2027 Approval of IFRS 18 took place on 13 February 2026, while approval of IFRS 19 is expected in 2026. The Group will adopt these standards and amendments on the basis of their expected date of application and assess their potential impact before their adoption, following their endorsement by the European Union. In particular, with reference to IFRS 18, during 2025 the Group began preliminary analyses of the impacts arising from its adoption, which are still ongoing. Completion and the relevant implementation actions are expected in 2026. 1 - Financial assets measured at fair value through profit or loss Classification criteria Item “20. Financial assets measured at fair value through profit or loss” includes: Financial assets held for trading; Financial assets designated at fair value; Other financial assets mandatorily measured at fair value. This category includes debt securities or loans with an “other” business model, i.e. a method of managing financial assets not intended to collect contractual cash flows (“held to collect”) or to collect contractual cash flows and sell financial assets (“held to collect and sell”), debt securities, loans and UCI units that do not pass the SPPI (Solely Payments of Principal and Interest) test and non-qualifying equity instruments for exclusive control, connection and joint control, held for trading purposes or for which, on initial recognition, no option was exercised to classify them as “financial assets measured at fair value through other comprehensive income”. “Financial assets designated at fair value” also includes financial assets designated at fair value through profit or loss connected with index-linked and unit-linked insurance or investment contracts written by the undertaking that fall within the scope of IFRS 17. Financial assets held for trading A financial asset is recognised under this item if it is acquired primarily with the aim of realising cash flows from its sale (the “Other” business model) in order to take advantage of profit opportunities. The item also includes derivative contracts with a positive fair value that are not designated in the context of an accounting hedging relationship.
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422 | Mediolanum Group - 2025 Annual Financial Report Financial assets designated at fair value Financial assets (debt securities and loans) can be designated at fair value with the results of the valuation recognised in the income statement on the basis of the fair value option recognised by IFRS 9. Designation at fair value is only permitted if it significantly eliminates or reduces the accounting asymmetry that would result from the valuation/recognition of gains (losses) on different bases for assets or liabilities that are linked on a management basis. Other financial assets mandatorily measured at fair value A financial asset (debt security, UCI units and loans) is recognised under this item if it is a financial instrument where the return is measured on the basis of fair value and, in contractual terms, has no cash flows on pre- established dates that represent solely payments of capital and interest on the capital to be repaid, i.e. if it fails the Solely Payment of Principal and Interest (SPPI test). Recognition criteria Such instruments are initially recognised at the time of settlement if they are debt securities, equity securities or loans. The initial value is equal to the fair value of the instrument (generally the same as the consideration paid), without considering any transaction costs or income directly attributable to the instruments. Measurement and recognition of income components After initial recognition, the valuation is made at fair value with the relevant changes recognised in the income statement. In particular: in Item “80. Net gains (losses) from trading” for financial assets recognised in item “20.a) Financial assets held for trading”; in item “110. a) Net gain (loss) from other financial assets and liabilities measured at fair value through profit or loss: financial assets and liabilities designated at fair value for financial assets recognised in Item “20.b) Financial assets designated at fair value”; in Item “110. b) Net result of other financial assets and liabilities at fair value through profit or loss: other financial assets mandatorily measured at fair value”, for financial assets recognised in Item “20. c) Other financial assets mandatorily measured at fair value”. The fair value of financial assets is determined based on prices recorded in active markets or on internal valuation models generally used in financial practice as described in more detail in Part A.4 “Fair value reporting”. Derecognition criteria Financial assets are derecognised when the contractual rights to the cash flows from the assets expire or when the financial assets are sold with the transfer of substantially all the associated risks and benefits. Furthermore, the assets transferred are derecognised from the balance sheet if the contractual right to receive the cash flows is retained but, at the same time, a contractual obligation is assumed to pay these cash flows to a third party, without delay and only to the extent of those received.
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423 | Mediolanum Group - 2025 Annual Financial Report Reclassification criteria Financial assets measured at fair value through profit or loss other than equity securities may be reclassified to “Financial assets measured at fair value through other comprehensive income” and “Financial assets measured at amortised cost”. Reclassification may occur in the rare event that the entity decides to change its business model for the management of financial assets. The transfer value is represented by the fair value on the reclassification date, with prospective effects as of that date. 2 - Financial assets measured at fair value through other comprehensive income (FVOCI) Classification criteria This item includes financial assets with contractual terms that provide for cash flows on pre-established dates that represent only payments of capital and interest on the capital to be repaid, and which have therefore passed the SPPI test, and with the Held to Collect and Sell business model, the aim of which is to manage short-term financial instruments solely to meet liquidity needs. This category also includes equity securities not held for trading purposes and not qualifying as being under exclusive control, connection or joint control, to which the option to classify them among financial assets measured at fair value through other comprehensive income applies. This option, which may be exercised at the time of initial recognition of the individual financial instrument, is irrevocable. Recognition criteria Initial recognition takes place on the settlement date for debt securities and equities and on the disbursement date for loans. Initial recognition takes place only when the Company becomes a party to the contractual clauses of the instrument, i.e. at the time of settlement. The carrying value is equal to the fair value, generally the same as the cost of the instrument including directly attributable transaction costs/revenues. Measurement and recognition of income components After initial recognition, these assets continue to be measured at fair value, with changes in value recognised in Item “120. Valuation reserves”. Value adjustments are recognised in the income statement in item “130. Credit-risk induced net value adjustments/write-backs”, balancing item “120. Valuation reserves”. Write-backs are recognised when there is an improvement in the creditworthiness of the asset. For the methods of determining fair value, see the criteria described above for “Financial assets measured at fair value through profit or loss” and “Part A.4 –Fair value reporting” below. Gains or losses arising from changes in fair value are recognised in a specific equity reserve (item “120. Valuation reserves”), which will be transferred to the income statement when the financial asset is derecognised.
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424 | Mediolanum Group - 2025 Annual Financial Report For equity instruments for which a classification has been opted for, which are measured at fair value; gains and losses arising from changes in fair value, net of the related tax effect, are recognised as a contra-entry to a specific equity reserve (item “120. Valuation reserves”). The amounts recognised in this reserve will never be reversed in the income statement; in this case, it will be necessary to reclassify them into another item of equity. No write-down of the income statement is also envisaged for these assets since they are not subject to any impairment process. The only component recognised in the income statement is dividends. Derecognition criteria Financial assets are derecognised when the contractual rights to the cash flows from the assets expire or when the financial assets are sold with the transfer of substantially all the associated risks/benefits. If it is not possible to ascertain the transfer of risks and rewards, financial assets are derecognised where no control over them is retained. Lastly, transferred assets are derecognised if the contractual right to receive the cash flows from the assets is maintained, but at the same time a contractual obligation is undertaken to pay only such flows received to a third party without delay. Reclassification criteria Financial assets measured at fair value through other comprehensive income other than equity securities may be reclassified to the accounting categories “Financial assets measured at fair value through profit or loss” and “Financial assets measured at amortised cost”. Reclassification may take place in the very rare circumstances in which a decision is made to change the business model. The transfer value is the fair value as at the reclassification date. In the event of reclassification to “Financial assets measured at amortised cost”, the gain/loss accumulated in the valuation reserve is eliminated against an adjustment of the fair value of the financial asset as at the reclassification date. In the event of reclassification to “Financial assets measured at fair value through profit or loss”, the gain (loss) accumulated in the valuation reserve is reclassified from shareholders’ equity to the income statement. 3 - Financial assets measured at amortised cost Classification criteria Item “40. Financial assets measured at amortised cost” includes financial assets (debt securities and loans) whose contractual terms include cash flows on pre-established dates that represent only payments of capital and interest on the capital to be repaid, and which have therefore passed the SPPI test held with the aim of collecting financial cash flows in the medium to long term (“Held To Collect” - HTC Business Model). In particular, the following are recognised under this item: a) loans to banks; b) loans to customers. Loans to customers include both loans granted to customers and investments in securities - mainly government securities - as part of the management of the Group’s banking book.
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425 | Mediolanum Group - 2025 Annual Financial Report Recognition criteria Initial recognition of the financial asset takes place on the settlement date for debt securities and on the disbursement date for loans. Upon initial recognition, financial assets are recognised at fair value, which corresponds to the consideration paid, including any costs and income directly attributable to the instrument. Measurement and recognition of income components After initial recognition, the financial assets in question are measured at amortised cost. Such financial instruments are measured by using the effective interest rate criterion, i.e. the rate that exactly discounts future payments or receipts estimated over the expected life of the financial instrument. In order to determine the effective interest rate, cash flows must be measured taking into account all the contractual terms of the financial instrument. The amortised cost method is not used for assets whose duration, defined as short-term, makes the effect of applying the discounting approach deemed immaterial. The carrying value is adjusted to take into account any provision to cover expected losses at each annual or interim reporting date. Such assets are tested for impairment to estimate the expected losses recognised through the income statement in item “130. Net credit risk-induced adjustments/write-backs”. The impairment model involves three separate stages based on changes to the borrower’s creditworthiness, corresponding to different criteria for measuring expected losses: Stage 1: includes performing financial assets for which there has been no significant decrease in credit risk since the date of initial recognition or whose credit risk is considered low. Impairment is based on the estimated expected loss with a time horizon of one year; Stage 2: includes performing financial assets that have suffered a significant deterioration in credit risk since initial recognition. Impairment is based on an estimate of the expected loss over a time horizon representing the entire residual life of the financial asset; Stage 3: includes non-performing financial assets to be measured on the basis of an estimate of the expected loss over the entire life of the instrument. For stage 1 and 2 assets, expected losses are determined according to a process that takes into account certain risk parameters consisting of the probability of default (PD), the loss rate in the event of default (LGD) and the exposure value (EAD), deriving from internal regulatory credit risk calculation models that take into account the specific requirements of accounting regulations. For level 3 assets, impairment is quantified on the basis of a measurement process - analytical or lump-sum based on homogeneous risk categories - aimed at determining the present value of expected recoverable future flows, discounted on the basis of the original effective interest rate or a reasonable approximation thereof, where the original rate is not directly available. Non-performing assets include exposures classified as doubtful, unlikely to pay or past due by more than 90 days, according to the definitions established by the relevant supervisory legislation and cited in Bank of Italy Circular 262.
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426 | Mediolanum Group - 2025 Annual Financial Report Derecognition criteria Financial assets are derecognised when the contractual rights to the cash flows from the assets expire or when the financial assets are sold with the transfer of substantially all the associated risks and benefits. Where it is not possible to ascertain the substantial transfer of risks and rewards, financial assets are derecognised where no control over them is retained. Value adjustments In accordance with IFRS 9, financial assets at amortised cost, financial assets measured at fair value with an impact on comprehensive income (other than equity securities) and off-balance sheet exposures are subject to an “impairment” assessment. In particular, the standard provides for these instruments to be classified in stages 1, 2 or 3 depending on their credit quality with respect to their initial recognition, as described above. The Group has adopted specific models to calculate the expected loss at one year for stage 1 and lifetime for stage 2 and 3 exposures. These models are based on the following parameters: PD: Probability of Default – probability of a default on the credit exposure in a specific time period; LGD: Loss Given Default – percentage estimated loss on occurrence of the default event; EAD: Exposure at Default – exposure at the time of the default of the credit position. For further details on how to determine value adjustments, see Part E - Risks section. 4 - Tangible assets Classification criteria Tangible assets include land, operating properties, property investments, technical plant, furniture, fixtures and equipment of any kind. These are tangible items that are held for use in the production or supply of goods or services, to be leased to third parties, or for administrative purposes and are expected to be used for more than one period. Tangible assets held for investment refers to investment property as defined in IAS 40, i.e. property held in order to obtain rent and/or generate capital appreciation. Any assets used in the context of finance leases are also recorded under this item, although their legal ownership remains with the leasing company. The rights of use acquired with a lease relating to the use of a tangible asset (for lessees), operating lease assets (for lessors) and the improvements and incremental expenses incurred on owned assets and rights of use on tangible assets under leases, are also included. Recognition criteria Tangible assets are initially recognised at cost, which includes not only the purchase price but also any ancillary costs directly attributable to purchasing and commissioning the asset. Extraordinary maintenance expenses that increase the future economic benefits associated with the asset are added to the carrying value of the asset, while the costs of day-to-day servicing are recognised in the income statement.
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427 | Mediolanum Group - 2025 Annual Financial Report Improvements and incremental expenses incurred on third party assets arising from lease agreements pursuant to IFRS 16 that are expected to deliver future benefits are recognised if they are individually identifiable and separable in item “90. Tangible assets” in the most appropriate category and provided they are not individually identifiable and separable in item “90. Tangible assets”, to increase the right of use, recognised in accordance with IFRS 16, to which they refer. Measurement and recognition of income components Tangible assets, including non-operating properties, are valued at cost, less any depreciation and amortisation. Assets are systematically depreciated over their useful life, using the straight-line method as the depreciation criterion, with the exception of land, whether acquired individually or incorporated into the value of buildings, since they have an indefinite useful life. Where the value of land is incorporated into the value of the building due to application of the component approach, it is regarded as an asset that can be separated from the building; the subdivision between the value of the land and the value of the building takes place on the basis of appraisals by independent experts, only in the case of self-contained buildings. At each interim or year-end reporting date, if there is any evidence that an asset may be impaired, a comparison is made between the carrying value of the asset and its recoverable value, equal to the greater of the fair value, net of any costs to sell, and the relative value in use of the asset, understood as the present value of future flows generated by the asset. Any adjustments are recognised in the income statement. If the grounds for impairment cease to apply, a write-back is recognised, which may not exceed the value that the asset would have had, net of depreciation calculated in the absence of previous impairment. Derecognition criteria A tangible asset is derecognised on disposal or when the asset is permanently withdrawn from use and no future economic benefits are expected from its disposal. Tangible assets represented by the right to use assets under leases Pursuant to IFRS 16, a lease is a contract or part of it which, in exchange for a consideration, transfers the right to use an asset (the underlying asset) for a period of time. A finance “lease” agreement essentially transfers to the lessee all the risks and benefits of ownership of the asset. Otherwise, the agreement is an operating “lease”. The lease agreement starts from the date on which the lessee is authorised to exercise their right to use the leased asset and corresponds to the date of initial recognition of the lease. On that date, the lessee takes on: an activity that consists of the right to use the leased asset. The asset is recognised at cost and determined by the sum of a financial liability for the lease, the lease payments paid before or on the start date of the lease, the initial direct costs and any costs incurred to restore the asset underlying the lease or to dismantle it; a financial liability corresponding to the present value of lease payments due. The discount rate used is, if determinable, the implicit interest rate; otherwise, the lessee’s marginal loan interest rate is used. The asset consists of the right of use. The right of use acquired through the lease is recognised as the sum of the present value of the future lease payments to be paid for the contractual term, the lease payments paid on or before the lease inception date, any incentives received, the initial direct costs and any estimated costs for the dismantling or restoration of the asset underlying the lease.
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428 | Mediolanum Group - 2025 Annual Financial Report The financial liability recognised corresponds to the present value of lease payments due. The term of the lease is determined taking into account periods covered by an extension option and/or periods covered by a lease termination option, if reasonably certain. During the term of the lease agreement, the lessee must: assess the right of use at cost, net of accumulated depreciation and cumulative value adjustments determined and recognised in accordance with IAS 36 “Impairment of assets”, adjusted to take account of any recalculations of the lease liability; increase the liability arising from the lease transaction due to the accrual of interest expenses calculated at the implicit interest rate of the lease or at the marginal loan rate and reduce it for payments of principal and interest. In the event of changes in lease payments, the liability must be recalculated; the impact of the recalculation of the liability is recognised as a balancing item of the asset consisting of the right of use. Based on the requirements of IFRS 16, the Group uses the implicit discount rate for each lease, where available. Derecognition criteria The right of use deriving from lease agreements is eliminated from the financial statements at the end of the term of the lease. For more information, see the relevant section of the notes (Part M – Leasing). 5 - Intangible assets Classification criteria Intangible assets include goodwill and application software to be used for several years, as well as intangible assets generated during the acquisition of a business. Goodwill is the positive difference between the acquisition cost and the fair value of the assets and liabilities acquired. Other intangible assets are recognised as such if they are identifiable and arise from legal or contractual rights. An intangible asset can be recognised as goodwill when the positive difference between the fair value of the net assets acquired and the acquisition cost of the equity investment (including ancillary costs) represents the equity investment’s future income-generating potential. If the difference is negative (badwill), it is recognised directly in the income statement, if it is not due to provisions for risks not reflected in the accounts of the business being acquired. Recognition criteria Intangible assets are recognised at purchase cost, including direct costs incurred to prepare the asset for use, and increased by any subsequent expenses incurred to increase its initial economic functionality, net of accumulated amortisation and any impairment losses recorded.
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429 | Mediolanum Group - 2025 Annual Financial Report Measurement and recognition of income components The cost of intangible assets is amortised on a straight-line basis over their useful life (defined mainly as a flat rate of 3 years for software where there are no conclusive elements that can be used to define useful life). If their useful life is indefinite, the assets are not depreciated, but only periodically tested for impairment. The asset’s recoverable amount is estimated at each reporting date. The impairment loss, which is recognised in the income statement, is equal to the difference between the carrying amount of the asset and its recoverable value. If there is objective evidence that an individual asset may have become impaired, the book value of the asset and its recoverable amount, which is equal to the greater of its fair value less the costs of sale and its value in use, understood as the present value of the future cash flows that are expected to arise from the asset, are compared. Any adjustments are recognised in item 220 “Charges/write-backs on impairment of intangible assets” in the income statement. If the value of an intangible asset previously written down is restored, the new book value may not exceed the net book value that would have been determined if no impairment loss had been recognised in the previous years. Intangible assets include goodwill, which may be recognised as part of a business combination when the positive difference between the consideration transferred and any recognition at fair value of the minority interest and the fair value of the assets acquired is representative of future earning capacity. The carrying amount of assets with an indefinite useful life, such as goodwill, are not subject to straight-line amortisation, but periodically tested for impairment. In relation to the requirements of the accounting standard, “trigger events” are defined for the purposes of such testing, i.e. Indicators from external/internal information sources, which are monitored at least every six months and lead to the impairment testing of equity investments and goodwill. Goodwill is tested for impairment annually (or whenever there is evidence of impairment). To this end, the cash generating unit to be allocated the goodwill is identified. The amount of any impairment loss is determined on the basis of the difference between the carrying amount and the recoverable amount, if lower, and is charged to the income statement in Item 270 “Goodwill impairment”. The recoverable amount is understood as the greater of the fair value of the cash-generating unit, net of any selling charges, and its value in use, represented by the present value of the estimated cash flows for the operating years of the cash- generating unit and deriving from its disposal at the end of its useful life, or by applying the market multiples methodology. The booking of any subsequent recoveries in value is not permitted. Derecognition criteria An intangible asset is derecognised from the statement of financial position on disposal or when no additional future economic benefits are envisaged from its use or disposal, and any difference between its disposal value or recoverable value and its book value is recognised in the income statement in item 280 “Gains (losses) on disposal of investments”.
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430 | Mediolanum Group - 2025 Annual Financial Report 6 - Current and deferred taxation The Italian companies of the Mediolanum Group participate in “national tax consolidation” for IRES purposes, governed by Articles 117-129 of the TUIR, introduced into the tax legislation by Legislative Decree No. 344/2003. This is an optional scheme under which the taxable profits or tax loss of each subsidiary participating in the tax consolidation – together with withholdings, deductions and tax credits – are consolidated into the Parent Company, for which a single taxable income or single tax loss amount is determined that can be carried forward (given by the algebraic sum of own income/losses and that of the participating subsidiaries and, consequently, a single tax debit/credit). Under this option, Group companies that are members of the tax consolidation scheme calculate their own tax charge and the corresponding taxable income is consolidated into the Parent Company. In case of tax losses of one or more Group companies against which consolidated taxable profit for the current year is available or against which there is a high probability that future taxable profits will be available, those tax losses are also consolidated into the Parent Company. The Group recognises current and deferred taxes applying the tax rates in effect in the countries where the consolidated subsidiaries are incorporated. Income taxes, calculated in accordance with current tax legislation, are accounted for on the basis of the expenses and revenues that generated them. They therefore represent the tax charge, equal to the balance between current and deferred taxation, relating to income for the year. Income taxes are recognised in the income statement, except for items which are credited/charged directly to shareholders’ equity. Provisions for income taxes are calculated on the basis of an estimate of the current, prepaid and deferred tax expense. Prepaid and deferred taxes are calculated in respect of the temporary differences, with no time limit, arising between the tax bases of assets and liabilities and their carrying amounts in the financial statements. Deferred tax assets are recorded to the extent that it is probable that they will be recovered, i.e. to the extent that the Company – or the Parent Company under Italy’s tax consolidation regime – is likely to continue to generate positive taxable income. Prepaid and deferred taxes are not netted, and are recognised separately in the statement of financial position under “Tax assets” and “Tax liabilities” respectively. Deferred taxes are calculated using the liability method based on the temporary differences recognised at the reporting date between the tax values used for the assets and liabilities and the values reported in the financial statements. Deferred tax liabilities are recognised for all taxable temporary differences. Deferred tax assets are recognised for all deductible temporary differences and for tax assets and liabilities carried forward, to the extent that it is probable that taxable profit will be available against which the deductible temporary differences and the tax assets and liabilities can be utilised, unless: the deferred tax asset associated with the deductible temporary differences arises from initial recognition of an asset or liability in a transaction that is not a business combination and that, at the time of the transaction, has no effect on the profit for the year calculated for financial reporting purposes or on the profit or loss calculated for tax purposes; with regard to taxable temporary differences associated with equity investments in subsidiaries, associates and joint ventures, deferred tax assets are only recognised to the extent that it is probable that deductible temporary differences will reverse in the immediate future and that there are adequate tax profits against which temporary differences can be utilised. Assets and liabilities recognised for prepaid and deferred taxes are systematically measured to take account of any changes in the rules or rates and of any subjectively different situations of the Group companies.
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431 | Mediolanum Group - 2025 Annual Financial Report Any tax disputes fall within the scope of IAS 12, which does not include specific valuation principles for the associated tax liabilities. The valuation of tax disputes was therefore carried out on the basis of IAS 37, without prejudice to the presentation principles of IAS 12. 7 - Provisions for risks and charges Classification criteria Commitments and guarantees given Provisions for risk and charges in respect of commitments and guarantees given are recognised for all commitments and guarantees, whether revocable or irrevocable, in accordance with both IFRS 9 and IAS 37. This item includes an estimate of the expected loss calculated on these instruments resulting from the valuation process, as described in the section Value Adjustments. The provision for the period is recorded in item “200. Net provisions for risk and charges: a) commitments and guarantees given”. For these cases, the same methods of allocation between credit risk stages and calculation of the expected loss are adopted as shown with regard to financial assets measured at amortised cost or at fair value through other comprehensive income. Pensions and similar obligations Pension provisions include employee benefit provisions that will be paid after employment is terminated and may be classified as defined-contribution or defined-benefit plans. In particular: Defined benefit plan: this ensures benefits that depend on different elements, such as age, years of service and remuneration policies. In this case the actuarial risk and the investment risk ultimately fall on the company; Defined contribution plan: for this type of plan, the company pays pre-determined contributions. The benefit is the accumulated amount represented by the contributions and their return. The provider has no actuarial and/or investment risk linked to this type of plan as it has no legal or implicit obligation to pay additional contributions if the fund does not have sufficient assets to pay benefits to all employees. The contributions made in each financial year are considered as separate units, recognised and valued individually for the purposes of determining the final obligation. Actuarial gains and losses (i.e. changes in the present value of the obligation arising from changes in actuarial assumptions and adjustments based on past experience) are recognised in the statement of comprehensive income. Other funds Provisions for risk and charges are liabilities of uncertain maturity or amount. A contingent liability is defined as such when: the company has a current obligation as a result of a past event; it is probable that an outlay of resources to produce economic benefits will be required to settle the obligation; and a reliable estimate can be made of the amount arising from fulfilment of the obligation. Recognition, measurement and recognition of income components.
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432 | Mediolanum Group - 2025 Annual Financial Report The amounts set aside are determined so as to represent the best estimate of the expenditure required to meet the obligations. Risks and uncertainties relating to the facts and circumstances at issue are considered in determining this estimate. Provisions set aside are periodically reviewed and may be adjusted to reflect the best current estimate. Provisions are released when it becomes unlikely that resources capable of yielding economic benefits will be expended in order to discharge the obligation or when the obligation is extinguished. “Other funds” include, inter alia, obligations concerning benefits payable to agents and in particular supplementary client benefits, portfolio and structure benefits and manager promoter benefits, relating to agents carrying out assistance and coordination activities whose remuneration is based on specific commercial parameters and is granted on the achievement of an old-age pension - conditional on the requirement not to carry out competitive activities in the two-year period following the end of their period in office - or in cases of permanent total disability or death. The provision for unlawful risks of promoters is also included, established to cover the risk of liabilities for losses not covered by the insurance policy to cover damage caused to customers by unlawful conduct on the part of financial promoters and potential liabilities arising from legal disputes. 8 - Financial liabilities measured at amortised cost Classification criteria The item “Financial liabilities measured at amortised cost” includes the sub-items “Due to banks”, “Due to customers” and “Debt securities issued”. Payables entered by the lessee in the context of lease transactions, as well as repurchase agreements for funding and securities lent with the receipt of money guarantees that are fully available to the lender, are also included. Finally, operating payables associated with the provision of financial services are included. Recognition criteria The value at which they are initially recognised is equal to their fair value, usually equal to the consideration received or the issue price including costs/income directly attributable to the transaction. Lease payables are recognised on the basis of the present value of future lease payments still to be paid for the contractual term. Measurement and recognition of income components After initial recognition, medium/long-term financial liabilities are measured at amortised cost using the effective interest rate method as defined above. Short-term liabilities, for which the time factor is not significant, remain recorded at the value collected. Lease payables must be restated in the event of a change in the payments due (lease modification). The impact of the redetermination will be recorded as a balancing item to the right of use asset. Derecognition criteria Financial liabilities are derecognised when they expire or are extinguished. The difference between the carrying amount of the liability and the amount paid to purchase it is recorded in the income statement.
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433 | Mediolanum Group - 2025 Annual Financial Report 9 - Financial liabilities held for trading Classification criteria Financial liabilities held for trading include: trading derivatives with a negative value; uncovered short positions on securities trading. Recognition criteria Such financial liabilities are initially recognised on receipt of the sums collected or on settlement of the financial instruments underlying the transaction. The fair value of any financial liabilities issued below market value is subject to appraisal and the difference from the market value is directly recognised in the income statement. After initial recognition, financial liabilities are measured at fair value. Measurement and recognition of income components After initial recognition, the financial instruments in question are measured at fair value, with changes in value recognised in item “80. Net gains (losses) from trading”. Derecognition criteria Financial liabilities held for trading are derecognised when the contractual rights to the related cash flows expire or when financial liabilities are transferred with the substantial transfer of all the risks and rewards of ownership. 10 - Financial liabilities designated at fair value Classification criteria Financial liabilities designated at fair value may be recognised on the basis of the option (known as the Fair Value Option) recognised by IFRS 9, or when it is a hybrid contract containing one or more embedded derivatives and the embedded derivative significantly modifies the cash flows that would otherwise be provided for in the contract or when designation at fair value through profit or loss allows for better disclosure. This item includes liabilities related to Unit Linked products and classified as financial investments in accordance with accounting standards. Recognition criteria Financial liabilities designated at fair value, carried in accordance with the Fair Value Option, are recognised at the issue date. The initial recognition value is at the fair value of the instrument. The option of designating a liability at fair value is irrevocable, it is carried out on the individual financial instrument and does not require the same application to all instruments with similar characteristics.
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434 | Mediolanum Group - 2025 Annual Financial Report Measurement and recognition of income components For financial liabilities designated at fair value, the fair value component attributable to the change in its creditworthiness is recognised in other comprehensive income and is not subsequently reversed to the income statement. These instruments are measured at fair value, allocating changes in value to item “110. a) Net gain (loss) from other financial assets and liabilities measured at fair value through profit or loss: financial assets and liabilities designated at fair value”. Derecognition criteria Financial liabilities are derecognised in the annual or interim financial statements when they expire or are extinguished. 11 - Foreign-currency transactions Assets and liabilities denominated in foreign currencies are recorded, at initial recognition, in the reporting currency, by applying the exchange rate in force on the transaction date to the foreign currency amount. At each interim or year-end reporting date, financial statement items in foreign currencies are valued as follows: monetary financial assets and liabilities are converted at the exchange rate at the reporting date; non-monetary items measured at historical cost are translated at the exchange rate in force at the transaction date; non-monetary assets measured at fair value are converted using the exchange rates in force at the reporting date. Foreign exchange differences resulting from the settlement of monetary items or the conversion of monetary items at rates other than the initial conversion rates or the conversion rates in the previous financial statements are recognised in the income statement for the period in which they arise. When a gain or loss relating to a non-monetary item is recognised in shareholders’ equity, the foreign exchange difference relating to that item is also recognised in equity. Conversely, when a gain or loss is recognised in the income statement, the relevant foreign exchange difference is also recognised in the income statement. 12 - Insurance assets and liabilities Insurance assets and liabilities An illustration is provided of the insurance assets and liabilities recognised in accordance with IFRS 17 and the main methodological choices made by the Group. Classification and measurement criteria This category includes insurance assets and liabilities governed by IFRS 17 – Insurance Contracts. These items derive from contracts that transfer an insurance risk assessed as significant and include temporary death policies, certain types of unit-linked policies, non-life policies and reinsurance contracts. Also included are liabilities recognised for investment products with discretionary profit-sharing items (separate management) as well as Class V capitalisation policies.
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435 | Mediolanum Group - 2025 Annual Financial Report Classification between insurance assets and liabilities depends on the net balance of the portfolio to which the contracts belong. If the net balance is liabilities, it is recognised as insurance liabilities; if the net balance is assets, it is recognised as insurance assets. IFRS 17 provides for the following measurement models: the General Model - applicable in principle to all contracts; Variable Fee Approach (“VFA”): applicable to contracts with direct participation in profits; There is also an optional simplified model (Premium Allocation Approach – PAA) for the valuation of the Liability for Remaining Coverage (LRC) for contracts with a hedging period of one year or less and for all contracts where the valuation is not materially different from that resulting from the application of the General Model. The Mediolanum Group does not apply the PPA model. More specifically, the accounting models applied are: the General Model for the non-life business and products purely at the risk of the life business; the Variable Fee Approach for direct participating products (i.e. linked products and products with discretionary profit-sharing). In view of the products offered by the Companies, this is the main model used in the Insurance Group. Initial recognition and accounting models Insurance assets and liabilities issued are initially recognised on the first of the following dates: the date of the beginning of the period of coverage of the group of contracts; at the date on which the first payment by an insured holder of a contract included in the group is due; in the case of a group of onerous contracts, the date on which the group becomes onerous. The value at initial recognition of the insurance assets and liabilities is equal to the algebraic sum of the fulfilment cash flows and the contractual service margin (CSM), where fulfilment cash flows are the estimated discounted Present Value Future Cash Flow –PVFCF), including the explicit risk adjustment (RA) component, to account for non-financial risks, while the CSM represents the present value of expected future profits arising from the contract. All contracts are grouped in order to identify “portfolios” that have similar risks and can be managed together. Each portfolio is then divided into groups of contracts: groups of contracts that are onerous at the time of initial recognition; groups of contracts that, at the time of initial recognition, have no significant possibility of subsequently becoming onerous; and the group comprising the other contracts in the portfolio. Measurement IFRS 17 requires an update of the insurance liability in each reporting period to verify the consistency of the estimates made with market conditions, to reflect the changes arising from the insurance services provided and the recognition of any liabilities for claims incurred. The effects of any updates recorded are included in the income statement if the changes refer to current or past events or to a reduction in the contractual service margin if the changes are due to future events. With regard to financial assumptions, the standard gives the option of representing the effects of the changes in the income statement or shareholders’ equity (OCI option).
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436 | Mediolanum Group - 2025 Annual Financial Report The standard requires the profitability generated by the policies over their life to be presented in the income statement “by margins”, i.e. a representation of the effect of the expected margins of insurance contracts through the initial quantification of the CSM and its release over the life of the underlying contracts. Accordingly, it does not require the recognition of premiums as revenues at the time of the signing of the contract nor claims as costs. This margin is included in the income statement under items 160. Result of insurance services and 170. Balance of revenues and financial costs relating to insurance management, which include both insurance revenues and costs for insurance services arising from insurance contracts issued. However, it should be noted that in the case of onerous contracts, the loss is recognised directly in profit or loss. Summary of the main methodological options adopted by the Group This section provides a summary of the Group’s main methodological decisions. Level of aggregation The level of aggregation for IFRS 17 purposes provides for a distinction between the non-life and life businesses and a further aggregation in groups of contracts that takes into account: for the life business, the types of products (pure risk products, “linked” products and products with discretionary profit-sharing) and, for the ““linked” business, the main contractual features of the products (aggregation into families of “linked” products) and, where relevant, of the reference market. for the non-life business, the ministerial class and business line values defined according to Solvency II. The annual cohort requirement is applied to all IFRS 17 portfolios, with the exception of contracts characterised by inter-generational mutuality, in application of the option introduced by Regulation (EU) 2021/2036. In particular, the contracts pertaining to Mediolanum Vita’s Medinvest Separate Account portfolio represent a single group of contracts for IFRS 17 (carve-out) purposes. Coverage Units For the purposes of representing profitability profiles over time (“amortisation pattern”), the following values have been identified (“Coverage Units”): Life business: sums insured (pure risk products) or commitments to policyholders (direct participating products); Non-life business: expected claims. These values were defined on the basis of the specific nature of the business analysed, in order to represent consistently as possible the “provision of the service” by Group companies over time. Financial margin The Mediolanum Group opted to apply the “accounting choice” which permits recognition in other comprehensive income (the so-called OCI option) of: any mismatches arising from the revaluation of assets and liabilities (IFRS 17, paragraph 89) – for products in the scope of application of the variable fee approach; changes in liabilities associated with updating financial conditions over time (IFRS 17, paragraph 88) – for products within the scope of application of the General Model. Based on the defined methodology, the financial result for insurance products is represented: for contracts within the scope of the VFA, by an equal and opposite amount (“mirroring”) to the booked financial result of the underlying assets;
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437 | Mediolanum Group - 2025 Annual Financial Report for contracts within the scope of the General Model, by an amount equal to the change in the insurance liability deriving from the application of the discount curve at the date of first valuation of the group of contracts (locked-in curve). Discount curve The Mediolanum Group identified a bottom-up approach for calculating the IFRS 17 discount curve, which requires the adjustment of the risk free curve for an illiquidity premium. This adjustment was determined for the separate account of Mediolanum Vita on the basis of the securities used to cover the reserves of the separate account and the market data relating to them. For the remaining businesses, reference was made to a European portfolio considered to be substantially representative. Risk adjustment The approach identified by the Mediolanum Group to define the risk adjustment involves the value at risk (VaR) risk measure as an estimation technique with a confidence level of the 80th percentile. With regard to the life business and the definition of stresses, the approach makes reference to the shocks used in the Standard Formula, recalibrated on the percentile identified. Other aspects With regard to the estimate of liabilities to policyholders and the contractual service margin, in accordance with the business model adopted by the Group, which provides that insurance companies pay distribution companies (Banca Mediolanum and Banco Mediolanum) remuneration for sales activities and for maintaining the insurance portfolio, while distribution companies incur direct costs for this remuneration to the sales network. In preparing the consolidated financial statements of the financial conglomerate, to determine cash flows and therefore the contractual service margin, account was taken of the remuneration of the network for the part closely associated with insurance products rather than the remuneration between companies and distribution companies. With reference to points of contact with the prudential Solvency II regulations, it should be noted that the undiscounted cash flows used to estimate fulfilment cash flows do not differ significantly from those used to estimate best estimate liabilities according to the prudential framework. It should be noted, in particular, that the main differences between the two frameworks for the measurement of insurance liabilities relate to: the identification of contract boundaries, i.e. the determination of whether a contractual option should be included in the projected cash flows from the issue of the contract or whether its exercise entails the generation of a new group of contracts; the determination of the discount curve; the determination of the risk margin under the Solvency regime and the risk adjustment in the IFRS 17 accounting standard.
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438 | Mediolanum Group - 2025 Annual Financial Report 13 - Other information Other assets – Other liabilities This item includes assets and liabilities that cannot be allocated to other asset and liability items in the statement of financial position. Other assets mainly include receivables associated with the provision of non-financial goods or services and tax payables other than those recorded in item “100. Tax assets” and other assets for transit items that will close at the beginning of the following year. Other liabilities mainly include transit items, payables associated with the payment of the supply of non-financial goods and services and miscellaneous tax credit items other than those recognised in item “60. Tax liabilities”. Other activities also include activity with customers arising as a result of the advance payment of stamp duty on life policies classified as financial liabilities, accounted for in line with what is defined in Joint Bank of Italy/Consob/Ivass Document No. 10. In the absence of a directly applicable IAS/IFRS standard, the accounting treatment was defined in accordance with IAS 8 and the asset is presented under “other assets” pursuant to IAS 1; where relevant, it is initially recognised at present value through discounting at risk-free rate consistent with the expected maturity and the difference compared with the nominal value is charged to the income statement in line with paragraph B.5.1.1 of IFRS 9. Severance benefits Employee severance benefits are recorded on the basis of the actuarial value calculated in line with the rules for “defined benefit” plans. The estimate of future disbursements is made on the basis of historical statistical analyses (for example turnover and retirements) and the demographic curve, including the salary increase assumptions provided for by Article 2120 of the Italian Civil Code (application of a fixed rate of 1.5% and 75% of the ISTAT inflation index where applicable). These flows are then discounted using the projected unit credit method. The discounting rate is determined on the basis of the market rates of high-quality bonds, in line with the estimated residual maturity of the commitments. The values thus determined entail recognition in the income statement of the cost components relating to work and net financial expenses, as well as the recognition of actuarial gains and losses deriving from the re-measurement of liabilities in other comprehensive income. The amounts accrued since 1 January 2007 allocated to the supplementary pension or INPS treasury fund constitute a “defined contribution” plan, since the company’s obligation to the employee ceases with the payment of the accrued amounts to the fund. These amounts are booked on the basis of the contributions accrued during the year. Employee pension funds Defined contribution plans for pension funds for which the company, through payment of contributions, does not assume any further obligation towards the fund members, entail recognition in the income statement of the benefits accrued during the year. Share-based payments These are payments to employees or similar persons as consideration for work or other services/goods received based on shares which may consist in the allocation of: rights to subscribe for paid capital increases (stock options); rights to receive shares when the qualitative/quantitative targets settled with equity instruments are met (performance shares); rights to receive shares when the quantitative/qualitative targets settled by cash are met (phantom shares).
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439 | Mediolanum Group - 2025 Annual Financial Report For these cases, the cost of the transaction, together with the corresponding increase in assets (shareholders’ equity or liabilities), is recognised in relation to the fair value of the benefits at the grant date, which is recognised during the vesting period. For stock option plans the fair value of the option was calculated using a model that took into account not only information such as the exercise price and life of the option, the current price of the shares and their expected volatility, the expected dividends and the risk-free interest rate, but also the specific characteristics of the plan in place. The option and the probability of realising market conditions are valued separately in the pricing model. The combination of the two values provides the fair value of the granted instrument. The cumulative costs recognised at each reporting date until the vesting date are commensurate with the maturity of the vesting period and the best available estimate of the number of participating instruments that will actually be exercised on vesting. The reversal of the cost recognised in the income statement in each year represents the change in the cumulative cost between what is recognised at the end of the year and the cumulative cost at the end of the previous year. No cost is recognised for rights that do not reach full accrual. Incentive schemes are also provided for key staff that are based on group share-based payments in accordance with the rules on the remuneration of such staff. Capital and treasury shares The capital item includes the amount of shares issued net of any capital subscribed but not yet paid up as at the reporting date. This item is shown gross of the treasury shares held by the bank, which are recognised under a specific item as a negative component of shareholders’ equity. The original cost of repurchased treasury shares and the gains or losses arising from their subsequent sale are recognised as changes in shareholders’ equity. Dividends on ordinary shares are recognised as a reduction in shareholders’ equity in the year in which the Shareholders’ Meeting resolved to distribute them. Any interim dividends are recognised in the “Interim dividends” liability item of the balance sheet with a negative sign. Tax credits related to the “Cure Italy” and “Relaunch” decrees acquired due to transfer by direct beneficiaries or previous acquirers (such as the “Ecobonus”) The credits introduced by Decree No. 18/2020 (“Cure Italy”) and Decree No. 34/2020 (“Relaunch”) acquired following disposal by direct beneficiaries or previous purchasers refer to tax incentive measures related to investment expenditure (e.g. the Ecobonus and the Sismabonus). These tax incentives, applicable to households or businesses, are commensurate with a percentage of the expenditure incurred and are paid in the form of tax credits or tax deductions. The main features of the tax credits introduced by the decrees are: the option of offsetting over a limited period of time; the possibility of transfer to third-party buyers; and no refunding by the tax authorities. The accounting treatment of the above credits is not governed by any IAS/IFRS accounting standard and it is therefore necessary to refer to the provisions of IAS 8 – Accounting Policies, Changes in Accounting Estimates and Errors, which require that a specific accounting policy be defined that ensures a faithful representation of the entity’s financial position, income and cash flows and reflects the economic substance.
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440 | Mediolanum Group - 2025 Annual Financial Report Also under the guidelines set forth by the Supervisory Bodies in the joint document published by them, taking into account that the tax credits referred to in the decrees are substantially more similar to a financial asset, as they may be used to offset a debt usually extinguished in cash (tax payables), and may be exchanged for other financial assets under conditions that might potentially be favourable to the entity and can be framed in a business model, it is believed that the accounting model based on IFRS 9 represents the accounting policy of reference. In order to define the accounting treatment to be adopted for the tax credits in question, reference was therefore made to certain provisions of the IFRS 9 accounting standard for financial instruments. In particular, the acquisition price of the tax credits is affected by: the time value of money; the ability to use it within the relevant timeframe. This price meets the condition of IFRS 9, according to which financial assets and liabilities are initially recognised at fair value and regarded as being at Level 3 of the fair value hierarchy provided for by IFRS 13, as there are currently no active markets or comparable transactions. At the time of initial recognition, the tax credit must therefore be recognised at the transaction price. In order to subsequently measure financial assets at amortised cost, the following must be considered: the time value of money; the use of an effective interest rate; the flows of the use of the tax credit through offsetting. The effective interest rate used is therefore the rate determined at the outset so that the discounted cash flows associated with the expected future offsetting estimated over the projected duration of the tax credit are equal to the acquisition price. It is therefore necessary to estimate the expected offsetting taking into account all the terms of the tax credit, including the fact that any tax credit not used in each offsetting period will be lost. Using the amortised cost method, pursuant to paragraph B5.4.6 of IFRS 9, it is necessary to periodically review the estimates of cash flows and to adjust the gross book value of the financial asset to reflect actual and restated cash flows. Applying IFRS 9 as the best approximation of the accounting standard that should be adopted, it is therefore necessary to define the correct portfolio among those covered by this standard, i.e. the held-to-collect (HTC) business model, in accordance with the classification currently adopted by the Group, according to which this is the reference portfolio for loans to customers, also considering the aim of holding these loans and using them for future offsetting. With regard to presentation, given that the tax credits obtained do not represent, pursuant to the international accounting standards, tax assets, public contributions, intangible assets or financial assets, the most appropriate classification for the purposes of presentation in the financial statements is the residual classification of “other assets” in the balance sheet in line with IAS 1. Income and expenses (interest and other valuation aspects such as adjustments for impairment and gains (losses) on disposal) are recognised in the income statement, in line with the HTC business model selected.
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441 | Mediolanum Group - 2025 Annual Financial Report INCOME STATEMENT Revenues Revenues are gross flows of economic benefits arising from the company’s ordinary business and are recognised when the control of goods or services is transferred to the client, for an amount that represents the consideration to which it considers it is entitled. Specifically, revenue is recognised through the application of a model that must meet the following criteria: the parties to the contract approved the contract and undertook to fulfil their respective obligations; the entity can identify the rights of each of the parties with regard to the goods or services to be transferred; determination of the expected consideration for the transfer of the goods or services to the client (transaction price); recognition of revenues when the obligation to perform is fulfilled by transferring the good or service to the customer. Interest income and expense Interest income and expense and similar income and expense comprise cash and cash equivalents and financial instruments classified under IFRS 9 (financial assets held for trading, designated at fair value or mandatorily measured at fair value, measured at fair value with an impact on comprehensive income, measured at amortised cost and financial liabilities at amortised cost). Interest income and expense is recognised in the income statement for all instruments valued according to the amortised cost criterion, using the effective interest rate method. Commission income and other income Commission income and other operating income is recognised in the income statement in accordance with IFRS 15: Revenue from contracts with customers. In particular: if the obligation to perform is fulfilled at a certain time, the relevant revenue is recognised in the income statement at the time the service is provided; if the obligation to perform is fulfilled over time, the relevant revenue is recognised in the income statement in such a way as to reflect the degree of fulfilment of the obligation. The amount of revenue recognised on commission income and other operating income is measured according to the contractually established amounts. Dividends Dividends are recognised in the income statement when they are received. Costs Costs are recognised when they are incurred in accordance with the principle of the correlation of costs and revenues. Costs that cannot be associated with revenue are immediately recognised in the income statement. Costs directly attributable to financial instruments measured at amortised cost are recorded in the income statement using the effective interest rate. The effective interest method is the method of allocating interest income or expense over the duration of a financial asset or liability. The effective interest rate is the rate that exactly discounts future payments or receipts expected over the life of the financial instrument to the net book value of the financial asset or liability. Impairment is recognised in the income statement in the financial year in which it is recognised.
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442 | Mediolanum Group - 2025 Annual Financial Report A.3 – REPORTING OF TRANSFERS OF FINANCIAL ASSETS BETWEEN PORTFOLIOS At the reporting date, there were no transfers between portfolios of financial assets requiring disclosure under IFRS 7 A.4 – FAIR VALUE REPORTING QUALITATIVE INFORMATION Fair value is defined as the price that would be received for the sale of an asset or paid for the transfer of a liability in an orderly transaction between market participants, under current conditions in the main or most advantageous market at the measurement date (exit price). Underlying the measurement of fair value is the presumption that the entity is a going concern. IFRS 13 establishes a fair value hierarchy according to the degree of observability of the inputs and parameters applied to the measurements. Three levels are envisaged: Level 1: the FV of the instruments classified at this level is determined on the basis of list prices observed in active markets; Level 2: the FV of the instruments classified at this level is determined on the basis of valuation models that mainly use inputs observable in active markets; Level 3: the FV of the instruments classified at this level is determined on the basis of valuation models that mainly use significant inputs not observable in active markets. The Group adopts a policy for recognising the fair value level of individual positions which contains the rules both for the definition of an “active market” and for the consequent operating procedure for valuing portfolios, in order to remove any discretionary power in identifying levels. Securities not belonging to either of the above two categories are regarded as belonging to a “non- active market”. Securities covering Class III policies for which the issuer has a repurchase agreement are excluded from this definition. As part of coordination activities for all Group companies, the Risk Management function provides methodology and/or operational support to the corresponding risk structures of the companies in the Conglomerate, including with regard to the definition of an active market. The following are deemed to be listed on an active market: securities traded on Italian and foreign regulated markets (e.g. MTS (electronic government securities market) and MOT (electronic bond and government securities market); securities traded on organised exchange systems authorised or recognised by Consob (multilateral trading facilities) for which the materiality of the price has been determined by the procedure described below; securities for which an executable list price is available that meets the following criteria:
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443 | Mediolanum Group - 2025 Annual Financial Report the reference time series is complete; the bid-ask price tolerance thresholds differ according to the financial instrument; significant variability in the daily price in the reference month; maximum monthly price variation limit; maximum limit of the price deviation from a benchmark quotation. Securities that meet the above criteria are classified as listed on an active market and their fair value is determined according to the type of financial instrument, as follows: for equity securities listed on the Italian stock exchange Borsa Italia and/or foreign stock exchanges, the closing price on the last trading day of the reference month; debt securities will be valued at the bid price (for long positions) and the ask price (for short positions) from an executable source. Financial instruments that are not in active markets are measured by assigning them to fair value Level 2 or Level 3. A.4.1 Fair value levels 2 and 3: measurement techniques and inputs used The Group’s Level 2 instruments comprise bonds and some derivative instruments. Securities in this category are valued on the basis of directly or indirectly observable market data. The fair value of the bonds is calculated as the sum of the present values at the end of the financial year of the cash flows deriving from them. The discount rate is determined as the sum of the following components: the risk-free rate; the credit spread; any illiquidity spread. The risk-free rate is deducted from the value implicit in IRS (interest rate swap) contracts, while the credit spread is deducted from the price of bonds of the same issuer. Where securities from the same issuer are not present, an estimated credit spread is used through the use of issuers with similar characteristics (such as issuer type, rating, maturity). If the values of coupon flows are not fixed, but variable and indexed to market interest rates, they are identified on the basis of: the forward rates implicit in the risk-free rates for the various maturities; in the event that future flows have implicit optionality, then implicit volatilities in the prices of cap and floor options are used in the estimate. Expected flows are determined based on implied volatilities (where relevant) using the Black-Scholes model. The Group’s derivative financial instruments with a fair value 2 level in 2025 were almost exclusively on foreign currency. In this case, the data necessary for the valuation are: interest rates in the currencies contracted in the derivative, the current exchange rate and the contracted exchange rate.
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444 | Mediolanum Group - 2025 Annual Financial Report Potential Level 3 assets fall into the following asset classes: units of real estate funds; unlisted equity securities positions; securities positions relating to index-linked policies; unlisted bond positions; units of closed-end UCIs funds. With regard to real estate fund units, the rationale behind real estate valuations is to determine a fair value through a mark to model. The starting point for determining the fair value of real estate (included in the real estate funds) is the (contractually fixed) rents that the tenant of the property undertakes to pay the property owner for an agreed number of years. These fees are discounted and capitalised using the valuation practice adopted by independent third-party valuers. In accordance with current legislation, the assets in real estate funds are valued by independent experts every six months. With reference to the other types of funds in the portfolio managed by leading asset management companies, the NAV of the fund’s share is assumed as an approximation of the fair value, provided that it can actually be considered an approximation of the FV. For some of the most significant equities, the Group has determined the fair value of these instruments on the basis of established academic valuation methods (DCF). Less significant unlisted equity securities were assumed to be equal to their historical cost in the absence of facts and information deemed sufficiently reliable to determine fair value reliably, such as recent transactions that could be taken as a reference or the presence of inherent characteristics of the company that enable it to be compared with other listed players. A position of a structured debt security with a fair value level of 3 is recorded in the portfolio of the subsidiary, Mediolanum Vita. The price of this instrument is provided directly by its issuer and since the quantities are not observable on the market, the fair value level is 3. A framework was developed involving validation by the Risk Management Function. Index-linked policy assets – the volumes of which are residual as a percentage of total assets held by the Irish life insurance company – consist of bonds and derivative contracts traded outside regulated markets and characterised by low liquidity and complex financial structures. They are measured on the basis of appropriately validated assessments of their counterparties or internal stochastic models. With regard to unlisted bonds, the FV estimation method presupposes the use of input parameters derived from market values and adjusted according to liquidity premium or other variables. Fair value Level 3 relating to assets and liabilities not measured at fair value on a recurring basis includes receivables and payables from/to customers and banks and real estate assets. For short-term receivables and payables from/to customers and banks the fair value was assumed to be equal to the carrying amount, as this was considered a good approximation.
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445 | Mediolanum Group - 2025 Annual Financial Report For medium/long-term performing and non-performing exposures (past due by more than 90 days and unlikely to pay), mainly consisting of loans to customers for mortgage contracts, the measurement of fair value took into account the discounting of contractual flows. A fair value corresponding to the carrying amount was assumed for non-performing exposures (non-performing loans). The assumptions underlying the determination of fair value, which are specific to the model and not observable in the market, determine classification at Level 3. The fair value of real properties directly owned by the Company and Group companies has generally been determined using the “comparative” method. A.4.2 Valuation processes and sensitivity This section includes disclosure on fair value as required by IFRS 13. Fair value is defined as the consideration that could be received to sell an asset or paid to transfer a liability, in an ordinary transaction between counterparties on the reference market on the measurement date. A financial instrument is considered quoted on an active market if the quoted prices are readily and regularly available on the regulated market (understood as a trading platform, dealer or broker) and such prices represent actual market transactions that take place regularly in normal trading. Alternative valuation models (mark to model) are used if market prices or other observable inputs are not available. The Group uses valuation methods in line with methods generally accepted and used by the market. The valuation models include techniques based on discounting future cash flows (and estimated volatility) and are reviewed periodically to ensure full consistency with the valuation objectives. As required by IFRS 13, 93 (h), for securities with fair value level 3, the sensitivity to inputs is reported (reference date 31/12/2025).
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446 | Mediolanum Group - 2025 Annual Financial Report Banking Group Fair value hierarchy Sensitivity IFRS 13.93 (b) Assets Level 3 (EUR/000) Level 3 (EUR/000) Financial assets held for trading (Equity instruments) 1,822 18 Non-trading financial assets mandatorily at fair value through profit or loss (Funds instruments) 127,642 1,276 Financial assets at fair value through other comprehensive income (Equity instruments) 7,956 80 Insurance Group Fair value hierarchy Sensitivity IFRS 13.93 (b) Assets Level 3 (EUR/000) Level 3 (EUR/000) Non-trading financial assets mandatorily at fair value through profit or loss (Funds instruments) 57,651 577 Financial assets at fair value through other comprehensive income (Equity instruments) 264 3 Sk = Vi(1.01 EQk, x, y, …) − Vi(EQk, x, y, …) Sensitivities follow the definitions described in the CRR in force in Article 325r 3(a), the numerator of which is shown in the table. In the specific case of perimeter shares, sensitivity is defined as follows: 0.01
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447 | Mediolanum Group - 2025 Annual Financial Report The sensitivity of debt securities belonging to the subsidiary Mediolanum Vita is shown below. Fair value hierarchy Sensitivity IFRS 13.93 (b) Assets Level 3 (EUR/000) Level 3 (EUR/000) Financial assets at fair value through other comprehensive income Debt Instruments 49,701 Interest Rate (40.54) 6M (0.1) 1Y (0.1) 2Y (0.4) 3Y (0.9) 5Y (5.1) 10Y (34.0) Credit Spread (40.5) 6M (0.1) 1Y (0.3) 3Y (1.1) 5Y (5.1) 10Y (34.0) In the specific case of perimeter debt instruments, sensitivity is defined as follows for the interest rate risk factor: Srkt = Vi(rkt + 0.0001, x, y, …) − Vi(rkt, x, y, …) 0.0001 The sensitivity of debt instruments to the credit spread risk factor is defined as follows: SCSkt = Vi(CSkt + 0.0001, x, y, …) − Vi(CSkt, x, y, …) 0.0001 The reference nodes considered for the calculation of sensitivity are as set out in Articles 325 terdecies and 325 quaterdecies respectively.
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448 | Mediolanum Group - 2025 Annual Financial Report A.4.3 Fair value hierarchy For the fair value hierarchy, see the description in the paragraph: Fair value reporting – qualitative disclosures. Description of migrations between asset valuation levels Banca Mediolanum has a policy in place for the recognition of the fair value level of individual positions. The policy establishes the rules applied by the individual Company for both the definition of an “active market” and the consequent operating procedure for valuing portfolios in order to avoid any discretion in the identification of levels. In 2025, following the controls carried out by the Risk Management Function in accordance with internal policies, there were no changes in the fair value level for any of the securities in the portfolios of the Banca Mediolanum. A.4.4 Other information There are no situations within the Mediolanum Group in which the maximum and best use of a non-financial asset differs from its current use. Moreover, there are no situations in which financial assets and liabilities managed on a net basis relating to market risks or credit risk are measured at fair value on the basis of the price that could be received from the sale of a net long position or the transfer of a net short position.
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449 | Mediolanum Group - 2025 Annual Financial Report QUANTITATIVE INFORMATION A.4.5 Fair value hierarchy A.4.5.1 Assets and liabilities measured at fair value on a recurring basis: breakdown by fair value level €/thousand 31/12/2025 31/12/2024 Financial assets/liabilities measured at fair value L1 L2 L3 L1 L2 L3 1. Financial assets at fair value through profit or loss 47,472,811 409,384 272,179 41,978,334 295,716 257,381 a) Financial assets held for trading 391,758 120 2,067 407,025 303 8,890 b) Financial assets designated at fair value 47,059,983 409,264 84,819 41,539,923 295,413 68,759 c) Other financial assets mandatorily measured at fair value 21,070 - 185,293 31,386 - 179,732 2. Financial assets measured at fair value through other comprehensive income 1,722,073 6,635 57,921 2,250,021 - 55,812 3. Hedging derivatives - - - - - - 4. Tangible assets - - - - - - 5. Intangible assets - - - - - - TOTAL 49,194,884 416,019 330,100 44,228,355 295,716 313,194 1. Financial liabilities held for trading - - - - 3 - 2. Financial liabilities designated at fair value 21,799,645 9,255 - 18,732,071 8,365 - 3. Hedging derivatives - - - - - - TOTAL 21,799,645 9,255 - 18,732,071 8,368 - Key: L1 = Level 1 L2 = Level 2 L3 = Level 3
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450 | Mediolanum Group - 2025 Annual Financial Report A.4.5.2 Changes during the year in assets measured at fair value on a recurring basis (Level 3) €/thousand Financial assets at fair value through profit or loss Financial assets measured at fair value through other comprehensive income Hedging derivatives Tangible assets Intangible assets Total of which: a) financial assets held for trading of which: b) financial assets designated at fair value of which: c) other financial assets mandatorily measured at fair value 1. Opening balances 257,381 8,890 68,759 179,732 55,812 - - - 2. Increases 154,406 10,139 111,753 32,514 2,134 - - - 2.1. Purchases 126,083 9,390 99,339 17,354 45 - - - 2.2. Profits booked to: 23,427 679 12,414 10,334 2,089 - - - 2.2.1. Income statement 23,427 679 12,414 10,334 - - - - - of which, capital gains 23,365 617 12,414 10,334 - - - - 2.2.2. Shareholders’ equity - X X X 2,089 - - - 2.3. Transfers from other levels - - - - - - - - 2.4. Other increases 4,896 70 - 4,826 - - - - 3. Decreases (139,608) (16,962) (95,693) (26,953) (25) - - - 3.1. Sales (131,293) (16,301) (95,693) (19,299) - - - - 3.2. Redemptions (699) - - (699) - - - - 3.3. Losses charged to: (5,008) (608) - (4,400) - - - - 3.3.1. Income statement (5,008) (608) - (4,400) - - - - - of which, capital losses (4,839) (596) - (4,243) - - - - 3.3.2. Shareholders’ equity - X X X - - - - 3.4. Transfers from other levels - - - - - - - - 3.5. Other decreases (2,608) (53) - (2,555) (25) - - - 4. Closing balances 272,179 2,067 84,819 185,293 57,921 - - - A.4.5.3 Annual changes in liabilities measured at fair value (Level 3) Nothing to report
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451 | Mediolanum Group - 2025 Annual Financial Report A.4.5.4 Assets and liabilities not measured at fair value or measured at fair value on a non-recurring basis: breakdown by fair value level €/thousand 31/12/2025 31/12/2024 CA L1 L2 L3 CA L1 L2 L3 1. Financial assets measured at amortised cost 36,961,812 16,320,767 597,501 21,952,028 37,863,887 18,482,860 280,249 20,968,454 2. Tangible assets held for investment purposes 52,514 - - 54,080 53,339 - - 58,200 3. Non-current assets and disposal groups - - - - 823 - - 823 TOTAL 37,014,326 16,320,767 597,501 22,006,108 37,918,049 18,482,860 280,249 21,027,477 1. Financial liabilities measured at amortised cost 33,077,523 314,597 - 32,763,398 35,555,496 306,378 - 35,241,867 2. Liabilities associated with assets held for sale - - - - - - - - TOTAL 33,077,523 314,597 - 32,763,398 35,555,496 306,378 - 35,241,867 Key: CA = Carrying amount L1 = Level 1 L2 = Level 2 L3 = Level 3 A.5 – INFORMATION ON THE SO-CALLED DAY ONE PROFIT/LOSS The Group has not entered into any transactions resulting in the recognition of a “day one profit/loss”.
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452 | Mediolanum Group - 2025 Annual Financial Report PART B – INFORMATION ON THE CONSOLIDATED STATEMENT OF FINANCIAL POSITION ASSETS Section 1 – Cash and cash equivalents –Item 10 1.1 Cash and cash equivalents: breakdown €/thousand 31/12/2025 31/12/2024 a) Cash 3,350 2,818 b) Current accounts and demand deposits with central banks 67,385 583,016 c) Current accounts and demand deposits with banks 91,088 98,606 TOTAL 161,823 684,440
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453 | Mediolanum Group - 2025 Annual Financial Report Section 2 – Financial assets measured at fair value through profit or loss - Item 20 2.1 Financial assets held for trading: breakdown by type €/thousand 31/12/2025 31/12/2024 L1 L2 L3 L1 L2 L3 A. On-balance sheet assets 1. Debt securities 391,755 3 245 367,346 - 79 1.1 Structured notes - - - - - 30 1.2 Other debt securities 391,755 3 245 367,346 - 49 2. Equity securities - - 1,822 39,676 - 8,811 3. Units in investment funds (UCIs) 3 - - 3 - - 4. Loans - - - - - - 4.1 Repurchase agreements - - - - - - 4.2 Other - - - - - - TOTAL (A) 391,758 3 2,067 407,025 - 8,890 B. Derivative instruments - 1. Financial derivatives - 117 - - 303 - 1.1 for trading - 117 - - 303 - 1.2 associated with the fair value option - - - - - - 1.3 other - - - - - - 2. Credit derivatives - - - - - - 2.1 For trading - - - - - - 2.2 Associated with the fair value option - - - - - - 2.3 Other - - - - - - TOTAL (B) - 117 - - 303 - TOTAL (A+B) 391,758 120 2,067 407,025 303 8,890 Key: L1 = Level 1 L2 = Level 2 L3 = Level 3 The item decreased by -€22.3 million; as the stock of debt securities in the portfolio increased by +€24.6 million, equity securities decreased by -€46.7 million as a result of the sale of the entire holding in Nexi and almost all of the Visa securities in the portfolio as at 31 December 2024.
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454 | Mediolanum Group - 2025 Annual Financial Report 2.2 Financial assets held for trading: breakdown by borrower/issuer/counterparty €/thousand 31/12/2025 31/12/2024 A. BALANCE SHEET ASSETS 1. Debt securities 392,003 367,425 a) Central banks - - b) General government 292,139 258,075 c) Banks 99,593 109,282 d) Other financial corporations 271 68 of which: insurance companies - - e) Non-financial corporations - - 2. Equity securities 1,822 48,487 a) Banks - - b) Other financial corporations 1,812 48,421 of which: insurance companies - - c) Non-financial corporations 10 66 d) Other issuers - - 3. Units of UCIs 3 3 4. Loans - - a) Central banks - - b) General government - - c) Banks - - d) Other financial corporations - - of which: insurance companies - - e) Non-financial corporations - - f) Households - - TOTAL (A) 393,828 415,915 B. DERIVATIVE INSTRUMENTS - a) Central counterparties - - b) Other 117 303 TOTAL (B) 117 303 TOTAL (A+B) 393,945 416,218
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455 | Mediolanum Group - 2025 Annual Financial Report 2.3 Financial assets designated at fair value: breakdown by type €/thousand 31/12/2025 31/12/2024 L1 L2 L3 L1 L2 L3 1. Debt securities 274,688 2,465 84,819 419,937 247 68,759 1.1 Structured notes 274,688 2,465 84,819 419,937 247 68,759 1.2 Other debt securities - - - - - - 2. Loans 46,785,295 406,799 - 41,119,986 295,166 - 2.1 Structured - - - - - - 2.2 Other 46,785,295 406,799 - 41,119,986 295,166 - TOTAL 47,059,983 409,264 84,819 41,539,923 295,413 68,759 Key: L1 = Level 1 L2 = Level 2 L3 = Level 3 2.4 Financial assets designated at fair value: breakdown by borrower/issuer €/thousand 31/12/2025 31/12/2024 1. Debt securities 361,972 488,943 a) Central banks - - b) General government 174,317 142,963 c) Banks 68,068 103,083 d) Other financial corporations 15,078 86,829 of which: insurance companies - 1,166 e) Non-financial corporations 104,509 156,068 2. Loans 47,192,094 41,415,152 a) Central banks - - b) General government - - c) Banks 57,146 65,810 d) Other financial corporations 47,134,948 41,349,342 of which: insurance companies - - e) Non-financial corporations - - f) Households - - TOTAL 47,554,066 41,904,095
Page 456
456 | Mediolanum Group - 2025 Annual Financial Report 2.5 Other financial assets mandatorily measured at fair value: breakdown by type €/thousand 31/12/2025 31/12/2024 L1 L2 L3 L1 L2 L3 1. Debt securities - - - - - - 1.1 Structured notes - - - - - - 1.2 Other debt securities - - - - - - 2. Equity securities - - - - - - 3. Units in investment funds (UCIs) 21,070 - 185,293 31,386 - 179,732 4. Loans - - - - - - 4.1 Repurchase agreements - - - - - - 4.2 Other - - - - - - TOTAL 21,070 - 185,293 31,386 - 179,732 Key: L1 = Level 1 L2 = Level 2 L3 = Level 3 2.6 Other financial assets mandatorily measured at fair value: breakdown by borrower/issuer €/thousand 31/12/2025 31/12/2024 1. Equity securities - - of which: banks - - of which: other financial corporations - - of which: non-financial corporations - - 2. Debt securities - - a) Central banks - - b) General government - - c) Banks - - d) Other financial corporations - - of which: insurance companies - - e) Non-financial corporations - - 3. Units in investment funds (UCIs) 206,363 211,118 4. Loans - - a) Central banks - - b) General government - - c) Banks - - d) Other financial corporations - - of which: insurance companies - - e) Non-financial corporations - - f) Households - - TOTAL 206,363 211,118
Page 457
457 | Mediolanum Group - 2025 Annual Financial Report Section 3 – Financial assets at fair value through other comprehensive income – Item 30 3.1 Financial assets at fair value through other comprehensive income: breakdown by type €/thousand 31/12/2025 31/12/2024 L1 L2 L3 L1 L2 L3 1. Debt securities 1,722,003 6,635 49,701 1,840,468 - 47,315 1.1 Structured notes - - - - - - 1.2 Other debt securities 1,722,003 6,635 49,701 1,840,468 - 47,315 2. Equity securities 70 - 8,220 409,553 - 8,497 3. Loans - - - - - - TOTAL 1,722,073 6,635 57,921 2,250,021 - 55,812 Key: L1 = Level 1 L2 = Level 2 L3 = Level 3 The item “Financial assets valued at fair value with an impact on comprehensive income amounted in 31 December 2025 to €1,786.6 thousand (31.12.2024: €2,305.8 thousand). The change is mainly linked to the sale of the Mediobanca share capital, for which reference is made to the specific other information paragraph “Information on the sale of Mediobanca shares”.
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458 | Mediolanum Group - 2025 Annual Financial Report 3.2 Financial assets measured at fair value through other comprehensive income: breakdown by borrower/issuer €/thousand 31/12/2025 31/12/2024 1. Debt securities 1,778,339 1,887,783 a) Central banks - - b) General government 1,561,141 1,658,890 c) Banks 112,903 124,444 d) Other financial corporations 85,809 88,687 of which: insurance companies 34,742 26,451 e) Non-financial corporations 18,486 15,762 2. Equity securities 8,290 418,050 a) Banks - 409,513 b) Other issuers: 8,290 8,537 - other financial corporations 1,190 1,190 of which: insurance companies - - - non-financial corporations 7,100 7,322 - other - 25 3. Loans - - a) Central banks - - b) General government - - c) Banks - - d) Other financial corporations - - of which: insurance companies - - e) Non-financial corporations - - f) Households - - TOTAL 1,786,629 2,305,833 3.3 Financial assets measured at fair value through other comprehensive income: gross value and overall adjustments €/thousand Gross value Overall value adjustments Stage 1 of which: Instruments with low credit risk Stage 2 Stage 3 Purchased or originated impaired Stage 1 Stage 2 Stage 3 Purchased or originated impaired Overall partial write- offs* Debt securities 1,779,147 1,779,147 - - - (808) - - - - Loans - - - - - - - - - - TOTAL 31/12/2025 1,779,147 1,779,147 - - - (808) - - - - TOTAL 31/12/2024 1,888,963 1,888,963 - - - (1,180) - - - -
Page 459
459 | Mediolanum Group - 2025 Annual Financial Report Section 4 – Financial assets measured at amortised cost - Item 40 4.1 Financial assets measured at amortised cost: breakdown by type of loans to banks (Part 1 of 2) €/thousand 31/12/2025 Carrying amount Fair value Stages 1 and 2 Stage 3 Purchased or originated impaired L1 L2 L3 A. Loans to central banks 276,560 - - - - 276,560 1. Deposits at notice - - - X X X 2. Mandatory reserve 276,560 - - X X X 3. Repurchase agreements - - - X X X 4. Other - - - X X X B. Loans to banks 882,823 - - 45,262 597,501 223,602 1. Loans 223,603 - - - - 223,602 1.1 Current accounts - - - X X X 1.2. Deposits at notice 222,592 - - X X X 1.3. Other loans: 1,011 - - X X X - Reverse repurchase agreements - - - X X X - Leasing loans - - - X X X - Other 1,011 - - X X X 2. Debt securities 659,220 - - 45,262 597,501 - 2.1 Structured notes - - - - - - 2.2 Other debt securities 659,220 - - 45,262 597,501 - TOTAL 1,159,383 - - 45,262 597,501 500,162 At 31 December 2025, loans to banks amounted to €1,159.4 million, compared with €811.4 million at the end of 2024. The growth was essentially due to an increase in the stock of debt securities classified in the Held-to- Collect portfolio (+€329.1 million compared with the comparative period).
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460 | Mediolanum Group - 2025 Annual Financial Report 4.1 Financial assets measured at amortised cost: breakdown by type of loans to banks (Part 2 of 2) €/thousand 31/12/2024 Carrying amount Fair value Stages 1 and 2 Stage 3 Purchased or originated impaired L1 L2 L3 A. Loans to central banks 282,338 - - - - 282,338 1. Deposits at notice - - - X X X 2. Mandatory reserve 282,338 - - X X X 3. Repurchase agreements - - - X X X 4. Other - - - X X X B. Loans to banks 529,044 - - 51,266 280,249 198,911 1. Loans 198,910 - - - - 198,911 1.1 Current accounts - - - X X X 1.2. Deposits at notice 193,031 - - X X X 1.3. - Other loans: 5,879 - - X X X 1.4 Reverse repurchase agreements - - - X X X 1.5 Leasing loans - - - X X X 1.6 Other 5,879 - - X X X 2. Debt securities 330,134 - - 51,266 280,249 - 2.1 Structured notes - - - - - - 2.2 Other debt securities 330,134 - - 51,266 280,249 - TOTAL 811,382 - - 51,266 280,249 481,249
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461 | Mediolanum Group - 2025 Annual Financial Report 4.2 Financial assets measured at amortised cost: breakdown of loans to customers by type (Part 1 of 2) €/thousand 31/12/2025 Carrying amount Fair value Stages 1 and 2 Stage 3 Purchased or originated impaired L1 L2 L3 1. Loans 19,566,940 144,174 3,279 - - 21,451,866 1.1 Current accounts 487,622 8,027 370 X X X 1.2 Reverse repurchase agreements - - - X X X 1.3 Mortgages 13,277,586 63,944 - X X X 1.4 Credit cards, personal loans and salary-backed loans 3,323,333 43,237 2,823 X X X 1.5. Leasing loans - - - X X X 1.6 Factoring - - - X X X 1.7 Other loans 2,478,399 28,966 86 X X X 2. Debt securities 16,088,036 - - 16,275,505 - - 2.1 Structured notes - - - - - - 2.2 Other debt securities 16,088,036 - - 16,275,505 - - TOTAL 35,654,976 144,174 3,279 16,275,505 - 21,451,866 Loans to customers amounted to €35,802.4 million, compared with €37,052.5 million at the end of 2024. The change was essentially due to a reduction in the stock of debt securities classified in the Held-to-Collect portfolio (-€2,245.8 million compared with the comparative period) now matured. As a result of the above decrease, during the period the stock of mortgages increased by +€831.1 million compared to the comparative period.
Page 462
462 | Mediolanum Group - 2025 Annual Financial Report 4.2 Financial assets measured at amortised cost: breakdown of loans to customers by type (Part 2 of 2) €/thousand 31/12/2024 Carrying amount Fair value Stages 1 and 2 Stage 3 Purchased or originated impaired L1 L2 L3 1. Loans 18,578,064 137,576 3,025 - - 20,487,205 1.1 Current accounts 457,696 7,631 377 X X X 1.2 Reverse repurchase agreements 90,148 - - X X X 1.3 Mortgages 12,445,133 65,267 - X X X 1.4 Credit cards, personal loans and salary-backed loans 3,195,167 37,807 2,546 X X X 1.5. Leasing loans - - - X X X 1.6 Factoring - - - X X X 1.7 Other loans 2,389,920 26,871 102 X X X 2. Debt securities 18,333,840 - - 18,431,594 - - 2.1 Structured notes - - - - - - 2.2 Other debt securities 18,333,840 - - 18,431,594 - - TOTAL 36,911,904 137,576 3,025 18,431,594 - 20,487,205 4.3 Financial assets measured at amortised cost: breakdown of loans to customers by borrower/issuer €/thousand 31/12/2025 31/12/2024 Stages 1 and 2 Stage 3 Purchased or originated impaired assets Stages 1 and 2 Stage 3 Purchased or originated impaired assets 1. Debt securities 16,088,036 - - 18,333,840 - - a) General government 16,078,313 - - 18,323,635 - - b) Other financial corporations 9,723 - - 10,205 - - of which: insurance companies 2,663 - - 2,702 - - c) Non-financial corporations - - - - - - 2. Loans to: 19,566,940 144,174 3,279 18,578,064 137,576 3,025 a) General government 1,602 1,244 - 1,632 1,437 - b) Other financial corporations 777,476 195 - 1,126,684 165 - of which: insurance companies 2,988 191 - 4,001 153 - c) Non-financial corporations 787,390 24,365 - 664,220 24,668 - d) Households 18,000,472 118,370 3,279 16,785,528 111,306 3,025 TOTAL 35,654,976 144,174 3,279 36,911,904 137,576 3,025
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463 | Mediolanum Group - 2025 Annual Financial Report 4.4 Financial assets measured at amortised cost: gross value and overall value adjustments €/thousand Gross value Overall value adjustments Stage 1 of which: Instruments with low credit risk Stage 2 Stage 3 Purchased or originated impaired Stage 1 Stage 2 Stage 3 Purchased or originated impaired Overall partial write- offs* Debt securities 16,753,543 16,753,543 - - - (6,287) - - - - Loans 19,430,579 - 693,086 284,795 5,606 (28,549) (28,013) (140,621) (2,327) (245) TOTAL 31/12/2025 36,184,122 16,753,543 693,086 284,795 5,606 (34,836) (28,013) (140,621) (2,327) (245) TOTAL 31/12/2024 37,076,513 18,676,063 716,320 259,265 4,900 (39,446) (30,101) (121,689) (1,875) (242) Section 5 – Hedging derivatives Item 50 Nothing to report
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464 | Mediolanum Group - 2025 Annual Financial Report Section 8 – Insurance assets – Item 80 Changes in the carrying amount of reinsurance cessions - GMM –asset for remaining coverage and for claims incurred – Aggregation base 1 €/thousand Asset for remaining coverage Asset for incurred claims Total Asset for remaining coverage Asset for incurred claims Total 31/12/2025 31/12/2025 31/12/2025 31/12/2024 31/12/2024 31/12/2024 Net of loss recovery component Loss recovery component Net of loss recovery component Loss recovery component A. Initial carrying amount 39,758 - 5,438 45,196 43,475 - 2,942 46,417 1. Reinsurance cessions that are classified as assets 39,758 - 5,438 45,196 43,475 - 2,942 46,417 2. Reinsurance cessions that are classified as liabilities - - - - - - - - 3. Net carrying amount at 1 January 39,758 - 5,438 45,196 43,475 - 2,942 46,417 B. Economic effects related to reinsurance cessions 1. Cost of reinsurance (23,082) - - (23,082) (23,090) - - (23,090) 2. Claims and other costs recovered - - 18,795 18,795 - - 14,463 14,463 3. Changes in the asset for incurred claims - - 193 193 - - 2,496 2,496 4. Reinsurance cessions covering onerous contracts - - - - - - - - 4.1 Revenues related to the recognition of onerous underlying insurance contracts - - - - - - - - 4.2 Releases of the loss recovery component other than changes in the cash flows of reinsurance contracts - - - - - - - - 4.3 Changes in cash flows of reinsurance cessions deriving from onerous underlying insurance contracts - - - - - - - - 5. Effects of changes in the risk of default on the part of reinsurers - - - - - - - - 6. Total (23,082) - 18,988 (4,094) (23,090) - 16,959 (6,131) C. Result of insurance services (Total B) (23,082) - 18,988 (4,094) (23,090) - 16,959 (6,131) D. Net financial revenues/costs 1. Relating to reinsurance cessions 1,199 - - 1,199 15 - - 15 1.1. Recognised in profit or loss 301 - - 301 282 - - 282 1.2. Recognised in other comprehensive income 898 - - 898 (267) - - (267) 2. Effects related to exchange rate fluctuations - - - - - - - - 3. Total 1,199 - - 1,199 15 - - 15 E. Investment components - - - - F. Total amount recognised in profit or loss and in comprehensive income (C+D+E) (21,883) - 18,988 (2,895) (23,075) - 16,959 (6,116) G. Other changes - - - - - - - - H. Cash movements 1. Premiums paid net of amounts not related to claims recovered from reinsurers 20,264 - - 20,264 19,358 - - 19,358 2. Amount of claims recovered by reinsurers - - (18,795) (18,795) - - (14,463) (14,463) 3. Other movements - - - - - - - - 4. Total 20,264 - (18,795) 1,469 19,358 - (14,463) 4,895 I. Net carrying amount at 31 December (A.3+F+G+H.3) 38,139 - 5,631 43,770 39,758 - 5,438 45,196 L. Closing carrying amount 1. Reinsurance cessions that are classified as assets 38,139 - 5,631 43,770 39,758 - 5,438 45,196 2. Reinsurance cessions that are classified as liabilities - - - - - - - - 3. Net carrying amount at 31 December 38,139 - 5,631 43,770 39,758 - 5,438 45,196 Key Aggregation Base 1 = Life segment Aggregation Base II = Non-life segment
Page 465
465 | Mediolanum Group - 2025 Annual Financial Report Changes in the carrying amount of reinsurance cessions –GMM asset for remaining coverage and for claims incurred – Aggregation Base 2 €/thousand Asset for remaining coverage Asset for incurred claims Total Asset for remaining coverage Asset for incurred claims Total 31/12/2025 31/12/2025 31/12/2025 31/12/2024 31/12/2024 31/12/2024 Net of loss recovery component Loss recovery component Net of loss recovery component Loss recovery component A. Initial carrying amount 22,431 - 3,370 25,801 20,335 - 11,475 31,810 1. Reinsurance cessions that are classified as assets 22,431 - 3,370 25,801 20,335 - 11,475 31,810 2. Reinsurance cessions that are classified as liabilities - - - - - - - - 3. Net carrying amount at 1 January 22,431 - 3,370 25,801 20,335 - 11,475 31,810 B. Economic effects related to reinsurance cessions 1. Cost of reinsurance (16,927) - (18) (16,945) (17,434) - (184) (17,618) 2. Claims and other costs recovered - - 13,945 13,945 - - 17,531 17,531 3. Changes in the asset for incurred claims - - (329) (329) - - (7,587) (7,587) 4. Reinsurance cessions covering onerous contracts - - - - - - - - 4.1 Revenues related to the recognition of onerous underlying insurance contracts - - - - - - - - 4.2 Releases of the loss recovery component other than changes in the cash flows of reinsurance contracts - - - - - - - - 4.3 Changes in cash flows of reinsurance cessions deriving from onerous underlying insurance contracts - - - - - - - - 5. Effects of changes in the risk of default on the part of reinsurers - - - - - - - - 6. Total (16,927) - 13,598 (3,329) (17,434) - 9,760 (7,674) C. Result of insurance services (Total B) (16,927) - 13,598 (3,329) (17,434) - 9,760 (7,674) D. Net financial revenues/costs 1. Relating to reinsurance cessions 186 - 47 233 (138) - (334) (472) 1.1. Recognised in profit or loss 184 - 56 240 202 - (338) (136) 1.2. Recognised in other comprehensive income 2 - (9) (7) (340) - 4 (336) 2. Effects related to exchange rate fluctuations - - - - - - - - 3. Total 186 - 47 233 (138) - (334) (472) E. Investment components - - - - - - - - F. Total amount recognised in profit or loss and in comprehensive income (C+D+E) (16,741) - 13,645 (3,096) (17,572) - 9,426 (8,146) G. Other changes - - - - - - - - H. Cash movements 1. Premiums paid net of amounts not related to claims recovered from reinsurers 24,120 - - 24,120 19,668 - - 19,668 2. Amount of claims recovered by reinsurers - - (13,944) (13,944) - - (17,531) (17,531) 3. Other movements - - - - - - - - 4. Total 24,120 - (13,944) 10,176 19,668 - (17,531) 2,137 I. Net carrying amount at 31 December (A.3+F+G+H.3) 29,810 - 3,071 32,881 22,431 - 3,370 25,801 L. Closing carrying amount 1. Reinsurance cessions that are classified as assets 29,810 - 3,071 32,881 22,431 - 3,370 25,801 2. Reinsurance cessions that are classified as liabilities - - - - - - - - 3. Net carrying amount at 31 December 29,810 - 3,071 32,881 22,431 - 3,370 25,801 Key Aggregation Base 1 = Life segment Aggregation Base II = Non-life segment
Page 466
466 | Mediolanum Group - 2025 Annual Financial Report Changes in the carrying amount of reinsurance cessions broken down by underlying elements of measurement – Aggregation Base 1 Items/elements underlying the measurement Elements underlying the measurement of the carrying amount of reinsurance cessions Present value of cash flows Adjustment for non-financial risks Contractual service margin Total Present value of cash flows Adjustment for non-financial risks Contractual service margin Total 31/12/2025 31/12/2025 31/12/2025 31/12/2025 31/12/2024 31/12/2024 31/12/2024 31/12/20 24 A. Initial carrying amount 10,531 8,293 26,372 45,196 11,509 7,852 27,056 46,417 1. Reinsurance cessions that are classified as assets 10,531 8,293 26,372 45,196 11,509 7,852 27,056 46,417 2. Reinsurance cessions that are classified as liabilities - - - - - - - - 3. Net carrying amount at 1 January 10,531 8,293 26,372 45,196 11,509 7,852 27,056 46,417 B. Changes related to current services 1. Contractual service margin recorded in profit or loss - - (1,352) (1,352) - - (1,288) (1,288) 2. Change due to overdue non-financial risks - (448) - (448) - (409) - (409) 3. Experience-related changes (2,487) - - (2,487) (6,930) - - (6,930) 4. Total (2,487) (448) (1,352) (4,287) (6,930) (409) (1,288) (8,627) C. Changes related to future services 1. Changes in estimates adjusting the contractual service margin (1,745) 519 1,226 - (327) 782 (455) - 2. Effects of contracts entered into during the year (1,055) 72 983 - (953) 68 885 - 3. Adjustment of contractual service margin linked to recoveries related to the initial recognition of onerous underlying insurance contracts - - - - - - - - 4. Releases of the loss recovery component other than changes in the cash flows of reinsurance contracts - - - - - - - - 5. Changes in cash flows of reinsurance cessions deriving from onerous underlying insurance contracts - - - - - - - - 6. Total (2,800) 591 2,209 - (1,280) 850 430 - D. Changes related to past services 193 - - 193 2,496 - - 2,496 1. adjustments to the asset for incurred claims 193 - - 193 2,496 - - 2,496 E. Effects of changes in default risk - - - - - - - - F. Result of insurance services (B+C+D+E) (5,094) 143 857 (4,094) (5,714) 441 (858) (6,131) G. Net financial revenues/costs 1. Relating to reinsurance cessions 984 - 215 1,199 (159) - 174 15 1.1 Recognised in profit or loss 86 - 215 301 108 - 174 282 1.2. Recognised in other comprehensive income 898 - - 898 (267) - - (267) 2. Effects related to exchange rate fluctuations - - - - - - - - 3. Total 984 - 215 1,199 (159) - 174 15 H. Total amount recognised in profit or loss and in comprehensive income (F+G) (4,110) 143 1,072 (2,895) (5,873) 441 (684) (6,116) I. Other changes - - - - - - - - L. Cash movements 1. Premiums paid net of amounts not related to claims recovered from reinsurers 20,264 - - 20,264 19,358 - - 19,358 2. Amounts recovered from reinsurers (18,795) - - (18,795) (14,463) - - (14,463) 3. Other movements - - - - - - - - 4. Total 1,469 - - 1,469 4,895 - 4,895 M. Net carrying amount at 31 December (A.3+H+I+L.3) 7,890 8,436 27,444 43,770 10,531 8,293 26,372 45,196 N. Closing carrying amount 1. Reinsurance cessions that are classified as assets 7,890 8,436 27,444 43,770 10,531 8,293 26,372 45,196 2. Reinsurance cessions that are classified as liabilities - - - - - - - - 3. Net carrying amount at 31 December 7,890 8,436 27,444 43,770 10,531 8,293 26,372 45,196 Key Aggregation Base 1 = Life segment Aggregation Base 2 = Non-life segment
Page 467
467 | Mediolanum Group - 2025 Annual Financial Report Changes in the carrying amount of reinsurance cessions broken down by underlying elements of measurement – Aggregation Base 2 Items/elements underlying the measurement Elements underlying the measurement of the carrying amount of reinsurance cessions Present value of cash flows Adjustment for non-financial risks Contractual service margin Total Present value of cash flows Adjustment for non-financial risks Contractual service margin Total 31/12/2025 31/12/2025 31/12/2025 31/12/2025 31/12/2024 31/12/2024 31/12/2024 31/12/2024 A. Initial carrying amount 10,434 529 14,838 25,801 14,280 971 16,559 31,810 1. Reinsurance cessions that are classified as assets 10,434 529 14,838 25,801 14,280 971 16,559 31,810 2. Reinsurance cessions that are classified as liabilities - - - - - - - - 3. Net carrying amount at 1 January 10,434 529 14,838 25,801 14,280 971 16,559 31,810 B. Changes related to current services 1. Contractual service margin recorded in profit or loss - - (5,741) (5,741) - - (8,293) (8,293) 2. Change due to overdue non- financial risks - (151) - (151) - (304) - (304) 3. Experience-related changes 2,892 - - 2,892 8,510 - - 8,510 4. Total 2,892 (151) (5,741) (3,000) 8,510 (304) (8,293) (87) C. Changes related to future services 1. Changes in estimates adjusting the contractual service margin (2,392) (112) 2,504 - 24,061 (577) (23,484) - 2. Effects of contracts entered into during the year (8,326) 178 8,148 - (30,473) 924 29,549 - 3. Adjustment of contractual service margin linked to recoveries related to the initial recognition of onerous underlying insurance contracts - - - - - - - - 4. Releases of the loss recovery component other than changes in the cash flows of reinsurance contracts - - - - - - - - 5. Changes in cash flows of reinsurance cessions deriving from onerous underlying insurance contracts - - - - - - - - 6. Total (10,718) 66 10,652 - (6,412) 347 6,065 - D. Changes related to past services (329) - - (329) (7,587) - - (7,587) 1. adjustments to the asset for incurred claims (329) - - (329) (7,587) - - (7,587) E. Effects of changes in default risk - - - - - - - - F. Result of insurance services (B+C+D+E) (8,155) (85) 4,911 (3,329) (5,489) 43 (2,228) (7,674) G. Net financial revenues/costs 1. Relating to reinsurance cessions 7 - 226 233 (494) (485) 507 (472) 1.1 Recognised in profit or loss 13 - 226 239 (158) (485) 507 (136) 1.2. Recognised in other comprehensive income (6) - - (6) (336) - - (336) 2. Effects related to exchange rate fluctuations - - - - - - - - 3. Total 7 - 226 233 (494) (485) 507 (472) H. Total amount recognised in profit or loss and in comprehensive income (F+G) (8,148) (85) 5,137 (3,096) (5,983) (442) (1,721) (8,146) I. Other changes - - - - - - - - L. Cash movements 1. Premiums paid net of amounts not related to claims recovered from reinsurers 24,121 - - 24,121 19,668 - - 19,668 2. Amounts recovered from reinsurers (13,945) - - (13,945) (17,531) - - (17,531) 3. Other movements - - - - - - - - 4. Total 10,176 - - 10,176 2,137 - - 2,137 M. Net carrying amount at 31 December (A.3+H+I+L.3) 12,462 444 19,975 32,881 10,434 529 14,838 25,801 N. Closing carrying amount 1. Reinsurance cessions that are classified as assets 12,462 444 19,975 32,881 10,434 529 14,838 25,801 2. Reinsurance cessions that are classified as liabilities - - - - - - - - 3. Net carrying amount at 31 December 12,462 444 19,975 32,881 10,434 529 14,838 25,801 Key Aggregation Base 1 = Life segment Aggregation Base 2 = Non-life segment
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468 | Mediolanum Group - 2025 Annual Financial Report Changes in the contractual service margin of reinsurance cessions broken down on the basis of contracts existing at the time of transition to IFRS 17 - Aggregation Base 1 31/12/2025 31/12/2024 New contracts and contracts measured at the transition date with the full retroactive application method Contracts measured at the transition date with the modified retroactive application method Contracts measured at the transition date with the fair value method Carve- out contracts Total New contracts and contracts measured at the transition date with the full retroactive application method Contracts measured at the transition date with the modified retroactive application method Contracts measured at the transition date with the fair value method Carve- out contracts Total Contractual service margin – Opening balances 10,983 - 15,389 - 26,372 9,885 - 17,171 - 27,056 Changes related to current services (440) - (912) - (1,352) (330) - (958) - (1,288) - Contractual service margin recognised in profit or loss to reflect services received (440) - (912) - (1,352) (330) - (958) - (1,288) Changes related to future services 3,162 - (953) - 2,209 1,271 - (841) - 430 - Changes in estimates adjusting the contractual service margin 2,179 - (953) - 1,226 386 - (841) - (455) - Effects of contracts initially recognised in the reporting year 983 - - - 983 885 - - - 885 Financial revenues/costs 1. Relating to reinsurance cessions 187 - 28 - 215 157 - 17 - 174 2. Effects related to exchange rate fluctuations - - - - - - - - - - 3. Total 187 - 28 - 215 157 - 17 - 174 Other movements - - - - - - - - - - Total changes recognised in profit or loss and in comprehensive income 2,909 - (1,837) - 1,072 1,098 - (1,782) - (684) Contractual service margin – Closing inventories 13,892 - 13,552 - 27,444 10,983 - 15,389 - 26,372 Key Aggregation Base 1 = Life segment Aggregation Base 2 = Non-life segment
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469 | Mediolanum Group - 2025 Annual Financial Report Changes in the contractual service margin of reinsurance cessions broken down on the basis of contracts existing at the time of transition to IFRS 17 – Aggregation Base 2 31/12/2025 31/12/2024 New contracts and contracts measured at the transition date with the full retroactive application method Contracts measured at the transition date with the modified retroactive application method Contracts measured at the transition date with the fair value method Carve- out contracts Total New contracts and contracts measured at the transition date with the full retroactive application method Contracts measured at the transition date with the modified retroactive application method Contracts measured at the transition date with the fair value method Carve- out contracts Total Contractual service margin – Opening balances 8,530 - 6,308 - 14,838 16,979 - (420) - 16,559 Changes related to current services (3,896) - (1,845) - (5,741) (7,531) - (762) - (8,293) - Contractual service margin recognised in profit or loss to reflect services received (3,896) - (1,845) - (5,741) (7,531) - (762) - (8,293) Changes related to future services 3,178 - 7,474 - 10,652 (1,420) - 7,485 - 6,065 - Changes in estimates adjusting the contractual service margin (4,970) - 7,474 - 2,504 (30,969) - 7,485 - (23,484) - Effects of contracts initially recognised in the reporting year 8,148 - - - 8,148 29,549 - - - 29,549 Financial revenues/costs 1. Relating to reinsurance cessions 207 - 19 - 226 502 - 5 - 507 2. Effects related to exchange rate fluctuations - - - - - - - - - - 3. Total 207 - 19 - 226 502 - 5 - 507 Other movements - - - - - - - - - - Total changes recognised in profit or loss and in comprehensive income (511) - 5,648 - 5,137 (8,449) - 6,728 - (1,721) Contractual service margin – Closing inventories 8,019 - 11,956 - 19,975 8,530 - 6,308 - 14,838 Key Aggregation Base 1 = Life segment Aggregation Base 2 = Non-life segment
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470 | Mediolanum Group - 2025 Annual Financial Report Elements underlying the measurement of reinsurance cessions recognised in financial year – Aggregation Base 1 €/thousand Originated contracts Originated contracts 31/12/2025 31/12/2024 Items/contract groups Contracts without loss recovery component Contracts with loss recovery component Total Contracts without loss recovery component Contracts with loss recovery component Total A. Estimated present value of future cash inflows (2,268) - (2,268) (2,237) - (2,237) of which: Cash flows associated with the acquisition of insurance contracts - - - - - - B. Estimated present value of cash inflows (1,213) - (1,213) (1,284) - (1,284) C. Estimated net present value of future cash flows (A-B) (1,055) - (1,055) (953) - (953) D. Estimated net present value of future cash flows 72 - 72 68 - 68 E. Derecognition of previously recognised cash flows - - - - - - F. Contractual service margin 983 - 983 885 - 885 G. Increase in assets for reinsurance cessions recorded during the year due to the signing of new contracts (C+D+E+F) - - - - - - Key Aggregation Base 1 = Life segment Aggregation Base 2 = Non-life segment Elements underlying the measurement of reinsurance cessions recognised in financial year – Aggregation Base 2 €/thousand Originated contracts Originated contracts 31/12/2025 31/12/2024 Items/contract groups Contracts without loss recovery component Contracts with loss recovery component Total Contracts without loss recovery component Contracts with loss recovery component Total A. Estimated present value of future cash inflows (18,394) - (18,394) (73,030) - (73,030) of which: Cash flows associated with the acquisition of insurance contracts - - - - - - B. Estimated present value of cash inflows (10,068) - (10,068) (42,557) - (42,557) C. Estimated net present value of future cash flows (A-B) (8,326) - (8,326) (30,473) - (30,473) D. Estimated net present value of future cash flows 178 - 178 924 - 924 E. Derecognition of previously recognised cash flows - - - - - - F. Contractual service margin 8,148 - 8,148 29,549 - 29,549 G. Increase in assets for reinsurance cessions recorded during the year due to the signing of new contracts (C+D+E+F) - - - - - - Key Aggregation Base 1 = Life segment Aggregation Base 2 = Non-life segment
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471 | Mediolanum Group - 2025 Annual Financial Report Reinsurance cessions - Contractual service margin broken down by expected timing of recognition in profit or loss 1. The table below is broken down by life and non-life segments: (€ thousands) Bases of aggregation/expected timeframe Up to 1 year Over 1 year to 2 years Over 2 years to 3 years Over 3 years to 4 years Over 4 years to 5 years Over 5 years to 10 years Over 10 years to 20 years Over 20 years Total Life segment 1,455 1,476 1,493 1,508 1,500 6,967 9,432 3,614 27,444 Non-life segment 17,023 650 566 487 386 820 37 7 19,975
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472 | Mediolanum Group - 2025 Annual Financial Report Section 9 –Tangible assets – Item 90 9.1 Tangible assets for business use: breakdown of assets measured at cost €/thousand 31/12/2025 31/12/2024 1. Own assets 90,012 91,723 a) land 46,301 46,301 b) buildings 29,736 31,308 c) furniture 3,828 3,137 d) electronic equipment 5,459 4,858 e) other 4,688 6,119 2. Rights of use acquired through leasing 61,449 64,631 a) land b) buildings 61,054 64,222 c) furniture d) electronic equipment e) other 395 409 TOTAL 151,461 156,354 of which: obtained through the realisation of collateral - - 9.2 Investment property: breakdown of assets measured at cost €/thousand 31/12/2025 31/12/2024 Carrying amount Fair value Carrying amount Fair value L1 L2 L3 L1 L2 L3 1. Own assets 52,514 - - 54,080 53,339 - - 58,200 a) land 29,332 - - 30,040 30,272 - - 32,487 b) buildings 23,182 - - 24,040 23,067 - - 25,713 2. Rights of use acquired through leasing - - - - - - - - a) land - - - - - - - - b) buildings - - - - - - - - TOTAL 52,514 - - 54,080 53,339 - - 58,200 of which: obtained through the realisation of collateral - - - - - - - - Key: NV: Notional value L1 = Level 1 L2 = Level 2 L3 = Level 3
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473 | Mediolanum Group - 2025 Annual Financial Report 9.6 Tangible assets for business use: changes during the year €/thousand Land Buildings Furniture Electronic equipment Other TOTAL A. Gross opening balances 56,895 224,390 34,541 47,769 18,991 382,586 A.1 Total net impairment losses (10,594) (128,860) (31,404) (42,911) (12,463) (226,232) A.2 Net opening balances 46,301 95,530 3,137 4,858 6,528 156,354 B. Increases: - 14,744 1,757 2,864 1,676 21,041 B.1 Purchases - 1,551 1,756 2,830 1,629 7,766 - of which business combinations - - - - - - B.2 Capitalised improvement costs - - - - - - B.3 Write-backs - - - - - - B.4 Increases in fair value recognised in - - - - - - a) shareholders’ equity - - - - - - b) income statement - - - - - - B.5 Foreign exchange gains - - - - - - B.6 Transfers from investment property - - X X X B.7 Other changes - 13,193 1 34 47 13,275 C. Decreases: - (19,484) (1,066) (2,263) (3,121) (25,934) C.1 Sales - (163) (7) (1) (171) - of which business combinations - - - - C.2 Depreciation & amortization - (15,151) (1,058) (2,198) (582) (18,989) C.3 Impairment losses recognised in - (2,667) - (60) - (2,727) a) shareholders’ equity - - - - - b) income statement - (2,667) - (60) - (2,727) C.4 Decreases in fair value recognised in - - - - - - a) shareholders’ equity - - - - - - b) income statement - - - - - - C.5 Foreign exchange losses - - - - - - C.6 Transfers to: - - - - - - a) tangible assets held for investment purposes - - X X X - b) non-current assets and disposal groups - - - - - - C.7 Other changes - (1,503) (1) (4) (2,539) (4,047) D. Net closing balances 46,301 90,790 3,828 5,459 5,083 151,461 D.1 Total net impairment losses (10,594) (146,841) (32,469) (45,170) (13,045) (248,119) D.2 Gross closing balances 56,895 237,631 36,297 50,629 18,128 399,580 E. Valuation at cost - - - - - -
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474 | Mediolanum Group - 2025 Annual Financial Report 9.7 Tangible assets held for investment purposes: changes during the year €/thousand Land Buildings A. Opening balances 30,272 23,067 B. Increases - 1,013 B.1 Purchases - - - of which business combinations - - B.2 Capitalised improvement costs - - B.3 Increases in fair value - - B.4 Write-backs - - B.5 Foreign exchange gains - - B.6 Transfers from property for business use - - B.7 Other changes - 1,013 C. Decreases (940) (898) C.1 Sales (820) (156) - of which business combinations - - C.2 Depreciation & amortization - (690) C.3 Decreases in fair value - - C.4 Impairment losses (120) (52) C.5 Foreign exchange losses - - C.6 Transfers to: - - a) properties for business use - - b) non-current assets and disposal groups - - C.7 Other changes - - D. Closing balances 29,332 23,182 E. Measurement at fair value - -
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475 | Mediolanum Group - 2025 Annual Financial Report Section 10 - Intangible assets - Item 100 10.1 Intangible assets: breakdown by type of asset €/thousand 31/12/2025 31/12/2024 Definite life Indefinite life Definite life Indefinite life A.1 Goodwill X 125,625 X 125,625 A.1.1 attributable to the group X 125,625 X 125,625 A.1.2 attributable to minority interests X - X - A.2 Other intangible assets 95,253 - 87,289 - of which: software 94,899 - 86,946 - A.2.1 Assets measured at cost: 95,253 - 87,289 - a) Intangible assets generated internally - - - - b) Other assets 95,253 - 87,289 - A.2.2 Assets measured at fair value: - - - - a) Intangible assets generated internally - - - - b) Other assets - - - - TOTAL 95,253 125,625 87,289 125,625
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476 | Mediolanum Group - 2025 Annual Financial Report 10.2 Intangible assets: changes during the year €/thousand Goodwill Other intangible assets: generated internally Other intangible assets: other TOTAL DEF INDEF DEF INDEF A. Opening balances 125,625 - - 148,583 - 274,208 A.1 Total net impairment losses - - - (61,294) - (61,294) A.2 Net opening balances 125,625 - - 87,289 - 212,914 B. Increases - - - 37,667 - 37,667 B.1 Purchases - - - 35,713 - 35,713 - of which business combinations - - - - - - B.2 Increases in internal intangible assets X - - - - - B.3 Write-backs X - - - - - B.4 Increases in fair value - - - - - - - in shareholders’ equity X - - - - - - in the income statement X - - - - - B.5 Foreign exchange gains - - - - - - B.6 Other changes - - - 1,954 - 1,954 C. Decreases - - - (29,703) - (29,703) C.1 Sales - - - - - - - of which business combinations - - - - - - C.2 Value adjustments - - - (29,703) - (29,703) - Depreciation & amortization X - - (29,695) - (29,695) - Write-downs - - - (8) - (8) + shareholders’ equity X - - - - - + income statement - - - (8) - (8) C.3 Decreases in fair value: - - - - - - - in shareholders’ equity X - - - - - - in the income statement X - - - - - C.4 Transfers to non-current assets held for sale - - - - - - C.5 Foreign exchange losses - - - - - - C.6 Other changes - - - - - - D. Net closing balances 125,625 - - 95,253 - 220,878 D.1 Total net value adjustments - - - (90,997) - (90,997) E. Gross closing balances 125,625 - - 186,250 - 311,875 F. Valuation at cost - - - - - -
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477 | Mediolanum Group - 2025 Annual Financial Report In accordance with IAS 36 and taking into account the recommendations of the joint Bank of Italy/Consob/ISVAP document of 3 March 2010, the reporting on the impairment testing performed on the Cash Generating Units (CGUs) in place at 31 December 2025 is provided below. The impairment process aims to verify that the carrying amount of the CGUs does not exceed the recoverable amount, i.e. the greater of the value in use and the possible sale price on the market (fair value net of selling costs or exchange value) of the CGUs. In order to carry out the impairment testing on goodwill, the directors of Banca Mediolanum were assisted by a company with specific experience in company valuations (the independent expert). The impairment testing was conducted on the basis of the methods and assumptions described below.
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478 | Mediolanum Group - 2025 Annual Financial Report 10.3 Other information Definition of the CGUS and allocation of goodwill At 31 December 2025, total goodwill was €125.6 million (31.12.2024: €125.6 million). Of this amount, €102.8 million was allocated to the Spain CGU and €22.7 million to the Italy CGU. In accordance with the business reporting system adopted by the Group and as in previous years, the CGUs are identified on the basis of the geographical area in question. Impairment testing was therefore performed taking the following CGUs into account: €/m Description Allocated goodwill* Spain CGU Banco Mediolanum S.A. 102.8 Italy CGU Gamax Management AG - Italy Division 22.7 * The values shown are pre-impairment testing Valuation methods As in previous years, the recoverable amount of the CGUs has been determined, unless otherwise indicated, by reference to their value in use. For the determination of value in use, IAS 36 provides for the possibility of using the financial method known as the Discounted Cash Flow (DCF) method. This method identifies the value in use of a CGU, or company, by estimating the future (operational) cash flows it generates, discounted to reflect the explicit time frame over which it is assumed that these will be achieved. In operating practice, when credit companies are valued, the Free Cash Flow to Equity (FCFE) approach, known as the Dividend Discount Model (DDM) in the Excess Capital version, is used. This determines the value of a company on the basis of future cash flows that it will be able to distribute to its shareholders, without affecting the assets necessary to sustain expected development and in accordance with the capital regulations imposed by the supervisory authority, discounted at a rate that expresses the specific risk. It should also be noted that although the phrase “Dividend Discount Model” contains the word “dividend”, the cash flows considered by the model are not the dividends that are expected to be distributed to shareholders, but the cash flows that a shareholder could potentially benefit from within the limits of the capital resources required by company operations. Spain CGU The recoverable value of Banco Mediolanum was estimated considering the value in use obtained from the application of the Excess Capital version of the Dividend Discount Model valuation methodology, in accordance with the prevailing principles, on the basis of the 2026-2030 industrial plan approved by the directors of Banco Mediolanum and Banca Mediolanum S.p.A in December 2025. The approved plan was developed on the basis of reasonable and consistent assumptions, which constitute the best estimate currently available to management of Banco Mediolanum’s future economic performance. In particular, the objective of developing Banca Mediolanum’s typical business model in Spain has been confirmed, based on the experience and track record of the management of the Mediolanum Group, with sustained development of the sales network and a consequent increase in net funding and assets under management. The plan incorporates an update of the most recent expectations concerning the trend in interest rates in the forecasting period, the expected evolution of funding based on volumes and the sales network in place at 31
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479 | Mediolanum Group - 2025 Annual Financial Report December 2025 and the forecast of the profitability of assets under management. The main figures and parameters considered when determining the recoverable value of the equity investment are described below: expected cash flows from the latest approved plan and the most recent projections; growth in the Family Banker sales network, from 1,650 to 2,000; an increase in assets under administration at an average annual rate of 13.4%; the discount rate for future cash flows (Ke) is estimated at 12.39% based on the Capital Asset Pricing Model and considering the following parameters: o a risk-free rate of 3.22%, based on the average historical half-yearly return on 10-year bonds issued by the Spanish government; o the beta coefficient of 1.20, which indicates the risk level of a specific equity with respect to the equity market as a whole, estimated on the basis of the average value of a sample of companies operating in the Spanish banking sector; o a market premium, i.e. the difference in the return required by investors for an investment in equity securities compared with a risk-free investment, quantified at 6%, in line with the most common professional practice; o a specific risk premium, estimated conservatively at 2.0% to take into account the volatility underlying the achievement of the plan. Banco Mediolanum’s value at the end of the explicit planning horizon has been estimated on the basis of the dividend deemed sustainable beyond that period, taking into account expected results and target regulatory constraints, and assuming a long-term growth rate of 2.0%, in line with long-term inflation expectations. Particularly stressed sensitivity analyses were carried out, which concerned, separately: the discount rate; the long-term growth rate; net profitability. Sensitivity analysis: A sensitivity analysis was carried out on the values obtained on changes to: the cost of equity capital (+/- 0.25%) – there was a change to value in use of around +/- 2%; the reduction to zero of the long-term growth rate – 2% there was a change in the value in use of around -8%; the achievement of the economic objectives contained in the plan – 5% net income entails a reduction of approximately 5% in the recoverable amount, while a – 10% net income implies a reduction of approximately 11% of the recoverable amount. In light of the analyses that was conducted, the Directors did not find any evidence of impairment.
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480 | Mediolanum Group - 2025 Annual Financial Report Italy CGU The goodwill allocated to the CGU is €22.7 million. The recoverable amount of the CGU has been assumed to be greater than its carrying amount. A comparison of Banca Mediolanum S.p.A.’s market capitalisation (€14,392 million as at 31 December 2025) with its equity or tangible equity reveals an implied multiple of 3.2x and 3.4x respectively (balance sheet figures as at 30 September 2025). There is therefore no evidence to suggest that the goodwill allocated to the Italian CGU is impaired. In conclusion, the higher market capitalisation than shareholders’ equity led the Directors to conclude that there was no evidence of impairment at either the individual CGU or the group level. Section 11 – Tax assets and tax liabilities – Item 110 of assets and Item 60 of liabilities 11.1 Deferred tax assets: breakdown €/thousand 31/12/2025 31/12/2024 Balancing item in the income statement 112,974 94,716 Balancing item in shareholders’ equity 74,304 75,189 TOTAL 187,278 169,905 11.2 Deferred tax liabilities: breakdown €/thousand 31/12/2025 31/12/2024 Balancing item in the income statement 36,982 42,879 Balancing item in shareholders’ equity 52,542 60,957 TOTAL 89,524 103,836
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481 | Mediolanum Group - 2025 Annual Financial Report 11.3 Changes in prepaid taxes (balancing item of the income statement) €/thousand 31/12/2025 31/12/2024 1. Initial amount 94,716 91,887 2. Increases 40,058 29,955 2.1 Prepaid taxes recognised during the year 40,058 29,955 a) relating to previous years - - b) due to the change in accounting policies - - c) write-backs - - d) other 40,058 29,955 2.2 New taxes or increases in tax rates - - 2.3 Other increases - - 3. Decreases (21,800) (27,126) 3.1 Prepaid taxes cancelled during the year (21,800) (27,126) a) reversals - (5,197) b) write-downs due to non-recoverability - - c) due to the change in accounting policies - - d) other (21,800) (21,929) 3.2 Reductions in tax rates - - 3.3 Other decreases: - - a) conversion into tax credits pursuant to Law 214/2011 - - b) other - - 4. Final amount 112,974 94,716
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482 | Mediolanum Group - 2025 Annual Financial Report 11.4 Changes in prepaid taxes pursuant to Law 214/2011 €/thousand 31/12/2025 31/12/2024 1. Initial amount 1,397 2,603 2. Increases - - 3. Decreases - (1,206) 3.1 Reversals - (1,206) 3.2 Conversion into tax credits - - a) deriving from operating losses - - b) deriving from tax losses - - 3.3 Other decreases - - 4. Final amount 1,397 1,397 11.5 Changes in deferred taxes (balancing item of the income statement) €/thousand 31/12/2025 31/12/2024 1. Initial amount 42,879 31,585 2. Increases 19,979 27,008 2.1 Deferred taxes recognised in the year 19,260 24,590 a) relating to previous years - - b) due to the change in accounting policies - - c) other 19,260 24,590 2.2 New taxes or increases in tax rates - - 2.3 Other increases 719 2,418 3. Decreases (25,876) (15,714) 3.1 Deferred taxes cancelled during the year (25,296) (14,625) a) reversals - - b) due to the change in accounting policies - - c) other (25,296) (14,625) 3.2 Reductions in tax rates - - 3.3 Other decreases (580) (1,089) 4. Final amount 36,982 42,879
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483 | Mediolanum Group - 2025 Annual Financial Report 11.6 Changes in prepaid taxes (balancing item of shareholders’ equity) €/thousand 31/12/2025 31/12/2024 1. Initial amount 75,189 69,919 2. Increases 8 5,675 2.1 Prepaid taxes recognised during the year 8 5,675 a) relating to previous years - - b) due to the change in accounting policies - - c) other 8 5,675 2.2 New taxes or increases in tax rates - - 2.3 Other increases - - 3. Decreases (893) (405) 3.1 Prepaid taxes cancelled during the year (800) (253) a) reversals - - b) write-downs due to non-recoverability - - c) due to the change in accounting policies - - d) other (800) (253) 3.2 Reductions in tax rates - - 3.3 Other decreases (93) (152) 4. Final amount 74,304 75,189 11.7 Changes in deferred taxes (balancing item of shareholders’ equity) €/thousand 31/12/2025 31/12/2024 1. Initial amount 60,957 48,738 2. Increases 15,630 12,500 2.1 Deferred taxes recognised in the year 15,630 12,500 a) relating to previous years - - b) due to the change in accounting policies - - c) other 15,630 12,500 2.2 New taxes or increases in tax rates - - 2.3 Other increases - - 3. Decreases (24,045) (281) 3.1 Deferred taxes cancelled during the year (20,997) (281) a) reversals - - b) due to the change in accounting policies - - c) other (20,997) (281) 3.2 Reductions in tax rates - - 3.3 Other decreases (3,048) - 4. Final amount 52,542 60,957
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484 | Mediolanum Group - 2025 Annual Financial Report Tax dispute With reference to the Mutual Agreement Procedure pursuant to Convention No. 90/436/EEC of 23 July 1990 on the elimination of double taxation in connection with the adjustment of profits of associated enterprises, and Article 24 of the Convention between Italy and Ireland for the avoidance of double taxation and the prevention of income tax evasion, already referred to in the 2024 Consolidated Annual Financial Report and in the previous periodic report, we report as follows. Following the closure, in 2024, of the 2017 and 2018 tax years by means of a tax assessment for Banca Mediolanum S.p.A. and Mediolanum Vita S.p.A., during 2025 the Companies began a negotiation with the Italian Revenue Agency in relation to subsequent tax periods, taking into account the imminent expiry dates for 2019 and the continuation of mutual agreement procedures (BAPA/MAP) relating to the 2019-2023 periods. On July 2025, Banca Mediolanum S.p.A., Mediolanum Vita S.p.A. and the Italian Revenue Agency signed a settlement agreement for the 2019-2022 tax periods, based on the same criteria already adopted in the agreements concluded in April 2024 and December 2024, which in turn were based on the results of the mutual agreement procedures between the competent Italian and Irish authorities. This agreement provides, also for the periods 2019-2022: a retrocession rate on management fees to Banca Mediolanum S.p.A. and Mediolanum Vita S.p.A. of 59.65%; a retrocession rate on performance fees to Banca Mediolanum S.p.A. of 7.70%, without prejudice to the non- recognition of the retrocession of performance fees for Mediolanum Vita S.p.A. Following the signing of the above agreement, on 7 August 2025, Banca Mediolanum S.p.A. and Mediolanum Vita S.p.A. submitted an application for a mutual agreement procedure to the competent Italian and Irish authorities, pursuant to EU tax dispute resolution legislation (Directive (EU) 2017/1852), in order to eliminate the double taxation arising from the adjustments agreed for the 2019-2022 tax periods. It should also be noted that on 22 December 2025, the competent Irish authority informed the companies concerned of the outcome of the mutual agreement procedures relating to intra-group transactions between the Irish entity and Mediolanum Vita S.p.A. for the tax periods 2010-2017. The agreement reached by the competent Italian and Irish authorities provides for the recognition, for these periods, of an arm’s length retrocession rate on of management fees of 59.65%, in line with the agreements already concluded and therefore of the accrual of the related tax credit by the Irish Group company. In light of the developments described and on the basis of the information currently available, the Group has updated its estimates, without recognising any further significant economic effects beyond those recorded in previous years.
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485 | Mediolanum Group - 2025 Annual Financial Report Section 12 – Non-current assets and disposal groups Associated liabilities – Item 120 of Assets and item 70 of Liabilities 12.1 Non-current assets and disposal groups: breakdown by type of asset €/thousand 31/12/2025 31/12/2024 A. Assets held for sale A.1 Financial assets - - A.2 Equity investments - - A.3 Tangible assets - 823 of which: obtained through the realisation of collateral - - A.4 Intangible assets - - A.5 Other non-current assets - - Total A - 823 of which measured at cost - - of which measured at fair value Level 1 - - of which measured at fair value Level 2 - - of which measured at fair value Level 3 - 823 B. Discontinued operations B.1 Financial assets measured at fair value through profit or loss - - - Financial assets held for trading - - - Financial assets designated at fair value - - - Other financial assets mandatorily measured at fair value - - B.2 Financial assets measured at fair value through other comprehensive income - - B.3 Financial assets measured at amortised cost - - B.4 Equity investments - - B.5 Tangible assets - - of which: obtained through the realisation of collateral - - B.6 Intangible assets - - B.7 Other assets - - Total B - - of which measured at cost - - of which measured at fair value Level 1 - - of which measured at fair value Level 2 - - of which measured at fair value Level 3 - - C. Liabilities associated with assets held for sale C.1 Payables - - C.2 Securities - - C.3 Other liabilities - - Total C - - of which measured at cost - - of which measured at fair value Level 1 - - of which measured at fair value Level 2 - - of which measured at fair value Level 3 - - D. Liabilities associated with discontinued operations D.1 Financial liabilities measured at amortised cost - - D.2 Financial liabilities held for trading - - D.3 Financial liabilities designated at fair value - - D.4 Provisions - - D.5 Other liabilities - - Total D - - of which measured at cost - - of which measured at fair value Level 1 - - of which measured at fair value Level 2 - - of which measured at fair value Level 3 - -
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486 | Mediolanum Group - 2025 Annual Financial Report Section 13 – Other Assets – Item 130 13.1 Other Assets breakdown €/thousand 31/12/2025 31/12/2024 Receivables for commission income 2,260 4,236 Receivables from the tax authorities 761,761 872,217 Receivables from financial advisors 5,699 5,360 Advances to suppliers and professionals 12,953 15,631 Security deposits 47,946 23,419 Receivables from employees 274 248 Other receivables 352,221 347,985 Assets for transit items 97,712 99,471 Accrued income 24,126 10,471 Prepaid expenses 33,035 35,828 Other sundry assets 26,044 25,091 TOTAL 1,364,031 1,439,957 The Item Other assets amounted to €1,364.0 million, a decrease of - €75.9 million compared to the previous year. The reduction was mainly due to lower tax receivables; in particular, ecobonus receivables decreased, partly offset by higher receivables for virtual stamp duty, higher advances on capital gains and higher advances for withholding taxes on capital income. In line with the provisions of Joint Document No. 10 between the Bank of Italy, Consob and IVASS, this item includes the receivable to be recovered from policyholders in respect of the stamp duty calculated on the portfolio in existence at 1 January 2025 (known as Stock 2024) and already paid to the tax authorities in June 2025. This amount, also considering the recoveries for the year, amounted to €59.3 million and was recognised net of the discounting effect of €13.5 million thus reaching a balance of €45.8 million.
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487 | Mediolanum Group - 2025 Annual Financial Report SECTION 1 – FINANCIAL LIABILITIES MEASURED AT AMORTISED COST – ITEM 10 1.1 Financial liabilities measured at amortised cost: breakdown of payables to banks by type €/thousand 31/12/2025 31/12/2024 CA Fair Value CA Fair Value L1 L2 L3 L1 L2 L3 1. Payables to central banks - X X X - X X X 2. Payables to banks 630,185 X X X 717,433 X X X 2.1 Current accounts and demand deposits 215 X X X 717 X X X 2.2 Term deposits - X X X - X X X 2.3 Loans 627,547 X X X 713,157 X X X 2.3.1 Repurchase agreements 627,547 X X X 713,157 X X X 2.3.2 Other - X X X - X X X 2.4 Payables for commitments to repurchase own shares - X X X - X X X 2.5 Lease liabilities - X X X 784 X X X 2.6 Other payables 2,423 X X X 2,775 X X X TOTAL 630,185 - - 630,185 717,433 - - 717,433 Key: CA = Carrying amount L1 = Level 1 L2 = Level 2 L3 = Level 3 Payables to banks amounted to €630.2 million (31/12/2024: €717.4 million). The change is mainly due to the reduction in repurchase agreements payable (-€85.6 million compared with 31 December 2024).
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488 | Mediolanum Group - 2025 Annual Financial Report 1.2 Financial liabilities measured at amortised cost: breakdown of payables to customers by type €/thousand 31/12/2025 31/12/2024 CA Fair Value CA Fair Value L1 L2 L3 L1 L2 L3 1. Current accounts and demand deposits 27,421,025 X X X 24,892,832 X X X 2. Deposits at notice 2,313,844 X X X 3,445,935 X X X 3. Loans 2,009,733 X X X 5,837,342 X X X 3.1 Repurchase agreements 2,001,452 X X X 5,823,922 X X X 3.2 Other 8,281 X X X 13,420 X X X 4. Payables for commitments to repurchase own shares - X X X - X X X 5. Lease liabilities 66,373 X X X 69,044 X X X 6. Other payables 322,238 X X X 279,281 X X X TOTAL 32,133,213 - - 32,133,213 34,524,434 - - 34,524,434 Key: CA = Carrying amount L1 = Level 1 L2 = Level 2 L3 = Level 3 The balance of amounts due to customers amounted to €32,133.2 million, down by -€2,391.2 million compared to 31 December 2024 (31.12.2024: €34,524.4 million); this change was mainly due to the decrease in repurchase agreements payable (- €3,822.5 million compared with the comparative period) and the reduction in term deposits (-€1,132.1 million compared with the comparative period), which was only partly offset by the growth in current accounts and demand deposits (+€2,528.2 million compared with the comparative period). 1.3 Financial liabilities measured at amortised cost: breakdown of securities in issue by type €/thousand 31/12/2025 31/12/2024 CA Fair Value CA Fair Value L1 L2 L3 L1 L2 L3 A. Securities 1. Bonds 314,125 314,597 - - 313,629 306,378 - - 1.1 structured - - - - - - - - 1.2 other 314,125 314,597 - - 313,629 306,378 - - 2. Other securities - - - - - - - - 2.1 structured - - - - - - - - 2.2 other - - - - - - - - TOTAL 314,125 314,597 - - 313,629 306,378 - - Key: CA = Carrying amount L1=Level 1 L2=Level 2 L3=Level 3
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489 | Mediolanum Group - 2025 Annual Financial Report The amount recognised in the item at 31 December 2025 refers to the Green Senior Preferred Bond issued in November 2022 for a nominal amount of €300 million. It was awarded a “BBB” rating by Fitch and S&p. The Bond provided for an early coupon at a fixed rate of 5.035% and an early redemption option on 22/01/2026 without repricing mechanisms. Due to the characteristics of the issue, the bond was classified among financial liabilities measured at amortised cost and has a carrying amount of €314.1 million. As reported in the section on subsequent events in the Report on Operations, in January the Bank called up the bond in advance and issued a new Senior Preferred Bond amounting to €500 million, maturing in 5 years (January 2031, callable as of January 2030), with a coupon of 3.125% and an expected rating of BBB+, in line with the rating that the issuer obtained from S&P Global Ratings For further details, please see the information contained in the report on operations. 1.6 Lease liabilities €/thousand 31.12.2025 Breakdown of the contractual flows of lease agreements based on contractual term Payables to banks Payables to customers Up to 1 year - 3,932 1 to 5 years - 26,460 Over 5 years - 35,981 Overall total - 66,373 For more information, see Section M – Leasing.
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490 | Mediolanum Group - 2025 Annual Financial Report SECTION 2 – FINANCIAL LIABILITIES HELD FOR TRADING – ITEM 20 2.1 Financial liabilities held for trading: breakdown by type €/thousand 31/12/2025 31/12/2024 NV Fair Value Fair Value* NV Fair Value Fair Value* L1 L2 L3 L1 L2 L3 A. On-balance sheet liabilities 1. Payables to banks - - - - - - - - - - 2. Payables to customers - - - - - - - - - - 3. Debt securities - - - - - - - - - - 3.1 Bonds - - - - - - - - - - 3.1.1 Structured - - - - X - - - - X 3.1.2 Other bonds - - - - X - - - - X 3.2 Other securities - - - - - - - - - - 3.2.1 Structured - - - - X - - - - X 3.2.2 Other - - - - X - - - - X TOTAL (A) - - - - - - - - - - B. Derivative instruments 1. Financial derivatives - - - - - - - 3 - - 1.1 For trading X - - - X X - 3 - X 1.2 Associated with the fair value option X - - - X X - - - X 1.3 Other X - - - X X - - - X 2. Credit derivatives - - - - - - - - - - 2.1 For trading X - - - X X - - - X 2.2 Associated with the fair value option X - - - X X - - - X 2.3 Other X - - - X X - - - X TOTAL (B) X - - - X X - 3 - X TOTAL (A+B) X - - - X X - 3 - X Key: NV= Nominal or notional value L1=Level 1 L2=Level 2 L3=Level 3 Fair value*= Fair value calculated excluding changes in value due to a change in the issuer’s credit rating since the issue date
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491 | Mediolanum Group - 2025 Annual Financial Report SECTION 3 – FINANCIAL LIABILITIES DESIGNATED AT FAIR VALUE – ITEM 30 3.1 Financial liabilities designated at fair value: breakdown by type €/thousand 31/12/2025 31/12/2024 NV Fair value Fair value* NV Fair value Fair value* L1 L2 L3 L1 L2 L3 1. Payables to banks - - - - - - - - - - 1.1 Structured - - - - X - - - - X 1.2 Other - - - - X - - - - X of which: - - - - - - - - - - - commitments to disburse funds - X X X X - X X X X - financial guarantees given - X X X X - X X X X 2. Payables to customers 21,808,900 21,799,645 9,255 - 21,808,900 18,740,436 18,732,071 8,365 - 18,740,436 2.1 Structured - - - - X - - - - X 2.2 Other 21,808,900 21,799,645 9,255 - X 18,740,436 18,732,071 8,365 - X of which: - - - - - - - - - - - commitments to disburse funds - X X X X - X X X X - financial guarantees given - X X X X - X X X X 3. Debt securities - - - - - - - - - - 3.1 Structured - - - - X - - - - X 3.2 Other - - - - X - - - - X TOTAL 21,808,900 21,799,645 9,255 - 21,808,900 18,740,436 18,732,071 8,365 - 18,740,436 Key: NV= Nominal value L1=Level 1 L2=Level 2 L3=Level 3 Fair value*= Fair value calculated excluding changes in value due to a change in the issuer’s credit rating since the issue date The item amounts to €21,808.9 thousand (31 December 2024: €18,740.4 thousand) and includes financial liabilities associated with unit-linked and index-linked investment contracts that do not present a significant insurance risk and therefore measured in accordance with IFRS 9.
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492 | Mediolanum Group - 2025 Annual Financial Report SECTION 4 – HEDGING DERIVATIVES – ITEM 40 Nothing to report SECTION 6 – TAX LIABILITIES– ITEM 60 For tables containing the quantitative data, see Section 11 of the assets section. SECTION 8 – OTHER LIABILITIES’ – ITEM 80 €/thousand 31/12/2025 31/12/2024 Provision for agency termination indemnities 9,870 8,552 Payables to promoters, producers and mediators 79,651 64,228 Trade payables 113,494 114,883 Payables to the tax authorities 334,867 435,736 Social security contributions 11,508 10,656 Payables to employees 50,204 46,308 Payables to professionals, directors and statutory auditors 5,825 5,777 Security deposits 42 42 Transit items 281,522 262,300 Deferred income 961 1,156 Accrued expenses 1,278 3,185 Other sundry liabilities 373,391 302,970 Escrow accounts 925 5,868 Tax payables from policyholders 1,525 1,424 TOTAL 1,265,063 1,263,085 Payables for transit items include direct debit payment instructions, bank transfers arranged by customers and settled on the Interbank Network in the early days of 2026 and other items in processing that are regularly closed during the early days of the new year. Trade payables refer to goods and services received and not yet settled at the reporting date. Payables to promoters, producers and mediators mainly include commissions to be paid to the network. Other sundry liabilities primarily consist of taxes to be paid on behalf of customers through F24 tax forms.
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493 | Mediolanum Group - 2025 Annual Financial Report Disclosure in terms of “Tax on excess profits” Law No. 199 of 30 December 2025 (“Budget Law 2026”) amended, with paragraph 68 of Article 1, Article 26 of Legislative Decree No. 104 of 10 August 2023, converted, with amendments, by Law No. 136 of 9 October 2023. In detail, the new regime introduced provides that, as of the financial year commencing after 1 January 2028, in the event of distribution of profits, including interim dividends, or reserves, regardless of the shareholders’ meeting resolution, it is assumed that as a priority the reserve referred to in paragraph 5-bis, i.e. the reserve established, at the time of approval of the financial statements for 2023, is distributed, using the option provided for by the rule as a means of meeting the obligation provided for as an alternative to payment of the extraordinary tax then introduced against the banks (the so-called “2023 Reserve”). Paragraph 69 of Article 1 of Budget Law 2026, on the other hand, introduced the provision whereby, until the current year ended 31 December 2028, the “2023 Reserve” may be subject to an extraordinary contribution to be applied to the said reserve regardless of “the nature of the items that contributed to its formation and the manner in which they were established”. Paragraph 70 below provides that the extraordinary contribution shall be determined at the rate of 27.5% of the reserve existing at the end of the current year as at 31 December 2025, or 33% of the reserve existing at the end of the following year. Paragraph 72 also provides, in the event of payment of the contribution, for the disapplication of the provisions of Article 26, paragraph 5-bis, last sentence, of Legislative Decree No. 104 of 10 August 2023 on the restriction on the non-distributability of the reserve. It should be noted that the reserve of this kind entered in the consolidated financial statements of Banca Mediolanum as at 31 December 2025 amounts to a total of €67.4 million. From a strictly accounting standpoint, following the in-depth analyses and analyses conducted at the banking system level, considering the specific features of the legislation in question, it was considered that the contra- entry for the liability relating to the extraordinary contribution, if recognised in the financial statements for the year ended 31 December 2025, should be identified in an equity item. In particular, in the absence of IASs/IFRSs directly applicable to this case, reference was made to the provisions of IAS 8 to define the accounting method to be used with reference to IAS 12 and in particular paragraph 61A, which requires that taxation be recorded in accordance with the criterion for recognising the reference item from which taxation originates. In this case, since the extraordinary contribution insists on a balance-sheet item, the accounting entry of the liability was identified in equity. With regard to the contribution, however, it should be noted that the 2026 Budget Law was approved on 30 December 2025 and, therefore, is deemed to have been “substantially enacted” at the end of the 2025 financial year. It follows that the liability arising from the extraordinary contribution was considered already existing in 2025 and, consequently, recognised in these consolidated financial statements for an amount of €18.5 million - determined by applying the rate of 27.5% to the amount of the 2023 Reserve - in the light of the decision taken by the administrative body to pay the contribution when settling taxes for 2025. The amount in question was recorded under ‘Other Liabilities’ as a contra-entry to ‘Other reserves’, leaving it to the shareholders’ meeting approving the 2025 financial statements to identify the equity reserve from which to effect the extraordinary contribution.
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494 | Mediolanum Group - 2025 Annual Financial Report SECTION 9 – EMPLOYEE TERMINATION BENEFITS– ITEM 90 9.1 Employee severance benefits: changes during the year €/thousand 31/12/2025 31/12/2024 A. Opening balances 12,228 11,876 B. Increases 13,318 12,729 B.1 Provision for the year 12,747 12,180 B.2 Other changes 571 549 - of which business combinations - - C. Decreases (13,678) (12,377) C.1 Settlement payments (380) (476) C.2 Other changes (13,298) (11,901) - of which business combinations - - D. Closing balances 11,868 12,228 TOTAL 11,868 12,228 9.2 Other information As described in “Part A – Accounting Policies”, as a result of the supplementary pension scheme reform, post- employment benefits are recognised under this balance sheet item, and for companies with an average of at least 50 employees during 2006, refer to the portion accrued until 31 December 2006 only. The provision therefore does not include portions which, as a result of the aforementioned reform, are paid to supplementary pension schemes or to the INPS treasury fund. Employee severance benefits accrued from 1 January 2007 are in fact a “defined contribution plan” and are recognised under personnel costs on the basis of the contributions due without the application of actuarial calculation methods. The main assumptions used for Banca Mediolanum were as follows: Mortality rate: table RG48; Inflation rate: 2%; Frequency of early severance pay: 3.7%; Turnover rate: 6%.
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495 | Mediolanum Group - 2025 Annual Financial Report SECTION 10 – PROVISIONS FOR RISKS AND CHARGES – ITEM 100 10.1 Provisions for risk and charges: breakdown €/thousand 31/12/2025 31/12/2024 1. Provisions for credit risk relating to commitments and financial guarantees given 999 454 2. Provisions on other commitments and guarantees given 514 476 3. Company pension funds 78 105 4. Other provisions for risk and charges 395,883 341,301 4.1 legal and tax disputes 16,264 13,937 4.2 staff costs - - 4.3 Other 379,619 327,364 TOTAL 397,474 342,336 10.2 Provisions for risk and charges: changes during the year €/thousand Provisions on other commitments and guarantees given Pension funds Other provisions for risk and charges TOTAL A. Opening balances 476 105 341,301 341,882 B. Increases 61 160 110,040 110,261 B.1 Provision for the year 61 160 98,081 98,302 B.2 Changes due to the passage of time - - 8,876 8,876 B.3 Changes due to changes in the discount rate - - 1,723 1,723 B.4 Other changes - - 1,360 1,360 - of which business combinations - - - - C. Decreases (23) (187) (55,458) (55,668) C.1 Utilisation during the year - (187) (30,168) (30,355) C.2 Changes due to changes in the discount rate - - (15) (15) C.3 Other changes (23) - (25,275) (25,298) - of which business combinations - - - - D. Closing balances 514 78 395,883 396,475 10.3 Provisions for credit risk relating to commitments and financial guarantees given €/thousand 31/12/2025 Stage 1 Stage 2 Stage 3 Impaired, acquired or originated Total Commitments to disburse funds 656 14 - - 670 Financial guarantees given 309 - 20 - 329 Total 965 14 20 - 999
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496 | Mediolanum Group - 2025 Annual Financial Report 10.6 Provisions for risk and charges: other provisions €/thousand Balance as of Allocations in the period Other changes Utilisations in the period Balance as of 31/12/2024 31/12/2025 Provision name: - legal disputes 13,937 6,677 (2,581) (1,769) 16,264 - other: Managers’ allowance 81,406 16,144 (2,345) (6,321) 88,884 Risk of misconduct by financial advisors 6,371 3,244 (1,034) (1,790) 6,791 Additional customers’ allowance 178,831 28,128 (978) (2,767) 203,214 Portfolio and structure allowance 31,432 29,181 (15,637) (3,455) 41,521 Sundry provisions 29,324 25,306 (1,355) (14,066) 39,209 TOTAL 341,301 108,680 (23,930) (30,168) 395,883 The above table shows the breakdown of, and changes in, the provisions in question. The provision for legal disputes mainly includes legal liabilities (litigation and pre-litigation) relating to the Company. The additional customers’ allowance comprises the accrued provision for financial advisors. This provision is determined on the basis of accrued fees, applying the statutory rates provided for, and is subject to statistical-actuarial assessments that take into account the achievement of and to pensionable as well as cases of anticipated early liquidation (e.g. disability or death), the rate of turn-over derived from historical trends and the discounting of flows on the basis of a rate consistent with the expected duration. The provision is estimated in accordance with IAS 37. In addition to the benefits due contractually under its own voluntary, unilateral and discretionary rules, the Bank recognises additional and bonus allowances for its financial advisors. These allowances, consisting of the manager advisors’ allowance and the portfolio and structure allowance, are described below. The manager advisor’s allowance is paid to agents providing assistance and coordination, whose compensation is based on specific commercial parameters and is granted upon the achievement of an old-age pension – provided that no competing activities have been performed in the two years following the end of the mandate – or in cases of total permanent disability or death and in the other circumstances as provided by the regulations. The Consultant Manager indemnity is paid within 3 years after termination of the agency mandate. The actuarial calculation, based on the estimate of the probability of pension payments of the manager advisors present at the end of the financial year, as well as the risk of death or total permanent disability, took into account the ratio of the length of service of the MA at the calculation date to the length of service at the date of occurrence of the events determining payment (so-called pro-rata application), with the application of a discount rate. The portfolio and structure allowance consists, depending on the case, of remuneration related to the value of the customer portfolio or the agent structure managed by a financial advisor. The regulations adopted govern the transfer between financial advisors of responsibility for managing the portfolios of bank customers or the support and assistance of a financial advisors’ structure. Transfers may take place during the relationship, due to a reduction in the customers or agents portfolio, or when financial advisors leave due to the termination of the agency relationship and are succeeded by another financial advisor. The Bank continues to play an active role in identifying the incoming financial advisor.
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497 | Mediolanum Group - 2025 Annual Financial Report At the time of transfer, the regulations provide for: payment to the transferring financial advisor - provided that he or she meets certain subjective requirements and does not perform competing activities in the next two years - of an allowance deriving from the valuation of the transferred portfolio or structure, according to predetermined criteria; the relative charging to the incoming financial advisor of an equivalent amount, equal to the value of the portfolio and/or structure acquired under management. The Bank liaises between the transferor and successor, paying the transferor directly and exercising its right of recourse in respect of the successor. In the course of the activity of the transferring agent, the compensation will be paid in a maximum of 60 equal monthly instalments in arrears from the time of transfer, will be recovered from the successor agent in the same period. In the event of termination of the relationship by the transferring agent, the payment of the indemnity will be made on the basis of the agent’s age, from the following two months until the final deadline provided by the regulations or within three years. Neither of these cash flows provides for the application of an interest rate in operations currently in progress. It is understood that if no successor is identified, no allowance is paid to the transferring advisor. The provision estimates the effect of the risk of non-collection/collection eligibility to which Banca Mediolanum is exposed for the portion of the receivable to be recovered from the incoming sponsor, as well as the effect of the relevant timing of occurrence and, where applicable, the effect of discounting flows in line with the expected duration of recognition. The provision for misconduct by financial advisors covers the risk of future liabilities for claims below the excess of the insurance policy taken out to cover losses suffered by customers as a result of misconduct on the part of the Bank’s financial advisors. The provision is estimated on the basis of updated historical trends and takes into account the situation of claims reported to the Bank at the reporting date. Item “Other provisions” mainly consists of provisions for early repayment of the subsidiary Prexta amounting to approximately €14.0 million, while €8.8 million relates to the provision for risks and charges recorded to cover the costs of disposing of the German subsidiary.
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498 | Mediolanum Group - 2025 Annual Financial Report Section 11 – INSURANCE LIABILITIES – Voce 110 This item includes “Insurance liabilities” determined on the basis of IFRS 17 and amounts to €28,455.3 million (31/12/2024: €25,804.0 million). In particular, it includes the “Liability for remaining coverage - LRC” line, which breaks down as follows: Present Value Future Cash Flows (PVFCF) i.e. all expected future cash flows associated with discounted insurance contracts adjusted for time value and risk; the contractual service margin (CSM), which represents the expected profit of the group of contracts released over the life of the contracts; the risk adjustment to take account of “non-financial” risks. The following table shows the changes in the Contractual Service Margin – CSM that occurred during the 2025 financial year. €/million Initial CSM 01/01/2025 2,638 Movements 693 Release (224) Final CSM 31/12/2025 3,107 The information provided below, in accordance with IFRS 17, paragraphs 98, 99, 101, 104 and 105, is provided by aggregation base. It should be noted that, in accordance with Annex 1 (Instructions) of ISVAP Regulation No. 7 and subsequent updates in the tables of direct business, the Group made use of the right to also display within Aggregation Base 1 – Insurance issued with direct participation (life segment), investment contracts issued with discretionary participation features (life segment). Aggregation Base 2 sets out the details of insurance contracts issued without direct participation elements from the Life segment, whilst Aggregation Base 4 sets out the details of insurance contracts issued without direct participation elements from the Non-Motor Non-Life segment. As already reported in the consolidated financial statements as at 31 December 2024, with regard to the amendments introduced to the stamp duty legislation, it should be noted that for insurance contracts measured in accordance with International Financial Reporting Standard (IFRS) 17, account has been taken of the expected outlay for the payment of the duty and its recovery from policyholders at the time of contract termination, in accordance with the contractual provisions and the technical assumptions already adopted for the purpose of projecting technical cash flows.
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499 | Mediolanum Group - 2025 Annual Financial Report Changes in the carrying amount of insurance issued - GMM or VFA - liability for remaining coverage and for claims incurred – Aggregation Base 1 Items/liabilities Liability for remaining coverage 31.12.2025 Liability for incurred claims Total Liability for remaining coverage 31.12.2024 Liability for incurred claims Total Net of loss Loss 31/12/2025 31/12/2025 Net of loss Loss 31/12/2024 31/12/2024 A. Initial carrying amount 1. Insurance contracts issued that constitute liabilities 25,370,411 81 77,920 25,448,412 21,999,930 234 72,348 22,072,512 2. insurance issued that are classified as assets - - - - - - - - 3. Net carrying amount at 1 January 25,370,411 81 77,920 25,448,412 21,999,930 234 72,348 22,072,512 B. Insurance revenues (335,186) (113) (335,299) (293,263) (2) - (293,265) C. Costs of insurance services 1. Incurred claims and other directly attributable costs - - 140,200 140,200 - - 130,441 130,441 2. Changes in liabilities for incurred claims - - 48 48 - - (428) (428) 3. Losses and related recoveries on onerous contracts - 448 - 448 - (149) - (149) 4. Amortisation of contract acquisition costs 28,719 - - 28,719 17,578 - - 17,578 5. Total 28,719 448 140,248 169,415 17,578 (149) 130,013 147,442 D. Result of insurance services (B+C) (306,467) 335 140,248 (165,884) (275,685) (151) 130,013 (145,823) E. Net financial costs/revenues 1. Related to insurance issued 1,111,195 - - 1,111,195 2,899,447 - - 2,899,447 1.1 Recognised in profit or loss 1,109,430 - - 1,109,430 2,879,997 - - 2,879,997 1.2 Recognised in other comprehensive income 1,765 - - 1,765 19,450 - - 19,450 2. Effects related to exchange rate fluctuations - - - - - - - - 3. Total 1,111,195 - - 1,111,195 2,899,447 - - 2,899,447 F. Investment components (2,059,214) (113) 2,059,327 - (2,173,591) (2) 2,173,593 - G. Total amount recognised in profit or loss and in comprehensive income (D+E+F) (1,254,486) 222 2,199,575 945,311 450,171 (153) 2,303,606 2,753,624 H. Other changes - - - - - - - - I. Cash movements 1. Premiums received 3,899,004 - - 3,899,004 2,970,595 - - 2,970,595 2. Payments related to the costs of acquiring contracts (56,490) - - (56,490) (50,285) - - (50,285) 3. Claims paid and other cash outflows - 71 (2,174,530) (2,174,459) - - (2,298,034) (2,298,034) 4. Other movements (10) - - (10) - - - - 5. Total 3,842,504 71 (2,174,530) 1,668,045 2,920,310 - (2,298,034) 622,275 L. Net carrying amount at 31 December (A.3+G+H+I.4) 27,958,429 374 102,965 28,061,768 25,370,411 81 77,920 25,448,411 M. Closing carrying amount 1. Insurance contracts issued that constitute liabilities 27,958,463 374 102,931 28,061,768 25,370,411 81 77,920 25,448,411 2. insurance issued that are classified as assets - - - - - - - - 3. Net carrying amount at 31 December 27,958,463 374 102,931 28,061,768 25,370,411 81 77,920 25,448,412 Key: Aggregation Base 1 = Insurance issued with direct participation features - Life segment Aggregation Base 2 = Insurance issued without direct participation features - Life segment Aggregation Base 3 = Insurance issued without direct participation features - Motor non-life segment Aggregation Base 4 = Insurance issued without direct participation features - Non-Motor non-life segment Aggregation Base 5 = Investment issued without discretionary participation features - Life segment
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500 | Mediolanum Group - 2025 Annual Financial Report Changes in the carrying amount of insurance issued - GMM or VFA - liability for remaining coverage and for claims incurred- Aggregation Base 2 Items/liabilities Liability for remaining coverage 31.12.2025 Liability for incurred claims Total Liability for remaining coverage 31.12.2024 Liability for incurred claims Total Net of loss Loss 31/12/2025 31/12/2025 Net of loss Loss 31/12/2024 31/12/2024 A. Initial carrying amount 1. Insurance contracts issued that constitute liabilities 109,587 - 8,893 118,480 103,692 - 6,060 109,752 2. insurance issued that are classified as assets - - - - - - - - 3. Net carrying amount at 1 January 109,587 - 8,893 118,480 103,692 - 6,060 109,752 B. Insurance revenues (40,919) - - (40,919) (36,777) - - (36,777) C. Costs of insurance services 1. Incurred claims and other directly attributable costs - - 15,848 15,848 - - 12,950 12,950 2. Changes in liabilities for incurred claims - - 902 902 - - 2,833 2,833 3. Losses and related recoveries on onerous contracts - - - - - - - - 4. Amortisation of contract acquisition costs 1,359 - - 1,359 701 - - 701 5. Total 1,359 - 16,750 18,109 701 - 15,783 16,484 D. Result of insurance services (B+C) (39,560) - 16,750 (22,810) (36,076) - 15,783 (20,293) E. Net financial costs/revenues 1. Related to insurance issued (284) - - (284) (1,169) - - (1,169) 1.1 Recognised in profit or loss 656 - 656 441 - - 441 1.2 Recognised in other comprehensive income (940) - - (940) (1,610) - - (1,610) 2. Effects related to exchange rate fluctuations - - - - - - - - 3. Total (284) - - (284) (1,169) - - (1,169) F. Investment components - - - - - - - - G. Total amount recognised in profit or loss and in comprehensive income (D+E+F) (39,844) - 16,750 (23,094) (37,245) - 15,783 (21,462) H. Other changes - - - - - - - - I. Cash movements 1. Premiums received 52,066 - - 52,066 47,342 - - 47,342 2. Payments related to the costs of acquiring contracts (4,996) - - (4,996) (4,202) - - (4,202) 3. Claims paid and other cash outflows - - (15,848) (15,848) - - (12,950) (12,950) 4. Other movements - - - - 5. Total 47,070 - (15,848) 31,222 43,140 - (12,950) 30,190 L. Net carrying amount at 31 December (A.3+G+H+I.4) 116,813 9,795 126,608 109,587 - 8,893 118,480 M. Closing carrying amount 1. Insurance contracts issued that constitute liabilities 116,813 9,795 126,608 109,587 - 8,893 118,480 2. insurance issued that are classified as assets - - - - - - - - 3. Net carrying amount at 31 December 116,813 9,795 126,608 109,587 - 8,893 118,480 Key: Aggregation Base 1 = Insurance issued with direct participation features - Life segment Aggregation Base 2 = Insurance issued without direct participation features - Life segment Aggregation Base 3 = Insurance issued without direct participation features - Motor non-life segment Aggregation Base 4 = Insurance issued without direct participation features - Non-Motor non-life segment Aggregation Base 5 = Investment issued without discretionary participation features - Life segment