Annual report
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Annual report 2025
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Foto forside: Eidsvatnet i Eidsdal, Møre og Romsdal Foto: Bondhusvatnet i Sunndal, Møre og Romsdal Table of contents Chapter 1 This is SpareBank 1 SMN 3 Chapter 2 Report of the Board of Directors 20 Sustainability auditor’s report 227 Chapter 3 Annual financial statement w/ notes 229 Statement in compliance with the STA section 5-5 367 Auditor’s report 368 Chapter 4 Attachments 371
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1 This is SpareBank 1 SMN Statement by the Group CEO 4 Important events in 2025 5 Key figures 6 We stand firm in a changing world 11 Board of Directors 14 Group Management 17
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4SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | STATEMENT BY THE GROUP CEO Statement by the Group CEO - Strong community-builder 2025 was marked by geopolitical turmoil, rising uncertainty and fierce competition. At the same time, SpareBank 1 SMN delivered very strong results, building on the robust foundation laid down over generations. At a time of market and societal change, we have remained true to our values and our aim of being a market leader and a driving force for growth and development in Central Norway. One of the year’s highlights was the opening of a new finance centre in Kristiansund. The city has long been a hub for business and community life in Nordmøre, as well as the largest population centre without a SpareBank 1 SMN presence. This step strengthens our representation in a region with great potential. Finance centres are a key aspect of our strategy of bringing banking, insurance, accounting and real estate brokerage under one roof. The centres ensure proximity to customers and showcase a comprehensive product and service portfolio that gives us a competitive advantage. The model is already producing results: it gives customers a single point of contact for everything they need and we can accompany them through all phases of their lives and businesses. During the course of the year, SpareBank 1 Markets – in which SpareBank 1 SMN is the largest owner – launched a new partnership with its longstanding Swedish commercial partner Swedbank, targeting the Swedish market and strengthening its Nordic presence under the name SB1 Markets. Collaborations and special-purpose product and development companies are central to SpareBank 1 SMN’s strategy. In 2025, Eika was integrated into Fremtind, while Vipps launched tapping payments worldwide. Here in Central Norway, EiendomsMegler 1 Midt-Norge has acquired Norion Næringsmegling and merged the business with its own. Our ambition is to take a leading position in commercial real estate brokerage in the region while also making our mark nationally. The acquisition boosts our expertise and capacity, and strengthens our comprehensive offering to corporate clients. Throughout 2025, we continued to invest in both physical presence and digital solutions. Our FYGITAL model, which combines the best of the physical and digital worlds, has been further strengthened. We have adopted new digital tools and artificial intelligence to improve the customer experience and improve efficiency. We see these as the first steps in a rapid, targeted rollout of AI-powered technologies. Profitable growth is a long-standing priority for us, and we have therefore combined various growth initiatives with increased coordination of our different business areas. The resulting synergies are now supporting growth and profitability throughout Central Norway, and we are winning market share in high-priority sectors in Oslo. Our breadth makes us the least interest rate-dependent bank in Norway. At the same time, we remain committed to our societal mission. Our ownership model again channelled substantial funds into socially beneficial causes in 2025, with some NOK 336.3 million being allocated directly to such projects in Central Norway. We are proud to be administering this legacy, and take our responsibility to promote development and value creation in the region very seriously. One of the main societal projects in 2025 focused on public health and public celebrations in connection with the World Ski Championships. We contributed around NOK 35 million in support and activities that directly benefited teams and clubs before and during the event. This project was, and is, an important contribution to better public health, and will continue to create value for local communities throughout Central Norway for a long time to come. In the same spirit, we prioritised support for teams and organisations promoting equal opportunities and activities to strengthen public health throughout 2025. Equal opportunities are also being promoted through a joint project with Rosenborg BK Football Club focusing on development opportunities for children and young people, as well as on highlighting women’s initiatives and women’s health. The results achieved in 2025 demonstrate the strength of the Group. A pre-tax profit of NOK 5,449 million and a CET 1 capital ratio of 16.8 per cent underline SpareBank 1 SMN’s strong position, while a return on equity of 14.8 per cent represents yet another good result for our owners. The Board of Directors has proposed a dividend of NOK 13.50 per equity certificate, a level that reflects both the results achieved and our objective of giving back to our owners. As we enter 2026, we can be confident that our broad-based approach and in-depth knowledge of Central Norway – combined with other drivers like the finance centre model – will power further growth and development. We will maintain client proximity, develop new services and support value creation throughout Central Norway as we continue to build our region with our customers, partners and local communities. Jan-Frode Janson Group CEO SpareBank 1 SMN
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5SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | IMPORTANT EVENTS Important events in 2025 First quarter • Post-tax profit of NOK 1,004 million and a return on equity of 14.0 per cent. • SpareBank 1 and Swedbank enter into a partnership to create a leading Nor dic investment bank. Swedbank’s Corporate Finance and High Yield operations are incorporated into SpareBank 1 Markets, and SpareBank 1 Markets expands its equity analysis and securities brokerage operations to include the Swedish market. • EiendomsMegler 1 Midt-Norge takes over Norion Eiendomsmegling as of 1 April 2025, aiming to be the mark et leader in sales, rentals and valuations in Central Norway. • As the main sponsor of the World Ski Championships 2025, SpareBank 1 SMN creates experiences r elated to public health and equal opportunities. During the World Championships, from 26 February to 9 March, various events and initiatives are held in Trondheim, attracting over 80,000 participants. • Executive Director, Financial Crime and Business Support is appointed. Johan-P etter Winsnes, who was acting director, takes up the position permanently on 1 April 2025. Second quarter • Post-tax profit of NOK 1,131 million and a return on equity of 16.2 per cent. • The financial markets experience volatility as a result of US tariff s imposed on 2 April. However, increased uncertainty has little impact on the investment plans of companies in Central Norway for 2025 and 2026. • Inflation approaches Norges Bank’s target of 2 per cent, and tighter monetar y policy is considered less necessary. Norges Bank cuts the base rate from 4.50 per cent to 4.25 per cent in June 2025. • On 3 June 2025, the Court of Appeal delivers its judgment in the case between Spar eBank 1 Utvikling DA and Tietoevry Norway AS. The judgment results in an adjustment of the fixed price paid by the banks in the SpareBank 1 Alliance, amounting to approximately NOK 100 million per year. • A new Capital Requirements Regulation (CRR3) is implemented in Norw egian law as of 1 April 2025, entailing a change in how the floor for risk-weighted assets is calculated. The floor will be phased in gradually over a five-year period, rising from 50 per cent in 2025 to 72.5 per cent in 2030. The Ministry of Finance decides to increase the risk- weight floor for residential mortgages from 20 per cent to 25 per cent, effective as of 1 July 2025. Third quarter • Post-tax profit of NOK 1,171 million and a return on equity of 15.9 per cent. • Norges Bank cuts the base rate from 4.25 per cent to 4.00 per cent. • Following the first quarter’s partner ship agreement between SpareBank 1 Markets and Swedbank (now SB1 Markets), SB1 Markets begins operations in Sweden on 1 September 2025. The Group recognizes a gain of NOK 42 million on the transaction, and hold a 31.9 per cent stake upon completion of the transaction. • The Board of Directors decides to off er group management a one-off opportunity to purchase of equity certificates in SpareBank 1 SMN. The scheme allows the Group CEO and other members of group management to purchase up to 30,000 and up to 15,000 equity certificates, respectively, at a 30 per cent discount on the bank’s cost price. Fourth quarter • Post-tax profit of NOK 1,061 million and a return on equity of 13.7 per cent. • Finanstilsynet (the Financial Supervisory Authority of Norwa y) adopts a new Pillar 2 requirement of 1.6 per cent of the Group’s calculation basis, representing a reduction of 0.1 percentage points compared to the previous Pillar 2 requirement. Further, Finanstilsynet decides to reduce the expected capital requirement margin from a minimum of 1.25 per cent to 1.00 per cent. On 18 December, the Board of Directors therefore adopts a new long-term target for core capital adequacy. The target is set at a minimum of 15.9 per cent. • The Board of Directors adopts a new gr oup strategy for the period 2026 to 2028. The strategy aims to strengthen the bank’s competitiveness as an independent regional bank through better digital platforms, increased value creation powered by technology and AI, further development of the SpareBank 1 Alliance and targeted investment in expertise, management and culture. • Sparebanken Møre (8 December 2025) and Lokalbank-alliansen (7 Januar y 2026) become co-owners of Kredittbanken. This brings the number of Norwegian banks investing jointly in consumer financing through membership of Kredittbanken to 70. • The Board of Directors of Spar eBank 1 SMN decides to expand the savings programme for group employees. Employees who sign up for the savings scheme can save up to NOK 48,000 per year. 81 per cent of the Group’s employees are participating in the savings scheme for 2026.
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6SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | KEY FIGURES Key figures The Group’s financial alternative performances measures (APMs) are further described at smn.no Description Unit 2025 2024 2023 2022 2021 Profitability Return on equity Per cent 14.8 % 16.6 % 14.2 % 12.3 % 13.5 % Cost-income ratio Per cent 44% 42% 45% 42% 45% Balance sheet Gross loans (ex. SB1 Boligkreditt and næringskr editt) NOKm 184,387 180,102 169,862 152,629 147,301 Gross loans (incl. SB1 Boligkreditt og næringskreditt) NOKm 258,923 249,350 236,329 211,244 195,353 Gross loans in retail market NOKm 175,343 167, 159 159,777 141,833 132,894 Gross loans in corporate market NOKm 83,580 82,191 76,553 69,411 62,458 Growth in loans (gross) Per cent 3.8 % 5.5 % 11.9 % 8.1 % 6,9 % Impairment losses ratio Per cent 0.06% 0.05% 0.01% 0.00% 0,09 % Loans and advances to customers at Stage 3 in percentage of gross loans Per cent 0.88% 0.89% 0.88% 0.97% 1.68% Deposits NOKm 146,165 140,897 132,888 122,010 111,286 Deposits from retail customers (Wage earners) NOKm 68,267 62,581 57,874 48,316 44,589 Deposits from Corporates NOKm 77,898 78,316 75,015 73,693 66,697 Growth in deposits last 12 month Per cent 3.7 % 6.0 % 8.9 % 9.6 % 14,1 % Deposit-to-loan ratio excl. SB1 Boligkreditt and SB1 Næringskr editt Per cent 79% 78% 78% 80% 76% Deposit-to-loan ratio incl. SB1 Boligkreditt and SB1 Næringskreditt Per cent 56% 57% 56% 58% 57%
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7SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | KEY FIGURES Description Unit 2025 2024 2023 2022 2021 Soliditity Common equity Tier 1 capital NOKm 23,328 22,409 21,589 19,776 17,790 Common equity Tier 1 capital ratio Per cent 16.8 % 18.3 % 18.8 % 18.9 % 18.0 % Tier 1 capital NOKm 25,731 24,769 23,793 21,835 19,322 Tier 1 capital ratio Per cent 18.5 % 20.2 % 20.8 % 20.9 % 19.6 % Capital ratio Per cent 20.8 % 22.8 % 23.0 % 23.1 % 21.6 % Risk weighted assets (RWA) NOKm 139,273 122,622 114,633 104,716 98,664 Total eligible capital NOKm 28,958 28,004 26,399 24,147 21,333 Liquidity Coverage Ratio (LCR) Per cent 156% 183% 175% 239% 138% Le verage ratio Per cent 7.0 % 7.0 % 7.2 % 7.1 % 6.9 % Equity capital certificates (MING) Quoted price NOK 206.05 171.32 141.8 127.4 149 No. of ECs issued No . (million) 144.19 144.21 144.20 129.29 129.39 Market value NOKm 29,711 24,706 20,448 16,471 19,279 Dividend per EC NOK 13.50 12.50 12.00 6.50 7.50 Book value per EC NOK 135.06 128.09 120.48 109.86 103.48 Profit per E C NOK 19.08 20.60 16.88 12.82 13.31 Price-Earnings (PE) ratio, annualised NOK 10.80 8.32 8.40 9.94 11.19 Price-Book (PB) value ratio NOK 1.49 1.34 1.18 1.16 1.44 EC Fraction Per cent 67% 67% 67% 64% 64%
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8SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | KEY FIGURES 8 Non-financial performance measures The Group’s non-financial performance measures follow the same governance and responsibility structure as the financial APM’s. The Group has re-established non-financial performance measures to manage its material impacts, risks and opportunities (IRO). During the year, the Group has conducted two projects in which non-financial performance measures have been a central component: “The Group’s transition plan for climate and nature” and “management of IRO related to social matters and corporate governance.” The Group’s transition plan has been prepared and adopted by the Board of Directors. However, key figures for climate and nature have not been published in the annual report, as these are still under development. See the chapter on Environmental for more information on the Group’s transition plan. The latter project was completed during the year. Integration of the non-financial performance measures into the Group’s corporate governance will be an ongoing process during the coming period. Corresponding action plans have also been prepared for each indicator and its associated target. These are described in more detail in the Board of Directors’ report. A complete summary can be found here. The Group’s non-financial performance measures are presented in the table on the next page. Detailed definitions and explanations are provided on the following page.
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9SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | KEY FIGURES 9 Key performance indicator Base year Base value Unit of measurement Division Scope Target Target-year Result 2025 Result 20242) Percieved work-life balance (WinningTemp) 2024 6.8 Score Absolute HR Own ops 7.5 2027 7.2 6.8 Equal pay (Group level) 2024 89.3 % Percent R elative HR Own ops 95% 2030 88.7 % 89.3 % Leaders (excl. Gr oup CEO) 2024 87.7 % Percent R elative HR Own ops 95% 2030 88.9 % 87.7 % Retail market (customer-facing positions) 2024 96.8 % Percent R elative HR Own ops 95% 2030 93.1 % 96.8 % Corporate market (customer-facing positions) 2024 90.7 % Percent R elative HR Own ops 95% 2030 90.2 % 90.7 % Accountants 2024 95.0 % Percent R elative HR Own ops 95% 2030 94.9 % 95.0 % Other employees 2024 91.8 % Percent R elative HR Own ops 95% 2030 90.4 % 91.8 % Sick leave 2024 5.2 % Percent R elative HR Own ops < 5,4% 2028 5.6 % 5.2 % Other work-related complaints 2024 10 Units Absolute HR Own ops 8 2027 12 10 Incidents of discrimination, including harassment 2024 3 Units Absolute HR Own ops 0 2026 2 3 Completion rate of mandatory competency enchancement 2024 89.6 % Percent R elative HR Own ops 95% 2025 94.1 % 89.6 % Assessment of suppliers with increased potential risks r elated to human and labour rights 2025 52% Percent Relative Property and procurement Upstream 100% 2027 52% N/A Suppliers with purchases > 100 K NOK where the Code of Conduct (CoC) has been signed 2025 34% Percent Relative Property and procurement Upstream 95% 2028 26% N/A Deviations from the lending regulation used to finance and include young customers and first-time buyers 1) 2024 53% Percent Relative Retail market Downstream IA IA 52% 53% Recovery rate of unauthorised/fraudulent transactions 2024 43% Percent Relative Financial crime and business support Downstream 80% 2027 77% 43% Compliance with the restitution obligation in complaint cases related to fraud 2025 80% Percent Relative Financial crime and business support Downstream 95% 2027 80% N/A Number of breaches of privacy or loss of customer data reported to the DPA 2025 6 Units Absolute Compliance Downstream 0 2026 6 11 Number of privacy-related deviations registered in IMS 2025 242 Units Absolute Compliance Own ops 240 2026 242 N/A Incidents that have resulted in information being compromised, leading to unacceptable consequences in line with the BIA 2024 0 Units Absolute Technology and development Own ops Upstream Downstream 0 Every year 0 0 Incidents that result in downtime of operational systems, leading to unacceptable consequences with the BIA 2024 0 Units Absolute Technology and development Own ops Upstream Downstream 0 Every year 0 0 1) The Bank aims to prioritise the use of the deviation quota for two groups: young customers and/or first-time buyers, and customers experiencing life events that affect their financial situation (e.g. relationship breakdown or temporary loss of income). At the reporting date, it is not possible at an aggregated level to distinguish between customers experiencing such life events and other customer groups. This is expected to improve following planned system changes in the upcoming period. In the longer term, the management indicator will include this group; consequently, no target has been set for the management indicator. 2) N/A = Not available
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10SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | KEY FIGURES 10 Key performance indicator Definition(s) Percieved work-life balance (WinningTemp) An average of several questions in the Group’s continuous employee survey Winningtemp: “I am able to disconnect from work during my spare time”, “I find it manageable to prioritise my tasks during busy work periods”, and “I have a manageable workload.” Equal pay (Group level) Equal pay (women relative to men) for the Group as a whole. Leaders (excl. Group CEO) Group executive management (GEM), subsidiary management, and other employees reporting directly to GEM or subsidiary management. Retail market (customer-facing positions) Employees in retail market (bank, realtor and SB1 Finans) which has direct customer contact. Corporate market (customer-facing positions) Employees in corporate market (bank, realtor and SB1 Finans) which has direct customer contact. Accountants Employees in SB1 Regnskapshuset which provides accounting services to customer. Other employees Backoffice, IT, marketing and business development, staff and support aswell as compliance. Sick leave Sick leave in accordance with ESRS S1-14 Other work-related complaints Matters that are in breach of statutory provisions, the company’s written Code of Conduct, or generally accepted ethical standards. Incidents of discrimination, including harassment Reported cases of discrimination and harassment, irrespective of whether the report has been substantiated or not. Completion rate of mandatory competency enchancement Mandatory training completed by year-end, not adjusted for sick leave or other types of leave (e.g. family-related leave). Assessment of suppliers with increased potential risks related to human and labour rights Risk is defined here as the risk of breaches of labour and human rights. Suppliers with elevated risk have an inherently higher risk due to the industry in which they operate or similar factors. Suppliers with procurement > KNOK 100 for whom a Code of Conduct (CoC) has been signed The Code of Conduct addresses norms and values and is intended to promote awareness of, and compliance with, the ethical standards required of employees and employee representatives within the Group in their day-to-day decision-making. Deviations from the lending regulation used to finance and include young customers and first-time buyers 1) Approved volume of the deviation quota divided by the total deviation quota. The Bank’s deviation quota is set based on specified percentage limits of the bank’s total lending volume. Recovery rate of unauthorised/fraudulent transactions Unauthorised transactions are defined as transactions to which the customer has not given consent. Compliance with the restitution obligation in complaint cases related to fraud The target consists solely of strict compliance with the reversal obligation (reversal within one business day). The target excludes cases where the Bank must extend the reversal period to conduct further investigations to detect or rule out fraud. Number of breaches of privacy or loss of customer data reported to the DPA Notifiable personal data breaches of greater severity, in terms of scope or number of individuals affected Number of privacy-related deviations registered in IMS Total privacy-related incidents (regardless of size or severity). Incidents that have resulted in information being compromised, leading to unacceptable consequences in line with the BIA In accordance with the DORA Regulation (EU) 2022/2554, the Group has conducted a Business Impact Analysis (BIA) to identify and assess how disruptions or failures in IT-related processes may affect critical processes and functions.Incidents that result in downtime of operational systems, leading to unac- ceptable consequences with the BIA
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11SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | WE STAND FIRM IN A CHANGING WORLD We stand firm in a changing world We have been supporting people and businesses in Central Norway through ups and downs since 1823, keeping a cool head when needed and always with one pri- mary objective in mind: to give people and businesses good financial advice. Having over 200 years’ experience in dealing with change is useful during a time of major and rapid change. Geopolitical unrest is destabilising financial markets, both internationally and here at home. At the same time, increased competition and technological upheaval are challenging our established ways of working. Such changes present both challenges and opportunities, and we are well-positioned to meet these thanks to our robust returns, strong market position, local presence and close, longstanding customer relationships. Innovation and transformation are key to our future. We will continue to leverage new technologies, and artificial intelligence in particular, to simplify, improve and streamline everyday life for our employees and customers. We have lived by the same principle since 1823: we will provide good financial advice to people and businesses, in good times and bad. We meet our customers both digitally and physically, offering insight, advice and a comprehensive range of financial products and services. The bank now known as SpareBank 1 SMN was founded as Trondhjems Sparebank. From our start as a local savings bank for Trondheim, we have become Central Norway’s leading financial group. We have a strong presence in Trøndelag and Møre og Romsdal, as well as offices in Vestland and Oslo. Our head office is still in Trondheim and we have customers throughout the country. The bank and its subsidiaries offer customers a comprehensive range of banking, accounting and real estate services. Together, we are “One SMN”. The bank’s founders wanted it to be owned by the community, and the community remains our largest owner. Over 40 per cent of our profits are reinvested in the local community. We call this our community dividend. We care deeply about the local communities in our region and have an unshakeable belief that, “Together, we make things happen”. A changing world requires adaptation, but one thing that does not change is our core values. We will continue to take these values and our social responsibility seriously, as we have done for over 200 years.
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12SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | WE STAND FIRM IN A CHANGING WORLD Targets and objectives SpareBank 1 SMN aims to be the leading financial group in Central Norway and one of the best performers in the Nordic region. We seek to create financial value, build the community in our region and take our share of responsibility for sustainable development. Our strong customer relationships and high returns over time give us a strong foundation on which to build. We have adopted clear targets for our profitability, solvency and efficiency. Our targets for the coming period are: • Profitable with a return on equity of at least 13 per cent. • Solvent with a CET 1 capital ratio of 16.3 per cent. Distribution ratio of appro ximately 50 per cent. • Efficient. Annual target of less than 40 per cent cost/income ratio for the parent bank and less than 85 per cent cost/income ratio f or subsidiaries. • Strengthened market position. Aim to be number one in the Group’s business areas. • More satisfied customers. Objective to have the most satisfied customer s in all operational and market segments. • Proud and committed employees. Aim to have the most committed emplo yees in the financial industry in Norway. • Quality in everything we do. Objectiv e to meet internal and external expectations in all processes. Strategic priorities The Board has adopted a new group strategy for the period 2026–2028. The strategy refines SpareBank 1 SMN’s foundation as an independent regional bank with strong roots in Central Norway. Many objectives remain unchanged: the vision of “One SMN”, added value from the group’s breadth and integration, the combi-nation of cutting-edge digital solutions and personal advice, and the goal of creating the best financial institution in the market. At the same time, competitiveness is being strengthened through better digital platforms, increased value creation based on technology and AI, further development of the SpareBank 1 Alliance and targeted investment in skills, management and culture. • Create the best financial institution in the market. • Simplify and improve by lev eraging technology and artificial intelligence. • Develop skills for the future. • Lead the development of savings bank s in Norway. • Build sustainable communities and businesses. SpareBank 1 SMNs organisational set-up We are an independent regional savings bank and Central Norway’s leading financial group. Together with our subsidiaries and associated companies, we constitute a comprehensive financial institution serving the private and corporate markets. Including subsidiaries, the Group had over 1,800 employees as at year-end 2025. Through the SpareBank 1 Alliance and the Group’s subsidiaries, the Group markets competitive products in the segments financing, savings, insurance, payments, real estate brokerage, leasing, accounting and accounting-related services, as well as capital market services tailored to clients’ current and future needs. SpareBank 1 SMN is organised under the following structure: SpareBank 1 SMN Group Retail market SpareBank 1 SMN (100 %) Organisational Structure Corporate market Support and administrative functions Associated companies EiendomsMegler 1 Midt-Norge AS (92.4 %) SpareBank 1 Finans Midt-Norge (64.8 %) SpareBank 1 Regnskapshuset SMN (93.3 %) SpareBank 1 SMN Kvartalet (100 %) SpareBank 1 SMN Invest (100 %) St.Olavs Plass 1 SMN (100 %) SpareBank 1 Bygget Steinkjer (100 %) Mavi XV (100 %) SpareBank 1 Gruppen (19.5 %) SpareBank 1 Boligkreditt (22.8 %) SpareBank 1 Næringskreditt (14.8 %) BN Bank (35.0 %) Kredittbanken (15.1 %) SpareBank 1 Betaling (20.5 %) SpareBank 1 Utvikling (18.0 %) SpareBank 1 Forvaltning (21.7 %) SB1 Markets (31.9 %)
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13SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | WE STAND FIRM IN A CHANGING WORLD Finance centre Banking services Banking and accounting services Accounting services Banking and estate agency services Estate agency services * City Center, Moholt, Heimdal, Byåsen, Grilstad AureKristiansund Bruhagen Rørvik Kolvereid Støren SunndalsøraVestnes Eidsvåg Angvik Midsund Brattvåg Ålesund Hareid Ørsta Volda Førde Berkåk Oppdal Røros Melhus Børsa Orkanger Rissa Brekstad Frøya Hitra Namsos Flatanger Grong Snåsa Inderøy Stjørdal Levanger Verdal Steinkjer Vikan Elnesvågen Aukra Surnadal Molde Hommelvik Leksvik Ålen Bjorli Lesja Dombås Lillehammer Trondheim* Løkken Skjåk Åfjord Spjelkavik Oslo Lom Stryn Fosnavåg Ulsteinvik Sykkylven Åndalsnes Finance centre Banking services Banking and accounting services Accounting services Banking and estate agency services Estate agency services * City Center, Moholt, Heimdal, Byåsen, Grilstad AureKristiansund Bruhagen Rørvik Kolvereid Støren SunndalsøraVestnes Eidsvåg Angvik Midsund Brattvåg Ålesund Hareid Ørsta Volda Førde Berkåk Oppdal Røros Melhus Børsa Orkanger Rissa Brekstad Frøya Hitra Namsos Flatanger Grong Snåsa Inderøy Stjørdal Levanger Verdal Steinkjer Vikan Elnesvågen Aukra Surnadal Molde Hommelvik Leksvik Ålen Bjorli Lesja Dombås Lillehammer Trondheim* Løkken Skjåk Åfjord Spjelkavik Oslo Lom Stryn Fosnavåg Ulsteinvik Sykkylven Åndalsnes Our head office is located in central Trondheim, and we have additional offices both in and outside Central Norway, from Oslo in the south to Kolvereid in the north. Many of our offices gather several operational areas under the same roof. Twenty-six of our offices are what we call finance centres which offer banking, accounting and real estate brokerage in one location. Our regional presence ensures customer proximity and puts us at the heart of our local community. For further details of the Group’s subsidiaries, associated companies and joint ventures, see the “Financial results” section of the Report of the Board of Directors.
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14SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | BOARD OF DIRECTORS AND GROUP MANAGEMENT Board of Directors Kjell Bj ordal (1953), board chair Board member since 2007 and board chair since 2013. Member of the remuneration committee since 2012 and chair since 2013. AMP Wharton Business School (1989). Economics degree (MBA) from NHH Norwegian School of Economics (1976) and law studies. Self-employed with extensive experience from senior management positions, including as CEO of the EWOS Group, head of the feed division at Cermaq, CEO of NorAqua, and CFO and later CEO of the Glamox Group. Extensive board experience from serving as chair of the Nordlaks Group, Axio and Norsk Landbrukskjemi. Holds 130,000 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Mette Ka msvåg (1971), board member Board member since 2018. Member of the remuneration committee since 2024. Economics degree (MBA) from BI Norwegian Business School (1994). Self-employed with extensive experience in IT and payment services from various management positions at BBS and Nets over a period of 15 years. CEO of Nets from 2011 to 2014. Extensive board experience from serving as chair of WebMed AS, group.one and SmartCraft ASA and as a board member at Worldline SA. Holds 5,600 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Christ ian Stav (1968), deputy chair Board member since 2019. Chair of the audit committee and member of risk committee since 2019. Master of Business Administration from NHH Norwegian School of Economics (2003); Certified European Financial Analyst (AFA) from NHH Norwegian School of Economics (2003); State-authorised public accountant (1994) and economics degree from NHH Norwegian School of Economics (1991). Advanced auditor studies at NHH Norwegian School of Economics (1992). Group CEO at Nord-Trondelag Elektrisitetsverk (NTE). Experienced in auditing and advisory services. Previously a partner at EY Transaction Advisory Services and has held management positions in finance and economics at NTE, including as CFO. Extensive board experience from serving as board chair of NTE Energi AS, NTE Marked AS, NTE Elektro AS and NTE Telekom AS. Holds 35,000 EC’s SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Nina Olu fsen (1976), board member Board member since 2024. Member of risk committee and audit committee since 2024. Economics degree (MBA) from BI Norwegian Business School (2003), studies in public law and private law at the University of Oslo. Chief Strategy & People Officer at ScaleAQ Group. Broad management experience, including from Mestergruppen, Morris AS and Norrøna Sport AS. Extensive board experience from various board appointments Holds 0 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties).
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15SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | BOARD OF DIRECTORS AND GROUP MANAGEMENT Ingrid F inboe Svendsen (1961), board member Board member since 2023, chair of risk committee and member of audit committee since 2023. Business degree from BI Norwegian Business School (1990) and training in municipal administration from the Norwegian Municipal and Social College (1983). Director of Thomas Angells Stiftelser. Previous experience as a director at the Norwegian Labour Inspection Authority. Management experience from the public sector, including as chief executive of Trondheim Municipality and as director at Sør-Trøndelag County Authority. Extensive board experience from serving as chair of Trondheim Spektrum and as a member of the boards of Olavsfestdagene and E.C. Dahls stiftelse. Holds 1,150 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Freddy A ursø (1972), board member Board member since 2022 MBA from University of Newcastle (2003). Engineering degree from the Norwegian University of Science and Technology (NTNU) (1998). CEO of Lighthouse8. Broad experience as managing director of several international companies, including Global Media, Bigmouthmedia and LBi. Extensive board experience from serving as chair of Lighthouse8 AS, Lighthouse8 Pte Ltd, Lighthouse8 Pty Ltd and Lighthouse8 Ltd. Previously served as board chair and board member of several companies in and outside Norway. Holds 0 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Kristi an Sætre (1961), board member Board member since 2023. Engineering degree from the Norwegian Institute of Technology (NTH) (1987). Mechanical engineering degree from Ålesund Engineering College (1982). Senior Vice President at Vard Group AS. Broad management experience from the maritime and industrial sectors. Previously held several key positions at AS Volda Mekaniske Verksted and Scana Volda, including 11 years as CEO of Scana Volda AS. CEO of Ulstein Verft AS from 2013 to 2019, and subsequently served as managing director of A-K Maskiner. Extensive board experience from SpareBank 1 Søre Sunnmøre, serving as deputy board chair from 2008 to 2014 and as an alternate member from 2022 to 2023. Holds 1,000 EC’s SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Inge Lind seth (1963), employee representative Board member since 2019. Degree in IT management from Sør-Trøndelag University College (HiST) and studies in project management from BI Norwegian Business School. Group employee representative since 2019. Broad experience of organisational work. Board member of the Finance Sector Union, Trøndelag region, since 2020 and permanent deputy representative on the union’s executive committee. Previously held roles as employee representative and member of the board of representatives. Experience as a technical expert and head of service desk in the technology, operations and security areas. Employed by SpareBank 1 SMN since 1982 in various positions and functions. Holds 13,563 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties).
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16SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | BOARD OF DIRECTORS AND GROUP MANAGEMENT Christ ina Straub (1974), employee representative Board member since 2019. Bankakademiet stage 1 and insurance studies. Product Manager Payments at SpareBank 1 SMN and various positions within the bank since 2006. Deputy chair of the Finance Sector Union’s branch at SpareBank 1 SMN since 2019. Previous positions at Vår Bank & Forsikring from 1998 to 2001 and TietoEvry from 2001 to 2006. Deputy chair of the Finance Sector Union, Trøndelag region, and previously a representative on several internal committees. Holds 1,279 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties).
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17SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | BOARD OF DIRECTORS AND GROUP MANAGEMENT Group Management Jan-Fr ode Janson (1969) Group CE O Doctorate in Industrial Economics and Technology Management from the Norwegian University of Science and Technology (NTNU) (1996). Economics degree (MBA) from Bodø University College (1992). Group CEO of SpareBank 1 SMN since 1 May 2019. Former Group CEO of SpareBank 1 Nord-Norge and deputy managing director of Fokus Bank/Danske Bank. Previous management positions at Orkla and ABB. Board chair of SpareBank 1 Betaling AS, Fremtind Forsikring AS, Fremtind Holding AS and SpareBank 1 SMN’s subsidiaries EiendomsMegler 1 Midt-Norge AS, Mavi XV AS and SpareBank 1 Regnskapshuset SMN AS. Member of the boards of SpareBank 1 Gruppen AS, SpareBank 1 Utvikling DA, Vipps Mobilepay AS, VIPPS Holding AS, BankID BankAxept AS and NTNU. Holds 52,816 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Astrid U ndheim (1980), Executi ve Director Technology and Dev elopment Doctorate in Communications Technology from the Norwegian University of Science and Technology (NTNU) (2009). Master’s degree in Communications Technology from NTNU (2004). Employed by SpareBank 1 SMN since 2020. Extensive previous experience from Telenor, most recently as head of the research department at Analytics & AI. Member of the board of BN Bank ASA. Member of the Council of Statistics Norway. Member of the “Norway towards 2025 Commission” (2020-2021). Previous experience from various public commissions. Holds 3,044 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties).
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18SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | BOARD OF DIRECTORS AND GROUP MANAGEMENT Trond Sø raas (1968) Execut ive Director Finance and Strategy Authorised Financial Analyst (AFA) from NHH Norwegian School of Economics (2006) and economics degree (MBA) from NHH (1994). Employed by SpareBank 1 SMN since February 2022. Previous experience from KLP Banken AS and BN Bank ASA, most recently as Director, Economy and Finance at BN Bank ASA. Board chair of SpareBank 1 Markets AS. Board chair of BN Bank ASA. Member of the boards of SpareBank 1 Boligkreditt AS and SpareBank 1 Næringskreditt AS. Board chair of SpareBank 1 SMN Invest AS and Gma Invest AS. Holds 10,817 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Ola Neråsen (1965) Execut ive Director Risk Management State-authorised public accountant from NHH Norwegian School of Economics (1994). Economics degree (MBA) from BI (1990). Employed by SpareBank 1 SMN since 1997. Executive Director Risk Management since 2009. Previous experience from Deloitte and the Norwegian Armed Forces. Member of the board of Stiftstaden Sykkelklubb Holds 50,632 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Rolf Jar le Brøske (1980) Executi ve Director Marketing, Communications and Digital Sales Studies in political science and history at Molde University College and the Norwegian University of Science and Technology (NTNU). Employed by SpareBank 1 SMN since 2016. Former member of group management with responsibility for communications at Det norske Oljeselskap and of executive management at Danske Bank (Fokus Bank). Experience as an adviser to former Minister of Trade and Industry Børge Brende and to the Mayor of Trondheim. Has held various political appointments. Board chair of Brøske & Bianchi Wine Import AS. Member of the boards of SpareBank 1 Spleis AS, Trøndelag Conservative Party, Sør-Trøndelag Conservative Party and Nidaros Cathedral Boys Choir. Holds 16,363 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Vegard Helland (1975) Executi ve Director Corporate Banking Authorised Financial Analyst (AFA) from NHH Norwegian School of Economics (2007) and economics degree (MBA) from Bodø Graduate School of Business (1999). Employed by SpareBank 1 SMN since 2003, focusing primarily on the corporate market. Executive Director Corporate Banking since 2010. Previous experience as a member of audit staff and consultant at KPMG and as an analyst at Fontiera AS. Board chair of SpareBank 1 Finans Midt-Norge. Member of the boards of SpareBank 1 Markets AS, SpareBank 1 Factoring AS, SpareBank 1 Regnskapshuset SMN AS, Kredinor AS and Mavi XV AS. Holds 36,852 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties).
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19SPAREBANK 1 SMN | ANNUAL REPORT 2025 | THIS IS SPAREBANK 1 SMN | BOARD OF DIRECTORS AND GROUP MANAGEMENT Johan-P etter Winsnes (1975) Execut ive Director Financial Crime and Business Support Economics degree from BI Norwegian Business School (2008) and sociology studies at the Norwegian University of Science and Technology (NTNU). Employed by SpareBank 1 SMN since 2012, including head of HR in the period 2015–2024. Executive Director Financial Crime and Business Support since 2025. Previous experience from the consultancy firms Accenture and Fara. Board chair of the Norwegian University of Science and Technology (NTNU). Holds 3,312 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Monica H aftorn Iversen (1975) Execut ive Director Retail Banking Economics degree (MBA) from NHH Norwegian School of Economics (2002). Employed by SpareBank 1 SMN since May 2022. Executive Director since November 2024. Formerly Director of Market Areas for the Retail Market. Extensive previous experience from Danske Bank/Fokus Bank, most recently as Head of Performance Management Business Customers in the Nordics and a member of the management team in Norway. Member of the board of EiendomsMegler 1 Midt-Norge AS. Holds 817 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Kjetil R einsberg (1961) CEO Eiend omsMegler 1 Midt-Norge Graduate in real estate brokerage from BI Norwegian Business School (2008). CEO of EiendomsMegler 1 Midt-Norge since 1999. Previous experience from Storebrand Bank, Notar, Bedre Råd and several years in the construction industry. Board chair of Brauten Eiendom AS. Member of the boards of EiendomsMegler 1 Norge, Agri Eiendom AS, Eiendom Norge Holding AS and Eiendom Norge. Holds 35,440 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties). Arne Nyp an (1970) CEO Spar eBank 1 Regnskapshuset SMN Master of Business Administration (MBA) from Lund University (1997). Bachelor in Business Administration (BSc) from Copenhagen Business School (1995). Officer training, Norwegian Army (1992). CEO of SpareBank 1 Regnskapshuset SMN since 2020. Formerly CEO of SpareBank 1 Finans Midt-Norge (2013– 2020), head of customer concept at SpareBank 1 SMN (2013), general manager at SpareBank 1 SMN (2003–2012). Previous experience from Innovation Strategic Consulting and Fokus Bank (Danske Bank). Board chair of Nypan AS. Member of the boards of Rosenborg Sport AS and Rosenborg Ballklub. Holds 39,697 EC’s in SpareBank 1 SMN as at 31 December 2025 (including any EC’s owned by related parties).
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VIRKSOMHETEN VÅR 2 Report of the Board of Directors Introduction 21 Sustainability report General information 23 Environmental 65 Social 161 Governance 206 Financial results 216
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21SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | INTRODUCTION Introduction The report of the Board of Directors provides a comprehensive account of the Group’s operations, developments, performance, results and material matters for the year, including risks, targets and governance practices. The report is intended to give a holistic and balanced view of the Group’s position and performance. The Group’s reporting in accordance with the Corporate Sustainability Reporting Directive (CSRD) is included as a part of the report of the Board of Directors. The Group’s sustainability reporting follows the European Sustainability Reporting Standards (ESRS) as they apply as at 31 December 2025, and contains material information on the Group’s activities across a range of sustainability- related areas. Whether a topic is deemed material is determined through a double materiality assessment (DMA). The purpose of the DMA is to ensure that the Group focuses on, and reports on, material topics and associated reporting requirements. The Group reports across four topics within Environmental, four topics within Social, and one topic under Governance. Although eight out of ten standards are considered material, not all associated disclosure requirements are material. The most extensive disclosures relate to Climate Change, the Group’s Employees (Own workforce), Consumers and End Users, and Business Conduct. The implementation of the Group’s DMA is described in more detail on page 33. The analysis was conducted in 2024 and subsequently updated in 2025. It has resulted in several material impacts, risks and opportunities (IROs) which the Group will manage through objectives, action plans, measures and policies. The Group’s IROs are described further on page 38. In 2025, the Group updated objectives and performance measures in accordance with the CSRD. The Board of Directors, the Audit Committee and Group Management have been closely involved in the development of these performance measures which is to be integrated into the Group’s corporate governance framework in the coming period. The Group’s financial and non-financial performance measures are presented on page 6. An overview of the Group’s ESRS-aligned reporting is set out on page 41. The ESRS index provides a detailed overview of where each disclosure requirement is addressed in the Group’s reporting. A glossary of acronyms and abbreviations used in the Group’s reporting is included in the appendix.
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General information Basis for preparation 23 Governance 26 Strategy 28 The Group’s double materiality assessment 33 ESRS-index 41 List over datapoints that derive from other EU-legislation 56 Targets 60 Actions 61 Policies 64
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23SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION General information Basis for preparation of the sustainability statement The sustainability statement provides the Group’s stakeholders with an objective and complete picture of the Group’s handling of material impacts, risks and opportunities (IROs) related to the environment, climate, and social and governance issues. The statement covers the period 1 January to 31 December 2025. The sustainability statement relates to SpareBank 1 SMN at group level, and all information has been consolidated on the same basis as the Group’s financial statements. Where information is included that relates to entities outside the Group (value chain data), this is stated explicitly. No information related to intangible rights, know-how or development has been omitted. The Group’s sustainability statement has been drawn up in accordance with chapter 2 of the Accounting Act (as amended to incorporate the Corporate Sustainability Reporting Directive (CSRD) and the related European Sustainability Reporting Standards ). The statement reflects all applicable standards as at 31 December 2025. The sustainability statement forms part of the report of the Board of Directors and is structured in keeping with the requirements of ESRS 1. The structure is as follows: • General information • Environment • Social • Governance The Board of Director s’ report on the Group’s financial performance pursuant to section 2-2 of the Accounting Act can be found in the Financial results chapter. Other frameworks and legislation incorporated into the sustainability statement The Group is subject to the provisions of the Transparency Act and the Equality and Anti- Discrimination Act, as well as section 6-16b of the Public Limited Liability Companies Act on the pay and other remuneration of senior executives. Executive remuneration reports pursuant to section 6-16b and the Group’s reports pursuant to its activity and disclosure duty under the Equality and Anti-Discrimination Act are published on the Group’s website. The Group’s 2025 report under the Transparency Act will be published by 30 June 2026. The Group’s reporting in accordance with the Norwegian Code of Practice for Corporate Governance (NUES) and section 2-9 of the Norwegian Accounting Act is published on smn.no. Where reference is made to other parts of the annual report or to other publicly available information existing on the reporting date, this will be stated explicitly. Referenced information is attested by the Group’s auditor to the same level of certainty as reporting pursuant to the Corporate Sustainability Reporting Directive (CSRD). Where the Group has identified material impacts, risks or opportunities which are not covered by a given standard under ESRS, reporting is based on the Global Reporting Initiative (GRI) 2021 and any available thematic and/or sector-specific standards. In cases where CSRD guidance is lacking, other frameworks may be applied. When applicable, this is explicitly stated in relation to the relevant information.
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24SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION References to other parts of the report of the Board of Directors The following information is incorporated by reference to other parts of the report: Standard Disclosure requirement Reference to other parts of the Directors’ report ESRS 2 SBM-3.48 Sector specific-standards1) ESRS E1 IRO-1.20 et seq. General information - The Group’s double materiality assessment ESRS E2 IRO-1.11 General information - The Group’s double materiality assessment ESRS E32) IRO-1.8 General information - The Group’s double materiality assessment ESRS E4 IRO-1.17 et seq. General information - The Group’s double materiality assessment ESRS E5 IRO-1.11 General information - The Group’s double materiality assessment ESRS S1 SBM-2.12 General information - Stakeholder dialogue in SpareBank 1 SMN ESRS S2 SBM-2.9 General information - Stakeholder dialogue in SpareBank 1 SMN ESRS S4 SBM-2.8 General information - Stakeholder dialogue in SpareBank 1 SMN ESRS G1 GOV-1.5 General information - Governance ESRS G1 IRO-1.6 General information - The Group’s double materiality assessment 1) The exception in ESRS 2 SBM-3.49 has been used by describing the approach and managing of the group’s significant IRO, and how they are integrated with business models and strategy under relevant sector agnostic standards 2) IRO-1 must be complied with even though the standard has not been identified as material. Reference to other reports and disclosures The following information is incorporated by reference to other reports: Standard Disclosure requirement Reference to other disclosures ESRS 2 GOV-3.29 Report on remuneration and emoluments to senior personnel1) ESRS E1 GOV-3.13 Report on remuneration and emoluments to senior personnel1) 1) Report on remuneration and emoluments to senior personnel is available on smn.no Sustainability-related matters are described in several notes to the financial statements: • Revenues per operating segment in line with IFRS 8 are presented in Note 4. • ESG risk is described under risk factors in Note 6. The following are appended to the Boar d of Directors’ report: • ESRS-index with detailed references to where the various disclosur e requirements are met. • Detailed overview of datapoints in the ESRS deriv ed from other EU legislation. Specific information items The general reporting principles below apply to all aspects of the sustainability statement. Where more detailed explanations or information on non-conformances are required, these are provided in the relevant information items. Time horizons The time horizons applied in the sustainability statement are short term, medium term and long term. The time horizons are defined in ESRS 1. The time horizons are as follows: Time horizon Definition Short-term Reporting period Medium-term End of short-term reporting period up to five years Long-term More than five years Information covering an extended period of time may be disaggregated to ensure relevance. This is specified explicitly in relevant cases. Where a topic-specific reporting requirement is subject to a different time horizon, this is applied. Value chain information The Group’s interactions with its value chain are restricted to its direct business partners (the first link in the chain). Accordingly, the Group does not normally engage in direct dialogue or other interaction with third parties such as its clients’ customers or its suppliers’ sub-contractors. Such links further down the value chain are impacted indirectly through the requirements, expectations and conditions set by the Group for its own partners. Where indirect sources are utilised to obtain value chain information for targets and key performance indicators (KPIs), they are described in connection with each individual KPI. The calculation methodology and accuracy are also described in the context of relevant targets and KPIs. If the transitional provision in ESRS 1 chapter 10.2 is applied, this is explicitly stated. In such cases, a description is provided of the efforts made to obtain necessary information, the reasons why the information could not be obtained, and what steps have been taken to ensure that such information will be available in future.
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25SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION Comparative information, estimation uncertainty and limitations Targets and KPIs contain comparative information if this can be obtained without disproportionate effort. In cases where comparative information is unavailable, reasons are given. Where relevant, qualitative comparative information is also included. Estimation uncertainty arises where information cannot be measured directly. In cases of estimation uncertainty, the sources, assumptions, limitations and level of uncertainty are highlighted and specified explicitly. Forward-looking information is always subject to estimation uncertainty. To the extent possible, it is ensured that data sources and assumptions applied in the sustainability statement are consistent with financial information. Changes in sustainability reporting and correction of errors in prior periods Changes in reporting may arise as a result of correction of errors in prior reporting periods or based on information that was not available at the time of reporting. In the event of changes that impact KPIs or key financial figures, comparative figures are also restated to ensure consistency over time. If it is inexpedient to restate comparative information, this is specified. If errors are discovered in earlier reports, they are corrected in the current year’s sustainability statement unless doing so is deemed impractical or unnecessary. Any such corrections are described in connection with the relevant information. The most important changes to the sustainability statement compared with the statement for 2024 are as follows: • The Group’s double materiality assessment has been revised in accordance with the annual update plan. No material new IR Os have been added during this process, although some previous IROs are no longer considered material. This is described in greater detail in the section on The Group’s double materiality assessment. • The structure of the General information chapter has been amended to reflect the structure o f ESRS 2. • Major and minor changes have been made to the factors, assumptions and methodology used to calculate upstream and do wnstream greenhouse gas emissions. The aim is to ensure a more stable level of accuracy that will persist in future periods. These changes are described in more detail in Note 2 under Climate change. • The KPIs published in the 2024 annual report have been updated to address the Gr oup’s material IROs and associated action plans. These are described in the relevant thematic sections under the headings Climate and nature, Social and Governance. A complete overview can be found in the Targets and Actions sections in the General information chapter. • The Group’s transition plan for climate and nature has been finalised and is described in more detail under Climate Change . • Figures for 2024 have been restated in se veral tables under Group employees, due to discovered errors. This applies, among other things, to Note 2 and Note 3. In the first half of 2025, the European Commission adopted the first of several simplification decisions aimed at reducing the administrative reporting burden and minimising the impact on small and medium-sized enterprises indirectly affected by the regulations. The first simplification measure, the ‘Stop-the-Clock’ Directive, defers the reporting obligation for around 80 per cent of companies that were initially subject to reporting obligations from 1 January 2025. This simplification does not affect SpareBank 1 SMN. In view of the pending changes to the sustainability statement, a ‘quick-fix’ legal act has also been adopted which ensures that undertakings which already report in line with the ESRS will not be subject to the additional requirements which were initially supposed to apply as of the 2025 reporting year. Further, the Omnibus II Directive will simplify and reduce reporting requirements under the EU Taxonomy and the ESRS. • Changes to the threshold values governing which companies are subject to CSRD. • Changes to the Taxonomy introduce a concept of materiality with the intention of r educing the number of data points and simplifying the relevant forms considerably. • Changes to the ESRS will affect the future design and structure of repor ts. The first of these changes was adopted by the EU in December 2025. SpareBank 1 SMN will not be affected by this change. The remaining changes in Omnibus II will affect the Group, and are expected to take effect for the 2026 reporting year. Events after the balance sheet date Information which only becomes available after year-end but which is material, relevant and useful for decision-making related to other information will be mentioned in this section. There are no known events after the balance sheet date.
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26SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION Governance The Group’s governing bodies are defined as the Supervisory Board, the Board of Directors and group management. Other committees, panels and group functions are intended to help the Group’s governing bodies perform their tasks in an effective, objective and efficient manner. The Group’s material IROs were considered and assessed by the governing bodies on multiple occasions in 2025, in the context of both specific agenda items and periodic reporting on different types of commercial risk. Examples of discussed IROs include: • Climate and nature in the Group’s transition plan for climate and nature. • Circular economy in the Group’s ongoing pilot projects. • Social conditions and corporate governance through periodic reporting on mone y laundering and terrorist financing, including fraud, HR risk, data protection, etc. The Group’s governance structure and governing bodies are illustrated in the chart to the right. The risk management and compliance functions may report directly to the Board of Directors when needed. Appropriate mechanisms for monitoring and measuring goal achievement follow the governance structure. Supervisory Board The Group’s highest governing body is the Supervisory Board, which consists of 32 persons from four different stakeholder groups. These members comprise eight employees, nine clients, 12 equity certificate holders and three public-sector representatives. Of the members, 20 are men and 12 are women, equating to a female-to- male ratio of 60 per cent. The various representatives of the different stakeholder groups are elected every second year by their respective stakeholder groups. Deposit customers (over the age of 18) elect the customer representatives, and equity certificate holders elect the representatives of the equity certificate holders. In February 2025, the equity certificate holder election was held. The customer election will take place from 29 December 2025 to 16 January 2026. As at 31 December 2025, the Supervisory Board’s leadership comprised a male chair and a female deputy chair. The Supervisory Board meets twice yearly, once for a formal review and approval of the annual financial statements and related documents and once for continuing professional development purposes. The Supervisory Board’s professional development needs are clarified through dialogue with the administration, and the Supervisory Board chair decides what resources are needed. Supervisory Board Consists of customers, equity certifi cate holders, employees, and representatives from the public sector, and is the Group’s highest governing body. Chair: Knut Solberg The Board of Directors Consists of nine members. Two of the members are employee representatives. The remaining members are independent. Chair: Kjell Bjordal Group Management Consists of ten members, including the CEO. The CEO holds the highest administrative responsibility for the company’s governance processes, and the executive management team serves as an advisory body to the CEO. Group CEO: Jan-Frode Janson Business areas Private Market, Corporate Market, Accounting Firm, Brokerage, Finance, Branding, Data, HR, Legal, etc. Various committees Credit Committee, ESG Committee Independent control functions Risk Management and Compliance.1) Audit Committee Chair: Christian Stav Risk Committee Chair: Ingrid Finboe Svendsen Compensation committee Technology committee Internal Auditor1) Nomination Committee1) Chair: Elin Hagerup 1) Se NUES pkt. 7, 9, 10 og 15.
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27SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION Board of Directors The Board of Directors has nine members. Five members are men and four are women, equating to a female-to-male ratio of 80 per cent. Two of the members are employee representatives elected by the employees. The remaining members of the Board of Directors are elected by the Supervisory Board’s nomination committee. All members elected by the Supervisory Board are independent, and without special interests in the Group (78 per cent of the board are independent). The Board of Directors holds 12 fixed meetings a year and otherwise convenes as needed. During the course of 2025 the Board has had 18 meetings. The Board has a broad range of expertise from different industries. In the Group’s view, the expertise needed to manage the Group’s material IROs is secured through the Board’s broad commercial experience. Moreover, the Board can draw on the knowledge and expertise of internal and external specialists when necessary. The Board assumes a monitoring role vis-à-vis the administration to ensure that material IROs are addressed and that appropriate reporting lines are established between the Board and the administration. The members of the board are described in the Board of Directors and Group Management sections of the chapter This is SpareBank 1 SMN. Risk committee and audit committee As a stock-exchange-listed financial institution, the Group is required to have a risk committee and an audit committee. The committees each consist of three board members – one man and two women. The committee members have broad managerial experience from sizeable private enterprises and the public sector. The audit committee’s tasks include informing the Board of Directors of the outcome of the financial audit and attestation of the sustainability statement, monitoring the systems for internal control of financial and sustainability reporting, and maintaining ongoing contact with the elected auditor. The audit committee must also evaluate and oversee the auditor’s independence. During the course of the year the committee had 10 meetings. The committee meets at least five times a year. The risk committee’s tasks include helping to ensure that risk management is consistent with best practice and the Board’s objectives, and helping to ensure that the Group’s capital adequacy aligns with internal and regulatory requirements. In addition, the committee reviews risk management strategies, cases and matters related to the bank’s anti-money laundering and anti-terrorist financing efforts and policies in preparation for consideration by the board. The committee is also responsible for monitoring the internal audit function. The risk committee is also required to help ensure that laws, regulations and internal rules governing the Group are identified, implemented and complied with. During the course of the year the committee had 12 meetings. The committee meets at least five times a year Group management Group management comprises eight men and two women, equating to a female-to- male ratio of 20 per cent. The Group CEO bears ultimate administrative responsibility for the Group’s governance processes, and group management advises the Group CEO. To enable group management to perform its assigned tasks, managers receive regular reports on a range of matters from experts within the Group for discussion and input. The members of group management have extensive experience from the banking, technology, consultancy and financial sectors. The combination of experience and expertise gives group management a strong basis for understanding how the Group and Central Norway as a region are impacted by different factors. In areas where group management needs additional expertise, it can draw on internal and external specialist resources. It has been decided that responsibility for the management and supervision of the Group’s material IROs rests with group management. Responsibility for managing and supervising the IROs has been delegated to various executive directors. The Board of Directors receives status reports on IRO management and goal achievement. In 2025, KPIs were defined for management of the Group’s IROs. Integration of the IROs into corporate governance procedures is ongoing, as is finalisation of the schedule for reporting to group management. The members of group management are described in the Board of Directors and Group Management sections of the chapter This is SpareBank 1 SMN. Integration of sustainability into incentive schemes The criteria for evaluating the performance of group management form the basis for fixed salary and are broadly composed. Sustainability-related objectives and criteria form part of this evaluation basis. Read more about salaries and other remuneration of senior executives in the Group’s executive remuneration report on smn.no. Sustainability-related due diligence assessments Due diligence assessments are the process for identifying, preventing, minimising and taking account of actual and potential negative impacts on climate, nature and society. Impacts may stem from own operations or the value chain, including products and services offered by the Group, or from business partners. Identified risks and opportunities are often a result of identified impacts. The Group’s due diligence assessments incorporate the double materiality assessment and the evaluation of material impacts.
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28SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION The Group’s due diligence assessments – and how these are implemented, assessed and managed – are described under each topic in the chapters Environment, Social and Governance. The different parts of the due diligence assessment, and where they can be found, are described in the table below. Key elements of due diligence Information in report of the Board of Directors Embedding due diligence in governance, strategy and business model Governance (GOV-2) Report on remuneration and emoluments to senior personnel (GOV-3) Managing material impacts, risks and opportunities (SBM-3) Engaging with affected stakeholders in all key steps of the due diligence Governance (GOV-2) Stakeholder dialogue in SpareBank 1 SMN (SBM-2) The Group’s double materiality assessment (IRO-1) Policies (MDR-P) Processes for engaging with stakeholders (S1-2, S2-2, S4-2) Identifying and assessing adverse impacts The Group’s double materiality assessment (IRO-1) Managing material impacts, risks and opportunities (SBM-3) Taking actions to address those adverse impacts Actions (MDR-A) The Group’s transition plan (E1-1 and E4-1) T racking the effectiveness of these efforts and communi- cating Targets and metrics (MDR-T and MDR-M) As at the reporting date, specific due diligence assessments have not been prepared for all the sections mentioned above. The Board of Directors has agreed on the need to assign due diligence-related responsibilities. In 2025, KPIs and action plans were developed for several IROs related to social conditions and corporate governance. Relevant KPIs and action plans will be established for climate and nature-related IROs in 2026. Risk management and internal control of sustainability reporting The CEO is responsible for ensuring that sound internal controls are established based on an assessment of relevant risks and guidelines adopted by the Board of Directors. The establishment and monitoring of internal controls follows the Group’s lines of defence, with Compliance being responsible for monitoring and advising the Group. During the reporting period, internal controls have been developed for various aspects of the sustainability statement. The internal controls are based on previously introduced internal controls for financial reporting. The process of identifying risks is managed by the sustainability statement manager, and is based on experience from previous years’ reporting processes and identified risk areas and sources of error. The Group’s control functions are involved in ensuring that identified risks and subsequent controls are appropriate and verifiable. The internal control system for sustainability must address two different types of risk: • errors in the sustainability statement, and • the risk of greenwashing Errors in the sustainability statement, including incomplete, inconsistent or inaccurate inf ormation, are partly attributable to the fact that the reporting process features manual data entry, uncertain and limited data sources, and varying degrees of system support. The risk of greenwashing is linked to objectives and the use of adjectives that create an unrealistic impression of what the Group is capable of achieving within a given timeframe. Both prevention and detection control measures have been established for both risk categories. Implemented controls are revised when weaknesses are identified, and form the basis for the Group’s risk management systems and processes. The Group’s internal controls are considered adequate for managing identified risks, and results are reported to the Group’s audit committee annually. Strategy The Group’s business models The main objective of SpareBank 1 SMN’s business models is to create financial value. To ensure that the Group’s interests do not fall out of step with society’s expectations, the business models will be refined to ensure even greater value creation for stakeholders. Based on the Group’s double materiality assessment, further development of the business models will entail an increased focus on SpareBank 1 SMN’s material IROs. Pursuant to the Corporate Sustainability Reporting Directive (CSRD), the integrated reporting framework has been adopted as the starting point for describing SpareBank 1 SMN’s business models. Input factors Various types of capital are included as inputs in SpareBank 1 SMN’s business models. Capital values are increased, reduced or converted through the Group’s commercial activities, products and services. The following input factors feature in the Group’s business models: • Financial capital: financing of the Group through deposits from customer s, debt capital and equity capital investors.
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29SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION • Human capital: to fulfil investor requirements and expectations, the Gr oup is dependent on competent and committed employees. This is the reason for the Group’s ongoing investment in the employees’ work environment, wellbeing and professional and personal development. • Relational capital: the Group is reliant on fruitful collaboration and positive r elationships with customers, suppliers, companies, clusters and other business partners. This helps the Group secure relevance and trust in its local region. • Natural capital: all natural resources and ecosystems impacted b y the Group and on which the Group is reliant in its own operations and its value chains. These include both renewable and non-renewable resources. To develop and safeguard its input factors, the Group maintains an ongoing dialogue with stakeholders, analyses research results and market trends, and takes into account recognised responsible banking and innovation practices. Products and services The Group markets a broad range of products and services to private and public-sector clients across Central Norway, including lending, savings and investments, accounting, real estate brokerage and leasing services. The breadth of the offering creates synergy effects, as customers can have their everyday and business financial needs met by the group. The Group’s distribution channels include physical branches, a customer service centre and digital channels designed to ensure flexibility and accessibility. Innovation and refinement of the product and service range are integral aspects of the Group’s strategy, and serve the aim of meeting changing customer needs and adapting to prevailing market conditions. Retail market This business area offers products and services to private individuals, including deposits, savings and investment, financing, real estate brokerage services, and vehicle financing and leasing. Around 70 per cent of the Group’s lending is to private individuals (including loans sold to SpareBank 1 Boligkreditt), and car financing represents a significant focus area for transition within the Group. Among other things, the Group has identified the following challenges: • Approximately 53 per cent of the portfolio (measur ed by volume) lacks official energy labels. • Approximately 70 per cent of car financing and leasing involves f ossil fuel vehicles. • Approximately 21 per cent of the portfolio (measur ed by volume) is exposed to material physical climate risks, including landslides and flooding. This is described in more detail in the chapter on Climate change. This represents a financial risk, but also opportunities for SpareBank 1 SMN. The Group offers favourable financing for measures that help to increase the energy efficiency of homes and climate adaptation measures, including through Enova support schemes. In 2025, the transition plan for mortgages was prepared. The plan is designed to enable the Group’s financial advisers to provide reliable, relevant advice to retail customers. The aim is to reduce customers’ climate impact and the impact of climate change on their everyday finances and major financial decisions. Corporate market This business area offers products and services to small and large companies in areas including deposits, capital market services, financing, accounting, leasing, real estate brokerage and other related services. Around one-third of the Group’s income comes from the corporate market, which is a significant arena for transition within the Group . The Group’s clients across both the bank and its subsidiaries are mainly small and medium- sized enterprises. Certain sustainability-related challenges stand out: • Transition risk in several industries related to market pr eferences, technology, framework conditions, terms and political decisions in the medium to long term. • The portfolio represents the majority of the Gr oup’s greenhouse gas emissions, with individual industries accounting for a large proportion of these emissions. However, considerable uncertainty attaches to the estimates. Industry-specific challenges are not described above. These vary in both scope and type. SpareBank 1 SMN will play an active role in influencing and advising these industries in its role as a close financial sparring partner. However, the Group recognises that the restructuring of its portfolios and the goal of net zero by 2050 cannot be achieved without a shift in macroeconomic conditions. Examples include technological changes, political framework conditions and demand for green products and services. In 2025, the transition plan for commercial property was completed, providing business advisers with a tool for influencing and advising clients in the commercial property sector. Results The Group’s activities and business models impact stakeholders in various ways: • Customers: greater financial security and over view, increased financial inclusion and better, more effective financial solutions. • Investors: stable return and long-term value creation. • Employees: secure jobs across the r egion. • Society: economic growth and sustainable development in the r egion
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30SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION The Group’s value chain Access to capital Bonds, deposits, EC-holders, residential and commercial credit Product companies Fremtind Forsikring, SpareBank 1 Markets, SpareBank 1 Kreditt, SpareBank 1 Forvaltning Local procurement Offi ce spaces, IT operations and equipment, supplies, cleaning services, etc. Centralized procurement SpareBank 1 Utvikling Employees Brokers, advisors, analysts, managers, specialists, leaders Business units Banking, accounting, brokerage, leasing Corporate functions Communication, brand, marketing, legal, real estate and procurement, HR, data privacy, data management, corporate governance, fi nancial crime, accounting Administrative, managing and supervisory bodies The Representative Council, the Board of Directors, the Risk and Audit Committee, the Group Executive Management Retail market Home loans, agriculture fi nancing, car loans, insurance, savings, funds, asset management, brokerage, valuation, rental services Corporate market Financing, insurance, accounting, tax, VAT, sustainability, transactions, HR, commercial real estate brokerage Community dividend Sustainability, community, sports and outdoor activities, innovation and value creation, art and culture Own investments Liquidity portfolio, affi liated companies Upstream Own operations Downstream Upstream The Group’s upstream activities encompass all processes and activities carried out by suppliers and business partners that are necessary for the Group’s operations and delivery of its products and services. The most important upstream activities are: • Financing of the Group, where deposits, debt and equity capital are the k ey sources of capital. The bank’s liquidity portfolio ensures that the Group has sufficient liquid assets. The Group’s current Moody’s rating is Aa3 (stable outlook). • The product companies in the SpareBank 1 Alliance are part of the Gr oup’s value chain. The companies boost the Group’s capacity to provide a broad range of products and services. • Purchases of goods and services include both strategic and local procurements. Spar eBank 1 Utvikling handles many of the major strategic procurements which are used across the banks in the Alliance. These procurements include things such as major investments, maintenance of technological and security-related infrastructure, and marketing campaigns. Procurements related to individual bank operations are handled at local level. Own operations The Group’s own operations are processes and business activities carried out to achieve the Group’s financial objectives, strengthen its market position, acquire more satisfied customers, and ensure that employees are proud and committed. These activities are crucial for ensuring that customers can access and benefit from the Group’s products and services. • Professional and personal dev elopment is important if the Group is to attract and retain skilled staff. It is also an important driver of a good customer experience. • Group functions help the business entities meet internal and external stakeholder expectations and requir ements. Downstream Downstream activities are a result of the Group’s upstream activities and own operations. It is in these activities that the majority of the Group’s IROs arise. Examples of downstream activities include: • Lending, savings and investments, real estate brok erage and insurance for personal customers. • Financing, accounting and insurance for business customers. • Community building through the community dividend fund, targeting areas such as community spirit, sports and outdoor r ecreation, art and culture, driving the green transition, innovation and value creation. • The final category of downstream activities are the Gr oup’s own investments in jointly- owned companies and affiliates, as well as investments in the liquidity portfolio. Downstream activities help develop the Group’s local region and communities. See Financial results for a description of the results of jointly-owned and associated companies.
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31SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION Stakeholder dialogue at SpareBank 1 SMN The Group engages in ongoing stakeholder dialogue as part of pursuing an integrated and long-term approach to value creation for investors, customers, employees and the region. The Group has both internal and external stakeholders. The table below shows the Group’s stakeholders and the various types of dialogue and involvement engaged in. The stakeholder dialogue varies in form, timing and frequency depending on the particular objectives. Stakeholders and dialogue activities are listed in random order. Internal stakeholders External stakeholders Supervisory board Investors Board of Directors Rating agency Group Management Customers Worker representatives Suppliers ESG-committee Government and supervisory authorities Environmental representative Clubs, associations and business clusters Employees Media Subsidiaries and affiliated companies Regional community Supervisory board Academia Nature Internal dialogue and follow-up External dialogue and follow-up Town halls Quarterly presentations Board meetings NæringsDriv1) Group Management meetings Stakeholder meetings Quarterly meetings in ESG-committee and miljøgruppe Press releases and stock exchange announcements Employee and development reviews Customer survey (CSI) Cooperation and Working Environment Committee (CWEC) Various events WinningTemp2) Supervisory board meetings Daily formal and informal dialogue Various information on smn.no Booths, lectures and company presentations The sustainability barometer Economic barometer 1) Meeting place and arena organized by SpareBank 1 SMN for the region’s business environment, focusing on innovation and value creation. 2) Digital platform to measure and improve employee engagement, well-being and performance
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32SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION The purpose of stakeholder dialogues is to ensure that the Group’s strategies, directional decisions and focus areas reflect the opinions, viewpoints and perspectives of internal and external stakeholders. The dialogue with internal stakeholders provides insights into different areas of the business. It is utilised to formulate overall strategic input for the Group, enhance the customer experience and maintain a positive working environment. One arena for dialogue with internal stakeholders is the Group’s ESG Committee. The committee members have expertise and experience from a range of departments and business areas within the Group, and can raise relevant sustainability-related issues for discussion. The committee is chaired by the Group’s sustainability officer, and reports to the CFO. Each committee member is responsible for reporting back to their own department and business area. The committee meets at least four times per year. The Group’s external stakeholder dialogues in 2025 included the following: • NæringsDriv: “Working together for a shared future” . • ”Valuable days”: Various e vents with current and future-oriented themes. • Sustainability barometer: Norway’s largest sustainability sur vey among businesses, municipalities and the population. • Business associations and clusters: Collaboration with NHO, LO and aquaculture, technology and real estate cluster s. • Authorities: Meetings with the Ministry of Climate and Environment, municipalities and county councils. • Industry associations: Finance Norway, R eal Estate Norway • Academia: Seminars and research projects in collaboration with NTNU and SINTEF in ar eas such as AI ethics, digitalisation and nature risk. Stakeholder dialogue is a central aspect of the Group’s double materiality and due diligence assessments. See the section on The Group’s double materiality assessment for a fuller description of how the related stakeholder dialogue was carried out. More information on the Group’s dialogue with affected stakeholders is provided in the sections Group employees, Workers in the value chain and Consumers and end-users in the Social chapter. Governing bodies are informed of the dialogue with affected stakeholders throughout the year, both directly and indirectly. Measures in this regard include a range of reports from different departments and business areas. The Group’s understanding of its stakeholder dialogue In addition to informal dialogues with stakeholders, a more systematic and extensive stakeholder dialogue was conducted in conjunction with the double materiality assessment in 2024. This involved in-depth interviews with and surveys of investors, managers, employees, suppliers and customers. The stakeholder dialogue highlighted topics including active prevention of financial crimes such as money laundering, terrorist financing and fraud, climate change, circular economy, biodiversity, employee skills and the development of customer offerings. Despite some changes, the analysis results are consistent with previous materiality assessments. No structured stakeholder analysis was conducted in 2025. This will be carried out in 2026 as part of updating the Group’s double materiality assessment. Adjustments and changes to strategies and business models Material IROs identified through the double materiality assessment and related stakeholder dialogues will impact the Group’s strategy and business models in the medium to long term. The planning processes for managing IROs in the form of KPIs and action plans were adopted by the Board of Directors in 2024 and have been implemented according as planned. A complete overview of the Group’s KPIs and action plans pursuant to MDR-T and MDR-A can be found on page 60. The integration of these KPIs into the Group’s corporate governance has started, but had not been completed by the end of the year. Further information on the Board of Directors’ and group management’s monitoring and management of the Group’s IROs can be found in the section on Governing bodies.
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33SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION The Group’s double materiality assessment In 2024, for the first time, a double materiality assessment was conducted in line with the Corporate Sustainability Reporting Directive (CSRD) and the methodology outlined in EFRAG’s implementation guidance (IG 1) for double materiality assessments. The Group updated its double materiality assessment in 2025. This involved reassessing the gross list of sustainability-related topics. No new stakeholder dialogue was conducted. The update did not add any new material topics, but did result in some previously material topics no longer being deemed to be material. Among other things, the revised assessment reflects altered macroeconomic conditions in 2024 and 2025, as well as a more thorough assessment of some of the Group’s IROs. This applies to the following topic: • Pollution from the purchase of goods and services (ESRS E2) The Gr oup will carry out a complete update of the double materiality assessment in 2026. In addition, EFRAG is expected to issue further guidance and guidelines on double materiality assessments during the course of the year. This chapter describes how the Group’s double materiality assessment has been carried out. Double materiality is based on two dimensions: impact materiality and financial materiality. These are inter-dependent. Impact materiality How SpareBank 1 SMN impacts climate, nature, and society Financial materiality How climate, nature, and society impact SpareBank 1 SMN Double Materiality Impact materiality Impact materiality refers to the Group’s impact on climate and nature, social conditions and corporate governance. This impact may be positive or negative, actual or potential, and may stem from the Group’s own operations or its value chains. The value chain includes both suppliers (upstream value chain) and the Group’s customers (downstream value chain). The various topics were assessed based on impact severity (scale, scope and recoverability) and the likelihood of the impact occurring. Impacts are assessed with a short, medium and long time horizon. Finansiell påvirkning Financial materiality concerns how changes in the macro-picture, including changes related to climate, nature and society, could impact the Group’s financial position. Examples include revenue, market position and various types of risk. Financial materiality comprises both risks and opportunities, and can stem from own operations or the Group’s value chains. As in the case of impact materiality, the value chain encompasses the Group’s suppliers and customers. The assessment of financial materiality covers items like IT security, greenhouse gas emissions, controversial exposures and greenwashing. Opportunities linked to innovation and development of business models and customer offerings, and the Group’s role as a driver of green transition, are also considered. Risks and opportunities are assessed based on scope (financial effect), and the likelihood of the risk occurring or of the opportunity being realised. The assessments incorporate short, medium and long time horizons. Process description The Group’s process is described step-by-step to provide insight into strategic prioritisations, how the Group impacts and is impacted by various sustainability-related factors, and related risks and opportunities. The Group’s ESG Committee acted as the steering group for the process, with the CFO was the designated project owner. External consultants functioned as project managers, and internal specialists with in-depth knowledge of ESG risk and ESG reporting were involved in analysing and interpreting the results (see process steps 3–5 below). This combination added necessary capacity and expertise to the process with respect to both regulatory requirements and insight into Group operations.
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34SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION For reporting purposes, the process is divided into five steps: Step 1: Gain overview of activities, business relationships, and identify key stakeholders Sources: Competitor Analysis Value Chain Analysis Stakeholder Analysis Desk Research/Analyses Step 2: Draw up a gross List of sustainability topics Purpose: Consolidate components and results from Step 1 to create a gross list of relevant topics for SpareBank 1 SMN. Step 3: Assess Material Impact Sources: Value Chain Analysis Desk Research/Analyses Customer and Supplier Data Climate Accounting and Industry Analyses WinningTemp Step 4: Assess Financial Impact Sources: Analysis of Material Impact ERM Framework ESG Model Industry Analyses WinningTemp Step 5: Integration Purpose: Integration into ERM and strategy with associated plans, measures, and key fi gures. Identify and understand the implications for reporting. Steps 1–5 are repeated annually in the event of signifi cant changes, otherwise bi-annually. The list of sources is not exhaustive, but gives a pointer to information which has impacted the various steps. In addition, external documentation in the form of research, public reports and other data has been obtained to substantiate the assessments made. Each step is described below. Step 1: Build an overview of activities and business relationships, and identify key stakeholders The majority of the Group’s impacts are concentrated in the value chain. To gain an overview of indirect activities to which the Group contributes through the value chain, a value chain analysis is performed. In addition to providing a basis for understanding the Group’s impacts, this analysis provides input for Steps 3 and 4. The value chain analysis only examines the first-order value chain (the Group’s customers and suppliers), and not subsequent links in the value chain (for example customers’ suppliers). A stakeholder analysis is also undertaken to identify and calibrate all relevant IROs for the Group. Questionnaires are sent to numerous internal and external stakeholders (for example employees, retail customers, corporate clients, accounting clients and real estate brokerage customers), and in-depth interviews are conducted with – among others – governing bodies, the Group’s foundations, the ESG Committee, large corporate clients, the Group’s industry officers and investors. In addition, a competitor analysis is done to build an overview of competitors’ sustainability-related ambitions, objectives and strategies. The competitor analysis provides insight into current industry practice and future ambitions. Step 2: Draw up a gross list of sustainability topics The different analyses are used to compile a gross list of sustainability topics. The gross list employs a bottom-up approach. To ensure that the topics align with sector-agnostic sustainability topics in the ESRS, the gross list is reconciled with the list in ESRS 1 Appendix A, AR 16. Where topics are identified which are not on the gross list, entity-specific reporting is used in accordance with Appendix A, AR 1-5. Step 3: Assess impact Using the analysis, an assessment is made of positive and negative, actual and potential impacts throughout the value chain in order to compile a net list of the Group’s material impacts.
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35SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION The process of assessing impact materiality is illustrated below. Positive/ negative Actual/ potential Impact Value Chain Time Horizon Upstream Midstream Downstream Short-term Medium-term Long-term Assessments Total Severity Scope Possibility of Restoration Probability of Occurrence Scale Score (as a result of assessments) Results ESRS Topic Material Not material Topic Sub-topic Sub-sub-topic To ensure that only material reporting requirements are reported on, each impact is linked to one or more topics in the AR 16 list. For each identified impact, the relevant part of the value chain, and the time horizon in which it occurs, are defined. The time horizons utilised in reporting are described more fully in the General information section. The majority of the Group’s impacts will occur in the short and medium term. Impacts are assessed based on scale, scope and recoverability. Remediability is only assessed for negative impacts. Probability is only assessed if an impact is potential. • Scale refers to the degree o f negative/positive impact. A scale from one to five is employed. To establish the severity of social and governance-related impacts, qualitative assessments are employed in most cases, unless quantitative data are available. For climate and nature impacts, quantitative assessments are used. These are based on the Group’s estimated financed greenhouse gas emissions in accordance with PCAF. • Scope refers to the breadth and e xtent of an impact. A scale from one to five is used. Qualitative assessments based on scope are used for all impacts. • Remediability refers to any limits to r emediation of negative impacts on the climate, environment and/or social conditions. A scale from one to five is used. Qualitative assessments based on remediability are undertaken for all negative impacts. • Probability of occurrence ref ers to the likelihood of an impact occurring. Qualitative assessments based on probability of occurrence are carried out for all impacts. Internal analyses and stakeholder dialogue are used to secure sufficient insight into all points. A weighted score (degree of severity) determines whether an impact is material or not. The analysis shows that the Group’s financing activities account for the largest actual and potential impacts on climate, nature and society. However, this does not mean that other activities, whether in the Group’s own operations or in its upstream value chain, are immaterial.
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36SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION Step 4: Assess risks and opportunities Risks and opportunities can stem from the Group’s impacts or dependences, and risks and opportunities are therefore assessed after impacts. All identified risks and opportunities that impact, or can reasonably be expected to impact, the Group’s financial position in the short, medium or long term are assessed. The process for assessing financial materiality is illustrated below. ERM (quantita- tive/qualitative) Framework Value Chain Time Horizon Upstream Midstream Downstream Short-term Medium-term Long-term Users Financial Accounting Primary users Other stakeholders Scenario’s Two scenarios (Net zero & Current policies) Scope Probability of Occurrence Single scenario (Current policies) Scope Probability of Occurrence Results Weighted Score Non-weighted- Score Material Not Material Topic Sub-topic Sub-sub-topic ESRS Topic To ensure that only material reporting requirements are reported on, each risk and opportunity is linked to one or more topics in the AR 16 list. For each identified risk or opportunity, the relevant part of the value chain and the applicable time horizon are defined. The time horizons used are the same as in the assessment of impact materiality. The Group’s risks and opportunities arise in the short, medium and long term. In the assessment of financial materiality the scope (potential size of financial effects) and the likelihood of occurrence are assessed on a scale from one to five. The starting point is two different scenarios developed by the Network for Greening the Financial System (NGFS): • Net zero 2050: Global warming limited to 1.5 degrees through strict climate policies and innovation. Net zer o emissions are achieved. Physical risk is lower, whereas transition risk is higher. • Current policies: Emissions increase in the period to 2080, leading to a temperature increase o f 3 degrees. Net zero emissions are not achieved. Physical risk is very high and brings irreversible changes. Transition risk is lower. For risks and opportunities where the difference between the scenarios materially impacts the assessments of scope and probability, both scenarios are taken into account. For risks and opportunities where the difference between the scenarios does not impact the assessments of scope and probability, only Current policies is assessed, as it is a more representative portrayal of the current situation. When assessing the financial materiality of risks and opportunities, differentiated threshold values are utilised. Threshold values linked to a given risk or opportunity are dependent on whether or not the type of risk or opportunity that arises or is realised is of an operational or commercial nature. For operational risks and opportunities, the bank’s framework for operational risk is utilised. When defining and assessing commercial risks and opportunities, the Group has adopted the external auditor’s financial materiality thresholds for the financial year 2023. This is because these thresholds are designed to prevent the omission of decision-useful information. The score is weighted when both scenarios are used, or based solely on the Current policies scenario, and determines whether a risk or opportunity is material or not. The Group has defined ESG risk as a driver of traditional risk types. ESG risk serves to nuance assessments of the different risk types. Step 5: Integrate into strategies, risk management and reporting Based on the analyses of impact materiality and financial materiality, an overview is drawn up of areas which support achievement of the Group’s strategic priorities. These comprise IROs which are subject to a significant level of innovation and development. In addition, assumptions and drivers are identified which support the Group’s operations. These comprise IROs which are subject to a significant level of quality improvement
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37SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION 37 and monitoring. Several of the Group’s IROs have already been integrated into business models and strategies. This applies, for example, to IROs related to financial crime, the Group’s employees, and consumers and end users. Other IROs require further integration and adjustment. Work in this regard continued in 2025. The results are highly consistent with the results of previous materiality assessments, although greater attention was given to topics such as biodiversity and circular economy in the updated double materiality assessment. The Group’s material topics are illustrated in the table below. Topics Strategically relevant topics Environment Climate Change Pollution Biodiversity and Ecosystems Circular Economy and Resource Use Consumers and end-users Social Inclusion Access to quality information Prevention of fraud Governance Combating money laundering, terrorist fi nancing and corruption Topics Key enablers and drivers The Group’s employees Safety, remuneration, working time, work environment Diversity and inclusion Professional development and competence Workers in the value chain Working- and human rights. Governance Business culture Data- and cyber-security Data- and cyber-security Community dividend1 Community dividend Topics Strategically relevant topics Environment Climate Change Pollution Biodiversity and Ecosystems Circular Economy and Resource Use Consumers and end-users Social Inclusion Access to quality information Prevention of fraud Governance Combating money laundering, terrorist fi nancing and corruption Topics Key enablers and drivers The Group’s employees Safety, remuneration, working time, work environment Diversity and inclusion Professional development and competence Workers in the value chain Working- and human rights. Governance Business culture Data- and cyber-security Data- and cyber-security Community dividend1 Community dividend 1) Reporting related to community dividend is entity-specific (ES). This is further described under the chapter on Social. IROs related to climate change and pollution are closely interlinked, and concern energy consumption and greenhouse gas emissions from own operations and in the Group’s value chains, as well as value-chain pollution to air, water and earth. Biodiversity and ecosystems also play out in the value chain, where IROs are largely centred around the Group’s downstream activities. Circular economy and resource use are regarded as a solution strategy for mitigating climate change and preventing biodiversity and ecosystem loss. IROs are also centred in the Group’s value chain in this context, and particularly in downstream activities. As previously, the fight against money laundering, terrorist financing and corruption has been identified as strategically important. This is consistent with earlier materiality assessments, and represents a natural link with the financial industry and fraud-related developments in recent years. Social inclusion and customer access to quality information support all strategic focus areas. This involves developing and providing access to products and services for disadvantaged retail customers. It also includes ensuring that the Group avoids greenwashing and provides customers with reliable and accurate information on various topics through the Group’s market communications. Additionally, the Group aims to help prevent fraud affecting its customers, an increasingly pressing issue for customers, society and the financial system as a whole. The Group’s key enablers and drivers include its employees, workers in the value chain, corporate governance, data security, cybersecurity and the community dividend . IROs in these areas include data protection, professional development, diversity and working conditions for employees, as well as human rights in the value chain.
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38SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION Material impacts, risks and opportunities The table to the left and on the next page present the Group’s IROs, where in the value chain they are centred, their applicable time horizons and which standards contain relevant reporting requirements. Impacts Value chain Time horizons Standard Energy consumption from lending Negative Downstream Medium, long E1 Energy consumption from own operations Negative Own operations Medium, long E1 Financed and invested emissions Negative Downstream Medium, long E1 Emissions from procurement of goods and services Negative Upstream Medium, long E1 Financed pollution to air, water, and soil Negative Downstream Medium, long E2 Direct impact factors on biodiversity loss Negative Downstream Long E4 Impacts on state of species Negative Downstream Long E4 Waste Negative Downstream Medium, long E5 Resource use Negative Upstream Medium, long E5 Working conditions Positive and Negative Own operations Short, medium S1 Inequality and discrimination Negative Own operations Short, medium S1 Professional development Positive Own operations All S1 Diversity and inclusion Positive Own operations Short, medium S1 Working conditions Negative Upstream Downstream Medium, long S2 Breaches of personal data protection Negative Downstream All S4 Fraud Negative Downstream All S4 Lack of social inclusion Negative Downstream All S4 Access to quality information Positive Downstream All S4 Regional contributor Positive Downstream All Community dividend Corruption and bribery Negative Own operations Downstream All G1 Money laundering and terrorist fi nancing Negative Own operations Downstream All G1 Poor data and cybersecurity Negative Upstream Own operations Medium, long G1 Poor animal welfare Negative Downstream Medium, long G1 Risks Value chain Time horizons Standard Credit risk in the loan portfolio Downstream Medium, long E1, E2, E4, E5 Defi cient ESG data, quality, and insight Upstream Downstream Medium, long E1, E2, E4, E5 Reduced access to or increased prices of goods and services Upstream Medium, long E1 Loss of customers to ESG requirements Downstream Short, medium E1, E2, E4, E5 Lack of sustainability competence Own operations Medium, long S1 Inability to attract competent people Own operations Short, medium S1 Increased sick absence Own operations All S1 Breaches of labour and human rights in the value chain Upstream Downstream Medium, long S2 Greenwashing Downstream Medium, long S4 Poor protection of personal data, including personal and customer information Downstream All S4 Poor processes for combating fraud Downstream All S4 Poor processes for combating money laundering and terrorist fi nancing Own operations Downstream All G1 Disloyal employees Own operations All G1 Breaches of IT security Own operations All G1 Breaches of legislation All All G1 Unrealistic ambitions Own operations Long G1 Opportunities Value chain Time horizons Standard Increased innovation and development of business models and customer off ering Downstream Short, medium-long E1, E4, E5 The role of driver of the green transition All Short, medium-long E2, E4, G1 Major operator All All S1 Focus on mental health Own operations All S1 Focus on diversity and inclusion Own operations Short, medium S1 Local presence and identity Downstream All S4
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39SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION The analyses (Steps 3 and 4) and the results above must be incorporated into the Group’s risk management and strategy processes. The reports integrate standards which regulate the Group’s material IROs. These standards are ESRS E1, E2, E4, E5, S1, S2, S4 and G1. Although the Group’s sustainability statement integrates eight out of ten topic-specific standards, it does not cover all reporting requirements in the standards. Only material reporting requirements are integrated into reports. For IROs concerning the community dividend, cybersecurity, fraud, money laundering and terrorist financing, entity-specific reporting requirements have been developed in line with ESRS 1 AR 1-5. Entity-specific reports are described below. Chapter Sub-chapter Social Community dividend Consumers and end-users Anti-fraud Consumers and end-users Data protection Business conduct Anti-money laundering and anti-terrorist financing Business conduct Cybersecurity Internal controls and decision-making processes Important clarifications and issues are checked with internal specialists and external consultants to ensure relevance and objectivity. Decisions are made at weekly status meetings with the steering group, as well as other meetings with group management and internal and external specialists. Decision-making on further strategic steps based on analyses and results is integrated into the annual activity plans of the governing bodies and the Group’s strategy work. Topic-specific assessments of impacts, risks and opportunities When identifying and assessing IROs linked to climate change, pollution, biodiversity, ecosystems, resource use, circular economy and business practices, the Group adopts the general assumptions in Steps 1 to 5 above. Climate-related IROs For several years, the Group has analysed financed greenhouse gas emissions in line with the Partnership for Carbon Accounting Financials (PCAF) to gain insight into climate-related impacts of the Group’s loan portfolios. These estimates are utilised together with data and insights from the Group’s climate accounts relating to Scopes 1, 2 and 3 (upstream). Working groups, in-depth interviews and other international and national reports are also utilised to assess the Group’s climate-related IROs. Climate-related IROs are assessed for the entire value chain and the Group’s own operations. The most material IROs arise in relation to loan portfolios and customers. Downstream has been identified as the stage where the Group has the greatest opportunity to impact – and to be impacted by – climate. However, this does not mean that the Group has failed to assess the supplier chain and its own operations. In addition to the sources of data and insights mentioned above, all IROs are assessed based on two NGFS scenarios: one high-emissions scenario (“Current policies”) and one low-emissions scenario (“Net zero”). The Group’s transition plans are designed to support an orderly transition (“Net zero”), but also to prepare the Group for a disorderly transition and the high-emissions scenario (“Current policies”). The Group’s analyses focus primarily on the downside scenario. The scenarios and the reasons for their inclusion in the assessment of IROs are described below. The scenarios represent the Group’s objective of achieving net zero by 2050 (“Net zero”), and the current situation “(Current policies”). Both scenarios represent various consequences in the short, medium and long term. Net-Zero Global warming is limited to 1.5 degrees with little or no exceedance due to strict climate policies and innovation. Net zero emissions are expected to be achieved by 2050. In this scenario, physical risk is relatively low. Transition risk, however, is higher due to more frequent technology changes and speedier changes in market preferences, and greenhouse gas emissions need to be cut substantially over a short space of time. This scenario is in the border zone between an orderly and a disorderly scenario, and provides insight into the consequences of orderly versus disorderly transition for the economy and the industries to which the Group is exposed. Climate-related transition events are assessed implicitly when this scenario is used. Current policies Only current regulatory measures and policies are implemented. Emissions rise in the period to 2080, leading to a temperature increase of 3 degrees and increased physical risk. Emissions cause irreversible climate change. This scenario enables the Group to assess the long-term physical risks facing the economy. Climate-related impacts are assessed at industry level by examining challenges facing industries, and their emission sources. Risks and opportunities are assessed based on various analyses as described more fully in the section on Climate change. Physical risk and transition risk are assessed for the Group’s portfolios of loans to both retail and corporate clients. Quantitative and qualitative analyses pursuant to TCFD (Task Force on Climate-related Financial Disclosures) standards are used to assess physical risk and transition risk. The analyses are constantly updated to evaluate risk relevant to the
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40SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GENERAL INFORMATION Group’s loan portfolios. The analyses are based on two NGFS scenarios: “Current policies” and “Net zero” at industry level. The industries represent various types of physical risk and transition risk (including transition events), extending over short, medium and long time horizons. For example, the majority of the Group’s exposure to physical climate risk is centred round buildings financed by the Group. Transition risk is mainly centred round specific industries (e.g. shipping, agriculture and offshore), as well as residential and commercial property. In addition to previous TCFD analyses, use is made of data and insights from the SpareBank 1 Alliance’s ESG model and stress testing of ESG risk to assess risk and opportunities. Other climate-related risks and opportunities are assessed based on public and internal sources. Pollution-related IROs No assessment has been undertaken of the Group’s locations with regard to pollution- related IROs. This is covered by the assessments related to own operations and energy consumption as described under Climate-related IROs. Assessments of commercial activities where pollution is a material IRO are based on public sources, internal documentation and in-depth interviews with the Group’s industry officers. Pollution is identified as a material impact in several industries financed by the Group. Pollution-related risks and opportunities often relate to climate change and biodiversity and ecosystems. IROs related to water and marine resources The impact and dependency of the Group’s locations on water and marine resources are deemed to be immaterial. Assessments have been carried out of how the Group’s value chains are impacted by risks and opportunities linked to water and marine resources. Water consumption by, for example, data centres has been considered, but was concluded to be immaterial. Biodiversity and ecosystem-related IROs No assessments have been made of whether the Group’s locations are situated in, or adjacent to, areas that are biodiversity-sensitive. The Group’s own operations do not contribute to the degradation of natural habitats or species’ habitats, or to the disturbance of species present in protected areas. It has not been assessed whether it is necessary to implement measures to reduce biodiversity loss in the areas where the Group is located. Identification and assessment of impacts is based on the Group’s commercial activities and input factors. This refers, for example, to purchases of IT equipment and loans to retail customers or related to commercial property or agriculture. Most industries financed by the Group are dependent on natural diversity and well- functioning ecosystems, either directly or indirectly, and are thus mutually inter-dependent when it comes to minimising systemic risk. No in-depth assessments have been undertaken of inter-dependencies between the various industries beyond the fact that dependencies are known to be a source of additional risk. Systemic risk has not been assessed or analysed further. Biodiversity and ecosystem-related risks and opportunities have been assessed on the same basis as climate-related risks and opportunities. IROs related to resource use and circular economy Assessments of commercial activities and industries in which resource use and circular economy constitute material IROs are based on public sources, internal documentation and in-depth interviews with industry officers. Impacts have been identified as material in the Group’s value chains. In the downstream value chain, impacts are considered material due to the Group’s exposure to several resource-intensive and waste-generating industries. Upstream, impacts are considered material based on the Group’s purchases of goods and services. The risks and opportunities relate to climate change, biodiversity and ecosystems, and have been identified using, for example, data sources and insights from TCFD analyses, the ESG model and stress testing. IROs related to business conduct Public sources, internal documentation and in-depth interviews with group management and industry officers are among the resources utilised to identify IROs related to business conduct. The Group is dependent on trust, and is subject to regulatory requirements related to anti-money laundering and anti-terrorist financing. It also has to manage an increasing volume of fraud. The trust enjoyed by the Group is also linked to its handling of potential corruption and bribery. This is reflected in its business culture, processes, procedures and its societal role in its region.
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41SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX ESRS-index The table below shows SpareBank 1 SMN’s reporting for 2025 in accordance with the Corporate Sustainability Reporting Directive (CSRD) and the associated European Sustainability Reporting Standards (ESRS). Entity-specific reporting in line with ESRS 1 Appendix A AR 1-5 is presented in the table with a self-defined indicator. In cases where other reporting standards have been used due to the absence of guidelines in ESRS, this is noted under the ”Indicator” column. Not all material AR requirements are listed in the table below. They have been adhered to the extent they are deemed material. Disclosure requirements Indicator Description Description in annual report GENERAL INFORMATION (ESRS 2) Basis for preparation (BP) BP-1 5a Consolidated or individual preparation Basis for preparation of the sustainability statement BP-1 5b Confirmation of consistent consolidation basis as financial statements Basis for preparation of the sustainability statement BP-1 5c Inclusion of upstream and downstream value chain Basis for preparation of the sustainability statement BP-2 9 Deviations from time horizons defined in ESRS 1 section 6.4 Time horizons BP-2 10 Key metrics containing value chain data estimated using indirect sources Value chain information BP-2 11 Sources of estimation and outcome uncertainty Comparative information, estimation uncertainty and limitations BP-2 12 Uncertainty in forward-looking information Comparative information, estimation uncertainty and limitations BP-2 13 Changes in preparation or presentation of information Changes in sustainability reporting and correction of priod period errors BP-2 14 Correction of prior period errors Changes in sustainability reporting and correction of priod period errors BP-2 15 References to other parts of the report References to other parts of the sustainability statement BP-2 16 Disclosures required by other legislation References to other reporting Governance (GOV) GOV-1 21 Composition and diversity of governing bodies Governance GOV-1 22 Roles and responsibilities of governing bodies in managing IRO Governance
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42SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report GOV-1 23 Governing bodies’ competence on sustainability issues, their availability, or planned development Governance GOV-2 26a Frequency of updates to governing bodies on material impacts, risks, and opportunities (IRO), implementation of due diligence, and effectiveness of policies, actions, key metrics, and targets Governance GOV-2 26b Assessment of material IRO in strategy setting, transaction decisions, and risk management Governance GOV-2 26c Overview of material topics addressed by governing bodies during the reporting period Governance GOV-3 29 Governing bodies’ incentive schemes and compensation related to sustainability References to other reporting GOV-4 30 Sustainability due diligence Due diligence assessments related to sustainability GOV-5 36 Key components of risk management and internal controls related to sustainability reporting Risk management and internal control of sustainability reporting Strategy (SBM) SBM-1 40a Significant products, services, markets, customer groups, and employee count References to other parts of the sustainability statement SBM-1 40e Targets related to specific products, services, markets, customer groups, geographic areas, or stakeholder relations References to other parts of the sustainability statement SBM-1 40f Assessment of current products, services, markets, and customer groups in relation to set targets References to other parts of the sustainability statement SBM-1 40g Strategic elements related to sustainability References to other parts of the sustainability statement SBM-1 42a Input and process for collecting, developing, and ensuring input Strategy SBM-1 42b Outputs and outcomes in terms of current and expected benefits for customers, investors, and other stakeholders Strategy SBM-1 42c Key features of the value chain, position in the value chain, and description of important business relationships (suppliers, customers, distribution channels, and end-users) and their relation to the business Strategy SBM-2 45a Interaction with stakeholders Stakeholder dialogue in SpareBank 1 SMN SBM-2 45b Company’s understanding of conducted stakeholder dialogue Stakeholder dialogue in SpareBank 1 SMN SBM-2 45c Adjustments to strategy and/or business model Stakeholder dialogue in SpareBank 1 SMN SBM-2 45d Whether and how governing bodies are informed Stakeholder dialogue in SpareBank 1 SMN SBM-3 46 Integration of material impacts, risks, and opportunities into strategy and business model In each material standard Approach to the topic Management of impacts, risks and opportunities (IRO) IRO-1 53a Methodology and assumptions in identifying impacts, risks, and opportunities The Group’s double materiality assessment Process description Step 1: Gain overview of activities and business relationships, and identify key stakeholders Step 3: Assess impact
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43SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report IRO-1 53b Process related to identification, assessment, prioritization, and monitoring of potential and actual impacts on people and the environment The Group’s double materiality assessment Step 3: Assess impact IRO-1 53c Process related to identification, assessment, prioritization, and monitoring of risks and opportunities that have or may have financial effects The Group’s double materiality assessment Step 4: Assess risk and opportunities IRO-1 53d Process related to decision-making and internal controls The Group’s double materiality assessment Internal control and decision-making process IRO-1 53e Whether and how processes related to identification, assessment, and management of impacts and risks are integrated into overall risk management The Group’s double materiality assessment Step 4: Assess risk and opportunities IRO-1 53f Whether and how processes related to identification, assessment, and management of opportunities are incorporated into corporate governance The Group’s double materiality assessment Steg 5: Integrate into strategy, risk management and reporting IRO-1 53g Input parameters used in the process of identifying, assessing, and managing material impacts, risks, and opportunities The Group’s double materiality assessment Process description IRO-1 53h Changes in the process of identifying, assessing, and managing impacts, risks, and opportunities compared to previous years The Group’s double materiality assessment IRO-2 56 List of data points originating from other EU legislation and information on where they can be found in the sustainability report List of data points stemming from other EU legislation IRO-2 56 List of ESRS reporting requirements stemming from the double materiality analysis ESRS-index IRO-2 56 Explanation of how material information related to material impacts, risks, and opportunities has been determined The Group’s double materiality assessment Steg 5: Integrate into strategy, risk management and reporting SECTOR AGNOSTIC INFORMATION Environmental (ESRS E1 - E5) Climate change (ESRS E1) ESRS 2 GOV-3 13 Whether and how climate-related considerations influence governing bodies’ compensation, including targets for greenhouse gas (GHG) emission reduction and the proportion of compensation in the current period linked to such considerations References to other reporting ESRS 2 SBM-3 48b Current and expected effects of the most significant impacts, risks, and opportunities on business model, value chain, strategy, and decisions, and how the company responds or plans to respond Assessment of climate-related IROs ESRS 2 SBM-3 48c How negative impacts actually or potentially affect people or the environment, their sources, and impacts caused by the type of activities and business relationships the company is involved in Impacts on climate change ESRS 2 SBM-3 48d Current financial effects on financial position, performance, and cash flows, and material risks and opportunities that may affect the carrying value of assets or liabilities during the upcoming reporting period Climate-related risks and opportunities ESRS 2 SBM-3 48e Expected financial effects of the most significant risks and opportunities on financial position, performance, and cash flows over the short, medium, and long term Climate-related risks and opportunities E1-1 16a Description of how the company’s targets are aligned with the Paris Agreement’s 1.5 °C goal. The Group’s climate transition plan
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44SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report E1-1 16b Description of the identified decarbonisation levers and planned key actions, including changes in the product range and technological changes in own operations, upstream, or downstream. The Group’s climate transition plan E1-1 16c Description and quantification of investments and funding that support the company’s implementation of the transition plan. The Group’s climate transition plan E1-1 16d Qualitative assessment of locked-in GHG emissions from assets and products. The Group’s climate transition plan E1-1 16g Whether the company is excluded from the EU Paris-aligned benchmarks or not. The Group’s climate transition plan E1-1 16h Description of how the transition plan is integrated with and aligned to the business strategy and financial planning. The Group’s climate transition plan E1-1 16i Whether the transition plan has been approved by the governing bodies. The Group’s climate transition plan E1-1 16j The company’s progress in implementing the transition plan. The Group’s climate transition plan E1-SBM-3 18 For each identified climate risk, explain whether it is a physical risk or a transition risk Climate-related risks and opportunities E1-SBM-3 19 Describe the resilience of the company’s strategy and business model Climate-related risks and opportunities E1-IRO-1 20 Process related to identification and assessment of climate-related impacts, risks, and opportunities The Group’s double materiality assessment Topic-specific assessments of IROs E1-IRO-1 21 Explain how climate-related scenarios are used in identifying physical risk, transition risk, and opportunities over the short, medium, and long term The Group’s double materiality assessment Topic-specific assessments of IROs E1-2 24 Minimum disclosure requirement - policy (MDR-P) Policies E1-2 25 Whether and how policies address climate change, climate adaptation, energy efficiency, renewable energy, or other relevant topics Policies E1-3 28 Minimum disclosure requirement - actions (MDR-A) Actions plans and initiatives E1-3 29a Measures and actions to address climate change and decarbonization levers Actions plans and initiatives E1-3 29b Achieved and expected emission reductions from measures and actions Actions plans and initiatives E1-4 32 Minimum disclosure requirement - targets (MDR-T) Targets and KPI’s E1-4 33 Link between emission reduction targets and climate-related impacts, risks, and opportunities Targets and KPI’s E1-4 34a Reduction targets in absolute and intensity values (if relevant) Targets and KPI’s E1-4 34b Reduction targets for scope 1, 2, and 3 (either separately or combined) Targets and KPI’s E1-4 34c Base year and base value Targets and KPI’s E1-4 34d Targets for 2030 and potentially 2050 Targets and KPI’s E1-4 34e Science-based and compatible with limiting global warming to 1.5 degrees. describe framework and methodology Targets and KPI’s E1-4 34f Decarbonization levers and quantitative contribution to reduction target Targets and KPI’s E1-5 37 Company’s energy consumption and energy mix Note 3: Energy consumption E1-6 48 Gross greenhouse gas (GHG) emissions (scope 1) Note 4: GHG-emissions from own operations E1-6 49 Gross greenhouse gas (GHG) emissions (scope 2 - location- and market-based) Note 4: GHG-emissions from own operations E1-6 51 Gross greenhouse gas (GHG) emissions (scope 3) Note 5: GHG-emissions from the value chain E1-6 52 Total gross greenhouse gas (GHG) emissions (location- and market-based) Note 6: Total GHG-emissions
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45SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report E1-6 53 Emission intensity (total GHG emissions per net revenue) Note 7: GHG-intensity E1-6 55 Reconciliation with financial statements Note 7: GHG-intensity E1-9 66 Expected financial effects due to significant climate-related physical risk Note 8: Financial risks and opportunities from climate change and adaptation E1-9 67 Expected financial effects due to significant climate-related transition risk Note 8: Financial risks and opportunities from climate change and adaptation E1.9 68 Reconciliation with relevant assets, liabilities, revenue items, and/or other relevant financial statement line items Note 8: Financial risks and opportunities from climate change and adaptation E1-9 69 Expected financial effects due to climate-related opportunities Note 8: Financial risks and opportunities from climate change and adaptation Pollution (ESRS E2) ESRS 2 SBM-3 48b Current and expected effects of the most significant impacts, risks, and opportunities on the business model, value chain, strategy, and decision-making, as well as how the company responds or plans to respond. Assessment of pollution-related impacts and risks ESRS 2 SBM-3 48c How negative impacts actually or potentially affect people or the environment, where these impacts originate from, and the impacts caused by the types of activities and business relationships the company is involved in. Impacts on pollution ESRS 2 SBM-3 48d Current financial effects on financial position, performance, and cash flows, as well as significant risks and opportunities that may affect the balance sheet value of assets or liabilities during the upcoming reporting period. Pollution-related risks ESRS 2 SBM-3 48e Expected financial effects of the most significant risks and opportunities on financial position, performance, and cash flows over the short, medium, and long term. Pollution-related risks E2-1 14 Minimum Disclosure Requirement - Policy (MDR-P) Policies E2-1 15a Whether and how policies ensure the minimization of negative impacts related to pollution of air, water, and soil. Policies E2-2 18 Minimum Disclosure Requirement - Actions (MDR-A) Actions plans and initiatives E2-2 AR13 In cases where measures affect the value chain, include information on which measures are taken and their type. Actions plans and initiatives E2-3 22 Minimum Disclosure Requirement - Targets (MDR-T) Targets and KPIs E2-3 23 Whether and how the targets relate to the prevention and control of pollution to air, water, and soil, as well as respective quantities and substances of concern and high concern. Targets and KPIs E2-3 25 Whether pollution-related targets are legally required or not. Targets and KPIs E2-6 39a Quantitative and qualitative information on expected financial effects of pollution-related risks and opportunities. Note 1: Financial risks as a result of pollution E2-6 39b Assessment of effects, related impacts, and the time horizons in which the financial effects are expected to occur. Note 1: Financial risks as a result of pollution E2-6 39c Critical assumptions and sources of estimation uncertainty. Note 1: Financial risks as a result of pollution E2-6 41 Significant events where pollution had a negative impact on the environment and/or is expected to have a negative effect on cash flows, financial position, or financial performance. Note 1: Financial risks as a result of pollution
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46SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report Biodiversity and ecosystems (ESRS E4) ESRS 2 SBM-3 48b Current and expected effects of the most significant impacts, risks, and opportunities on the business model, value chain, strategy, and decision-making, as well as how the company responds or plans to respond. Assessment of IROs related to biodiversity and ecosystems ESRS 2 SBM-3 48c How negative impacts actually or potentially affect people or the environment, where these impacts originate from, and the impacts caused by the types of activities and business relationships the company is involved in. Impacts on biodiversity and ecosystems ESRS 2 SBM-3 48d Current financial effects on financial position, performance, and cash flows, as well as significant risks and opportunities that may affect the balance sheet value of assets or liabilities during the upcoming reporting period. Risks and opportunities linked to biodiversity and ecosystems ESRS 2 SBM-3 48e Expected financial effects of the most significant risks and opportunities on financial position, performance, and cash flows over the short, medium, and long term. Risks and opportunities linked to biodiversity and ecosystems E4-1 13 Resilience in current business models and strategy related to biodiversity and ecosystem-related physical, transitional, and systemic risks and opportunities. The Group’s nature strategy E4-2 22 Minimum Disclosure Requirement - Policy (MDR-P) Policies E4-2 23 Whether and how the policy(ies) relate to significant impacts, dependencies, physical risks, transition risks, systemic risks, production, sourcing, and consumption from ecosystems, as well as the social consequences of identified impacts. Policies E4-2 24 Whether policies or practices for sustainable land and agriculture are maintained and whether policies address deforestation. Policies E4-3 27 Minimum Disclosure Requirement - Actions (MDR-A) Action plans and initiatives E4-3 28 Biodiversity offsets used in action plans. Action plans and initiatives E4-4 29 Minimum Disclosure Requirement - Targets (MDR-T) Targets and KPIs E4-4 32 Ecological thresholds, alignment with international or national strategies, linkage to IDRO in own operations and value chain, biodiversity offsets, and the mitigation hierarchy. Targets and KPIs E4-6 45a Quantitative and qualitative information on expected financial effects of risks and opportunities related to biodiversity and ecosystems. Note 1: Financial risks and opportunities as a result of biodiversity and ecosystems E4-6 45b Assessment of effects, related impacts, and the time horizons in which the financial effects are expected to occur. Note 1: Financial risks and opportunities as a result of biodiversity and ecosystems E4-6 45c Critical assumptions and sources of estimation uncertainty. Note 1: Financial risks and opportunities as a result of biodiversity and ecosystems E4-6 AR39 How amounts are estimated and critical assumptions. Note 1: Financial risks and opportunities as a result of biodiversity and ecosystems Resource use and circular economy (ESRS E5) ESRS 2 SBM-3 48b Current and expected effects of the most significant impacts, risks, and opportunities on business model, value chain, strategy, and decisions, and how the company responds or plans to respond Assessment of IROs related to resource use and circular economy ESRS 2 SBM-3 48c How negative impacts actually or potentially affect people or the environment, their sources, and impacts caused by the type of activities and business relationships the company is involved in Impacts on resource use and circular economy ESRS 2 SBM-3 48d Current financial effects on financial position, performance, and cash flows, and material risks and opportunities that may affect the carrying value of assets or liabilities during the upcoming reporting period Risks and opportunities related to resource use and circular economy
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47SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report ESRS 2 SBM-3 48e Expected financial effects of the most significant risks and opportunities on financial position, performance, and cash flows over the short, medium, and long term Risks and opportunities related to resource use and circular economy E5-1 14 Minimum disclosure requirement - policy (mdr-p) Policies E5-2 19 Minimum disclosure requirement - actions (mdr-a) Action plans and initiatives E5-3 23 Minimum disclosure requirement - targets (mdr-t) Targets and KPIs E5-3 24 How the objective relates to circular design, circular resource usage rate, minimization of raw material consumption, reversal of resource depletion, or other areas related to resource use and circular economy Targets and KPIs E5-4 30 Information on resource supply Note 1: Resource use E5-4 31 Total weight of products used during the reporting period Note 1: Resource use E5-4 32 Calculation methodology and key assumptions Note 1: Resource use E5-4 AR25 How double counting is avoided Note 1: Resource use E5-6 43a Quantitative and qualitative information on expected financial effects of risks and opportunities related to biodiversity and ecosystems Note 2: Financial risks and opportunities as a result of resource use and circular economy E5-6 43b Assessed effects, related impacts, and the time horizons in which the financial effects are expected to occur Note 2: Financial risks and opportunities as a result of resource use and circular economy E5-6 43c Critical assumptions and sources of estimation uncertainty Note 2: Financial risks and opportunities as a result of resource use and circular economy E5-6 AR35 Definition of time horizons, amount estimation, and critical assumptions Note 2: Financial risks and opportunities as a result of resource use and circular economy Social (S1 - S4) Own workforce (ESRS S1) ESRS 2 SBM-2 12 How workers’ interests, views, and rights, including human rights, are safeguarded in strategy and business models Stakeholder dialogue in SpareBank 1 SMN ESRS 2 SBM-3 48b Current and expected effects of the most significant impacts, risks, and opportunities on business model, value chain, strategy, and decisions, and how the company responds or plans to respond Assessment of IROs related to employees ESRS 2 SBM-3 48c How negative impacts actually or potentially affect people or the environment, their sources, and impacts caused by the type of activities and business relationships the company is involved in Impacts on employees ESRS 2 SBM-3 48d Current financial effects on financial position, performance, and cash flows, and material risks and opportunities that may affect the carrying value of assets or liabilities during the upcoming reporting period Risks and opportunities related to employees ESRS 2 SBM-3 48e Expected financial effects of the most significant risks and opportunities on financial position, performance, and cash flows over the short, medium, and long term Risks and opportunities related to employees ESRS 2 SBM-3 13 Whether and how actual and potential impacts originate, are linked to, and adapt to strategy and business model, as well as the connection between impacts, risks, and opportunities Assessment of IROs related to employees ESRS 2 SBM-3 14a Types of employees and non-employees subject to significant impacts Assessment of IROs related to employees ESRS 2 SBM-3 14b Significant events with negative impact Approach to the topic
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48SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report ESRS 2 SBM-3 14c Activities that result in positive impacts and types of employees and non-employees affected or potentially affected Impacts on employees ESRS 2 SBM-3 14d Significant risks and opportunities arising from impacts and dependencies on the company’s workforce Assessment of IROs related to employees ESRS 2 SBM-3 14e Significant impacts that may arise due to transition plans intended to reduce negative impacts on climate and nature Impacts resulting from the Group’s transition plan for climate and environment ESRS 2 SBM-3 14f Tasks with significant risk of forced labor Assessment of IROs related to employees ESRS 2 SBM-3 14g Tasks significantly at risk of child labor Assessment of IROs related to employees ESRS 2 SBM-3 15 Developed understanding of how individuals in the company’s workforce with different traits, contexts, or job tasks may be particularly vulnerable to negative impacts Approach to the topic ESRS 2 SBM-3 16 Risks and opportunities related to specific employee groups Assessment of IROs related to employees S1-1 19 Minimum disclosure requirement - policy (MDR-P) Policies S1-1 20 Relevant commitments to human rights, approach to human and labor rights, engagement, and remediation of the company’s workforce Policy on protecting fundamental human rights and decent working conditions S1-1 21 Whether and how policies align with international standards and guidelines Policies S1-1 22 Policies explicitly addressing human trafficking, forced labor, or child labor Policy on protecting fundamental human rights and decent working conditions S1-1 23 Health and safety system(s) for managing and preventing work-related injuries Policies on health, environment and safety S1-1 24 Anti-discrimination policy, covered grounds for discrimination, specific commitments to inclusion or other measures for affected employees, whether and how policies are implemented Discrimination policy S1-2 27 Whether and how employee perspectives inform decisions or activities aimed at addressing actual or potential impacts Employee dialogue S1-2 27a How employee dialogue is conducted Employee dialogue S1-2 27b Steps, type, and frequency of employee dialogue Employee dialogue S1-2 27c Role responsible for ensuring dialogue occurs and that results are used in the approach to dialogue, and the function of this role Employee dialogue S1-2 27d Commitment to internationally recognized agreements or other agreements regarding human rights Employee dialogue S1-2 27e Assessment of the effectiveness of dialogue with employees Employee dialogue S1-2 28 Steps taken to gain insight into perspectives of employees particularly vulnerable to impacts Employee dialogue S1-3 32a General approach and processes for providing or contributing to remediation in cases where the company has caused or contributed to significant negative impacts on its workforce Concerns and whistleblowing channels S1-3 32b Specific channels in place where employees can express concerns or needs directly Concerns and whistleblowing channels S1-3 32c Mechanisms for handling issues related to employees Concerns and whistleblowing channels S1-3 32d Availability of various channels Concerns and whistleblowing channels
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49SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report S1-3 32e Monitoring and tracking concerns or reports submitted and addressed, and how the effectiveness of channels is ensured Concerns and whistleblowing channels S1-3 33 Whether and how the company has assessed if its workforce is aware of and trusts the structures or processes related to concerns and reporting channels, including policies protecting against retaliation Concerns and whistleblowing channels S1-4 37 Minimum disclosure requirement - actions (MDR-A) Action plans and measures S1-4 38a Implemented and planned measures to minimize negative impacts Action plans and measures S1-4 38b Whether and how measures have been implemented to provide or enable remediation Action plans and measures S1-4 38c Description of initiatives or actions aimed at positively impacting employees Action plans and measures S1-4 38d Effectiveness of measures and follow-up on this Action plans and measures S1-4 39 Processes for identifying necessary measures and responses to actual or potential negative impacts Action plans and measures S1-4 40 Planned and ongoing measures to reduce risks and promote opportunities related to workforce impacts and dependencies, and monitoring effectiveness Action plans and measures S1-4 41 How the company ensures that current practices do not negatively impact employees Action plans and measures S1-4 43 Resources allocated for managing significant impacts Action plans and measures S1-4 AR37 Whether and how actual impacts are considered in terminating business relationships and how negative impacts from potential terminations are addressed Action plans and measures S1-5 46 Minimum disclosure requirement - targets (MDR-T) Targets and KPIs S1-5 47 Process for setting targets, whether employees have been involved in setting, measuring, and identifying improvements or lessons learned Targets and KPIs S1-6 50a Employees (number and average) Note 1: Own employees S1-6 50b Employees by contract type and gender (number and average) Note 1: Own employees S1-6 50c Employees who have left the company (number and percentage) Note 1: Own employees S1-6 50d Methodology for data collection, aggregation, and presentation Note 1: Own employees S1-6 50e Definition of employees Note 1: Own employees S1-6 50f Cross-references to financial statements Note 1: Own employees S1-6 AR59 Methodology for calculating turnover Note 1: Own employees S1-7 55a Non-employees (number and average) divided into temporary and self-employed workers Note 1: Own employees S1-7 55b Methodology for data collection, aggregation, and presentation Note 1: Own employees S1-7 55c Explanation of changes if relevant Note 1: Own employees S1-7 56 Most common type of non-employee Note 1: Own employees S1-7 AR65 Necessary contextual information Note 1: Own employees S1-8 60 Percentage of employees covered by collective bargaining agreements Worker rights S1-8 63 Percentage of employees with a workers’ representative Worker rights S1-9 66a Gender and age distribution in top management (number and percentage) Note 2: Position level and age distribution
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50SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report S1-9 66b Gender and age distribution in the rest of the workforce (number and percentage) Note 2: Position level and age distribution S1-9 AR71 Definition of top management Note 2: Position level and age distribution S1-10 69 Sufficient wage in accordance with relevant comparison Remuneration S1-10 70 Percentage of employees without sufficient wage in accordance with relevant comparison Remuneration S1-11 74 All employees covered by social benefits schemes Worker rights S1-12 77 Employees with disabilities Worker rights S1-12 AR76 Necessary contextual information Worker rights S1-13 83a Evaluation of results and career development Worker rights S1-13 83b Average training hours per employee by gender Note 3: Competence and training S1-14 88a Percentage of employees covered by health and safety system Note 4: Health, safety and environment S1-14 88b Fatalities due to work-related injuries or illnesses Note 4: Health, safety and environment S1-14 88c Number of registered work-related accidents and their frequency Note 4: Health, safety and environment S1-14 88d Number of cases of work-related illnesses Note 4: Health, safety and environment S1-14 88e Number of lost workdays due to work-related injuries or illnesses Note 4: Health, safety and environment S1-15 93 Percentage of employees entitled to family-related leave, and percentage who took family-related leave by gender Worker rights S1-16 97a Gender pay gap Note 5: Remuneration disparities S1-16 97b Annual total remuneration ratio Note 5: Remuneration disparities S1-16 97c Necessary contextual information to understand data and information Note 5: Remuneration disparities S1-16 AR99 Gender pay gap for the past two reporting periods Note 5: Remuneration disparities S1-16 AR100 Information on how objective factors influence the gender pay gap Note 5: Remuneration disparities S1-17 103 Number of discrimination cases in the reporting period and other employee complaints through grievance channels, including any fines and contextual information Note 6: Work-related complaints S1-17 104 Identified serious incidents related to human rights violations and any fines Supporting employees’ human rights Workers in the value chain (ESRS S2) ESRS 2 SBM-2 9 How workers’ interests, views, and rights, including human rights, are safeguarded in strategy and business models Stakeholder dialogue in SpareBank 1 SMN ESRS 2 SBM-3 48b Current and expected effects of the most significant impacts, risks, and opportunities on business model, value chain, strategy, and decisions, and how the company responds or plans to respond Assessment of impact and risk related to workers in the value chain ESRS 2 SBM-3 48c How negative impacts actually or potentially affect people or the environment, their sources, and impacts caused by the type of activities and business relationships the company is involved in Impact on workers in the value chain ESRS 2 SBM-3 48d Current financial effects on financial position, performance, and cash flows, and material risks and opportunities that may affect the carrying value of assets or liabilities during the upcoming reporting period Risk related to workers in the value chain
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51SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report ESRS 2 SBM-3 48e Expected financial effects of the most significant risks and opportunities on financial position, performance, and cash flows over the short, medium, and long term Risk related to workers in the value chain ESRS 2 SBM-3 11 Whether and how actual and potential impacts originate from, relate to, and adapt strategy and business model, as well as the interconnection between impacts, risks, and opportunities Assessment of impact and risk related to workers in the value chain ESRS 2 SBM-3 11a Types of workers in the value chain subject to significant impacts Assessment of impact and risk related to workers in the value chain ESRS 2 SBM-3 11b Geographical locations or goods and services where there is a significant risk of child labor or forced labor in the value chain Assessment of impact and risk related to workers in the value chain ESRS 2 SBM-3 11c Significant events with negative impact Impact on workers in the value chain ESRS 2 SBM-3 11e Significant risks or opportunities arising from impacts and dependencies on workers in the value chain Risk related to workers in the value chain ESRS 2 SBM-3 12 Developed understanding of how individuals in the value chain with different characteristics, contexts, or job roles may be particularly vulnerable to negative impacts Assessment of impact and risk related to workers in the value chain ESRS 2 SBM-3 13 Risks and opportunities related to specific groups of workers in the value chain Assessment of impact and risk related to workers in the value chain S2-1 16 Minimum disclosure requirement - policy (MDR-P) Policies S2-1 17 Relevant commitments to human rights, approach to human and labor rights, engagement, and remediation of workers in the value chain Policy on protecting fundamental human rights and decent working conditions S2-1 18 Policies explicitly addressing human trafficking, forced labor, or child labor Policy on protecting fundamental human rights and decent working conditions S2-1 18 Policies related to suppliers Policies S2-1 19 Whether and how policies are developed in accordance with international standards Policies S2-2 22 Whether and how workers’ perspectives inform decisions or activities aimed at addressing actual or potential impacts Dialogue with the Group’s value chains S2-2 22a How dialogue with workers takes place Dialogue with the Group’s value chains S2-2 22b Steps, types, and frequency of dialogue with the value chain Dialogue with the Group’s value chains S2-2 22c The role operationally responsible for ensuring dialogue takes place and that results are used in the approach to dialogue, and the function of this role Dialogue with the Group’s value chains S2-2 22d Commitment to internationally recognized agreements or other agreements regarding human rights Dialogue with the Group’s value chains S2-2 22e Assessment of the effectiveness of dialogue with the value chain Dialogue with the Group’s value chains S2-2 23 Steps taken to gain insight into the perspectives of workers particularly vulnerable to impact Dialogue with the Group’s value chains S2-3 27a General approach and processes to provide or contribute to remediation in cases where the company has caused or contributed to significant negative impacts on workers in the value chain Dialogue with the Group’s value chains
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52SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report S2-3 27b Specific channels in place where workers in the value chain can express concerns or needs directly Dialogue with the Group’s value chains S2-3 27c Availability of various channels Dialogue with the Group’s value chains S2-3 27d Follow-up and monitoring of concerns or reports received and handled, and how it is ensured that channels are effective Dialogue with the Group’s value chains S2-3 28 Whether and how it has been assessed that workers in the value chain are aware of and trust the structures or processes related to concerns and reporting channels, including policies protecting against retaliation or reprisals against individuals using reporting channels Dialogue with the Group’s value chains S2-4 32 Minimum disclosure requirement - actions (MDR-A) Action plans and measures S2-4 32a Actions taken and planned measures to minimize negative impacts Action plans and measures S2-4 32b Whether and how measures have been implemented to provide or enable remediation Action plans and measures S2-4 32c Description of initiatives or actions aimed at positively influencing workers Action plans and measures S2-4 32d Effectiveness of measures and follow-up on this Action plans and measures S2-4 33a Processes for identifying necessary measures and responses to actual or potential negative impacts Action plans and measures S2-4 33b Approach to addressing specific impacts on workers in the value chain Action plans and measures S2-4 33c Approach to ensuring effective processes for remediation in cases of negative consequences for workers in the value chain Action plans and measures S2-4 34 Planned and ongoing measures to reduce risks and promote opportunities related to impacts and dependency on the workforce and follow-up on effectiveness Action plans and measures S2-4 35 How it is ensured that current practices do not negatively affect workers Action plans and measures S2-4 36 Severe human rights-related incidents in the upstream and/or downstream value chain Action plans and measures S2-4 38 Resources allocated to managing significant impacts Action plans and measures S2-5 46 Minimum disclosure requirement - targets (MDR-T) Targets and KPIs S2-5 47 Process for setting targets, whether workers have been involved in target setting, measurement, and identification of improvements or lessons learned Targets and KPIs Consumers and end-users (ESRS S4) ESRS 2 SBM-2 12 How consumers and end-users’ interests, views, and rights, including human rights, are considered in strategy and business models Stakeholder dialogue in SpareBank 1 SMN ESRS 2 SBM-3 48b Current and expected effects of the most significant impacts, risks, and opportunities on business model, value chain, strategy, and decisions, and how the company responds or plans to respond Assessment of IROs related to consumers and end-users ESRS 2 SBM-3 48c How negative impacts actually or potentially affect people or the environment, their sources, and impacts caused by the type of activities and business relationships the company is involved in Impacts on consumers and end-users ESRS 2 SBM-3 48d Current financial effects on financial position, performance, and cash flows, and material risks and opportunities that may affect the carrying value of assets or liabilities during the upcoming reporting period Risks and opportunities related to consumers and endusers ESRS 2 SBM-3 48e Expected financial effects of the most significant risks and opportunities on financial position, performance, and cash flows over the short, medium, and long term Risks and opportunities related to consumers and endusers
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53SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report ESRS 2 SBM-3 10 Whether and how actual and potential impacts originate, relate to, and align with strategy and business model, as well as the connection between impacts, risks, and opportunities Assessment of IROs related to consumers and end-users ESRS 2 SBM-3 10a Types of consumers and end-users subject to significant impacts Assessment of IROs related to consumers and end-users ESRS 2 SBM-3 10b Significant events with negative impact Assessment of IROs related to consumers and end-users ESRS 2 SBM-3 10c Activities that result in positive impacts and types of consumers and end-users affected or potentially affected Assessment of IROs related to consumers and end-users ESRS 2 SBM-3 10d Significant risks and opportunities arising from impacts and dependencies on own workforce Risks and opportunities related to consumers and endusers ESRS 2 SBM-3 11 Developed understanding of how individuals in the own workforce with different traits, contexts, or job tasks may be particularly vulnerable to negative impacts Assessment of IROs related to consumers and end-users ESRS 2 SBM-3 12 Which risks and opportunities are related to specific groups within employees Assessment of IROs related to consumers and end-users S4-1 15 Minimum disclosure requirement - policy (MDR-P) Policies S4-1 17 Whether and how policies are developed in accordance with international standards Policies S4-2 20 Whether and how consumers and end-users’ perspectives inform decisions or activities aimed at managing actual or potential impacts Customer dialogue S4-2 20a How dialogue with consumers and end-users takes place Customer dialogue S4-2 20b Steps, type, and frequency of dialogue with consumers and end-users Customer dialogue S4-2 20c Role responsible for ensuring dialogue occurs and results are used in the approach to dialogue, and the function of this role Customer dialogue S4-2 20d Assessment of the effectiveness of dialogue with the value chain Customer dialogue S4-2 21 Steps taken to gain insight into the perspectives of employees particularly vulnerable to impacts Customer dialogue S4-3 25a General approach and processes for providing or contributing to remediation in cases where the company has caused or contributed to significant negative impact on workers in the value chain Customer dialogue S4-3 25b Specific channels in place where workers in the value chain can voice concerns or needs directly Customer dialogue S4-3 25c Accessibility of different channels Customer dialogue S4-3 25d Monitoring and follow-up of concerns or reports received and handled, and how it is ensured that channels are effective Customer dialogue S4-3 26 Whether and how workers in the value chain are aware of and trust the structures or processes related to concerns and whistleblowing channels, including policies protecting against retaliation or retribution against individuals using whistleblowing channels Customer dialogue S4-4 31 Minimum disclosure requirement - actions (MDR-A) Action plans and measures S4-4 31a Completed and planned measures to minimize negative impacts Action plans and measures S4-4 31b Whether and how measures have been implemented to provide or enable remediation Action plans and measures S4-4 31c Description of initiatives or actions with the primary purpose of positively impacting consumers and end-users Action plans and measures
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54SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report S4-4 31d Effectiveness of measures and follow-up of this Action plans and measures S4-4 32a Processes for identifying necessary measures and responses to actual or potential negative impacts Action plans and measures S4-4 32b Approach to handling specific impacts on consumers and end-users Action plans and measures S4-4 32c Approach to ensuring effective processes for remediation of negative consequences for consumers and end-users Action plans and measures S4-4 33 Planned and ongoing measures to reduce risks and promote opportunities related to impacts and dependence on workforce, and follow-up of effectiveness Action plans and measures S4-4 34 How it is ensured that current practices do not negatively affect employees Action plans and measures S4-4 38 Resources allocated for managing significant impacts Action plans and measures S4-5 41 Minimum disclosure requirement - targets (MDR-T) Targets and KPIs S4-5 41 Process for target setting, whether consumers and end-users have been involved in target setting, measurement, and identification of improvements or learnings Targets and KPIs SMN1-1 ESRS 1 AR1-5 Data protection Personal data protection SMN1-2 GRI 418-1a Number of complaints processed related to data protection breaches from third parties and regulatory authorities Personal data protection SMN1-2 GRI 418-1b Number of identified customer data losses Personal data protection SMN1-2 GRI 418-1c Description if no incidents have been identified Personal data protection SMN1-2 GRI 418-2 Whether breaches are related to incidents in previous reporting periods Personal data protection SMN2-1 ESRS 1 AR1-5 Anti-fraud Anti-fraud SMN2-2 ESRS 1 AR1-5 Number of prevented fraud attempts Anti-fraud SMN2-2 ESRS 1 AR1-5 Losses due to fraud Anti-fraud Governance (G1) Business conduct (ESRS G1) ESRS 2 GOV-1 5a Role of governing bodies related to business conduct Governing bodies ESRS 2 GOV-1 5b Competence of governing bodies related to business conduct Governing bodies ESRS 2 SBM-3 48b Current and expected effects of the most significant impacts, risks, and opportunities on business model, value chain, strategy, and decisions, and how the company responds or plans to respond Assessment of IROs related to business conduct ESRS 2 SBM-3 48c How negative impacts actually or potentially affect people or the environment, their sources, and impacts caused by the type of activities and business relationships the company is involved in Impacts on business conduct ESRS 2 SBM-3 48d Current financial effects on financial position, performance, and cash flows, and material risks and opportunities that may affect the carrying value of assets or liabilities during the upcoming reporting period Risks and opportunities related to business conduct
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55SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ESRS-INDEX Disclosure requirements Indicator Description Description in annual report ESRS 2 SBM-3 48e Expected financial effects of the most significant risks and opportunities on financial position, performance, and cash flows over the short, medium, and long term Risks and opportunities related to business conduct G1-1 7 Minimum disclosure requirement - policy (MDR-P) Policies G1-1 9 Establishment, development, promotion, and evaluation of corporate culture Approach to the topic G1-1 10a Description of procedures for identifying, reporting, and investigating breaches of ethical guidelines or other internal rules Approach to the topic Policies G1-1 10c Whistleblower protection Approach to the topic G1-1 10f Guidelines related to animal welfare Policies G1-1 10g Competence development on business conduct Approach to the topic G1-1 10h High-risk departments exposed to corruption and bribery Note 1: Competency enhancement SMN3-1 ESRS 1 AR1-5 Anti-money laundering and counter-terrorist financing Anti-money laundring and terrorist financing G1-3 18a Procedures implemented to prevent, detect, and handle allegations or instances of corruption and bribery Anti-corruption G1-3 18b Whether individuals responsible for investigating cases are independent Anti-corruption G1-3 18c Procedures for reporting results to governing bodies Anti-corruption G1-3 20 How guidelines are communicated to relevant areas of responsibility Anti-corruption G1-3 21a Type of training related to corruption and misconduct that is offered, what is required, what it includes, and its level of detail Anti-corruption G1-3 21b Percentage of high-risk departments receiving training Note 1: Competency enhancement G1-3 21c Training offered to governing bodies Note 1: Competency enhancement SMN4-1 ESRS 1 AR1-5 Data and cybersecurity Data- and cyber-security G1-4 24a Convictions and potential fines Anti-corruption
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56SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | LIST OVER DP FROM OTHER EU-LEGISLATION 56 List over datapoints that derive from other EU-legislation Disclosure requirement Datapoint Description in the report of the Board of Directors Description in other EU legislation Reference to: SFDR Pillar III Benchmark regulation EU Climate Law General information (ESRS 2) GOV-1 21d Governance Board’s gender diversity x x GOV-1 21e Governance Percentage of board members who are independent x GOV-4 30 Sustainability due diligence Statement on due diligence x SBM-1 40d i Not relevant Involvement in activities related to fossil fuel activities Not relevant Not relevant Not relevant SBM-1 40d ii Not relevant Involvement in activities related to chemical production Not relevant Not relevant SBM-1 40d iii Not relevant Involvement in activities related to controversial weapons Not relevant Not relevant SBM-1 40d iv Not relevant Involvement in activities related to cultivation and production of tobacco Not relevant Climate change (ESRS E1) E1-1 14 The Group’s climate transition plan Transition plan to reach climate neutrality by 2050 x E1-1 16g The Group’s climate transition plan Undertakings excluded from Paris-aligned Benchmarks x x E1-4 34 Targets and KPIs GHG emission reduction targets x x x E1-5 38 Note 3: Energy consumption Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) x E1-5 37 Note 3: Energy consumption Energy consumption and mix x E1-5 40-43 Note 3: Energy consumption Energy intensity associated with activities in high climate impact sectors x E1-6 44 Note 4: GHG-emissions from own operations Note 5: GHG-emissions from the value chain Note 6: Total GHG-emissions Gross Scope 1, 2, 3 and Total GHG emissions x x x E1-6 53-55 Note 7: GHG-intensity Gross GHG emissions intensity x x x E1-7 56 Not material GHG removals and carbon credits Not material
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57SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | LIST OVER DP FROM OTHER EU-LEGISLATION 57 Disclosure requirement Datapoint Description in the report of the Board of Directors Description in other EU legislation Reference to: SFDR Pillar III Benchmark regulation EU Climate Law E1-9 66 Note 8: Financial risks and opportunities from climate change and adaptation Exposure of the benchmark portfolio to climate- related physical risks x E1-9 66a Note 8: Financial risks and opportunities from climate change and adaptation Disaggregation of monetary amounts by acute and chronic physical risk x E1-9 66c Note 8: Financial risks and opportunities from climate change and adaptation Location of significant assets at material physical risk x E1-9 67c Note 8: Financial risks and opportunities from climate change and adaptation Breakdown of the carrying value of its real estate assets by energy-efficiency classes x E1-9 69 Note 8: Financial risks and opportunities from climate change and adaptation Degree of exposure of the portfolio to climate- related opportunities x Pollution (ESRS E2) E2-4 28 Not material Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil Not material Water and marine resources (ESRS E3) E3-1 9 Not material Water and marine resources Not material E3-1 13 Not material Dedicated policy Not material E3-1 14 Not material Sustainable oceans and seas Not material E3-4 28c Not material Total water recycled and reused Not material E3-4 29 Not material Total water consumption in m 3 per net revenue on own operations Not material Biodiversity and ecosystems (ESRS E4) SBM-3 16a i) Not material Significant locations in own operations (and/or under operational control) where activities impact biodiversity-sensitive areas Not material SBM-3 16b Not material Significant locations in own operations (and/or under operational control) with negative impacts on land degradation, desertification, or soil sealing Not material SBM-3 16c Not material Significant locations in own operations (and/ or under operational control) where operations impact endangered species Not material
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58SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | LIST OVER DP FROM OTHER EU-LEGISLATION 58 Disclosure requirement Datapoint Description in the report of the Board of Directors Description in other EU legislation Reference to: SFDR Pillar III Benchmark regulation EU Climate Law E4-2 24b Policies Sustainable land / agriculture practices or policies x E4-2 24c Policies Sustainable oceans / seas practices or policies x E4-2 24d Policies Policies to address deforestation x Circular economy and resource use (ESRS E5) E5-5 37d Not material Non-recycled waste Not material E5-5 39 Not material Hazardous waste and radioactive waste Not material Own workforce (ESRS S1) SBM-3 14f Assessment of IROs related to employees Risk of incidents of forced labour x SBM-3 14g Assessment of IROs related to employees Risk of incidents of child labour x S1-1 20 Policies Human rights policy commitments x S1-1 21 Policies Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8 x S1-1 22 Not material Processes and measures for preventing trafficking in human beings Not material S1-1 23 Policies Workplace accident prevention policy or management system x S1-3 32c Concerns and whistleblowing channels Grievance/complaints handling mechanisms x S1-14 88b Note 4: Health, safety and environment Number of fatalities and number and rate of work- related accidents x x S1-14 88c Note 4: Health, safety and environment Number of fatalities and number and rate of work- related accidents x x S1-14 88e Note 4: Health, safety and environment Number of fatalities and number and rate of work- related illness x S1-16 97a Note 5: Remuneration disparities Unadjusted gender pay gap x x S1-16 97b Note 5: Remuneration disparities Excessive CEO pay ratio x S1-17 103a Note 6: Work-related complaints Incidents of discrimination x S1-17 104a Note 6: Work-related complaints Non-respect of UNGPs on Business and Human Rights and OECD Guidelines x x
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59SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | LIST OVER DP FROM OTHER EU-LEGISLATION 59 Disclosure requirement Datapoint Description in the report of the Board of Directors Description in other EU legislation Reference to: SFDR Pillar III Benchmark regulation EU Climate Law Workers in value chain (ESRS S2) SBM-3 11b Assessment of impact and risk related to workers in the value chain Significant risk of child labour or forced labour in the value chain x S2-1 17 Policies Human rights policy commitments x S2-1 18 Policies Policies related to value chain workers x S2-1 19 Policies Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines x x S2-1 19 Policies Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8 x S2-4 36 Approach to the topic Human rights issues and incidents connected to its upstream and downstream value chain x Affected communities (ESRS S3) S3-1 16 Not material Human rights policy commitments Not material S3-1 17 Not material Non-respect of UNGPs on Business and Human Rights, ILO principles or OECD guidelines Not material x S3-4 36 Not material Human rights issues and incidents Not material Consumers and end-users (ESRS S4) S4-1 16 Policies Policies related to consumers and end-users x S4-4 17 Approach to the topic Non-respect of UNGPs on Business and Human Rights and OECD guidelines x x S4-4 35 Approach to the topic Human rights issues and incidents x Business conduct (ESRS G1) G1-1 10b Anti-corruption United Nations Convention against Corruption x G1-1 10d Approach to the topic Protection of whistle-blowers x G1-4 24a Anti-corruption Fines for violation of anti-corruption and anti- bribery laws x x G1-4 24b Anti-corruption Standards of anti- corruption and anti- bribery x
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6060 Targets The Group’s governance indicators have been prepared in accordance with MDR‑T in ESRS 2. Specific considerations for each indicator are described in relevant chapters. Definitions are provided under Key Figures in the “ About SpareBank 1 SMN” section. For some governance indicators, it has not been possible to obtain comparable figur es. These are marked “N/A”.2). Key performance indicator Base year Base value Unit of measurement Division Scope Target Target- year Result 2025 Result 2024 Percieved work‑life balance (WinningTemp) 2024 6.8 Score Absolute HR Own ops 7.5 2027 7.2 6.8 Equal pay (Group level) 2024 89.3 % Percent Relativ e HR Own ops 95% 2030 88.7 % 89.3 % Leaders (excl. Gr oup CEO) 2024 87.7 % Percent Relativ e HR Own ops 95% 2030 88.9 % 87.7 % Retail market (customer‑facing positions) 2024 96.8 % Percent Relativ e HR Own ops 95% 2030 93.1 % 96.8 % Corporate market (customer‑facing positions) 2024 90.7 % Percent Relativ e HR Own ops 95% 2030 90.2 % 90.7 % Accountants 2024 95.0 % Percent Relativ e HR Own ops 95% 2030 94.9 % 95.0 % Other employees 2024 91.8 % Percent Relativ e HR Own ops 95% 2030 90.4 % 91.8 % Sick leave 2024 5.2 % Percent Relativ e HR Own ops < 5,4% 2028 5.6 % 5.2 % Other work‑related complaints 2024 10 Units Absolute HR Own ops 8 2027 12 10 Incidents of discrimination, including harassment 2024 3 Units Absolute HR Own ops 0 2026 2 3 Completion rate of mandatory competency enchancement 2024 89.6 % Percent Relativ e HR Own ops 95% 2025 94.1 % 89.6 % Assessment of suppliers with increased potential risks r elated to human and labour rights 2025 52% Percent Relative Property and procurement Upstream 100% 2027 52% N/A Suppliers with purchases > 100 K NOK where the Code of Conduct (CoC) has been signed 2025 34% Percent Relative Property and procurement Upstream 95% 2028 26% N/A Deviations from the lending regulation used to finance and include young customers and first-time buyers 1) 2024 53% Percent Relative Retail market Downstream IA IA 52% 53% Recovery rate of unauthorised/fraudulent transactions 2024 43% Percent Relative Financial crime and business support Downstream 80% 2027 77% 43% Compliance with the restitution obligation in complaint cases related to fraud 2025 80% Percent Relative Financial crime and business support Downstream 95% 2027 80% N/A Number of breaches of privacy or loss of customer data reported to the DPA 2025 6 Units Absolute Compliance Downstream 0 2026 6 11 Number of privacy ‑related deviations registered in IMS 2025 242 Units Absolute Compliance Own ops 240 2026 242 N/A Incidents that have resulted in information being compromised, leading to unacceptable consequences in line with the BIA 2024 0 Units Absolute Technology and development Own ops Upstream 0 Every year 0 0 Incidents that result in downtime of operational systems, leading to unacceptable consequences with the BIA 2024 0 Units Absolute Technology and development Own ops Upstream 0 Every year 0 0 1) The Bank aims to prioritise the use of the deviation quota for two groups: young customers and/or first-time buyers, and customers experiencing life events that affect their financial situation (e.g. relationship breakdown or temporary loss of income). At the reporting date, it is not possible at an aggregated level to distinguish between customers experiencing such life events and other customer groups. This is expected to improve following planned system changes in the upcoming period. In the longer term, the management indicator will include this group; consequently, no target has been set for the management indicator. 2) N/A = Not available SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | TARGETS
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6161 Actions The Group has prepared action plans for its indicators in accordance with the MDR‑A requirements in ESRS 2. Specific considerations for each action plan are described in relevant chapters. If future planned measures r equire significant financial investments, this will be disclosed in connection with the respective measure. Key performance indicator Key actions taken in the reporting year Achieved results Future planned actions Time horizon Expected outcomes Percieved work‑life balance (WinningTemp) • Further dev eloped support tools aimed at strengthening coping skills, reducing stress and promoting balance. • Implemented a governance mechanism for monitoring and prioritising various HSE initiatives. • Conducted training and provided managerial support related to follow‑up of sickness absence. • Implemented AI ‑based support tools to streamline work tasks and pr ocesses. • Improved absolute scores on relevant questions in Winningtemp. • Contributed to increased awareness of work–life balance in management groups and teams. • Continue and strengthen HSE initiatives with a focus on workload, recovery and organisation of work. • Maintain managerial support and training with emphasis on early dialogue and follow‑up. Short-term • Increased perceived balance between work and leisure. • Improved accessibility and use of digital support tools. • Enhanced managerial support in managing workload. Equal pay (Group level) • Increase the number of women in leadership and specialist roles in order to reduce structural drivers of pay disparities. Historical decline over time, with only minor changes from 2024 to 2025. • Role evaluation conducted across the Group. Medium-term Greater systematic alignment between pay and work of equal value. Sick leave • Further developed support tools aimed at strengthening coping skills, reducing stress and promoting balance. • Implemented a governance mechanism for monitoring and prioritising various HSE initiatives. • Conducted training and provided managerial support related to follow‑up of sickness absence. • Implemented AI ‑based support tools to streamline work tasks and pr ocesses. Sick leave absence increased in 2025. • Continue and strengthen HSE initiatives with a focus on workload, recovery and organisation of work. • Maintain managerial support and training with emphasis on early dialogue and follow‑up. Short-term • Enhanced managerial support in managing workload. • Increased consistency and more systematised follow‑up and prevention. Other work ‑related complaints • Carried out risk assessments related to violence and threats in collaboration with the occupational health service. • Established and operated an AKAN forum to enable early prevention and handling of unwanted incidents. • Expanded ongoing employee surveys and followed up findings. • Initiated improvements in the employee journey to reduce risk and enhance quality. • More systematic and consistent handling of deviations and complaints. • Earlier detection of issues with potential implications for the working environment. • Increased awareness related to substance use, violence, threats and data protection. • Implement a register for conflict‑of‑interest disclosures to strengthen integrity and transparency. • Structure and systematise follow‑up processes within HSE, AKAN and the working environment. • Increase focus on the psychosocial working environment. • Improve reporting routines and data quality. Medium-term • Gradual improvement in handling and follow‑up processes. • Strengthened risk assessments and working -environment processes. • More predictable and consistent practice in HSE and AKAN w ork. • Expected reduction in the number of deviations and complaints. SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ACTIONS
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6262 Incidents of discrimination, including harassment • Increased attention to available internal and external whistleblowing channels. Reduction in number of incidents • Maintain continued focus on promoting awareness of whistleblowing channels. Short-term • Strengthen the ability to identify and capture a greater number of relevant cases of discrimination and harassment. Completion rate of mandatory competency enchancement • Continued enforcement of the reminder regime introduced in spring/summer 2024, prior to deadline. • Increased completion rate compared with 2024. • Introduce a reminder regime for incomplete mandatory training that accommodates employees returning from leave/ sick leave, as well as new hires. Short-term Achieved targeted completion rate Assessment of suppliers with increased potential risks related to human and labour rights • Updated overview of all suppliers • Classified suppliers according to risk in line with the procedure • Collected documentation from suppliers All critical suppliers have been mapped. • Subsequent risk assessment of mapped critical suppliers Medium-term 100 per cent mapping of suppliers with increased potential risk Suppliers with purchases > 100 K NOK where the Code of Conduct (CoC) has been signed • Integrate the CoC into all contract templates • Prioritize high‑risk suppliers • Ensure follow‑up and internal alignment with employees involved in procurement 26 per cent signed • Training • Clarify the CoC as a qualification requirement Medium-term 95 per cent signed Deviations from the lending regulation used to finance and include young customers and first ‑time buyers 1) • Prioritised groups incorporated into advisory pr ocedure descriptions • All deviation cases decided at an overarching decision level, contributing to strengthened focus on routines and consistent assessments Improved routines and decision‑making levels for deviation cases • Expand the performance indicator to also measure customers experiencing life events that affect their financial situation, such as relationship breakdowns, temporary loss of income, etc. Medium-term Maintain a strong proportion of the deviation quota used for financial inclusion of young customers and those in the establishment phase. Recovery rate of unauthorised/fraudulent transactions • Close cooperation with the police and Økokrim in cases where funds are misappropriated • Staffed inbox and phone line for the anti‑fraud team with alerts to/from the bank from 08:00–16:00 • Mapping and identification of latent customers within the bank, including isolation and reduction of potential harm • Implementation of real‑time transaction‑monitoring functionality aimed at fraud prevention Reduction in operational losses. Part of the reduction can be attributed to a high recovery rate this year (77%). • Maintain key actions taken Short-term Reduction in operational losses by an additional 20 per cent Compliance with the restitution obligation in complaint cases related to fraud • Internal audit of account‑related complaint cases • Quality improvement of routines for handling complaint cases • Control point in the data flow that alerts when deadlines are exceeded Repayment obligation of 80 percent (including cases with missed deadlines due to suspected fraud). • Ongoing quality control Short-term Repayment obligation of 95 percent in cases not classified as (potential) fraud. Number of breaches of privacy or loss of customer data reported to the DPA • Continuous work internally and with suppliers to reduce the risk of notifiable deviations occurring Reduction in the number of notifiable deviations compared with previous years. • Continuous work internally and with suppliers to reduce the risk of notifiable deviations occurring Short-term Continued reduction in the number of notifiable deviations compared with previous years. SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ACTIONS
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6363 Number of privacy‑related deviations registered in IMS • Training to reduce the number of human err ors that lead to deviations 240 deviations • Training to recognise and report deviations (with the aim of ensuring that more deviations are identified and reported) • Training to reduce the number of human errors that lead to deviations Short-term • More deviations are identified and reported • Reduction in the number of serious deviations Incidents that have resulted in information being compromised, leading to unacceptable consequences in line with the BIA • Operationalization of DORA • Hired subject ‑matter responsible Digital Resilience • Completed implementation of DORA • Subject ‑matter responsible hired in 2Q 2025 • Continue and improv e information classification when new solutions are adopted • Operationalise/implement changes in line with the results of the BIA Short-term • Maintain control over information and its criticality • Improve the ability to prioritise security measures in line with criticality identified in the BIA SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ACTIONS
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6464 Policies Policy Topic/standard Related IRO Responsibilities Policy diversity and inclusion1) Group employees (I) Working conditions (I,O) Diversity and inclusion Executive Director Technology and Development Remuneration policy Group employees (I) Working conditions (I) Diversity and inclusion (R) Inability to attract competent people Executive Director Technology and Development Policy skills development 1) Group employees (I) Professional development (R) Lack of sustainability competence Executive Director Technology and Development Policy on protecting fundamental human rights and decent working conditions Group employees Workers in the value chain (I) Working conditions (R) Breaches of labour and human rights in the value chain Executive Director Technology and Development Executive Director Finance and Strategy Policy health, environment and safety Group employees (R) Increased sick absence (O) Focus on mental health Executive Director Technology and Development Requirements on suppliers as regards sustainability and ethical business practices Workers in the value chain (I) Working conditions (R) Breaches of labour and human rights in the value chain Executive Director Financial Crime and Business Support Policy for managing ESG risk in the Corporate market Workers in the value chain (I) Working conditions (R) Breaches of labour and human rights in the value chain Executive Director Corporate Banking Executive Director Risk Management Anti ‑fraud policy Consumers and end‑users (I) Fraud (R) Poor processes f or combating fraud Executive Director Financial Crime and Business Support Policy on personal data protection Consumers and end‑users (I) Breaches of personal data pr otection (R) Poor protection of personal data, including personal and customer information Executive Director Technology and Development Policy on outsourcing of functions Consumers and end ‑users Business conduct (I) Breaches of per sonal data protection (I) Poor data and cybersecurity (R) Poor protection of personal data, including personal and customer information Executive Director Technology and Development Policy on responsible marketing Consumers and end ‑users (I) Access to quality information (R) Greenwashing Ex ecutive Director Marketing, Communications and Digital Sales Policy on measures to combat money laundering and terrorist financing Business conduct (I) Money laundering and terrorist fi nancing (R) Poor processes for combating money laundering and terrorist financing Executive Director Financial Crime and Business Support Policy on internal malpractices and corruption Business conduct (I) Corruption and bribery (R) Disloyal employees Executive Director Financial Crime and Business Support Policy for information security and digital resilience Business conduct (I) Poor data and cybersecurity (R) Breaches of IT security Executive Director Technology and Development Code of conduct Business conduct (R) Breaches of legislation (R) Unrealistic ambitions Executive Director Financial Crime and Business Support Whistleblowing procedure Business conduct (R) Disloyal employees Executive Director Technology and Development Policy sustainable agriculture Business conduct (I) Poor animal welfare Executive Director Retail Banking 1) The policy is still under development, and is not approved by the Board of Directors as of 31 December 2025. SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | POLICIES
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t Environment EU Taxonomy 66 Reporting principles and assumptions 66 Changes from last year’s reporting 67 Results and KPIs at entity level 67 Annex I & II - Non-financial undertakings 67 Annex V & VI - Credit institutions 73 Annex XII - Nuclear power and gas-related activities 104 Results and KPIs at Group level 105 Climate change 108 Approach to the topic 108 Assessment of climate-related IROs 108 Impacts on climate change 109 Climate-related risks and opportunities 109 The Group’s transition plan for climate and nature 114 Targets and KPIs 120 Action plans and measures 120 Policies 120 Note 1: GHG-accounting principles 121 Note 2: Significant changes compared to the previous year 124 Note 3: Energy consumption 125 Note 4: GHG-emissions from own operations 127 Note 5: GHG-emissions from the value chain 128 Note 6: Total GHG-emissions 137 Note 7: GHG-intensity 138 Note 8: Financial risks and opportunities from climate change and adaptation 140 Pollution 147 Approach to the topic 147 Assessment of pollution-related impacts and risks 147 Pollution-related impacts 148 Pollution-related risks 148 Targets and KPIs 148 Action plans and measures 148 Policies 148 Note 1: Financial risks as a result of pollution 150 Biodiversity and ecosystems 151 Approach to the topic 151 Assessment of IROs related to biodiversity and ecos ystems 151 Impacts on biodiversity and ecosystems 152 Risks and opportunities linked to biodiversity and ecos ystems 152 The Group’s nature strategy 153 Targets and KPIs 153 Action plans and measures 153 Policies 153 Note 1: Financial risks and opportunities as a result of biodiv ersity and ecosystems 154 Resource use and circular economy 155 Approach to the topic 155 Assessment of IROs related to resource use and cir cular economy 155 Impacts on resource use and circular economy 156 Risks and opportunities related to resource use and cir cular economy 156 The Group’s roadmap for circular economy 157 Targets and KPIs 157 Action plans and measures 157 Policies 157 Note 1: Resource use 159 Note 2: Financial risks and opportunities as a result of resour ce use and circular economy 160
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66SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY EU Taxonomy The EU Taxonomy Regulation - (EU) 2020/852 - establishes a Europe-wide classification system that helps companies and investors to identify environmentally sustainable economic activities. This classification standard aims to promote sustainable investments and economic activities by providing companies and investors with clear guidelines and criteria for assessing and reporting on sustainability aspects of their businesses and projects. The EU Taxonomy Regulation sets concrete requirements as to what activities can be considered sustainable and criteria that must be met in order for a company’s activity to be regarded as sustainable. In order for an activity to be regarded as taxonomy-aligned, it must be considered to substantially contribute to at least one of the Taxonomy’s six environmental objectives (technical screening criteria), while doing no significant harm (DNSH) to any of the other five objectives. The activity must moreover comply with minimum social safeguards. The Sustainable Finance Act incorporates the Taxonomy Regulation with subsequent Commission regulations into Norwegian law. On 4 July, the European Commission adopted a delegated act to simplify the application of the EU taxonomy framework. The changes were scheduled to apply from 1 January 2026, and the Ministry of Finance has been clear that Norwegian undertakings may apply the same requirements as in the EU. The amendments were published in the Official Journal of the EU on 8 January 2026, and undertakings may choose to report under the previous rules. SpareBank 1 SMN has decided to report under the previous rules in light of timing considerations and changes associated with the adoption of the new regulatory framework. The six overarching climate and environmental objectives are: • Climate change mitigation • Climate change adaptation • Sustainable use and protection of water and marine resources • Transition to a circular economy • Pollution prevention and control • Protection and restoration of biodiversity and ecos ystems Reporting principles and assumptions The same undertakings that disclosed taxonomy information for the 2024 financial year are also required to report such information for 2025 in accordance with the requirements set out in EU 2013/34. For the 2025 reporting year, all environmental objectives apply and include an assessment of whether, and to what extent, the Group’s economic activities are taxonomy -eligible and taxonomy-aligned. For credit institutions (and undertakings with a credit institution as the par ent company), taxonomy reporting must be prepared on a proportionally consolidated basis in line with EU 575/2013. The Group comprises various types of financial and non -financial economic activities, and its key performance indicator s are reported as a “mixed group”. The Group reports KPIs and corresponding templates for the different financial activities included in the consolidated financial statements. The following companies that are included in the Group’s taxonomy reporting is presented on the following page.
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67SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Company1) Ownership share Consolidation approach Criteria Annex SpareBank 1 SMN 100.0 % Full Annex V Annex VI SpareBank 1 Finans Midt-Nor ge AS 64.8 % Full Annex V Annex VI BN Bank ASA 35.0 % Proportional Annex V Annex VI SpareBank 1 Boligkreditt AS 22.8 % Proportional Annex V Annex VI Kredittbanken ASA 15.1 % Proportional Annex V Annex VI SpareBank 1 Næringskreditt AS 14.8 % Proportional Annex V Anne x VI SpareBank 1 Invest SMN AS2) 100.0 % Full Annex I Annex II SpareBank 1 Regnsk apshuset SMN AS 93.3 % Full Annex I Annex II EiendomsMegler 1 Midt-Norge AS 92. 4 % Full Annex I Annex II Spar eBank 1 Forvaltning AS (konsern)4) 21.7 % Proportional Annex III Annex IV SB1 Markets AS3,4) 31.9 % Proportional Annex VII Annex VIII 1) All companies are included in the regulatory consolidation in accordance with EU 575/2013 in Annex VI. For non- financial companies, taxonomy-eligible activities are reported only in the relevant Annex in accordance with the overview in the table above. 2) The company manages a portfolio on behalf of SpareBank 1 SMN. Portfolio management is defined in MiFID II as: ”Managing portfolios in accordance with mandates given by clients on a discretionary, client-by-client basis, where such portfolios include one or more financial instruments.” The company’s management does not align with this definition, nor does the company hold a license from the Financial Supervisory Authority of Norway (Finanstilsynet) to engage in portfolio management. The exception in Chapter 9 of the Securities Trading Act does not apply to portfolio managers. Therefore, the company is reported in accordance with the criteria for non-financial undertakings, as defined in EU 2021/2178 Annex I, following the reporting framework in Annex II. 3) SpareBank 1 Markets has taken over the investment business of Swedbank and changed its name to SB1 Markets in 2025. 4) Not part of the accounting Group, and no information has been reported in accordance with the relevant Annex. In addition, SpareBank 1 Kvartalet SMN AS, SpareBank 1 Bygget Steinkjer AS and St. Olavs Plass 1 SMN AS are fully consolidated. SB1 Markets AS and SpareBank 1 Forvaltning AS are not included in this year’s taxonomy reporting. Changes from last year’s reporting From next year’s reporting onwards, significant changes will be introduced to the Group’s taxonomy disclosures. For that reason, only minimal adjustments have been made compared with last year’s reporting, unless changes have been deemed highly material: • The calculations applied in Templates 3 and 4 for Annex VI has been updated. Historical figures hav e been restated. Next year’s amendments will include, among other things: • Revisions to the definition of the top 15 per cent most energy-efficient residential buildings. • Inclusion of estimated energy labels in line with the Norwegian Water R esources and Energy Directorate’s (NVE’s) revised energy labelling scheme and updated threshold values. • Materiality thresholds aligned with the simplification of the taxonomy framework. • New reporting templates reducing the number of data points b y approximately 89 per cent. Results and KPIs at entity level In accordance with EU 2021/2178 (the Disclosures Delegated Act), the Group is required to report a number of KPIs. The Group reports as a mixed group, including the associated KPIs and templates for all business areas. The following KPIs are described in more detail on the subsequent pages, in the following order: Annex I and II – Non-financial undertakings • Turnover • Capital expenditure (CapEx) • Operation expenditures (OpEx) Annex V and VI - Credit institutions • Green Asset Ratio (GAR) Stock (Green ratio for holdings) • Green Asset Ratio (GAR) Flow (Green ratio for new e xposures) • Financial Guarantees (FinGuar) (Green ratio for financial guarantees to financial and non-financial undertakings): • Assets under Management (AuM)
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68SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Annex I and II – Non-financial undertakings 1. Turnover 2. Capital expenditure (CapEx) 3. Operating expenditure (OpEx) The Group’s non-financial undertakings generate no turnover, capital e xpenditure (CapEx) or operating expenditure (OpEx) from activities considered to be taxonomy-aligned. The Group’s wholly owned real estate companies hav e not made taxonomy-aligned investments in 2025. Turnover Activities included in 2025 relate primarily to IT consultancy and advisory services within SpareBank 1 Regnskapshuset SMN AS. Capital expenditure (CapEx) Activities included in 2025 consist of new or amended lease agreements in accordance with IFRS 16, as well as renovation and maintenance of buildings and technical installations, including energy efficiency improvements. Investments are planned to certify additional Group -owned buildings in accordance with the BREEAM In-Use criteria in forthcoming periods, thereby contributing to incr eased energy efficiency. Operating expenditure (OpEx) Operating expenditure includes activities such as: • Building renovation • Short-term lease agreements • Maintenance and repairs For 2025, activities included under OpEx primarily consist of expensed building r enovation and maintenance. The Group’s non-financial undertakings has the following taxonomy- eligible activities: Economic activity Code Turnover Capital Expenditure (CapEx) Operating expenses (OpEx) Data processing, hosting and related activities CCA 8.1 X Computer programming, consultancy and related activities CCA 8.2 X Renovation of existing buildings CCM 7.2 X Installation, maintenance and repair of energy efficiency equipment CCM 7.3 X Acquisition and ownership of buildings 1) CCM 7.7 X 1) New or amended lease agreements in accordance with IFRS 16. Share of taxonomy-aligned and -eligible activities per KPI: Proportion of turnover / total turnover Taxonomy-aligned per objective Taxonomy-eligible per objective CCM - - CCA - 8.6 % WTR - - CE - - PPC - - BIO - -
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69SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Proportion of CapEx / total CapEx Taxonomy-aligned per objective Taxonomy-eligible per objective CCM - 97.9 % CCA - - WTR - - CE - - PPC - - BIO - - Proportion of OpEx / total OpEx Taxonomy-aligned per objective Taxonomy-eligible per objective CCM - 10.3 % CCA - - WTR - - CE - - PPC - - BIO - -
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70SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template: Proportion of turnover from products or services associated with Taxonomy-aligned economic activities – disclosure covering year 2025 Financial year 2025 Year 2025 Substantial contribution criteria DNSH criteria (‘Does Not Significantly Harm’) () Economic Activities (1) Code (a) (2) Turno- ver (3) Pro- por- tion of T urn- over, year 2025 (4) Climate Change Mitiga- tion (5) Climate Change Adapta- tion (6) Water (7) Pollu- tion (8) Circular Econo- my (9) Biodi- versity (10) Climate Change Mitiga- tion (11) Climate Change Adapta- tion (12) Water (13) Pollu- tion (14) Circular Econo- my (15) Biodi- versity (16) Mini- mum Safe- guards (17) Proportion of Taxono- my-aligned (A.1.) or -eligible (A.2.) turnover, year 2024 (18) Cate- gory ena- bling activi- ty (19) Cate- gory transi- tional activi- ty (20) Text MNOK % Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T A. TAXONOMY-ELIGIBLE ACTIVITIES A. 1. Environmentally sustainable activities (Taxonomy-aligned) Turno ver of environmentally sustainable activi- ties (Taxonomy-aligned) (A.1) 0 0% 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % N N N N N N N 0,0 % Of which enabling 0 0% 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % N N N N N N N 0,0 % E Of which transitional 0 0% 0,0 % N N N N N N N 0,0 % T A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) () EL; N/EL EL; N/EL EL; N/ EL EL; N/EL EL; N/EL EL; N/EL Computer programming, consultancy and related activities CCA 8.2 17 1,1 % N/EL EL N/EL N/EL N/EL N/EL 1,2 % Data processing, hosting and related activities CCM 8.1 CCA 8. 1 117 7,5 % EL EL N/EL N/EL N/EL N/EL 6,2 % Turnover of T axonomy-eligible but not environ- mentally sustainable activities (not Taxono- my-aligned activities) (A.2) 134 8,6 % 7,5 % 8,6 % 0,0 % 0,0 % 0,0 % 0,0 % 8,0 % A. Turnover of T axonomy-eligible activi- ties (A.1+A.2) 134 8,6 % 7,5 % 8,6 % 0,0 % 0,0 % 0,0 % 0,0 % 8,0 % B. TAXONOMY-NON-ELIGIBLE ACTIVITIES T urnover of Taxonomy-non-eligible activities 1.431 91,4 % TOTAL 1.565 100 %
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71SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template: Proportion of CapEx from products or services associated with Taxonomy-aligned economic activities – disclosure covering year 2025 Financial year 2025 Year 2025 Substantial contribution criteria DNSH criteria (‘Does Not Significantly Harm’) () Economic Activities (1) Code () (2) CapEx (3) Pro- por- tion of CapEx, year 2025 (4) Climate Change Mitiga- tion (5) Climate Change Adapta- tion (6) Water (7) P ollu- tion (8) Circular Econo- my(9) Biodi- versi- ty(10) Climate Change Mitiga- tion (11) Climate Change Adapta- tion (12) Water (13) Pollu- tion (14) Circular Econo- my (15) Biodi- versity (16) Mini- mum Safe- guards (17) Proportion of Taxono- my-aligned (A.1.) or eligible (A.2.) CapEx, year 2024 (18) Cate- gory ena- bling activi- ty (19) Cate- gory transi- tional activi- ty (20) Text MNOK % Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T A. TAXONOMY-ELIGIBLE ACTIVITIES A. 1. Environmentally sustainable activities (Taxonomy-aligned) Capex o f environmentally sustainable activities (Taxonomy-aligned) (A.1) 0 0% 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % N N N N N N N 0,0 % Of which enabling 0 0% 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % N N N N N N N 0,0 % E Of which transitional 0 0% 0,0 % N N N N N N N 0,0 % T A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) () EL; N/EL EL; N/EL EL; N/ EL EL; N/EL EL; N/EL EL; N/EL Acquisition and ownership of buildings CCM 7.7 CCA 7.7 49 84,6 % EL EL N/EL N/EL N/EL N/EL 51,9 % Installation, maintenance and repair of energy efficiency equipment CCM 7.3 CCA 7.3 8 13,3 % EL EL N/EL N/EL N/EL N/EL 0,0 % Capex of Taxonomy-eligible but not envir on- mentally sustainable activities (not Taxono- my-aligned activities) (A.2) 57 97,9 % 97,9 % 97,9 % 0,0 % 0,0 % 0,0 % 0,0 % 53,1 % A. Capex of Taxonomy-eligible activi- ties (A.1+A.2) 57 97,9 % 97,9 % 97,9 % 0,0 % 0,0 % 0,0 % 0,0 % 53,1 % B. TAXONOMY-NON-ELIGIBLE ACTIVITIES CapEx o f Taxonomy-non-eligible activities 1 2,1 % TOTAL 58 100 %
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72SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template: Proportion of OpEx from products or services associated with Taxonomy-aligned economic activities – disclosure covering year 2025 Financial year 2025 Year 2025 Substantial contribution criteria DNSH criteria (‘Does Not Significantly Harm’) () Economic Activities (1) Code () (2) OpEx (3) Pro- por- tion of OpEx, year 2025 (4) Climate Change Mitiga- tion (5) Climate Change Adapta- tion (6) W ater (7) Pollu- tion (8) Circular Econo- my (9) Biodi- versity (10) Climate Change Mitiga- tion (11) Climate Change Adapta- tion (12) Water (13) Pollu- tion (14) Circular Econo- my (15) Biodi- versity (16) Mini- mum Safe- guards (17) Proportion of Taxono- my-aligned (A.1.) or -eligible (A.2.) OpEx, year 2024 (18) Cate- gory ena- bling activi- ty (19) Cate- gory transi- tional activi- ty (20) Text MNOK % Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y; N; N/ EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T A. TAXONOMY-ELIGIBLE ACTIVITIES A. 1. Environmentally sustainable activities (Taxonomy-aligned) OpEx of envir onmentally sustainable activities (Taxonomy-aligned) (A.1) 0 0% 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % N N N N N N N 0,0 % Of which enabling 0 0% 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % 0,0 % N N N N N N N 0,0 % E Of which transitional 0 0% 0,0 % N N N N N N N 0,0 % T A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) () EL; N/EL EL; N/EL EL; N/ EL EL; N/EL EL; N/EL EL; N/EL Renovation of exisiting buildings CCM 7.2 CCA 7.2 CE 3.2 1 10,3 % EL EL N/EL N/EL EL N/EL 20,9 % OpEx of Taxonomy-eligible but not environ- mentally sustainable activities (not T axono- my-aligned activities) (A.2) 1 10,3 % 10,3 % 10,3 % 0,0 % 0,0 % 10,3 % 0,0 % 24,7 % A. OpEx of Taxonomy-eligible activities (A.1+A.2) 1 10,3 % 10,3 % 10,3 % 0,0 % 0,0 % 10,3 % 0,0 % 24,7 % B. TAXONOMY-NON-ELIGIBLE ACTIVITIES OpEx o f Taxonomy-non-eligible activities 5 89,7 % TOTAL 6 100 %
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73SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Annex V & VI - Credit institutions 1. Green Asset Ratio (GAR) Stock (Green ratio for holdings):: Represents the total value of sustainable exposur es on the balance sheet divided by total assets (total assets correspond to point 1 through 6 in the table below). 2. Green Asset Ratio (GAR) Flow (Green ratio for new e xposures): Represents the total value of new sustainable exposures in the current year divided by total assets. 3. Financial Guarantees (FinGuar) (Green ratio for financial guarantees to financial and non-financial undertakings): Repr esents the share of financial guarantees for debt instruments that finance taxonomy-aligned activities, divided by total financial guarantees (point 8 in the table). 4. Assets under Management (AuM): Represents the share of assets under management that belong to under takings financing taxonomy-aligned economic activities, divided by total assets under management (point 8 in the table). Key performance indicators related to Fees and Commissions (F&C) and the Trading Book are not required for the current reporting year and will not become mandatory until the 2027 reporting year. The next page provides an overview of the various exposure categories included in the Group’s taxonomy reporting for credit institutions. The Group’s GAR (see Template 0) has increased by respectively 1.5 percentage points and 1.9 percentage points, for GAR measured based on turnover and CapEx. During the reporting year, the Group has experienced an increase in the financing of A - and B-rated residential buildings, which contributes to this growth.
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74SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY # Reporting category Description/definition Taxonomy-aligned activities Data collection 1 Financial undertakings Financial undertakings or holdings in financial undertakings (which are not held for trading purposes) Gross exposure to NFRD undertakings that have submitted taxonomy reports multiplied by GAR. Also includes special purpose bonds Reporting based on the company’s/customer’s own reporting to SpareBank 1 SMN. 2 Non-financial undertakings subject to CSRD Based on screening of our loan portfolio, our customers are essentially small/medium undertakings with no reporting obligation for 2025 None Reporting based on the company’s/customer’s own reporting to SpareBank 1 SMN. No voluntary reports submitted by the reporting date. 3 Households – mortgages This category deals with loans secured on dwellings able to meet requirements as to climate change mitigation and climate change adaptation (objectives 1 and 2) Assessment based on construction year, energy consumption and doing no significant harm to climate adaptation All data used in the classification are delivered by Eiendomsverdi. Specifically, energy consumption is obtained for dwellings with a valid energy certificate, and all dwellings are checked against the NVE’s risk map for flooding, high water levels and landslide. Selection criteria are described below the table. 4 Households – car loans This category deals with loans to households secured on electric cars None We lack information on electric car tyres. All electric car loans are therefore excluded since most car tyres lead to environmental damage. 5 Local authorities This category deals with exposure to local and regional authorities None Local authorities are not subject to CSRD and no voluntary reporting submitted. 6 Non-financial, not subject to CSRD Small and medium-sized enterprises None This category not to be included in the numerator when calculating GAR for 2025 due to no reporting obligation. No voluntary reporting submitted by reporting date. 7 Other assets not included in calculation of GAR Government securities, exposures to central banks and trading portfolio Not relevant Not relevant 8 Off-balance-sheet assets – financial guarantees and assets under management subject to CSRD Guarantees or assets under management None Reporting is based on the company’s/customer’s own reporting to SpareBank 1 SMN.
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75SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Several of the Group’s NFRD-obliged counterparties lack taxonomy reporting or have submitted incomplete disclosures. This limits the ability to perform a full assessment of taxonomy-eligible and taxonomy-aligned exposures in engagement categories 1 and 2. In such cases, both taxonomy-eligible and taxonomy-aligned exposures are set to 0. Specific considerations related to Minimum Social Safeguards in engagement categories 1 and 2 In cases where counterparties are subject to the Norwegian Transparency Act (Åpenhetsloven), the counterparty’s disclosures are used to assess whether due diligence processes related to human rights are embedded in accordance with the OECD Guidelines for Multinational Enterprises. Reporting under the Transparency Act is used where the counterparty is not subject to the CSRD. In most cases, it is not possible to assess counterparties’ reporting for 2025, as such reporting is not available at the time of assessment. Where the Group has counterparties subject to the CSRD, information from the previous year’s reporting is applied. For counterparties outside the EU, other sources are used, including board -approved policies and publicly available r eporting. Methodology for calculating engagement category 3: Households – mortgages The upper threshold values for energy consumption in green residential buildings have been established in collaboration with Multiconsult. For dwellings constructed from 2021 onwards, the corrected “Guidance on the Calculation of Primary Energy Demand in Buildings and Energy Frameworks for Nearly Zero -Energy Buildings (NZEB)” has been applied, including all dwellings with Energy Label A. F or the reporting category “Households – mortgages”, the upper thresholds for energy consumption in green residential buildings have been set in consultation with Multiconsult. Dwellings constructed from 2021 onwards must meet the requirements for Nearly Zero -Energy Buildings (NZEB) and, in addition, be at least 10 per cent more energy efficient than the national NZEB definition. This corr esponds to dwellings compliant with TEK17 and carrying Energy Label A, or the highest-performing B-labelled dwellings, provided their specific primary ener gy consumption remains below a defined threshold. Dwellings constructed before 2021 must meet the requirements of TEK10 or TEK17, both of which impose stricter energy standards than earlier building regulations. Alternatively, dwellings may qualify by carrying Energy Label A or B, indicating very low energy consumption. To meet these criteria, they must also fall within the 15 per cent most energy -efficient dwellings in Norway. When assessing the “Do No Significant Harm” r equirement for the climate adaptation objective, dwellings exposed to physical climate risk (flooding, storm surge, landslides and avalanches) are excluded. The same assessment methodology is applied as in Note 8: Financial Consequences of Climate -related Risks and Opportunities. See the chapter on Climate Change for further details.
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76SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 0: Summary of KPIs to be disclosed by credit institutions under Article 8 Taxonomy Regulation - disclosure covering year 2025 Total environmentally sustainable assets (NOKm) KPI**** KPI***** % coverage (over total assets)*** % of assets excluded from the numerator of the GAR (Article 7(2) and (3) and Section 1.1.2. of Annex V) % of assets excluded from the denominator of the GAR (Article 7(1) and Section 1.2.4 of Annex V) Main KPI Green asset ratio (GAR) stock 30.624 9,30% 9,27% 95,21% 34,92% 4,79% Total environmentally sustainable activities (NOKm) KPI KPI % coverage (over total assets) % of assets e xcluded from the numerator of the GAR (Article 7(2) and (3) and Section 1.1.2. of Annex V) % of assets excluded from the denominator of the GAR (Article 7(1) and Section 1.2.4 of Annex V) Additional KPIs GAR (flow) 8.489 8,65% 8,65% 62,69% Trading book* Financial guarantees - 0% 0% Assets under management - 0% 0% Fees and commissions income** * For credit institutions that do not meet the conditions of Article 94(1) of the CRR or the conditions set out in Article 325a(1) of the CRR **Fees and commissions income from services other than lending and AuM Instutitons shall dislcose forwardlooking information for this KPIs, including information in terms of targets, together with relevant explanations on the methodology applied. *** % of assets covered by the KPI over banks´ total assets ****based on the Turnover KPI of the counterparty *****based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used Note 1: Across the reporting templates: cells shaded in black should not be reported. Note 2: Fees and Commissions (sheet 6) and Trading Book (sheet 7) KPIs shall only apply starting 2026. SMEs´inclusion in these KPI will only apply subject to a positive result of an impact assessment.
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77SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 0: Summary of KPIs to be disclosed by credit institutions under Article 8 Taxonomy Regulation - disclosure covering year 2024 Total environmentally sustainable assets (NOKm) KPI**** KPI***** % coverage (over total assets)*** % of assets excluded from the numerator of the GAR (Article 7(2) and (3) and Section 1.1.2. of Annex V) % of assets excluded from the denominator of the GAR (Article 7(1) and Section 1.2.4 of Annex V) Main KPI Green asset ratio (GAR) stock 25.646 7,76% 7,38% 95,16% 37,07% 4,84% T otal environmentally sustainable activities (NOKm) KPI KPI % coverage (over total assets) % of assets excluded from the nu- merator of the GAR (Article 7(2) and (3) and Section 1.1.2. of Annex V) % of assets excluded from the denominator of the GAR (Article 7(1) and Section 1.2.4 of Annex V) Additional KPIs GAR (flow) 5.839 8,72% 8,72% 41,37% Trading book* Financial guarantees - 0% 0% Assets under management - 0% 0% Fees and commissions income** * For credit institutions that do not meet the conditions of Article 94(1) of the CRR or the conditions set out in Article 325a(1) of the CRR **Fees and commissions income from services other than lending and AuM Instutitons shall dislcose forwardlooking information for this KPIs, including information in terms of targets, together with relevant explanations on the methodology applied. *** % of assets covered by the KPI over banks´ total assets ****based on the Turnover KPI of the counterparty *****based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used Note 1: Across the reporting templates: cells shaded in black should not be reported. Note 2: Fees and Commissions (sheet 6) and Trading Book (sheet 7) KPIs shall only apply starting 2026. SMEs´inclusion in these KPI will only apply subject to a positive result of an impact assessment.
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78SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 1: Assets for the calculation of GAR - disclosure covering year 2025 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af NOK million 31.12.2025 Total [gross] carrying amount Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxono- my-aligned) Of which environmentally sustainable (Taxono- my-aligned) Of which environmentally sustainable (Taxono- my-aligned) Of which environmentally sustainable (Taxono- my-aligned) Of which environmentally sustainable (Taxono- my-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 214.315 199.126 30.624 29.249 7 7 0 0 199.133 30.624 29.249 7 2 Financial under- takings 12.463 3.903 610 312 7 7 0 0 3.910 610 312 7 3 Credit institutions 12.463 3.903 610 312 7 7 0 0 3.910 610 312 7 4 Loans and advances 477 5 Debt securities, including UoP 11.858 3.903 610 312 7 7 0 0 3.910 610 312 7 6 Equity instruments 128 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which manage- ment companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial under- takings 2.063 3 3 21 Loans and advances 2.063 3 3 22 Debt securities, including UoP 23 Equity instruments 24 Households 199.789 195.220 30.014 28.937 195.220 30.014 28.937
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79SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 188.628 188.628 30.014 28.937 188.628 30.014 28.937 26 of which building renovation loans 27 of which motor vehicle loans 6.592 6.592 28 Local governments financing 29 Housing financing 30 Other local govern- ment financing 31 Collateral obtained by taking possession: residential and com- mercial immovable proper ties 32 Assets excluded from the numerator for GAR calculation (cov ered in the denominator) 115.014 33 Financial and Non-fi- nancial undertakings 98.518 34 SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations 98.401 35 Loans and advances 74.895 36 of which loans collateralised by com- mercial immovable proper ty 6.939 37 of which building renovation loans 38 Debt securities 18.423 39 Equity instruments 5.083 40 Non-EU country coun- terparties not subject to NFRD disclosure obligations 117 41 Loans and advances 117 42 Debt securities 43 Equity instruments 44 Derivatives 9.239 45 On demand interbank loans 3.441 46 Cash and cash-related assets 2 47 Other categories of assets (e.g. Goodwill, commodities etc.) 3.814 48 Total GAR assets 329.329 199.126 30.624 29.249 7 7 0 0 199.133 30.624 29.249 7 49 Assets not covered for GAR calculation 16.558 50 Central governments and Supranational issuers 12.339 51 Central banks exposure 698 52 Trading book 3.522 53 Total assets 345.887 199.126 30.624 29.249 7 7 0 0 199.133 30.624 29.249 7
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80SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations 54 Financial guarantees 55 Assets under man- agement 56 Of which debt securities 57 Of which equity instruments
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81SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 1: Assets for the calculation of GAR - disclosure covering year 2024 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af NOK million 31.12.2024 Total [gross] carrying amount Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which towards taxonomy relevant sectors (Taxonomy-eligible) Of which environmentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-alig- ned) Of which environmentally sustainable (Taxonomy-alig- ned) Of which environmentally sustainable (Taxonomy-alig- ned) Of which environmentally sustainable (Taxonomy-alig- ned) Of which environ- mentally sustainable (Taxonomy-aligned) Of which environmentally sustainable (Taxonomy-aligned) Of which Use of Proce- eds Of which transiti- onal Of which ena- bling Of which Use of Proce- eds Of which ena- bling Of which Use of Proce- eds Of which ena- bling Of which Use of Proce- eds Of which ena- bling Of which Use of Proce- eds Of which ena- bling Of which Use of Proce- eds Of which ena- bling Of which Use of Proce- eds Of which transiti- onal Of which ena- bling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 207.791 182.313 25.646 24.373 24.373 182.313 25.646 24.373 24.373 2 Financial under- takings 14.022 346 319 1 346 319 1 3 Credit institutions 14.022 346 319 1 346 319 1 4 Loans and advances 2 5 Debt securities, including UoP 14.020 346 319 1 346 319 1 6 Equity instruments 0 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which manage- ment companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial undertakings 1.395 13 0 0 13 0 0 21 Loans and advances 1.395 13 0 0 13 0 0 22 Debt securities, including UoP 23 Equity instruments 24 Households 192.349 181.954 25.326 24.372 24.372 181.954 25.326 24.372 24.372
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82SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 178.604 178.604 25.326 24.372 24.372 178.604 25.326 24.372 24.372 26 of which building renovation loans 27 of which motor vehicle loans 242 242 242 28 Local governments financing 25 29 Housing financing 30 Other local govern- ment financing 31 Collateral obtained by taking possession: residential and commercial immova- ble proper ties 32 Assets excluded from the numerator for GAR calculation (cov ered in the denominator) 122.416 33 Financial and Non-fi- nancial undertakings 101.612 34 SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations 101.474 35 Loans and advances 79.267 36 of which loans collate- ralised by commercial immovable proper ty 6.909 37 of which building renovation loans 38 Debt securities 17.884 39 Equity instruments 4.323 40 Non-EU country coun- terparties not subject to NFRD disclosure obligations 138 41 Loans and advances 138 42 Debt securities 43 Equity instruments 44 Derivatives 11.268 45 On demand interbank loans 5.587 46 Cash and cash-related assets 3 47 Other categories of assets (e.g. Goodwill, commodities etc.) 3.946 48 Total GAR assets 330.207 182.313 25.646 24.373 24.373 182.313 25.646 24.373 24.373 49 Assets not covered for GAR calculation 16.801 50 Central governments and Supranational issuers 12.227 51 Central banks exposure 1.559 52 Trading book 3.015 53 Total assets 347.008 182.313 25.646 24.373 24.373 182.313 25.646 24.373 24.373 Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
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83SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 54 Financial guarantees 7 0 55 Assets under management 56 Of which debt securities 57 Of which equity instruments
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84SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 2: GAR sector information 2025 (KPI turnover) KPI turnover a b c d e f g h i j k l Breakdown by sector - NACE 4 digits level (code and label) Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount NOK million Of which environ- mentally sustaina- ble (CCM) MNOK Of which environ- mentally sustaina- ble (CCM) MNOK Of which environ- mentally sustaina- ble (CCA) MNOK Of which environ- mentally sustaina- ble (CCA) MNOK Of which environ- mentally sustaina- ble (WTR) MNOK Of which environ- mentally sustaina- ble (WTR) 1 A.03.21 334 - 2 A.03.21 1.036 - 3 C.10.20 332 - 4 F.43.21 0 - 5 A.03.22 323 - 6 J.58.12 38 - m n o p q r s t u v w x y z aa ab Breakdown by sector - NACE 4 digits level (code and label) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount NOK million Of which environmentally sustainable (CE) MNOK Of which environmentally sustainable (CE) MNOK Of which environmentally sustainable (PPC) MNOK Of which environmentally sustainable (PPC) MNOK Of which environmentally sustainable (BIO) MNOK Of which environmentally sustainable (BIO) MNOK Of which environmentally sustainable (CCM + CCA + WTR + CE + PPC + BIO) MNOK Of which environmentally sustainable (CCM + CCA + WTR + CE + PPC + BIO) 1 A.03.21 - 334 - 2 A.03.21 0 1.036 0 3 C.10.20 - 332 - 4 F.43.21 - 0 - 5 A.03.22 - 323 - 6 J.58.12 - 38 -
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85SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 2: GAR sector information 2025 (KPI capex) KPI capEx a b c d e f g h i j k l Breakdown by sector - NACE 4 digits level (code and label) Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount MNOK Of which environmentally sustainable (CCM) MNOK Of which environmentally sustainable (CCM) MNOK Of which environmentally sustainable (CCA) MNOK Of which environmentally sustainable (CCA) MNOK Of which environmentally sustainable (WTR) MNOK Of which environmentally sustainable (WTR) 1 A.03.21 334 - 2 A.03.21 1.036 0 3 C.10.20 332 - 4 F.43.21 0 - 5 A.03.22 323 - 6 J.58.12 38 - KPI CapEx m n o p q r s t u v w x y z aa ab Breakdown by sector - NACE 4 digits level (code and label) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD Non-Financial corporates (Subject to NFRD) SMEs and other NFC not subject to NFRD [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount [Gross] carrying amount MNOK Of which environmentally sustainable (CE) MNOK Of which environmentally sustainable (CE) MNOK Of which environmentally sustainable (PPC) MNOK Of which environmentally sustainable (PPC) MNOK Of which environmentally sustainable (BIO) MNOK Of which environmentally sustainable (BIO) MNOK Of which environmentally sustainable (CCM + CCA + WTR + CE + PPC + BIO) MNOK Of which environmentally sustainable (CCM + CCA + WTR + CE + PPC + BIO) 1 A.03.21 334 - 2 A.03.21 1.036 0 3 C.10.20 332 - 4 F.43.21 0 - 5 A.03.22 323 - 6 J.58.12 38 -
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86SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 3: GAR KPI stock (turnover) - disclosure covering year 2025 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af % (compared to total covered assets in the denominator) 31.12.2025 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Pro- por- tion of total new assets cov- ered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 92,91% 14,29% 13,65% 0,00% 0,00% 0,00% 0,00% 92,92% 14,29% 13,65% 0,00% 61,96% 2 Financial under- takings 31,31% 4,90% 2,50% 0,05% 0,05% 0,00% 0,00% 31,37% 4,90% 2,50% 0,05% 3,60% 3 Credit institutions 31,31% 4,90% 2,50% 0,05% 0,05% 0,00% 0,00% 31,37% 4,90% 2,50% 0,05% 3,60% 4 Loans and advances 0,14% 5 Debt securities, including UoP 32,91% 5,15% 2,63% 0,06% 0,06% 0,00% 0,00% 32,97% 5,15% 2,63% 0,06% 3,43% 6 Equity instruments 0,04% 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which manage- ment companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial under- takings 0,16% 0,16% 0,60% 21 Loans and advances 0,16% 0,16% 0,60% 22 Debt securities, including UoP 23 Equity instruments 24 Households 97,71% 15,02% 14,48% 97,71% 15,02% 14,48% 57,76%
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87SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 100,00% 15,91% 15,34% 15,91% 15,34% 54,53% 26 of which building renovation loans 27 of which motor vehicle loans 100,00% 1,91% 28 Local governments financing 29 Housing financing 30 Other local govern- ment financing 31 Collateral obtained by taking possession: residential and com- mercial immovable properties 32 Total GAR assets 60,46% 9,30% 8,88% 0,00% 0,00% 0,00% 0,00% 60,47% 9,30% 8,88% 0,00% 95,21%
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88SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 3: GAR KPI stock (CapEx) - disclosure covering year 2025 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af % (compared to total covered assets in the denominator) 31.12.2025 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Pro- por- tion of total new assets cov- ered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 92,62% 14,24% 13,64% 0,00% 0,00% 0,00% 92,68% 14,24% 13,64% 0,00% 61,96% 2 Financial under- takings 26,69% 3,99% 2,37% 0,05% 0,07% 0,00% 26,76% 4,01% 2,37% 0,05% 3,60% 3 Credit institutions 26,69% 3,99% 2,37% 0,05% 0,07% 0,00% 26,76% 4,01% 2,37% 0,05% 3,60% 4 Loans and advances 0,14% 5 Debt securities, including UoP 28,05% 4,20% 2,49% 0,05% 0,08% 0,00% 28,13% 4,22% 2,49% 0,05% 3,43% 6 Equity instruments 0,04% 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which manage- ment companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial under- takings 3,33% 0,02% 3,33% 0,02% 0,60% 21 Loans and advances 3,33% 0,02% 3,33% 0,02% 0,60% 22 Debt securities, including UoP 23 Equity instruments 24 Households 97,65% 15,02% 14,48% 97,71% 15,02% 14,48% 57,76%
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89SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 100,00% 15,91% 15,34% 15,91% 15,34% 54,53% 26 of which building renovation loans 27 of which motor vehicle loans 100,00% 1,91% 28 Local governments financing 29 Housing financing 30 Other local govern- ment financing 31 Collateral obtained by taking possession: residential and com- mercial immovable properties 32 Total GAR assets 60,27% 9,27% 8,88% 0,00% 0,00% 0,00% 60,31% 9,27% 8,88% 0,00% 95,21%
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90SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 3: GAR KPI stock (turnover) - disclosure covering year 2024 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af % (compared to total covered assets in the denominator) 31.12.2024 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Of which Of which Of which Use of Of which Of which Use of Of which Of which Use of Of which Of which Use of Of which Of which Use of Of which Of which Use of Of which Of which GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 87,74% 12,34% 11,73% 11,73% 87,74% 12,34% 11,73% 11,73% 59,88% 2 Financial undertakings 2,46% 2,28% 0,00% 2,46% 2,28% 0,00% 4,04% 3 Credit institutions 2,46% 2,28% 0,00% 2,46% 2,28% 0,00% 4,04% 4 Loans and advances 0,00% 5 Debt securities, including UoP 2,47% 2,28% 0,00% 2,47% 2,28% 0,00% 4,04% 6 Equity instruments 0,00% 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which management companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial undertakings 0,91% 0,03% 0,03% 0,91% 0,03% 0,03% 0,40% 21 Loans and advances 0,91% 0,03% 0,03% 0,91% 0,03% 0,03% 0,40% 22 Debt securities, including UoP 23 Equity instruments 24 Households 94,60% 13,17% 12,67% 12,67% 94,60% 13,17% 12,67% 12,67% 55,43%
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91SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 100,00% 14,18% 13,65% 13,65% 14,18% 13,65% 13,65% 51,47% 26 of which building renovation loans 27 of which motor vehicle loans 100,00% 0,07% 28 Local governments financing 0,01% 29 Housing financing 30 Other local government financing 31 Collateral obtained by taking possession: residential and commercial immovable properties 32 Total GAR assets 55,21% 7,77% 7,38% 7,38% 55,21% 7,77% 7,38% 7,38% 95,16%
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92SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 3: GAR KPI stock (CapEx) - disclosure covering year 2024 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af % (compared to total covered assets in the denominator) 31.12.2024 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Pro- por- tion of total new assets cov- ered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 87,74% 12,34% 11,73% 11,73% 87,74% 12,34% 11,73% 11,73% 59,88% 2 Financial under- takings 2,46% 2,28% 0,00% 2,46% 2,28% 0,00% 4,04% 3 Credit institutions 2,46% 2,28% 0,00% 2,46% 2,28% 0,00% 4,04% 4 Loans and advances 0,00% 5 Debt securities, including UoP 2,47% 2,28% 0,00% 2,47% 2,28% 0,00% 4,04% 6 Equity instruments 0,00% 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which manage- ment companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial under- takings 0,91% 0,03% 0,03% 0,91% 0,03% 0,03% 0,40% 21 Loans and advances 0,91% 0,03% 0,03% 0,91% 0,03% 0,03% 0,40% 22 Debt securities, including UoP 23 Equity instruments 24 Households 94,60% 13,17% 12,67% 12,67% 94,60% 13,17% 12,67% 12,67% 55,43%
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93SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 100,00% 14,18% 13,65% 13,65% 14,18% 13,65% 13,65% 51,47% 26 of which building renovation loans 27 of which motor vehicle loans 100,00% 0,07% 28 Local governments financing 0,01% 29 Housing financing 30 Other local govern- ment financing 31 Collateral obtained by taking possession: residential and com- mercial immovable properties 32 Total GAR assets 55,21% 7,77% 7,38% 7,38% 55,21% 7,77% 7,38% 7,38% 95,16%
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94SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 4: GAR KPI Flow (turnover) - disclosure covering year 2025 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af % (compared to flow of total eligible assets) 31.12.2025 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Pro- por- tion of total new assets cov- ered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 83,19% 8,65% 1,02% 0,00% 0,00% 0,00% 0,00% 83,19% 8,65% 1,02% 0,00% 75,36% 2 Financial under- takings 8,90% 0,78% 0,43% 0,00% 0,00% 0,00% 0,00% 8,90% 0,78% 0,43% 0,00% 9,42% 3 Credit institutions 8,90% 0,78% 0,43% 0,00% 0,00% 0,00% 0,00% 8,90% 0,78% 0,43% 0,00% 9,42% 4 Loans and advances 5 Debt securities, including UoP 8,90% 0,78% 0,43% 0,00% 0,00% 0,00% 0,00% 8,90% 0,78% 0,43% 0,00% 9,42% 6 Equity instruments 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which manage- ment companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial under- takings 21 Loans and advances 22 Debt securities, including UoP 23 Equity instruments 24 Households 93,80% 9,77% 1,10% 93,80% 9,77% 1,10% 65,94%
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95SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 99,94% 10,41% 1,17% 99,94% 10,41% 1,17% 61,88% 26 of which building renovation loans 27 of which motor vehicle loans 4,05% 28 Local governments financing 29 Housing financing 30 Other local govern- ment financing 31 Collateral obtained by taking possession: residential and com- mercial immovable properties 32 Total GAR assets 67,23% 6,99% 0,82% 0,00% 0,00% 0,00% 0,00% 67,23% 6,99% 0,82% 0,00% 93,24%
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96SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 4: GAR KPI Flow (CapEx) - disclosure covering year 2025 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af % (compared to flow of total eligible assets) 31.12.2025 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Pro- por- tion of total new assets cov- ered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 83,19% 8,65% 1,02% 0,00% 0,00% 0,00% 0,00% 83,19% 8,65% 1,02% 0,00% 75,36% 2 Financial under- takings 8,90% 0,78% 0,43% 0,00% 0,00% 0,00% 0,00% 8,90% 0,78% 0,43% 0,00% 9,42% 3 Credit institutions 8,90% 0,78% 0,43% 0,00% 0,00% 0,00% 0,00% 8,90% 0,78% 0,43% 0,00% 9,42% 4 Loans and advances 5 Debt securities, including UoP 8,90% 0,78% 0,43% 0,00% 0,00% 0,00% 0,00% 8,90% 0,78% 0,43% 0,00% 9,42% 6 Equity instruments 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which manage- ment companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial under- takings 21 Loans and advances 22 Debt securities, including UoP 23 Equity instruments 24 Households 93,80% 9,77% 1,10% 93,80% 9,77% 1,10% 65,94%
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97SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 99,94% 10,41% 1,17% 99,94% 10,41% 1,17% 61,88% 26 of which building renovation loans 27 of which motor vehicle loans 4,05% 28 Local governments financing 29 Housing financing 30 Other local govern- ment financing 31 Collateral obtained by taking possession: residential and com- mercial immovable properties 32 Total GAR assets 67,23% 6,99% 0,82% 0,00% 0,00% 0,00% 0,00% 67,23% 6,99% 0,82% 0,00% 93,24%
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98SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 4: GAR KPI Flow (turnover) - disclosure covering year 2024 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af % (compared to flow of total eligible assets) 31.12.2024 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxono- my relevant sectors (Taxonomy-eligible) Pro- por- tion of total new assets cov- ered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxono- my-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which ena- bling Of which Use of Pro- ceeds Of which transi- tional Of which ena- bling GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 62,15% 8,72% 8,26% 8,26% 62,15% 8,72% 8,26% 8,26% 66,57% 2 Financial under- takings 0,16% 0,16% 19,35% 3 Credit institutions 0,16% 0,16% 19,35% 4 Loans and advances 5 Debt securities, including UoP 19,35% 6 Equity instruments 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which manage- ment companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial under- takings 21 Loans and advances 22 Debt securities, including UoP 23 Equity instruments 24 Households 87,56% 12,30% 11,64% 11,64% 87,56% 12,30% 11,64% 11,64% 47,22%
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99SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 98,23% 13,80% 13,06% 13,06% 98,23% 13,80% 13,06% 13,06% 42,09% 26 of which building renovation loans 27 of which motor vehicle loans 5,13% 28 Local governments financing 29 Housing financing 30 Other local govern- ment financing 31 Collateral obtained by taking possession: residential and com- mercial immovable properties 32 Total GAR assets 48,05% 6,74% 6,38% 6,38% 48,05% 6,74% 6,38% 6,38% 86,12%
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100SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 4: GAR KPI Flow (CapEx) - disclosure covering year 2024 a b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af % (compared to flow of total eligible assets) 31.12.2024 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Pro- por- tion of total new assets cov- ered Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy- aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Pro- ceeds Of which Of which Of which Use of Of which Of which Use of Of which Of which Use of Of which Of which Use of Of which Of which Use of Of which Of which Use of Of which Of which GAR - Covered assets in both numerator and denominator 1 Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation 62,15% 8,72% 8,26% 8,26% 62,15% 8,72% 8,26% 8,26% 66,57% 2 Financial undertakings 0,16% 0,16% 19,35% 3 Credit institutions 0,16% 0,16% 19,35% 4 Loans and advances 5 Debt securities, including UoP 19,35% 6 Equity instruments 7 Other financial corporations 8 of which investment firms 9 Loans and advances 10 Debt securities, including UoP 11 Equity instruments 12 of which management companies 13 Loans and advances 14 Debt securities, including UoP 15 Equity instruments 16 of which insurance undertakings 17 Loans and advances 18 Debt securities, including UoP 19 Equity instruments 20 Non-financial undertakings 21 Loans and advances 22 Debt securities, including UoP 23 Equity instruments 24 Households 87,56% 12,30% 11,64% 11,64% 87,56% 12,30% 11,64% 11,64% 47,22%
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101SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY 25 of which loans collateralised by residential immovable property 98,23% 13,80% 13,06% 13,06% 98,23% 13,80% 13,06% 13,06% 42,09% 26 of which building renovation loans 27 of which motor vehicle loans 5,13% 28 Local governments financing 29 Housing financing 30 Other local government financing 31 Collateral obtained by taking possession: residential and commercial immovable properties 32 Total GAR assets 48,05% 6,74% 6,38% 6,38% 48,05% 6,74% 6,38% 6,38% 86,12%
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102SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 5: KPI off-balance sheet exposures (turnover) - disclosure covering year 2025 a b c d e f g h i j k l m % (compared to total eligible off-balance sheet assets) 31.12.2025 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling 1 Financial guarantees (FinGuar KPI) 2 Assets under management (AuM KPI) n o p q r s t u v w x z aa ab ac ad ae % (compared to total eligible off-balance sheet assets) 31.12.2025 Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling 1 Financial guarantees (FinGuar KPI) 1% 2 Assets under management (AuM KPI)
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103SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Template 5: KPI off-balance sheet exposures (CapEx) - disclosure covering year 2025 a b c d e f g h i j k l m % (compared to total eligible off-balance sheet assets) 31.12.2025 Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Proceeds Of which transitional Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling 1 Financial guarantees (FinGuar KPI) 1% 2 Assets under management (AuM KPI) n o p q r s t u v w x z aa ab ac ad ae % (compared to total eligible off-balance sheet assets) 31.12.2025 Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + BIO) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-aligned) Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which enabling Of which Use of Proceeds Of which transitional Of which enabling 1 Financial guarantees (FinGuar KPI) 1% 2 Assets under management (AuM KPI)
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104SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Annex XII - Nuclear power and gas-related activities SpareBank 1 SMN has neither assets nor activities covered by rows 1 to 6 in template 1 of Annex XII DDA. According to C/2024/6691, paragraph 28, the Group does not report templates 2 to 5 in Annex XII for 2024. Row Nuclear energy related activities 1, The undertaking carries out, funds or has exposures to research, development, demon- stration and deployment of innovative electricity generation facilities that produce ener- gy from nuclear processes with minimal waste from the fuel cycle. NO 2, The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen produc- tion, as well as their safety upgrades, using best available technologies. NO 3, The undertaking carries out, funds or has exposures to safe operation of existing nu- clear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades. NO Fossil gas related activities 4, The undertaking carries out, funds or has exposures to construction or operation of electrici- ty generation facilities that produce electricity using fossil gaseous fuels. NO 5, The undertaking carries out, funds or has exposures to construction, refurbishment, and oper- ation of combined heat/cool and power generation facilities using fossil gaseous fuels. NO 6, The undertaking carries out, funds or has exposures to construction, refurbishment and opera- tion of heat generation facilities that produce heat/cool using fossil gaseous fuels. NO
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105SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Results and KPI’s at Group-level The results of the Group’s taxonomy reporting are presented in two tables to differentiate between green debt capital providers and other debt capital providers. Results and KPI’s for green bonds1): KPI per Business segment Green bonds Revenue (MNOK) Proportion of total group revenue (A) KPI turnover based (B) KPI CapEx based (C) KPI turnover based weighted (A*B) KPI CapEx based weighted (A*C) A. Financial activities 23,065 94.3 % 9.1 % 9.1 % 8.3 % 8.3 % Asset management 403 1.6 % 0.0 % 0.0 % 0.0 % 0.0 % Banking2) 22,315 91.3 % 9.1 % 9.1 % 8.3 % 8.3 % Investment firms 347 1.4 % 0.0 % 0.0 % 0.0 % 0.0 % Revenue (MNOK) Propor tion of total group revenue (A) Turnover KPI (B) CapEx KPI (C) Turnover KPI weighted (A*B) CapEx KPI weighted (A*C) B. Non-financial activities 1,385 5.7 % 0.0 % 0.0 % 0.0 % 0.0 % Total revenue o f the group 24,449 100.0 % Average KPI turnover based Average KPI CapEx based Average KPI of the Group 8.3 % 8.3 % 1) ISIN: CH1184694789, MING99 PRO ESG, MING100 PRO ESG, MING109 PRO ESG, MING110 PRO ESG, MING126 PRO ESG, MING127 PRO ESG, XS2051032444, XS2303089697, XS2536730448 2) Includes companies consolidated based on the equity-based method.
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106SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Results and KPIs for other bonds: KPI per Business segment Other bonds Revenue (MNOK) Proportion of total group revenue (A) KPI turnover based (B) KPI CapEx based (C) KPI turnover based weighted (A*B) KPI CapEx based weighted (A*C) A. Financial activities 23,065 94.3 % 0.2 % 0.0 % 0.0 % 0.0 % Asset management 403 1.6 % 0.0 % 0.0 % 0.0 % 0.0 % Banking1) 22,315 91.3 % 0.2 % 0.2 % 0.2 % 0.1 % Investment firms 347 1.4 % 0.0 % 0.0 % 0.0 % 0.0 % Revenue (MNOK) Propor tion of total group revenue (A) Turnover KPI (B) CapEx KPI (C) Turnover KPI weighted (A*B) CapEx KPI weighted (A*C) B. Non-financial activities 1,385 5.7 % 0.0 % 0.0 % 0.0 % 0.0 % Total revenue o f the group 24,449 100.0 % Average KPI turnover based Average KPI CapEx based Average KPI of the group 0.2 % 0.1 % 1) Includes companies consolidated based on the equity-based method.
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107SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | EU TAXONOMY Total Group-level results and KPIs KPI per Business segment Total Revenue (MNOK) Proportion of total group revenue (A) KPI turnover based (B) KPI CapEx based (C) KPI turnover based weighted (A*B) KPI CapEx based weighted (A*C) A. Financial activities 23,065 94.3 % 9.3 % 9.3 % 8.5 % 8.4 % Asset management 403 1.6 % 0.0 % 0.0 % 0.0 % 0.0 % Banking1) 22,315 91.3 % 9.3 % 9.3 % 8.5 % 8.4 % Investment firms 347 1.4 % 0.0 % 0.0 % 0.0 % 0.0 % Revenue (MNOK) Propor tion of total group revenue (A) KPI turnover based (B) KPI CapEx based (C) KPI turnover based weighted (A*B) KPI CapEx based weighted (A*C) B. Non-financial activities 1,385 5.7 % 0.0 % 0.0 % 0.0 % 0.0 % Total revenue o f the group 24,449 100.0 % Average KPI turnover based A verage KPI CapEx based Average KPI of the group 8.5 % 8.4 % 1) Includes companies consolidated based on the equity-based method.
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108SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Climate change Approach to the topic Limiting climate change has for several years been of material importance, and “Building sustainable communities and businesses” is one of the Group’s five strategic priorities. Climate change represents both a financial risk and an opportunity for the Group through the further development of customer offerings and business models. During 2025, the Board of Directors revised the strategic ambition for climate. The aim has been to clarify the Group’s responsibilities in the transition and to differentiate its roles across upstream, own operations, and downstream activities. In doing so, the Group acknowledges that political decisions, regulatory frameworks, and technological development will be necessary to achieve climate targets, and that measures such as active engagement and advisory services will contribute but alone will not be sufficient to achieve the ambition of net zero emissions. The Group’s transition plan for climate and nature, initiated in 2024, was approved by the Board in December 2025. The transition plan is intended to address the Group’s climate- and nature-related IROs across the value chain. Industry-level transition plans form a central part of the downstream management approach. Assessment of climate-related IROs Climate change is expected to have material effects across the value chain, and the Group is indirectly affected by the impacts of climate change on its suppliers and customers. Climate change has already contributed to adjustments in the Group’s range of services, supplier engagement, and the way the Group provides financing to customers. The Group’s material IROs, including where they are concentrated and the time horizons they span, are presented in the tables to the right. IMPACTS Value chain Time horizons Financed and invested emissions Negative Downstream Medium-term Long-term Emissions from purchased goods and services Negative Upstream Medium-term Long-term Energy consumption in lending Negative Downstream Medium-term Long-term Energy consumption in own operations Negative Own operations Medium-term Long-term RISKS Value chain Time horizons Credit risk in the loan portfolio Downstream Medium-term Long-term Reduced access to or increased prices of goods and services Upstream Medium-term Long-term Loss of customers to ESG requirements Downstream Short-term Medium-term Defi cient ESG data, quality and insight Upstream Downstream Medium-term Long-term OPPORTUNITIES Value chain Time horizons Increased innovation and development of business models and customer offering Downstream Short-term Medium-term The role of driver of the green transition All Short-term Medium-term
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109SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT The process underlying the implementation of the Group’s double materiality assessment is described in more detail under General Information. Detailed descriptions of the assessments made for climate-related IROs can also be found under the same chapter. Impacts on climate change As a provider of capital and other services to customers in the region, the Group’s impact on climate change is primarily indirect. Climate-related impacts stem directly from the Group’s business models and strategies. The Group shall contribute to the transition of the region in which it operates, while simultaneously transitioning its own operations. The Group’s material impacts are described below. Financied and invested emissions With total assets of approximately NOK 240 billion, the Group has a significant impact on climate change through its financing of the retail and corporate markets. In addition, the Group has invested emissions related to associated companies providing services on behalf of the Group’s customers. Financed and invested emissions account for 99 per cent of the Group’s GHG emissions and represent the Group’s largest impact on climate change. Emissions from purchased goods and services The upstream value chain constitutes the majority of the Group’s “own” emissions. The procurement of goods and services is a significant source of emissions, with services such as IT operations, branding, and other strategic purchases among the largest contributors. In addition, the Group’s travel activities also contribute to GHG emissions. Energy consumption in lending A significant portion of the bank’s loan portfolio is linked to residential mortgages, commercial real estate, construction, transportation, and energy and water supply. Although energy needs vary across industries, and a substantial share of consumption is already based on renewable sources, these sectors must also reduce their energy use to free up capacity in the power grid. This is necessary to enable the transition of industries that are currently dependent on fossil energy sources. Energy consumption in own operations The Group has locations spread across the region, and at several sites there is a need for improved energy efficiency. Landlords are encouraged to upgrade and renovate premises to meet the Group’s preferred standard. In addition, the Group’s procurement of IT services also results in significant energy consumption through data processing and server cooling. Climate-related risks and opportunities The Group aims to create sustainable growth and profitability for its owners, customers, employees, and the region. The Group’s climate risk strategy is designed to support these objectives by: • Identifying, assessing, and managing future climate risk related to the Group’s operations. • Developing and maintaining knowledge, tools, and methods to identify climate risk at the customer level and to quantify risk at the aggr egated portfolio level. • Designing procedures, policies, and authorisations to form an effective frame work for the business, with the aim of keeping the Group’s exposure to climate risk within the risk appetite approved by the Board of Directors. • Managing climate risk in the loan portfolio through advisory services, transition financing, r elevant products, and appropriate pricing. For the lending activity, significant industries are reviewed jointly by the industry officer, the Credit Department, and the Risk Management Department. Potential threats and uncertainties are identified, and risk is assessed over the short, medium, and long term. Where significant financial risk is identified, the ESG model can be adapted to identify vulnerable customers. Finally, the choice of risk management strategies is considered, including the development of new policy rules. More information regarding the Group’s reporting and management of climate-related risks is described in Note 8: Financial risks and opportunities related to climate change and adaptation. This section outlines the expected financial effects of significant physical risks and transition risks. Expected financial effects from risks such as reduced access to or increased prices for products, and loss of customers due to ESG requirements, have been omitted from this year’s reporting by utilising the phased-in disclosure requirement in ESRS 1 Appendix C. In the implementation of the Group’s double materiality assessment, scenario analyses were used to identify the following significant climate-related risks and opportunities:
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110SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Climate-related risk Description Interaction with strategy and/or business model Credit risk in the loan portfolio The risk of financial losses or reputational damage, which may be directly related to climate change (physical risk) or as a consequence of adjustments towards a lowcarbon society (transition risk). The Group has defined climate risk as a driver for traditional risk categories rather than as a separate risk category. The Group considers climate risk to be a significant financial risk. The results from the Group’s analyses show that climate risk is primarily a risk through financing. The Group is focused on reducing both ESG risk, including climate risk, and the GHG-emissions from its lending portfolio, in line with the Group’s revised strategic ambition for climate. Climate risk is assessed on an individual corporate client basis for engagements exceeding NOK 10 million, with the exception of agriculture, where engagements exceeding NOK 5 million are assessed. Transition plans towards net-zero for significant industries shall be developed and maintained. The credit policy and guidelines shall be designed so that ESG risk and GHG-emissions are included as key evaluation criteria in the approval, renewal, and follow-up of customers. The Group’s overview of industries where businesses are particularly vulnerable to systematic risk drivers such as climate risk, technological risk, market risk, etc., is maintained through annual industry and climate risk analyses, and a semi-annual industry indicator for industries where the Bank has significant exposure. This insight is emphasised in strategic frameworks and growth plans, as well as in recommendations for changes to policy and guidelines. Reduced access to or an increase in product prices The Group relies on robust supply chains within payment services, IT security, and infrastructure to avoid downtime and ensure the delivery of services. These supply chains, in turn, have subcontractors located in other countries or geographical areas that may be exposed to different types of climate risk. An increase in, for example, energy prices, infrastructure operations, or rising costs associated with purchasing IT equipment, etc., could affect the Group’s costs over the long-term. The Group sets requirements for suppliers through a dedicated standard declaration as an appendix to contracts. This includes, among other things, requirements and expectations regarding reuse and minimising environmental impact. This is also a topic in supplier dialogue. At the time of reporting, mapping and analysis of the supplier base with regard to climate-related risks has not been conducted.
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111SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Loss of customers to ESG requirements With a view to managing risk in the Group’s loan portfolios, the Group could impose sustainability-related requirements and expectations designed to avert situations where the Group has to write down or post a loss on an exposure. Such requirements extend beyond the Group’s expectations of general sustainabilityrelated factors described in the Group’s sustainability strategy and sustainability policy. By imposing more stringent ESG requirements the Group could risk losing customers to competitors who do not impose sustainability-related requirements and expectations. It is important to balance the Group’s requirements and expectations with a good customer dialogue and competitive terms and conditions. This also applies to other business lines in the Group such as accounting services, estate agency services, leasing and appurtenant advisory services. As a general rule, the Group aims to support the transition of new and existing corporate clients rather than excluding them. This means that the Group does not exclude customers solely due to company- or industry-specific climate-related challenges, but rather for excessive violations of industry standards. For example, companies with high GHG-emissions are considered to be engagements with a relative higher risk. Several controversial industries are excluded due to breaches of the Group’s guidelines on managing ESG risk in the corporate lending portfolio. This includes, among other things, financing to companies engaged in coal mining, controversial weapons and forced- or child labour. Ongoing assessments are made of activities and industries that are excluded or should be excluded based on the Group’s ESG requirements. Deficient ESG data, quality and insight Deficient ESG data, quality and insight could lead the Group to: • Grant finance to customers who could potentially subject the Group to undesired reputational and credit risk. • Make erroneous or poor risk assessments at customer or industry level. • Impede the transition upstream and downstream, leading in turn to the Group’s failure to achieve established targets and ambitions. • Fail to deploy community dividend in an optimal manner to support the region of which the Group is a part. The consequences of the above points could have financial consequences in the medium to long term. The risk could exacerbate other risks and may require changes to the Group’s strategies and business models. A large portion of the solutions related to ESG data is centralised in the SpareBank 1 Alliance’s development arm (SpareBank 1 Utvikling DA) at the request of the owner banks. The decision to centralise these operations was made because the owner banks face similar challenges in this area, and it is often more beneficial for the banks to address these issues in a unified manner. The ESG model for risk assessment of business engagements greater than NOK 10 million (agriculture above NOK 5 million) is an example of such economies of scale. A similar approach is applied across the alliance for many issues, though not all. For example, the Group’s allocation of community dividend may help manage more regional challenges or demands.
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112SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Climate-related risk Description Interaction with strategy and/or business model Increased innovation and development of business models and customer offering In addition to posing a transition risk, the customer’s transition presents a climaterelated opportunity for the Group’s business lines when it comes to products and advisory services. The Group notes a rising demand for green loans among larger companies, although green loans are also in demand by smaller businesses and residential mortgage borrowers. Innovation and development of business models serves both as an opportunity for increased sales and a motivation for the Group›s customers to make green investments, which might further reduce the Group›s climate risk. The need for sound advice from the Group›s business areas is crucial for enhancing customers› resilience to climate-related risks. Additionally, increased innovation and the development of business models and customer offerings will contribute to building the SpareBank 1 SMN brand, attracting and retaining skilled employees, and expanding the Group›s range of products and services. Innovation and development of products and services related to climate change in the Group’s business models and associated service models are ongoing and will continue in 2026 as part of the continious work with the Group’s transition plan for climate and nature. The role of driver of the green transition The Group’s strategic ambition is to be a driving force for the green transition through its own operations, advisory services, products, and services. Additionally, the Group’s expertise and influence will be leveraged to support the region and the business community in their green transition. Community dividend shall be allocated in a way that contributes to the transformation of the region in which the Group operates. This will help attract new customers, equity and debt investors, and skilled employees to the Group. The role of a driver of the green transition is one of three sustainability roles the Group holds. Sustainability is established as one of the five strategic pillars in the Group’s strategy. The opportunity is closely linked to the Group’s innovation efforts and the development of its business model and customer offering. The Group uses scenarios from the Network for Greening the Financial System (NGFS) to analyse the consequences of climate change on its activities and value chains. The scenarios “Orderly Transition,” “Disorderly Transition,” and “Hot World” have been applied. Industry-level transition plans are developed to support an orderly transition, while also preparing the Group to manage the other two scenarios. The qualitative analysis focuses on the two downside scenarios and has been continuously updated since 2021. The upside scenario, “Orderly Transition,” assumes rapid technological development and continuous implementation of new technology. Business models, operations, markets, and customer preferences change in the upside scenario, representing an increase in transition risk. In addition, markets adapt to changes in laws and regulations immediately and seamlessly. The downside scenarios, “Disorderly Transition” and “Hot World,” assume that technological development and implementation occur, but at a slower pace. Carbon
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113SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT pricing is higher in a disorderly transition, and climate policies are expected to intensify in the years after 2030. Both transition and physical risks are considered moderate and will in various ways affect the global macroeconomic landscape. In a downside scenario reflecting current climate policies and regulations, carbon prices remain low, and macroeconomic effects are expected to be largely driven by increasing physical risks, which will impact global supply chains, ecosystems, and economies. For each risk group, the analysis evaluates which events may occur, when they are likely to materialize, and what consequences they may have for affected customers. The impact assessment is performed using an ordinal scale with the categories high, medium, and low risk. This is a top-down assessment of the loan portfolio at the sector level, not at the individual customer level. In addition to the assumptions outlined above, the analysis is based on the following key premises: 1. A static portfolio over time; nothing changes. 2. Transition risk is assessed against NGFS’s “Deviating Net Zero” scenario. 3. Physical risk is assessed against NGFS’s “Current Policies” scenario. Quantitative analy ses of the loan portfolio have also been carried out based on these scenarios. For both physical and transition risks in the retail and corporate loan portfolios, several different analyses have been conducted. The analyses, including methodology, assumptions, and results, are described below. • For sectors classified as having high transition risk and high physical risk in the short , medium, and long term, expected credit losses have been estimated in stages 1, 2, and 3 in accordance with IFRS 9. Transition risk represents the largest potential for loss. There is significant uncertainty associated with these estimates, and they do not affect IFRS 9 provisions in the Group’s financial statements. • It has been assessed how increased carbon prices in the NGFS scenarios could impact the financial statements of corporate clients, given estimated GHG emissions per client in line with PCAF. The r esults confirm that, if polluters are responsible for paying for their emissions, industries with high GHG emissions will incur substantial costs. • During 2023, 87 percent of all corporate exposures abov e NOK 10 million were scored using the SpareBank 1 Alliance ESG model. This has formed the basis for further analysis of climate risk, as well as social and governance risks. The ESG model currently does not provide information regarding the time dimension of risk. This analysis also shows that transition risk is a significant risk. • ESG risk has begun to be integrated into the SpareBank 1 Alliance’s credit risk stress test model, with climate scenarios and climate-related variables at the customer lev el included in the model. The model examines two different NGFS scenarios over a 30- year time horizon. • For financed real estate, physical risk has been assessed based on NVE’s risk maps, and transition risk has been assessed using actual energy ratings and estimated energy ratings pr ovided by Eiendomsverdi. Only a small portion of the bank’s loan portfolio is considered exposed to physical risk, and is therefore deemed low. Transition risk for individual customers and associated mortgages is also considered low. • It is important to note that there is uncertainty regarding suppor t schemes related to the implementation of the EU Energy Efficiency Directive, despite clear EU guidance that support schemes must be provided for consumers in member states. If these support schemes are limited, transition risk could increase. Regarding the bank’s commercial real estate portfolio, it is already observed that tenants are seeking newer and more modern buildings, and no significant increase in transition risk is expected as a result of the EU Energy Efficiency Directive. The overall assessment is that a disorderly transition will be the most challenging scenario within the analysis horizon through 2050, and that transition risk is the most prominent climate risk. The Group is therefore actively working to support customers through advisory services, requirements, and expectations in the transition, in order to reduce vulnerability to a disorderly shift to a low-emissions economy.
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114SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT The Group’s transition plan for climate and nature The Group´s transition plan is not compliant with all of the requirements in ESRS E1. SpareBank 1 SMN has developed a Group-wide transition plan for climate and nature, encompassing strategic ambitions, an action plan, and an operational model. The transition plan has been developed in accordance with recognized frameworks, as well as insights and results from the Group’s double materiality assessment, climate accounts, and SBTi. The plan is anchored in the Group’s overall strategy and was reviewed and approved by the Board of Directors in December 2025. It is based on the Group’s value chain, with defined objectives, milestones, and measures for each part of the value chain. This is intended to build the necessary competence, systems, and governance structure to enable the Group to achieve its targets. For the Group’s own operations and the upstream value chain, the plan is currently focused on the 2030 horizon. For downstream activities, the sector-level transition plans are guiding, with a horizon extending to 2050. Strategic ambitions The Group’s strategic ambition for the transition has been approved by the Board of Directors and shall guide priorities and implementation: At an overarching level, SpareBank 1 SMN shall act as a driver and supporter of long-term value creation, risk awareness, and competitiveness in Central Norway. At the same time, through continuous improvement of its own operations and customer offerings, the Group shall take active responsibility to ensure that the region contributes to achieving Norway’s legally mandated climate and nature targets. Through sector-specific transition plans for energy efficiency and emissions reduction, the Group shall, based on national frameworks and roadmaps, assume its share of responsibility in the transition to a low-emission society, with the goal of achieving net zero emissions by 2050. This work is anchored in national frameworks and regulatory requirements. For upstream operations and the Group’s own activities, the ambition is to reduce the Group’s direct and indirect emissions through responsible consumption, procurement, and efficient operations. In the downstream segment, the ambition is to strengthen the Group’s role as a financial facilitator for customers and local communities in the transition to a low-emission society, through financing, advisory services, and collaboration. The Group acknowledges, however, that political decisions, regulatory frameworks, and technological development will be necessary to achieve climate targets. The Group’s measures, such as active engagement and advisory services, will contribute to ensuring that the Group assumes its share of responsibility in society’s transition to net zero by 2050. Operating model The transition process shall be integrated into the Group’s ordinary corporate governance and planning processes. Climate and nature are followed up through measurement, reporting, and management anchoring on the same level as other strategic priorities. The operating model is clearly anchored in Group Management, with defined lines of responsibility and structured follow-up. The model is designed to ensure coherence between strategy and execution, and to facilitate the transition over time. This will contribute to holistic coordination across all material focus areas, while ensuring that responsibility for implementation remains close to business operations and day-to-day activities Action plan - Own operations Culture and competence The Group shall ensure that employees and leaders possess relevant competence in climate and nature, tailored to their roles and responsibilities. This includes developing advisors who can support both retail and corporate customers in the transition. In addition, employees shall gain increased awareness of how the Group impacts climate and nature through energy consumption, travel, and procurement. This work is carried out through clear communication of expectations, mapping of competence gaps, and the establishment of a Group-wide competency framework. Akademiet, the Group’s competence initiative, plays a central role in the implementation. Real estate The Group shall establish uniform practices for energy use, waste management, reuse, and food waste reduction in both owned and leased premises. At the same time, space utilization in the Finance Houses shall be optimized through analysis of actual usage and future needs. Group-wide principles for flexible and cost- effective space management shall be established. Action plan - Upstream IT-operations, development, and procurement IT operations are both a major contributor to the Group’s indirect emissions and an important enabler of more efficient operations. The Group shall reduce climate and nature impacts from IT through increased standardization and joint Group- and Alliance-wide procurement. Artificial intelligence is also becoming an increasingly important part of the Group’s efficiency measures. In connection with technology choices, principles shall be developed for more energy-conscious use of artificial intelligence.
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115SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT In addition, the Group works systematically to reduce the climate footprint associated with IT equipment through longer usage periods, increased reuse, and recycling. This includes establishing standards for IT equipment lifespan and clearer guidelines for internal reuse prior to new acquisitions. Travel, transport and events Travel activity shall be reduced through needs-based management, clear guidelines, and leadership anchoring. Digital meetings shall be the default, and low-emission alternatives prioritized when physical presence is necessary. For events, a more purpose-driven practice shall be established with clear requirements regarding utility, scope, and execution, aligned with the Group’s climate and nature ambitions. Consumption and supplier follow-up The Group shall establish common practices for the procurement and use of promotional items and office supplies, aiming to reduce volume and environmental impact. Compliance is ensured through purchasing routines and line management responsibility. This shall contribute to a reduction in the Group’s CO 2 footprint and better cost control, in line with the Group’s overarching climate and nature ambitions and circular economy principles. Follow-up of strategic suppliers shall be integrated into regular management processes, with clearer requirements, improved data, and structured dialogue. Action plan - Downstream The majority of the Group’s financial risk and impact on climate and nature originates from its lending portfolio. At the reporting date, transition plans have been prepared for residential mortgages, commercial real estate, agriculture, fisheries, and shipping and offshore. These sectors have been prioritized due to their significance for the Group’s climate and nature-related risks. The need for transition plans for other sectors beyond the roadmaps and sector-specific plans is continuously evaluated. The Group’s insight into the climate and nature-related risks of its lending portfolio is continually improving. However, the Group acknowledges that data quality and data collection across sectors remain a challenge. This is being addressed both through collaboration within the SpareBank 1 Alliance and through initiatives led by the sectors themselves. Transition plans within selected sectors Transition plan for residential housing Residential mortgages constitute a significant portion of the bank’s lending portfolio (68 percent), where the Group has the potential to influence the transition to a low-emission society. The housing sector accounts for a large share of Norway’s electricity consumption, and the energy rating of a dwelling is directly linked to household finances, risk, and underlying property value. The Group can reduce transition risk through increased competence and advisory services for customers, focusing on information and awareness- raising. The Group’s mortgage portfolio includes all customers with housing finance, including financing of holiday homes. The portfolio consists of various types of residential properties, with detached and semi-detached houses and apartments making up the majority. At the end of the year, 48 percent of financed properties had a valid energy certificate from Enova (up from 44 percent in 2024), while 52 percent had estimated energy consumption based on data from Eiendomsverdi. 47 percent of loans are linked to properties with high energy consumption (energy rating E, F, or G), which account for 68.9 percent of the total estimated electricity consumption of 2.59 TWh in 2025. Inherent opportunities and challenges The following opportunities have been identified for private individuals in the transition of the mortgage portfolio: • Energy efficiency measures and smarter electricity management can reduce household costs and impact proper ty value. • Self-production of energy (solar panels), electric vehicle charging, and ener gy storage (battery solutions) can increase property value. • Reduced financing costs for green transition, for ex ample, transition financing for energy efficiency upgrades. Conversely, these factors also present challenges for the portfolio: • Poor energy ratings may potentially lower the pr operty value for the customer. • Fluctuations in electricity prices and changes in the energy market can negatively affect household finances. Targets and KPIs • 2030: 10% improvement in energy rating (kWh per m²) fr om the 2024 baseline. • 2050: 40% improvement in energy rating (kWh per m²) fr om the 2024 baseline. Decarbonisation levers and strategies • Offer favourable loans for energy-efficient homes and transition financing for upgrades to the existing housing stock. • Increase advisor competence and raise customer awareness of the link between climate risk, ener gy rating, property value, and personal finances.
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116SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT • Actively collaborate with the SpareBank 1 Alliance, industry organisations, and public authorities to promote sustainable solutions aimed at housing and private individuals. Transition plan for commerical real estate The Group is significantly exposed to commercial real estate in terms of both volume and emissions. The sector is material from an ESG perspective. While commercial buildings in Norway have relatively low operational emissions due to a high share of clean energy, the sector as a whole accounts for over 60 percent of the country’s total electricity consumption. Furthermore, the sector’s value chain generates substantial emissions related to high material use, land-use changes, and large amounts of waste. Requirements set by the EPBD, EED, EU Taxonomy, and national climate legislation increasingly mean that the value of commercial real estate is affected by the energy efficiency of buildings and their climate adaptation capacity. For the Group, the sector represents a significant transition risk, but also a financial opportunity. Inherent opportunities and challenges Commercial real estate is at the center of a structural transition driven by regulation, energy availability, and climate risk. The sector has substantial needs for upgrading existing building stock, which presents both opportunities and challenges for industry participants. • Energy efficiency affects both operational costs and underlying property values. Electricity consumption is the largest driv er of costs and emissions in the sector, and building efficiency is already a proven competitive advantage. • Revenue opportunities through self-generation o f electricity (solar panels), storage of surplus energy (battery solutions), and smart energy management can contribute to increased and new utilisation of existing property stock. • Regulations such as EPBD, EED, and the EU Taxonomy define what is considered sustainable and may pr ovide a competitive advantage over time. These factors also represent significant challenges for the sector. • The sector is heavily exposed to fluctuations in electricity prices. This increases credit risk for the Gr oup due to growing uncertainty in the cost structures of actors within the sector. • Transition risk arises from a potential decline in the value of buildings with poor energy perf ormance, which in turn may lead to higher capital requirements and reduced access to financing. Such buildings also potentially entail significant upgrade needs, resulting in substantial investment costs for actors merely to remain competitive. • Physical climate risk, stemming from increasing extreme w eather events and natural disasters in previously less-exposed areas, may impact the underlying values of existing property assets. Targets and KPIs The Group’s overarching objective for Commercial Real Estate is to reduce energy consumption per m² financed. The Group has limited control over the emission factors applied to produced and consumed kWh but can influence the kWh consumed per financed square metre. The following targets have been set for 2050, relative to 2024: • 2030: 15 per cent reduction in kWh/m2 • 2050: 50 per cent reduction in kWh/m2 The targets are based on recognised pathways (CRREM/SBTi) and reflect that energy consumption is the key indicator for electricity price risk, emissions risk, and financial risk within the portfolio. Decarbonisation levers and strategies • The Bank’s framework for sustainable products enables financing of customer s’ transition, including documentation of the use of funds and climate impact(s). • All new engagements within the Commercial Real Estate sector must provide a valid ener gy certificate. • New customers with properties in energy classes F and G must pr esent a plan for upgrading the property. This also creates new financing opportunities for the Group. • Collaboration with regional actors and industry clusters. Transition plan for agriculture The majority of emissions in the Group’s lending portfolio originate from agriculture, primarily livestock and fertilization. The sector accounts for 10 per cent of Norway’s mainland emissions. The Bank aims to be an active supporter through both capital and expertise, enabling the agricultural sector in the region to contribute to Norway’s target of a five million tCO 2eq reduction by 2030. At the same time, the sector presents opportunities for emissions reduction and value creation through measures such as fossil-free energy, improved fertilizer management, biogas, carbon sequestration, and innovation. For the Bank, as one of the country’s largest financiers of agriculture, the sector is thus strategically important both for reducing the Bank’s overall climate risk and for achieving the Group’s objectives and ambitions.
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117SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Inherent opportunities and challenges The sector faces significant emissions challenges, alongside opportunities for emissions reductions and circular solutions. Agriculture combines high climate risk with substantial potential for transition. The sector has several structural and technological opportunities that can deliver significant benefits for both the climate and farmers’ competitiveness: • Energy efficiency and reduced operating costs through measures such as modernisation of machiner y and optimisation of energy use. • Biogas and circular resource utilisation represent one o f the most tangible climate solutions in agriculture, as biogas from livestock manure replaces fossil energy. • Carbon sequestration in soil will reduce agriculture’s net climate footprint through measures such as co ver crops, grazing, and biochar. • New technologies and innovations, such as precision farming, alternative f eed types, and low-emission livestock, can achieve significant emission reductions in agriculture. At the same time, agriculture faces significant structural challenges and regulatory barriers, making the transition to a low-emission society more demanding. • Transition risk arising from uncertainty related to investments in technology and inno vations in production, feed, and harvesting. This increases operational risk for farmers. • Increased reporting requirements, such as detailed consumption o f fossil fuels, electricity, and chemical products, place an additional administrative burden on already overworked farmers. • Technological uncertainty. The agricultural sector has not yet reached consensus on which technological solutions to prioritise, and e ven less on which solutions can be applied in the transition to a low-emission society. This affects investment decisions. • Climate change makes agriculture vulnerable. Extreme weather ev ents, such as floods and droughts, are expected to impact production and harvesting capacity in particular. Targets and KPIs In the transition to a low-emission society, agricultural clients shall implement measures that are aligned with the Agricultural Climate Plan for emissions reductions. • By 2030: approximately 18 per cent annual reduction in emissions. • Agricultural clients shall use the agricultural climate calculator. • Agricultural exposures exceeding NOK 5 million shall be assessed using the Group’s ESG model. Decarbonisation levers and strategies • The Bank’s framework for sustainable products enables financing of the customer’s transition, including documentation o f the use of funds and climate impact(s). • Capacity building for agricultural advisors to identify transition opportunities and sustainable solutions for both new and e xisting agricultural clients. • Collaboration across the Alliance, across internal business areas within the Bank, and with interest groups and industr y organisations to support improvements in the agricultural sector. Transition plan for fisheries The fisheries sector represents one of the Bank’s largest industries. With over 5,000 vessels, approximately 11,000 employees, and an export share exceeding 95 percent of the catch volume, the sector is highly important both regionally and nationally. The industry has significant climate exposure due to its reliance on fossil fuels and the high energy intensity of the harvesting stage. Currently, the combustion of fossil fuels during fishing accounts for the majority of greenhouse gas emissions in the sector, representing roughly 8 percent of the Bank’s financed emissions. The sector is central to the Bank’s transition efforts: it is large, emission-intensive, exposed to various types of climate risk, and challenging to decarbonise. The fisheries industry is part of the non-quota sector, where Norway has obligations to reduce emissions by at least 40 percent by 2030—a target likely to increase to 50 percent in the future. For the Bank, the sector represents both a climate risk and opportunity: a risk stemming from requirements to reduce emissions, which will affect technology, operations, financing, and capital needs within the fleet, and an opportunity because new technology, more energy-efficient vessels, and better utilisation of residual raw materials provide significant potential for financing a green transition. Inherent opportunities and challenges The fisheries sector is facing extensive structural changes driven by regulatory requirements, technological development, and climate risk. This presents significant opportunities for actors in Norway. • Energy efficiency through new builds and retrofits: ne w vessels can achieve approximately a 30 percent reduction in fuel consumption and CO2 footprint compared with older technology, making this one of the most effective measures available to the fleet. • Alternative fuel solutions such as biofuels, LNG, hydrogen, and electrification (particularly f or coastal vessels) have the potential to reduce emissions over time.
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118SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT • Technological measures and optimisation of hulls, propellers, engines, battery hybridisation, and shore power can pro vide both economic and climate-related benefits. • Improved utilisation of by-pr oducts and more efficient logistics reduce both emissions and costs, while also increasing value creation in the processing stage. • Strong global position: Norwegian wild-caught fish has a very lo w climate footprint compared with meat products, which will strengthen competitiveness in a market with increasing demands for climate documentation. Similarly, risks related to regulation, technology, access to capital, and physical climate impacts are critical to the challenges the sector faces. • Operational risk from increased CO2-taxes and energy costs: the sector is heavily dependent on fossil fuels, and rising taxes and fuel prices could result in significant expenses. • Misinvestments in technology can be very costly. It remains unclear which pr opulsion solutions—hydrogen, biofuels, electrification, or hybridisation—will become the standard of the future. • Stricter requirements for reporting, catch v olumes, emissions data, and vessel condition will demand increased capital and greater professionalisation among operators. • Physical climate risks due to climate change affect sea temperatures, fish stocks, and quotas, which can impact pr ofitability, operations, and value chains. • Fleet renewal is costly, and the transition to zero- and low-emission solutions ma y require substantial financing, increased equity, and longer depreciation horizons. Targets and KPIs • 2030: At least a 30 per cent reduction in CO2 emissions from financed fisheries activities (measured against 2019). • 2050: Net zero (95-100 per cent reduction) in the portf olio. The Group monitors the portfolio using internal management indicators for emissions per vessel group and per tonne of catch. Decarbonisation levers and strategies • Expectations are set for energy-efficient vessels, the management of o ffcuts/by- products, and the customers’ own transition plans. • The Bank’s sustainable product framework enables financing of the customer’s transition, including documentation of the use o f funds and climate impact(s). • Collaboration with industry actors and clusters to explore technological solutions. Transition plan for shipping and offshore Shipping is one of the Group’s most climate-exposed and strategically important sectors. Offshore vessels in Norway curr ently account for 1 million tCO2eq, equivalent to 2 percent of Norway’s total emissions, making the sector one of the most emission-intensive in the region served b y the Bank. The portfolio primarily consists of offshore and aquaculture-related shipping, two segments central to the energy transition, both as suppliers to the oil and gas industr y and as enablers of growth in offshore wind. The shipping sector is undergoing extensive regulatory changes driven by the IMO, EU Taxonomy, and new energy and climate efficiency requirements. The IMO has tightened its emissions strategy, requiring a 20–30 percent reduction by 2030, 70–80 percent by 2040, and net -zero emissions by 2050 (compared with 2008 lev els). The EU is now including shipping in the emissions trading system and introducing fuel intensity requirements through FuelEU Maritime. This makes shipping a sector with both high transition risk (technology, fuels, regulations) and significant financial importance for the Group, as long -term investments in vessels with a 20–30-year lifespan must be made at a time when future technology remains uncer tain. Inherent opportunities and challenges The sector is undergoing one of the most complex transition processes among the industries in the Group’s loan portfolio. New technology and emerging markets present significant opportunities: • Energy efficiency can reduce operating costs and provide a clear competitive advantage in segments wher e charterers prefer low-emission vessels (particularly offshor e wind). • Technological developments, such as battery hybrids, alternative fuels (LNG, bio fuels, hydrogen, e-fuels), and technical measures like improv ed hull design and optimized propulsion, can deliver substantial emissions reductions over time. • Emerging markets in the transition from fossil to rene wable energy create new revenue streams for offshore shipping companies. Offshore wind installations and operations increase demand for low -emission vessels with high technical capability On the other hand, the sector is characterised by technological uncertainty, r egulatory pressure, and demanding investment requirements, which create challenges: • Technological uncertainty regarding which fuels and propulsion solutions will become standar d in the future. Vessels have long lifespans, and the risk of misinvestment is high—particularly in the zero-emission segment, which is still under development.
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119SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT • High costs of alternative fuels and zero-emission solutions, combined with insufficient infrastructure and varying market willingness to pay , pose core challenges for both shipping companies and banks. • Regulation and reporting requirements f or reliable emissions reporting, including IMO, EU ETS, and FuelEU Maritime standards. Increased obligations may affect predictability, financing capacity, and cash flow for shipping companies. • Strong linkage to oil and gas activities, requiring shipping companies to balance profitable fossil fuel operations with the need to transition to o ffshore wind and low-emission solutions. Targets and KPIs The Group uses the IMO’s emission pathways as a reference and has defined clear targets for the offshore and aquaculture -related shipping segments, which constitute the majority of the portfolio . The targets are measured relative to 2024. • 2030: 20 per cent reduction • 2040: 70 per cent reduction • 2050: 95-100 per cent reduction (net zero) The portf olio is monitored using management indicators such as emissions per vessel group and the share of activity directed toward oil and gas versus renewable energy. For shipping (transport), no KPIs have been set, as the Group is awaiting developments in international frameworks. Decarbonisation levers and strategies • The Bank’s sustainable products framework enables financing of the customer’s transition, including documentation of the use o f funds and climate impact(s). • Customers are expected to report concr ete emissions figures, have credible targets and plans for emissions reductions, maintain an overview of their exposure to fossil and renewable activities, and have a transition plan aligned with the GFANZ framework. • Collaboration with industry actors and clusters is also pursued.
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120SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Targets and KPIs The Group, with the aim of achieving net-zero emissions by 2050, will assume its share of responsibility in the transition to a low-emission society. In addition, a number of management indicators are embedded in the Group’s sector-level transition plans. The Group’s transition plan is intended to guide its objectives and management indicators related to climate. The plan defines workstreams and milestones that, among other things, are intended to establish management indicators for various focus areas. At the reporting date, management indicators designed to address the Group’s climate-related IRO in accordance with ESRS E1 requirements have not yet been developed. These indicators are expected to be in place during 2026 and 2027. Validation of SpareBank 1 SMN’s science-based climate targets was originally scheduled for Q4 2025. Following the publication by the Science Based Targets initiative (SBTi) of a new technical net-zero standard for the development of science-based targets tailored to banks and finance (FINZ), SpareBank 1 SMN has been granted a two-year extension until July 2027 to submit its targets and associated emissions pathways. The Group is currently assessing whether the new standard is suitable for Norway and regional conditions, and whether to continue the validation process. Regardless of the outcome, work on defining targets and management indicators for the Group’s financed emissions will continue in the coming period. Action plans and measures At the reporting date, no concrete action plans have been developed to address the Group’s climate-related IRO in accordance with ESRS E1 requirements. This will naturally follow from the milestones defined in the Group’s transition plan. Climate change has been one of several material topics for the Group for several years. In 2025, the following has, among other things, been completed: • The transition plan for residential properties and the transition plan for commer cial real estate have been prepared. These plans set requirements for financing new and existing customers and aim to reduce customers’ physical climate risk and transition risk (including energy efficiency). • The first version of the Group’s climate and natur e transition plan has been completed. This is described in more detail in the chapter The Group’s transition plan for climate and nature. The development of action plans is expected to follow the same timeline as targets and KPIs Policies The Group’s overarching governance documents related to climate change are the Group’s sustainability strategy and sustainability policy. At the reporting date, the Group has no overarching guideline addressing its material IRO. Guidelines will be developed to anchor the Group’s transition plan, either as new standalone guidelines or integrated into existing policies (e.g., procurement policy and credit policy). This work will continue in the coming periods. The guidelines will help manage IRO related to, among other things, greenhouse gas emissions, physical risk, and transition risk in the Group’s own operations and value chains. They will be closely linked to guidelines addressing IRO in relation to biodiversity and ecosystems.
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121SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 1: GHG-accounting principles Reporting standards The Group’s reporting on GHG emissions has been prepared in accordance with the reporting requirements for climate- and energy-related emissions specified in ESRS E1, and the reporting standard for GHG accounting, the Greenhouse Gas Protocol Corporate Standard, with supplementary Scope 2 and Scope 3 standards and technical guidance. Organisational boundaries The organizational boundaries for the reporting on GHG emissions define which of the Group’s companies and activities are to be included in the reporting. In addition to greenhouse gas emissions from the Group’s own operations, emissions based on the Group’s ownership interests in associated companies are also included. Emissions from equity investments and the Group’s lending activities are also included. The organizational boundaries are essentially identical to the Group’s financial consolidation. Companies over which the Group has operational control Subsidiaries, companies, or business activities over which the Group has operational control are consolidated in the same manner as for financial consolidation. Associated companies Associated companies are those in which the Group holds less than a 50 per cent stake but has significant influence. Significant influence is generally considered to exist when the ownership stake is 20 per cent or more. These are included as invested emissions in the GHG accounting. Invested emissions are limited to the Group’s ownership share and primarily relate to jointly owned companies within the SpareBank 1 alliance. In certain cases, jointly owned associated companies are excluded from the Group’s reporting. This applies to companies with little or no independent activity, or where the products provided by these companies are already included in other emissions categories. Other equity interests Other companies in which the Group holds stakes that are neither subsidiaries nor associated companies are included in the GHG accounting based on sector-based estimations and materiality assessments. This applies to all companies listed in note 30 of the financial statements. Subsidiaries and significant associated companies included are listed in table to the right. Company name Owners- hip share Consolidation Level Organizational boundary SpareBank 1 SMN 100% Full Parent Operational control SpareBank 1 Finans Midt-Norge AS 57.3 % Full Subsidiary Operational control SpareBank 1 Regnsk apshuset SMN AS 93.3 % Full EiendomsMegler 1 Midt-Norge AS 92.4 % Full Mavi XV AS 1) 100% Full SpareBank 1 Invest SMN AS 2) 100% Full SpareBank 1 SMN Kvartalet AS 100% Full SpareBank 1 Bygget Steinkjer AS 100% Full St. Olavs Plass 1 SMN AS 100% Full SpareBank 1 Boligkreditt AS 22.8 % Ownership share Associated company Transferr ed loans are included in Scope 3, category 15 - Financed emissions SpareBank 1 Næringskreditt AS 14.8 % Ownership share SB1 Markets AS 31.9 % Ownership share Included based on ownership shar e in Scope 3, category 15 SpareBank 1 Gruppen AS 19.5 % Based on ownership share Kredittbank en ASA 15.1 % Ownership share SpareBank 1 For valtning AS 21.7 % Ownership share BN Bank ASA 35.0 % Ownership share SpareBank 1 Utvikling DA 3) 18.0 % Ownership share Included based on invoices in Scope 3, category 1 1) 1) Parent company without operations but with subsidiaries that have operations. These are included in Scope 3 category 15. 2) Manages a portfolio on behalf of SpareBank 1 SMN. The portfolio›s emissions are included as invested emissions in Scope 3, Category 15. 3) GHG-emissions included in purchased goods and services.
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122SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Companies excluded from the Group’s GHG-accounting The companies that are excluded are described in the table below. Company name Ownership share Description SpareBank 1 Betaling AS 21.9 % Not included, considered immaterial SpareBank 1 Gjeldsinformasjon AS 18.9 % SpareBank 1 Bilplan AS 100.0 % No activity. Operational boundaries The scope of the Group’s GHG emissions includes indirect upstream emissions from purchased goods and services, emissions from its own operations, as well as invested and financed downstream emissions. The scope of reported GHGs follows the GHG Protocol and is converted to global warming potential (given as CO 2-equivalents) using the most recent conversion values provided by the IPCC. In line with the GHG Protocol, GHG emissions are categorised into three main categories, known as scopes. These are defined as: • Scope 1: Direct emissions from sources owned or contr olled by the Group, such as emissions released into the air through combustion or other direct processes. Relevant emission sources may include emissions from owned vehicles. Related emissions and supplementary information are described in Note 4: GHG emissions from own operations. • Scope 2: Indirect emissions from the production of pur chased electricity, heating, and cooling used by the Group in the operation of its facilities. Related emissions and supplementary information are described in Note 3: Energy consumption. • Scope 3: Indirect emissions occurring in the Group’s value chains, caused by the purchase and sale o f goods and services. Upstream emissions include emissions from the production of purchased goods and services, such as IT and office equipment, as well as employees’ business travel. Downstream emissions include financed emissions from the Group’s lending activities and invested emissions in associated companies. Related emissions and supplementary information are described in Note 5: GHG emissions from the value chain. Base year and policy for recalculation Since the Group’s first GHG accounting in 2019, there has been continuous improvement in reporting scope, calculation methodology, and data quality. In some cases, improvements or corrections of any errors or omissions may have a material impact on the results and comparability with previous years. If changes in company structure, calculation methods, or errors in the GHG accounting represent more than five per cent of the company’s upstream or downstream GHG emissions, previous years will be restated to ensure comparability. A dedicated policy for restatement has been established and is to be followed when adjusting previous years and the base year. Overarching calculation principles To ensure that the GHG accounting functions as an effective management tool, and to provide the Group’s stakeholders with the best possible insight into its climate work, it is crucial to maintain a complete GHG inventory. Multiple data sources and different calculation methods are used to provide a comprehensive picture of the Group’s GHG emissions. Primary and secondary data sources The GHG accounting has been prepared using two main types of data: primary and secondary data. • Primary data include activity and/or emissions data collected directly from the Group or the supply chain. In the GHG accounting, primary data ar e considered quantified data from the Group’s activities, such as fuel or electricity consumption, combined with specific emission factors. • Secondary data refer to other estimated or calculated data. This may include, for e xample, estimated electricity consumption at locations where meter readings are unavailable for various reasons, or emissions calculations based on costs. Of the total GHG emissions, 18 per cent (location-based) are calculated using primary data collected from suppliers or other business relationships in the value chain. Share of primary data Scope 2025 2024 Scope 1 100% 100% Scope 2 81% 76% Scope 3 - upstream 3% 0% Scope 3 - downstream 18% 25%
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123SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Calculation methodologies The data sources are combined using several calculation methods: • Physical data – calculation of primary data sources with specific emission factor s. The climate impact of direct and indirect emissions is calculated by converting primary data into GHG emissions using emission factors. This includes collecting meter readings and multiplying kilowatt-hours by an emission factor to estimate the Group’s GHG emissions related to energy consumption. This method primarily applies to the calculation of indirect energy-related emissions in Scope 2, purchases of IT equipment, and certain financed emissions in Scope 3. It is the most specific and reliable method for calculating GHG emissions. • Spend-based method – calculation of secondary data sources using cost data. Where primar y data are unavailable, secondary data sources are used. The Group’s indirect GHG emissions related to purchased goods and services, as well as investments, are calculated using emission factors from an environmentally extended input-output analysis (EEIOA) provided by Asplan Viak AS. The model uses emissions statistics from various countries, sectors, and industries, as well as trade between them, to estimate the carbon footprint per unit of currency spent on goods and services. It is particularly useful for estimating operational GHG emissions in Scope 3. The model provides a comprehensive overview of which purchase categories and activities have the greatest impact. This completeness comes at the expense of specificity, as it cannot distinguish emissions down to individual products or suppliers. Therefore, the model is suitable for identifying GHG emission hotspots and allows the identification of the most significant emission drivers that should be calculated using physical data. • Partnership for Carbon Accounting Financials (PCAF) – calculation of invested and financed emissions. The majority of the Group’s GHG emissions are in the downstream value chain. The Group is a member of the Partnership for Carbon Accounting Financials (PCAF), a global collaboration between financial institutions to harmonize estimation, measurement, and reporting of GHG emissions related to their lending and investments. The PCAF methodology, together with Finance Norway’s guidelines for reporting financed emissions, is used to estimate the Group’s financed GHG emissions in the lending portfolio and invested emissions from shares, holdings, and other equity investments. • Invested emissions from associated companies To calculate GHG emissions from associated companies, which primarily consist o f the SpareBank 1 Alliance’s product companies, the GHG accounting of these companies has been used. Recognition is done using the equity method. See further descriptions of the individual data sources used for the calculation of the various emission categories in Notes 3–5.
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124SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 2: Significant changes compared to the previous year For the 2025 financial year, improvements have been made to the organisational boundaries, data quality, and methodology. Some of these changes individually result in more than a 5 per cent change in calculated emissions. In line with the Group’s restatement policy, these changes hav e also been applied to 2024. Other minor adjustments have been included in the same restatement to ensure consistency and comparability between years. The significant changes are summarised below. Scope Level Description of recalculations and corrections Effect FY24 (tCO2eq) Effect FY24 (per cent) Scope 2 Material Updated emission factor for district heating The emission factor for district heating has been updated in accordance with the GHG Protocol, which requires that all combustion emissions be allocated to the end user. It now also includes emissions from waste incineration, which increases the emissions in this category. + 278 tCO 2eq (2) + 283 % (2) Scope 3: (3.1 - 3.8) Smaller Methodological changes in the calculation of emissions from capital goods To better align with the recommendations of the GHG Protocol, the full emissions associated with capital goods are reported in the year the assets are put into use (“pulse emissions”), rather than being allocated over the asset’s lifetime in line with accounting depreciation. General improvements in emission factors and data sources All spend-based emissions have been calculated using updated emission factors for 2024. In addition, minor improvements and adjustments have been made to the data sources for most upstream categories. -1.739 tCO 2eq (3.1 - 3.8) - 7,5 % (3.1 - 3.8) Scope 3: 3.15 Material Change in downstream emissions of invested companies SpareBank 1 Gruppen has adjusted downstream emissions for 2024 to align with the Group’s accounting of counterpart emissions. Previously, the counterparty’s Scope 1, Scope 2, and Scope 3 emissions were included. Scope 3 is now excluded. - 437 thousand tCO 2eq (3.15) - 17 % (3.15) Scope 3: 3.15 Material Change in the factor set for calculating financed emissions PCAF has recently changed the underlying datasets from Exiobase to CEDA (Comprehensive Environmental Data Archive), which provides more accurate and up-to-date emission factors. This improves the quality of calculations where counterparty data is unavailable but results in a significant change. Despite the improved estimate quality, the estimates remain subject to high uncertainty. - 309 thousand tCO 2eq (3.15) - 12 % (3.15)
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125SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 3: Energy consumption 1 Sectors with high climate impact are those listed under NACE codes A to H and L (as defined in the Commission Delegated Regulation (EU) 2022/1288). Collection of energy consumption for electricity, district heating, and fossil fuel sources. The Group’s total energy consumption of 6,267.8 MWh (6,175.7) primarily originates from sources used for the operation and heating of premises, including electricity (84 per cent), district heating (15 per cent), and heating and cooling from seawater (< 1 per cent). A smaller portion of energy comes from fossil fuel sources used in vehicles (1 per cent). Data on electricity and district heating consumption are based on meter readings from the Group’s office premises. To estimate energy consumption where meter readings from common areas are not included, a factor of five per cent has been applied. In some cases, the meter readings cover entire buildings where the Group is one of several tenants; in these cases, consumption is allocated based on rental area. For locations with incomplete meter readings, the remaining consumption is estimated based on the average energy consumption per square metre from locations with available meter readings, multiplied by the square metres not covered by meter readings. 38 MWh from fossil fuel sources has been collected from invoice data. Energy consumption from high-climate impacts sectors The Group’s companies are not classified as enterprises belonging to high-climate impact sectors, and therefore, it does not disaggregate fossil energy sources beyond the total consumption 1.
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126SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Distribution of renewable and non-renewable energy consumption (market-based) For calculations using the market-based method, the Group applies the Norwegian Water Resources and Energy Directorate’s (NVE) declaration of electricity suppliers in cases where guarantees of origin for purchased electricity 2 are lacking. Similarly, for district heating, the Norwegian District Heating Association’s overview of energy sources from Norwegian district heating plants is used. The share of renewable sources includes electricity procured through the purchase of guarantees of origin. The distribution of energy consumption according to the market-based method follows the requirements in ESRS E1 AR 32(j). Market-based Energy consumption and mix 2025 2024 Total energy consumption (MWh) 6,267.8 6,175.7 Share of fossil sources in total energy consumption 58.3 % 57.2 % Share of consumption from nuclear sources in total ener gy consump- tion 9.6 % 6.7 % Share of renewable sour ces in total energy consumption 32.1 % 36.0 % Of which non-renewable energy consumption Total f ossil energy consumption (MWh) 3,655.4 3,535.5 Of which energy consumption from nuclear sources Total energy consumption from nuclear sources (MWh) 599.9 415.1 Of which renewable energy consumption Fuel consumption for rene wable sources, including biomass (also comprising industrial and municipal waste of biologic origin, biogas, renewable hydrogen, etc.) (MWh) 0 0 Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh) 2,012.5 2,225.2 The consumption of self-generated non-fuel renewable energy (MWh) 0.0 0.0 Total renewable energy consumption (MWh) 2,012.5 2,225.2 2 Norwegian Water Resources and Energy Directorate (NVE): Supplier declaration for electricity – residual mix 3 Norwegian Water Resources and Ener gy Directorate (NVE): Climate declaration for physically delivered electricity. Distribution of renewable and non-renewable energy consumption (location-based) The Group owns and leases premises in Central Norway and has for several years applied the location-based method for reporting and measuring energy consumption and GHG emissions. The table below is included in accordance with the requirements of ESRS 1 AR 1-5, as this is the method used to monitor the Group’s energy consumption. When allocating electricity consumption between renewable and non-renewable sources, as well as the share of electricity from nuclear power, NVE’s reporting on production sources 3 is used as the allocation key in calculations according to the location-based method. Location-based Energy consumption and mix 2025 2024 Total energy consumption (MWh) 6,267.8 6,175.7 Share of fossil sources in total energy consumption 3.4 % 3.1 % Share of consumption from nuclear sources in total ener gy consump- tion 2.1 % 1.6 % Share of renewable sour ces in total energy consumption 94.5 % 95.2 % Of which non-renewable energy consumption Total f ossil energy consumption (MWh) 213.1 193.9 Of which energy consumption from nuclear sources Total energy consumption from nuclear sources (MWh) 129.7 100.5 Of which renewable energy consumption Fuel consumption for renewable sources, including biomass (also comprising industrial and municipal waste of biologic origin, biogas, renewable hydrogen, etc.) (MWh) 0 0 Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh) 5,925.1 5,881.3 The consumption of self-generated non-fuel renewable energy (MWh) 0.0 0.0 Total renewable energy consumption (MWh) 5,925.1 5,881.3
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127SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 4: GHG-emissions from own operations 4 Department for Energy Security and Net Zero: Greenhouse gas reporting: conversion factors 2024) 5 Norwegian Water Resources and Ener gy Directorate (NVE): Climate declaration for physically delivered electricity) (12 g CO2eq/kWh). 6 Norwegian Water Resources and Ener gy Directorate (NVE): Supplier declaration for electricity – residual mix (535g CO2eq/kWh). Scope 1 – Direct emissions A small amount of direct emissions is accounted for in Scope 1, related to the combustion of purchased fossil fuels for vehicles. In 2025, this amounted to 9 tCO2e (3 tCO2e). The change is mainly due to improved data availability. The Group has no GHG emissions from regulated emissions trading systems or from direct emissions from biomass decomposition or combustion in Scope 1. Tank-to-wheel factors used for Scope 1 calculations are sourced from the Department for Energy Security and Net Zero (formerly DEFRA) 4. Scope 2 – Indirect emissions from purchased electricity Indirect emissions from purchased energy for own operations originate from the production of electricity and district heating. In addition, a small share of locally produced heating and cooling from seawater is included in the Group’s total energy consumption. These emissions are not accounted for. Collection of energy data used as the basis for calculating Scope 2 emissions is described in more detail in Note 3: Energy Consumption. In 2025, location-based emissions amounted to 180 tCO 2eq (183 tCO2eq). The comparative figures have been adjusted due to an error. Location-based GHG emissions are calculated using an emission factor for the Norwegian consumption mix from NVE 5. For the calculation of market-based GHG emissions, purchases of guarantees of origin or renewable certificates are taken into account. In these cases, the emission factor is 0 gCO 2eq/kWh based on documentation from electricity suppliers received via the property managers used by the Group. This applies to 2,012 MWh of energy consumption in Scope 2 and corresponds to an increase of 1,077 tCO 2eq in market-based emissions if guarantees of origin had not been used. For all other market-based Scope 2 emissions, NVE’s electricity supplier declaration is applied. 6 Emission factors from Asplan Viak are used to calculate GHG emissions from district heating purchases in the region. The Group has no indirect GHG emissions from biomass decomposition or combustion. Scope 1 GHG emissions 2025 2024 Gross Scope 1 GHG emissions (tCO2eq) 9.0 3.4 Percentage of Scope 1 GHG emissions from regulated emission trading schemes 0.0 0.0 Scope 2 GHG emissions Gross location-based Scope 2 GHG emissions (tCO2eq) 180 183 Gross market-based Scope 2 GHG emissions (tCO2eq) 1,874 2,588
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128SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 5: GHG-emissions from the value chain The value chain accounts for the majority of the Group’s GHG emissions (99.9 percent), totaling 2,439,741 tCO2eq (1,766,301 tCO2eq) in 2025. These emissions occur indirectly through the purchase of goods and services related to the Group’s own operations (upstream), as well as invested and financed emissions (downstream). Upstream and downstream emissions together constitute the Group’s total Scope 3 emissions. The Group has chosen to include all upstream categories in Scope 3 where it has activity, regardless of materiality, amounting to 20,276 tCO 2eq (21,496 tCO2eq) for 2025. The Group only has activity in category 15 (invested and financed emissions), which accounts for 2,419,465 tCO 2eq (1,744,805 tCO2eq) in 2025, an increase of 28 percent. This increase is mainly due to changes in methodology and growth in invested companies. See Scope 3, category 15 – invested emissions. Intra-group transactions have been eliminated. The Group has no indirect GHG emissions from the degradation or combustion of biomass in Scope 3. The table on the right provides an overview of which Scope 3 categories are included in the GHG inventory, along with explanations for any exclusions. Category Included in GHG-accounting Upstream 1. Purchased goods and services Included. 2. Capital goods Fuel and energy-related activities (not included in Scope 1 or Scope 2) 4. Upstream transport and distribution 5. Waste generated in operations 6. Business traveling 7. Employee commuting 8. Upstream leased assets Operational emissions from leased premises are included in Scope 2. Leased premises are primarily recognised as right-of-use assets in accordance with IFRS 16. Other emissions related to leased premises are included in Scope 3, category 8. Downstream 9. Downstream transport and distribution Not included. The group has no financial activities that fall within the categories. 10. Processing of sold products 11. Use of sold products 12. End-of-life treatment of sold products 13. Downstream leased assets Not included. Leasing from SB1 Finans MN to corpo- rate clients is counted as financed emissions, allocated by sector. Leasing to retail market is included as a separate category under financed emissions. 14. Franchises Not included. The group has no financial activities that fall within the categories. 15. Invested/financed emissions Included. Invested emissions are based on ownership shares in associated companies and other invest- ments. Financed emissions are allocated to the sectors the Group›s exposed to according to the accounting note 8: Loans and advances to customers
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129SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Upstream emissions The Group’s upstream emissions have been calculated using a combination of physical quantities, accounting data, and other estimates. A spend-based approach has been applied, where costs in the income statement are linked to emission factors indicating kgCO 2eq per NOK of purchased goods and services. In addition, supplier information has been used for certain purchased goods in Scope 3, category 1, as well as for certain capitalised assets in Scope 3, category 2. See Note 1: GHG-accounting principles for detailed descriptions of the methodology. Scope 3 – Category 1: Purchased goods and services Purchases of goods and services accounted for 72.1 per cent (68.3 per cent) of the Group’s upstream emissions in 2025. Emissions were calculated using spend-based estimates (99 per cent) and supplier-specific data (1 per cent). A breakdown of the included costs is described in the financial statements, Notes 20 and 21. The largest sources of GHG emissions are IT-related services, marketing and media, and other operational agreements. Scope 3 – Category 2: Capital goods Emissions consist of capitalised assets (furniture, software, hardware, etc.) during 2025. This represented 5.8 per cent (8.5 per cent) of the Group’s upstream emissions. Scope 3 – Category 3: Fuel- and energy-related emissions (not included in Scope 1 or 2) Indirect emissions related to energy production, excluding the direct emissions from electricity generation itself, have been separated out. This includes emissions from losses during transmission and distribution in the electricity grid, as well as other life-cycle emissions related to the production of energy sources. This accounted for 0.1 per cent (0.1 per cent) of the Group’s upstream emissions. Well-to-tank factors 7 have been applied for fuel. For electricity, a total upstream emission factor from the IEA (5.3 gCO2eq/kWh) is used, which includes transmission and distribution losses as well as other life-cycle emissions associated with Norwegian electricity 8. For district heating, it has not been possible to separate life-cycle emissions related to the production, collection, or preparation of the inputs used for combustion. These emissions are therefore included in Scope 2. Scope 3 – Category 4: Upstream transport and distribution Calculated using a spend-based method on costs related to freight, postage, and cash- in-transit services. This accounted for 0.9 per cent (1.3 per cent) of the Group’s upstream emissions. 7 Department for Energy Security and Net Zero: Greenhouse gas reporting: conversion factors 2025 8 International Energy Agency (IEA): IEA Life Cycle Upstream Emission Factors (Pilot E dition) (2022) 9 National Travel Surve y 2024 - The Norwegian Public Roads Administration (Statens vegvesen) (Not availiable in English) Scope 3 – Category 5: Waste generated in operations Calculated using cost-based estimates for purchased waste management services. This accounted for 0.1 per cent (0.1 per cent) of the Group’s upstream emissions. Scope 3 – Category 6: Business travels Two methods are used to calculate GHG emissions from business travel, which account for 11.8 per cent (13.1 per cent) of the Group’s upstream emissions. Where possible, the travel agencies’ own GHG calculations are used to estimate emissions from the Group’s employee travel. For other trips, a spend-based method is applied using recorded travel expenses, primarily including both reportable and non-reportable travel costs and mileage allowances. Scope 3 – Category 7: Employee commuting This category is calculated based on statistics from nationwide surveys on Norwegian employees’ commuting patterns 9, multiplied by emission factors for the different modes of transport provided by DEFRA. Assumptions related to remote work have also been applied. The category accounts for 5.3 per cent (5.0 per cent) of the Group’s upstream emissions. Scope 3 – Category 8: Upstream leased assets Emissions from upstream leased assets account for 3.9 per cent (3.5 per cent) of the Group’s total upstream emissions. These are calculated using a spend-based method and include rental costs. Operation of other leased assets is covered under Scope 1 and Scope 2. 2025 2024 Gross upstream Scope 3 GHG emissions (tCO2eq) 20,276 21,496 Purchased goods and services 14,614 14,682 Capital goods 1,171 1,825 Fuel and energy-related activities (not included in Scope 1 or Scope 2) 30 30 Upstream transport and distribution 188 282 Waste generated in operations 20 28 Business traveling 2,397 2,806 Employee commuting 1,073 1,083 Upstream leased assets 782 759
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130SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Downstream emissions 2025 2024 Financied emissions (location-based) 760,859 756,911 Financied emissions (market-based) 1,807,385 1,919,329 Agriculture and forestry 379,818 383,254 Fisheries and hunting 58,780 56,225 Sea farming industries 31,908 12,160 Manufacturing 6,269 3,811 Construction, power and water supply 14,618 14,567 Retail trade, hotels and restaurants 11,627 11,703 Maritime sector and offshore 81,770 113,176 Property management (location-based) 10,311 11,977 Property management (market-based) 420,074 469,166 Business services 4,655 3,587 Transport and other services provision 115,270 93,884 Public administration 1 94 Other sectors 133 837 Wage earners (location-based) 16,956 20,409 Wage earners (market-based) 640,969 712,807 Wage earners (leasing) (location-based) 28,743 31,227 Wage earners (leasing) (market-based) 41,493 44,058 Invested emissions 1,658,606 987,894 Investments in associated companies1) 1,649,355 973,843 Investments in shares, stakes, or other equity interests 9,252 14,051 1) Description can be found in Note 1: GHG-accounting principles A more detailed breakdown of financed emissions by Scope 1, Scope 2, and Scope 3, along with the corresponding weighted data quality per industry, is presented on the f ollowing pages.
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131SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Scope 3 – Category 15: Invested emissions Invested emissions consist of GHG emissions from the Group’s ownership interests in associated companies and other equity holdings. In addition to Scope 1 and Scope 2, Scope 3 is also included, as this is the most significant emissions category for the Group’s associated companies. GHG emissions fr om invested companies are based on the associated companies’ reported Scope 1, Scope 2, and Scope 3 emissions. Note 1: Accounting principles for GHG reporting pro vides a complete overview of the companies included in this category. This accounts for 69 percent (57 percent) of the Group’s downstr eam emissions. There is inherent uncertainty in the estimates. Recognised emissions are based solely on ownership share and not on the activities the associated companies perform on behalf of SpareBank 1 SMN’s customers. Accounting for the associated companies’ downstream emissions based on ser vices provided to the Group’s customers, rather than ownership share, could increase or decrease the emissions. Accounting based on ownership share represents the best estimate at the reporting date. The emissions are distributed as follows: 2025 2024 Investment Total GHG- emissions Ownership share SMN Total GHG-emissions (ownership share- adjusted) Total GHG- emissions Ownership share SMN Total GHG-emissions (ownership share- adjusted) BN Bank ASA 6,520 35.0 % 2,283 8,479 35.0 % 2,969 Kredittbanken ASA 6,415 15.1 % 967 4,879 17.9 % 872 SB1 Markets AS 4,506 31.9 % 1,436 4,190 39.9 % 1,670 SpareBank 1 Forvaltning AS (Group) 7 ,083,707 21.7 % 1,536,456 3,987,894 21.5 % 857,796 SpareBank 1 Gruppen (Group) 554,934 19.5 % 108,212 566,850 19.5 % 110,536 Others1) 9,252 N/A 9,252 14,051 N/A 14,051 Total GHG-emissions 7,665,334 1,658,606 4,586,342 987,894 1) Other investments consist of SpareBank 1 SMN Invest’s portfolio, equity investments in subsidiaries, and other holdings that SpareBank 1 SMN holds in its capacity as a regional savings bank. For reporting purposes, these are not specified in more detail. See note 30 of the financial statements for further information. BN Bank ASA The company provides mortgage loans and commercial real estate loans, primarily in the Eastern Norway region. Estimation of Scope 1, Scope 2, and Scope 3 (upstream) emissions has been carried out using a spend-based methodology. Primary data has been used where a vailable. PCAF has been applied for the estimation of financed emissions. Kredittbanken ASA The company provides unsecured financing to the private market. During 2025, the company merged with Eika. Historical data has not been restated. Estimation of Scope 1, Scope 2, and Scope 3 (upstream) emissions has been carried out using a spend-based methodology. Primary data has been used where a vailable. SB1 Markets AS The company is a Nordic securities firm. It offers services in equity and credit analysis, trading in shares and bonds, and corporate finance services. During the year, the company acquired two divisions from Swedbank as part of a new initiative in Sweden. Estimation of Scope 1, Scope 2, and Scope 3 (upstream) emissions has been carried out using a spend-based methodology. Primary data has been used where a vailable. SpareBank 1 Forvaltning AS (Group) The Group consists of SpareBank 1 Forvaltning AS and Odin Forvaltning AS, and provides products and services to a broad range of clients in asset management and securities services. Estimation o f Scope 1, Scope 2, and Scope 3 (upstream) emissions has been carried out using a spend-based methodology. Primary data has been used where a vailable.
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132SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT The Group’s downstream emissions comprise fund investments and direct investments, primarily made on behalf of clients using client funds. In 2025, the Group relied on two external data providers—Datia and Morningstar Sustainalytics—to estimate emissions from its portfolios. The estimates remain subject to significant uncertainty. Historical data has not been restated. The Group has accounted for counterparties’ Scope 1, Scope 2, and Scope 3 emissions within its own Scope 3, Category 15. This differs from the Group’s r eporting of other invested and financed emissions. SpareBank 1 Gruppen AS (Group) The Group consists of Fremtind Forsikring AS, SpareBank 1 Forsikring AS, SpareBank 1 Factoring AS, and Kredinor AS. It provides non-life and life insurance, pension ser vices, factoring, and debt collection services to a broad range of clients across Norway. Estimation of Scope 1, Scope 2, and Scope 3 (upstream) emissions has been carried out using a spend-based methodology. Primary data has been used where a vailable. The Group has applied PCAF for estimating downstream emissions from its insurance and pension operations. The Group has accounted for counterparties’ Scope 1 and Scope 2 emissions within its Scope 3, Category 15. In 2024, Scope 3 emissions were also included. Historical data has been restated for comparability . Other investments The Group’s investments in shares, equity interests, and other ownership stakes are described in Note 30 of the financial statements. GHG emissions from these investments are calculated in accor dance with the PCAF standard, based on economic activity, with the method varying depending on data availability. For the assets of Mavi XV, company turnover is combined with sector-specific emission intensities (PCAF data quality score 4). For SpareBank 1 SMN Invest’s assets, market value is used as a proxy f or turnover, supplemented with sector-specific emission intensities (score 5). For the Group’s other ownership inter ests, market value is combined with an average emission factor for the entire portfolio (score 5). Scope 3 – Category 15: Financied emissions Financed emissions total 760 thousand tCO2eq (756 thousand tCO2eq) (location-based). This represents 31 per cent (46 per cent) of the Group’s downstream emissions. Customer s’ GHG emissions in Scope 1 and Scope 2 are included in the Group’s Scope 3 downstream emissions. Financed emissions are calculated by multiplying the customer’s total GHG emissions b y the financed share of the customer’s assets. For example, if the Group finances five percent of a customer’s assets, five percent of the customer’s GHG emissions are included. The methodology for estimating emissions fr om the loan portfolio follows Finance Norway’s “Guidelines for calculating financed emissions”, which is based on the PCAF standard. The core of the PCAF methodology relies on estimated emissions using revenue- or loan-based emission factors per sector. CEDA is used as the factor library. Proxy factors have been applied for customers in the fisheries sector who have not reported their own emissions. The Group’s objective is to replace these simple estimates with either customer- reported emissions or activity-based estimates. The data quality of estimated emissions, referred to in PCAF as the data-quality score, ranges from 1 (based on customer-reported GHG emissions) to 5 (factor-based emissions on loan balance). A lower score indicates higher data quality. For most corporate clients, GHG emissions are measured using the factor-based method. The estimated emissions presented below are generally of low quality and carry high uncertainty. The banks in the SpareBank 1 Alliance use a common approach to calculate financed emissions, and the calculations are centralised. GHG emissions related to loan balances at year-end ar e calculated by SpareBank 1 Utvikling DA in accordance with PCAF and Finance Norway’s guidance f or financed emissions. Emission estimates for the Group’s portfolio are subsequently updated with higher-quality data where available—for 2025, this includes recorded fuel consumption from some large shipping and fisheries clients. The table on the next page presents the Group’s estimated Scope 1 and Scope 2 GHG emissions from the loan portfolio, including loans transf erred to SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt, where the Group has operational contr ol.
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133SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT 2024 Scope 1-2 Scope 3 Sector1) Loans (NOKm) Financed emissions Scope 1 and Scope 2 (tCO2eq) Share of total financed emissions Weighted data quality Financied emissions Scope 3 (tCO2eq) Agriculture and forestry 14,026 383,254 51% 3.0 659,525 Fisheries and hunting 6,075 56,225 7% 2.9 25,871 Sea farming industries 4,169 12,160 2% 2.0 91,265 Manufacturing 3,926 3,811 1% 3.9 153,795 Construction, power and water supply 6,296 14,567 2% 4.2 87,675 Retail trade, hotels and restaurants 4,148 11,703 2% 4.1 91,258 Maritime sector and offshore 4,101 113,176 15% 2.6 56,730 Property management (location-based) 24,817 11,977 2% 3.8 5,984 Property management (market-based) 24,817 469,166 3.8 Business services 5,904 3,587 0% 4.2 28,884 Transport and other services provision 7,700 93,884 12% 3.6 114,600 Public administration 60 94 0% 4.9 131 Other sectors 1,454 837 0% 4.2 2,170 Wage earners (location-based) 156,606 20,409 3% 3.1 Wage earners (market-based) 156,606 712,807 3.1 Wage earners (leasing) (location-based) 7,248 31,227 4% 3.0 Wage earners (leasing) (market-based) 7,248 44,058 0.0 Total downstream Scope 3 GHG emissions (location-based) 246,530 756,912 1,317,887 Total downstream Scope 3 GHG emissions (market-based) 246,530 1,906,499 1,311,903 1) The presentation follows from the financial statements’ note 8: Loans and advances to customers
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134SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT 2025 Scope 1-2 Scope 3 Sector1) Loans (NOKm) Financed emissions Scope 1 and Scope 2 (tCO2eq) Share of total financed emissions Weighted data quality Financied emissions Scope 3 (tCO2eq) Agriculture and forestry 14,315 379,818 50% 3.0 704,163 Fisheries and hunting 6,362 58,780 8% 3.2 21,797 Sea farming industries 3,907 31,908 4% 4.0 24,321 Manufacturing 4,277 6,269 1% 4.0 170,681 Construction, power and water supply 6,544 14,618 2% 4.2 79,924 Retail trade, hotels and restaurants 3,841 11,627 2% 4.1 91,950 Maritime sector and offshore 3,926 81,770 11% 2.7 55,886 Property management (location-based) 25,197 10,311 1% 3.8 8,479 Property management (market-based) 25,197 420,074 3.8 Business services 5,500 4,655 1% 4.3 27,821 Transport and other services provision 9,023 115,270 15% 4.3 120,434 Public administration 33 1 0% 4.9 117 Other sectors 1,331 133 0% 4.2 1,702 Wage earners (location-based) 164,508 16,956 2% 3.1 Wage earners (market-based) 164,508 640,969 3.1 Wage earners (leasing) (location-based) 7,307 28,743 4% 3.0 Wage earners (leasing) (market-based) 7,307 41,493 0.0 Total downstream Scope 3 GHG emissions (location-based) 256,071 760,859 1,307,275 Total downstream Scope 3 GHG emissions (market-based) 256,071 1,807,385 1,298,796 1) The presentation follows from the financial statements’ note 8: Loans and advances to customers The table above presents estimated financed GHG emissions from the loan portfolio throughout 2025. The estimated emissions are concentrated in the agriculture and shipping-related sectors. The estimates for GHG emissions have changed significantly compared with the previous year. The main reason is a methodological change, using a new source for emission factors (CEDA). The new emission factors are considered better suited for the purpose, but there remains considerable uncertainty in the estimates, both in absolute terms and relative across sectors. Some minor methodological improvements have also been implemented. Updated figures for 2024 emissions using the new sector-specific emission factors result in a technical reduction of emissions for these customers by 60 percent. These customers accounted for 35 percent of reported financed GHG emissions f or 2024. Overall, the 2024 estimate decreases from 1,050 thousand tCO2eq to 757 thousand tCO2eq. These figures have guided the work on transition plans, but the Group remains cautious in taking strategic actions due to the high level of uncertainty. The majority of the Group’s customers have their emissions estimated using either a revenue-based or loan-based factor. Only a small number of customers currently report their own GHG emissions, and for those that do, the figures are not yet publicly available, which complicates data collection. A summary of the assumptions used in estimating GHG emissions for sectors where primary data has been collected is provided below.
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135SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Fisheries For the fisheries portfolio, fuel consumption data has been collected for the Group’s largest customers over several years. This data has been used to estimate GHG emissions for the fisheries portfolio with high data quality. The fisheries portfolio has the highest data quality in the analysis. Wage earners (mortgages) For the mortgage portfolio, estimated GHG emissions are provided by Eiendomsverdi AS and prepared by Simenergi AS. Emissions are estimated using a GHG emission factor based on the physical production mix, with emissions of 12 gCO2eq per kWh, down from 15 gCO2eq per kWh in 2024. In the tables above, the European residual mix of 535 gCO2eq per kWh is used for estimated market-based emissions. Commercial real estate GHG emissions from financed commercial properties are calculated using information on each individual building, including property type, floor area, and energy rating where available. This information is combined with PCAF emission factors for buildings, either per square metre or per building. Both location-based and market-based emissions are calculated in the same manner as for wage earners (mortgages). Vehicles Business customers are included in the reporting using factor-based emissions. Private customers are primarily included via leased vehicles and car loans. For private customers, information on all financed vehicles—both electric and fossil fuel—is collected. Fuel and electricity consumption are estimated, and for electric vehicles, both location-based and market-based GHG emissions are calculated. Agriculture and forestry Information on the number of animals, cultivated area, and production is obtained from the Norwegian agricultural subsidy registry and linked to the bank’s agricultural customers. Based on registered activity, GHG emissions are estimated at an individual level using activity-specific emission factors. There is considerable uncertainty associated with these figures, and differences between good and poor agronomic practices are not considered. A large share of the Group’s customers are involved in forestry. In total, 2.5 million decares of productive f orest are registered for the Group’s customers. Adjusted for financing share and multiplied by the area-based carbon uptake factor for forests (0.2959 tCO2eq per decare), the financed share of carbon sequestration in forests is estimated at 341 thousand tCO2eq. This is a high-uncertainty estimate and cannot be offset against financed emissions. In line with the updated guidance from Finans Norge and PCAF, the Group has followed the recommendation to report additional information on GHG emissions, electricity consumption, and other characteristics of financed properties, including both private housing and commercial real estate. This information is presented in the tables on the next page.
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136SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT 2025 Loans (MNOK) Financed emissions (location-based) (tCO2eq) Location-based GHG in- tensity (tCO2eq per MNOK exposure) Financed emissions (market-based) (tCO2eq) Market-based GHG inten- sity (tCO2eq per MNOK exposure) Households 163,899 16,941 0.10 640,269 3.9 Commercial real estate 44,103 9,485 0.22 419,248 9.5 Estimated total electricity consumption for all properties (MWh/year) Average electricity consumption (KWh/m2/ year) Average electricity consumption per property (MWh/year) Average GHG emissions (location-based) (kgCO2eq/ m2) Households 2,736,186 201 33,033 1.5 Commercial real estate 1,684,154 216 190,709 2.6 Average year of construction Average usable floor area (UFA) Number of properities Households 1981 134 82,832 Commercial real estate 1979 418 8,831 2024 Loans (MNOK) Financed emissions (location-based) (tCO2eq) Location-based GHG intensity (tCO2eq per MNOK exposure) Financed emissions (market-based) (tCO2eq) Market-based GHG intensity (tCO2eq per MNOK exposure) Households 156,000 20,298 0.13 709,005 4.5 Commercial real estate 42,504 11,743 0.28 465,278 10.9 Estimated total electricity consumption for all properties (MWh/year) Average electricity consumption (KWh/m2/ year) Average electricity consumption per property (MWh/year) Average GHG emissions (location-based) (kgCO2eq/ m2) Households 2,777,060 203 33,745 1.8 Commercial real estate 1,692,740 216 183,894 3.1 Average year of construction Average usable floor area (UFA) Number of properities Households 1981 133 82,296 Commercial real estate 1980 407 9,205
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137SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 6: Total GHG-emissions Retrospective Milestones and target years1) Scope 1 GHG emissions Base year 2024 2025 Changes 2030 2050 Annual %-target / base year Gross Scope 1 GHG emissions (tCO2eq) 3 3 9 62% Percentage of Scope 1 GHG emissions from regulated emission trading schemes - - - - Scope 2 GHG emissions Gross location-based Scope 2 GHG emissions (tCO2eq) 183 183 180 −2% Gross market-based Scope 2 GHG emissions (tCO2eq) 2,588 2,588 1,874 −38% Scope 3 GHG emissions Gross upstream Scope 3 GHG emissions (tCO2eq) 21,496 21,496 20,276 −6% Purchased goods and services 14,682 14,682 14,614 0% Capital goods 1,825 1,825 1,171 −56% Fuel and energy-related activities (not included in Scope 1 or Scope 2) 30 30 30 2% Upstream transport and distribution 282 282 188 −50% Waste generated in operations 28 28 20 −39% Business traveling 2,806 2,806 2,397 −17% Employee commuting 1,083 1,083 1,073 −1% Upstream leased assets 759 759 782 3% Gross downstream Scope 3 GHG emissions (tCO2eq) Investments (location-based) 1,744,805 1,744,805 2,419,465 28% Investments (market-based) 2,907,223 2,907,223 3,465,991 16% Total GHG emissions (tCO2eq) Totale GHG emissions (location-based) (tCO2eq) 1,766,488 1,766,488 2,439,930 28% Totale GHG emissions (market-based) (tCO2eq) 2,931,310 2,931,310 3,488,150 16%
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138SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 7: GHG-intensity Emission intensity is calculated in two different ways: GHG-intensity based on net revenue and financed GHG- intensity. The reason for these two different GHG-intensities is that GHG-intensity based on net revenue is a requirement in ESRS E1, while financed GHG-intensity is a more relevant metric. To calculate GHG-intensity based on net revenue, net revenue should be used as the denominator for calculating GHG-intensity. Net revenue is not directly defined in ESRS, and the definition used follows the NFRD: the amounts derived from the sale of products and the provision of services after deducting sales rebates and value added tax and other taxes directly linked to turnover. In principle, the definitions of net revenue according to international accounting standards (IFRS) or national accounting legislation (NGAAP) shall be used. Credit institutions, however, should use the definition of net revenue established in the regulation on annual accounts for banks, credit institutions, and financing companies, Chapter 4. The Group’s net revenue is the sum of elements 1, 3, 5, 6, and 7 of section 4-1 of this regulation. Elements of net turnover (NOKm) 2025 2024 (1) Interest income and other interest income 13,619 13,560 (3) Commisions receivable 1,757 1,611 (5) Dividends and other incoem from financial instruments 106 103 (6) Net profit or net loss on financial operations 1,017 1,254 (7) Other operating income 1,088 1,006 Net turnover 17,587 17,534 In 2025, the Group’s net income, according to the definition above, was NOK 17,587 million (NOK 17,534 million). This figure has been used to calculate emission intensity per unit of net income below: GHG intensity per net revenue 2025 2024 Total GHG emissions (location-based) per net revenue (tCO2eq/NOKm) 138.73 100.75 Total GHG emissions (market-based) per net revenue (tCO2eq/NOKm) 198.34 167.18 To calculate financed emission intensity, the Group’s financed emissions and exposure to various industries are used. This is presented in the table on the next page, based on Note 8 of the financial statements: Loans and receivables fr om customers, and Scope 3, category 15 emissions.
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139SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT 2025 2024 Sector Loans (NOKm) Financied emissions (scope 1-2) (tCO2eq) GHG intensity Loans (NOKm) Financied emissions (scope 1-2) (tCO2eq) GHG intensity Agriculture and forestry 14,026 383,254 27.3 14,315 379,818 26.5 Fisheries and hunting 6,075 56,225 9.3 6,362 58,780 9.2 Sea farming industries 4,169 12,160 2.9 3,907 31,908 8.2 Manufacturing 3,926 3,811 1.0 4,277 6,269 1.5 Construction, power and water supply 6,296 14,567 2.3 6,544 14,618 2.2 Retail trade, hotels and restaurants 4,148 11,703 2.8 3,841 11,627 3.0 Maritime sector and offshore 4,101 113,176 27.6 3,926 81,770 20.8 Property management (location-based) 24,817 11,977 0.5 25,197 10,311 0.4 Property management (market-based) 24,817 469,166 18.9 25,197 420,074 16.7 Business services 5,904 3,587 0.6 5,500 4,655 0.8 Transport and other services provision 7,700 93,884 12.2 9,023 115,270 12.8 Public administration 60 94 1.6 33 1 0.0 Other sectors 1,454 837 0.6 1,331 133 0.1 Wage earners (location-based) 156,606 20,409 0.1 164,508 16,956 0.1 Wage earners (market-based) 156,606 712,807 4.6 164,508 640,969 3.9 Wage earners (leasing) (location-based) 7,248 31,227 4.3 7,307 28,743 3.9 Wage earners (leasing) (market-based) 7,248 44,058 6.1 7,307 41,493 5.7
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140SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 8: Financial risks and opportunities from climate change and adaptation Climate risk is defined as the risk of financial loss or impaired reputation, which can be related either directly to climate change (physical risk) or as a consequence of adjustments towards a low-emissions society (transition risk). Losses resulting from climate risk will materialise through the traditional risk categories, such as credit risk, market risk, and operational risk. Climate risk is thus a risk driver, rather than a separate risk category. The Group considers climate risk to be a material financial risk. Management Board of Directors’ involvement in climate-related risks and opportunities Responsibility for climate risk follows the Group’s ordinary responsibility structure, in accordance with the Group’s risk management policy. The Board of Directors holds overall responsibility for climate risk through its approval of steering documents and follow-up of reporting from the administration. The Risk and Audit Committee monitors the Group’s work on climate risk and submits its recommendations to the Board. Climate risk is reported to the Board at least quarterly as part of the quarterly reporting and as a standing item in the risk report, and annually through the Group’s annual report and ICAAP/ILAAP. The Board has approved steering documents designed to manage climate risk, such as the Sustainability Strategy, Sustainability Policy, and Credit Strategy. The work of integrating and revising climate risk across all steering documents is an ongoing process. The Board recognises climate risk as both a strategic opportunity and threat, and has consequently approved the development of industry-level transition plans. Management of climate-related risks and opportunities The Group management has set the direction for work on climate risk by establishing sustainability as one of five strategic priorities in the Group strategy, revised in 2025. In the Group’s day-to-day operations, management of climate risk follows the ordinary lines-of-defence structure and responsibilities, with the Group CEO holding ultimate responsibility. Clarifications of roles and responsibilities in climate risk management, as part of the overall sustainability effort, are described in the Sustainability Policy. By including climate risk in all steering documents, responsibility for climate risk becomes an integral part of the Group’s operations. The Group’s ESG Committee contributes to the development and implementation of a Group-wide standard for sustainability, with climate risk being a key part of this work. All of the Group’s business areas are represented on the committee, with members appointed by the responsible Group director or head of the subsidiary. The committee’s mandate includes: • Monitoring trends and developments within ESG • Encouraging further development and intensification of effor ts to integrate sustainability across all parts of the Group, in line with applicable strategic initiatives • Contributing to the development of active impact strategies and transition plans that assist the Group’s customer s, suppliers, and business partners in successfully implementing necessary adjustments • Clarifying the Group’s ESG data requirements as a basis for comprehensiv e corporate governance and preparation for compliance with new regulatory requirements • Supporting the development of competencies regar ding relevant frameworks and regulatory requirements Strategy The Group’s work on climate risk is intended to support the Group’s long-term financial objectives for profitability and growth by: • Identifying, assessing, and managing future climate risk related to the Group’s operations. • Developing and maintaining knowledge, tools, and methods to identify climate risk at the customer level and to quantify risk at the aggr egated portfolio level. • Designing procedures, policies, and authorisations to form an effective frame work for the business, with the aim of keeping the Group’s exposure to climate risk within the risk appetite approved by the Board of Directors. • Managing climate risk in the loan portfolio through advisory services, transition financing, r elevant products, and appropriate pricing. Climate-related risks and opportunities in short, medium and long term The Group annually updates a detailed qualitative mapping of climate risk. Significant industries are reviewed collaboratively by the industry officer, the Credit Department, and the Risk Management Department. Potential threats and uncertainties are identified, and
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141SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT risk is assessed over the short, medium, and long term. Where significant financial risk is identified, adjustments to procedures, policy rules, and the ESG model are considered. The analysis shows that climate risk primarily manifests through lending to customers. The Group’s loan portfolio carries relatively low physical risk, with the exception of the fisheries and aquaculture industries, where the risk is moderate due to the expected rise in sea temperatures. Transition risk will affect most companies in their adaptation towards a low-emissions society. The Group is exposed to agriculture and ship-related industries, which in the analyses have high estimated GHG emissions and associated public attention. These industries are themselves aware of the issues and actively work to reduce GHG emissions, for example through the Agricultural Climate Plan (Landbrukets Klimaplan) and the International Maritime Organization (IMO). In addition to representing a transition risk, customer transition presents an opportunity for the Group’s business lines regarding products and advisory services. This is further described under Climate-related risks and opportunities at the beginning of the chapter. The Group does not have information on expected cost savings from customers’ climate actions, and any estimates would not be representative or relevant. Consequences for operations, strategy and financial planning The results from the climate risk mapping have been used to prioritise further work, establish new policy rules, and support the development of transition plans towards net zero. The results are also used as input in the work on the credit strategy. The implementation of measures emphasises supporting the sustainability strategy and the Group’s objectives of acting as a driver of green transition. In 2025, the transition plan for residential properties and the transition plan for commercial real estate were completed. Climate risk has for some time been integrated into corporate governance through various key performance indicators (KPIs). These KPIs are currently being updated in connection with the Group’s transition plan. KPIs monitoring climate risk are implemented through the credit strategy. The Group issues green bonds and has an established programme to ensure the proper use of funds. In addition, SpareBank 1 Boligkreditt has financed its operations with green bonds. The Group also offers green mortgages, construction loans, and agricultural loans. Climate scenarios’ potential impact on operations, strategy and financial planning This is described in Climate related-risks and opportunities at the beginning of the chapter. Risk management Identifying climate risk Several processes have been established to identify climate risk within the Group’s operations. Much of the work is centred on the lending business, as this is where the risk has been identified as greatest. Vulnerability to climate risk may vary within a given industry. All corporate clients for which the Group has exposure exceeding NOK 10 million are assessed using the SpareBank 1 Alliance’s shared ESG model. The model evaluates customers’ exposure to physical risk (Ef), transition risk (Eo), social factors (S), and corporate governance (G). The model has been developed to provide accurate and up-to-date risk assessments and to ensure robust data capture. Climate risk is an explicit assessment item for all loan applications from corporate and agriculture clients. The adviser must make a separate assessment of the customer’s vulnerability to climate risk in addition to performing the ESG scoring using the model. For the residential mortgage portfolio, information on energy performance certificates, estimated energy consumption, and identification of potential physical risk is updated quarterly for all pledged properties. Managing climate risk The Group manages climate risk primarily through advisory services and transition financing. Industry-specific transition plans include requirements and expectations for customers, which in turn help them manage their climate risk. Clear guidelines help mitigate credit risk and establish boundaries for the lending business. For financing of commercial properties, stricter loan-to-value requirements are applied to buildings with low energy efficiency. This is because upgrades to modern energy standards are expected to be necessary in order to attract tenants and comply with regulatory requirements. Integrating climate risk in the risk management framework Integrating climate risk into corporate governance is an ongoing process and entails incorporating the impact of climate risk into strategies, policies, and procedures. Beyond the Sustainability Strategy and Sustainability Policy, climate risk is integrated into the risk management framework as a risk driver. The aforementioned documents have served as guides for how other steering documents should integrate climate risk. The consequences of climate risk as a risk driver are assessed in the bank’s ICAAP/ILAAP.
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142SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Goals and method Methods used to assess climate-related risks and opportunities, in line with strategy and risk management processes The qualitative analyses of climate risk are conducted on material activities within the Group, with a focus on the largest industries in the Group’s loan portfolios. Potential events are assessed individually, and it is evaluated whether measures need to be implemented. Through these analyses, it has been identified that greenhouse gas (GHG) emissions pose a risk to the customers. This has driven the Group’s work on estimating GHG emissions from the loan portfolio. Detailed descriptions of the calculations and assumptions can be found in notes 1–6. The results from applying the ESG model at the customer level provide individual sub-scores for physical risk, transition risk, social risk, and corporate governance. Portfolio score development is monitored internally, and customers with a red score are followed up regularly by the credit department. The results represent a relative score and are not quantified in relation to credit risk. The Group has therefore chosen not to publish portfolio results. The proportion of loans classified as high risk is implemented as a performance target through the credit strategy. Physical climate risk The Group’s analyses indicate vulnerability to ocean warming through customers in the fisheries and aquaculture industries. Furthermore, properties that are unfavourably located in relation to rising sea levels, flooding, or landslides will become increasingly exposed under warmer and more extreme climatic conditions. Financed properties through mortgages and commercial loans have been linked to NVE’s risk maps and estimates of surface water risk. The data was provided by Eiendomsverdi and subsequently connected to the Group’s lending portfolio. For residential properties, a granular assessment has been conducted using a risk score provided by Eiendomsverdi, with materiality thresholds set jointly within the SpareBank 1 Alliance. The table on the following page shows total outstanding loans, including loans transferred to SpareBank 1 Boligkreditt, secured by real property. Interest and fee income represent gross income. These are account revenues throughout 2025, which, as of year-end, are linked to pledged and risk-assessed properties. This means that the figures are, in reality, understated due to: • New properties during 2025 generating partial-year income. • Refinancing or product changes often leading to new account numbers. Only accounts valid as o f 31.12.2025 are included.t
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143SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT 2024 (NOKm) House- holds Commercial and housing cooper- atives Total loans Share Income from interests and fees Total loans 175,880 26,306 202,186 9,845 of which exposed to climate risk Flooding 2,462 1,854 4,316 2% 238 2% Slides 3,221 1,898 5,119 3% 263 3% Surface water 17,424 NA 17,424 9% 823 8% Quick clay 10,745 135 10,880 5% 528 5% Sea level 3,570 1,869 5,439 3% 274 3% Total exposed at risk 37,423 5, 756 43,178 21% 1,907 19% 2025 (NOKm) House- holds Commercial and housing cooperatives Total loans Share Income from interests and fees Total loans 184,087 27,651 211,738 9,694 of which exposed to climate risk Flooding 2,571 1,870 4,440 2% 227 2% Slides 3,436 1,450 4,886 2% 231 2% Surface water 17,936 3,436 21,372 10% 1,202 12% Quick clay 11,077 407 11,484 5% 529 5% Sea level 3,702 3,868 7,571 4% 345 4% Total exposed at risk 38,722 11,030 49,753 23% 2,205 23% NVE’s risk maps only indicate identified risks in areas where mapping has been conducted, with the exception of sea level rise and surface water, which have been modelled for all properties. The flag does not indicate whether mitigation measures have been implemented. The Bank does not have an overview of which properties have implemented such measures. The table below shows exposure to physical risk by county, as well as Trondheim. Trondheim municipality is overrepresented in the quick clay landslide category. This is due both to the fact that the Group has the largest lending exposure in this municipality and that many areas with quick clay deposits have been identified. 2024 Flood- ing Slides Surface water Quick clay Sea level Total exposed at risk Total balance Trondelag 3,006 64 10,669 9,481 2,972 23,831 126,532 More og Romsdal 394 4,578 3,309 423 1,691 8,697 36,612 Oslo 7 - 1,202 385 114 1,664 11,121 Akershus 199 - 597 211 17 978 8,670 Vestland 116 314 681 104 277 1,346 6,227 Other counties 593 163 967 276 369 2,253 13,024 Total 4,316 5,119 17,424 10,880 5,439 38,769 202,186 Trondheim 1,439 - 6,005 6,326 958 13,121 53,227 2025 Flood- ing Slides Surface water Quick clay Sea level Total exposed at risk Total balance Trondelag 3,463 47 13,080 9,971 3,917 27,352 129,645 More og Romsdal 468 4,372 5,061 440 2,622 10,178 38,781 Oslo 13 - 2,487 376 95 2,749 13,677 Akershus 220 - 1,499 240 25 1,928 9,520 Vestland 131 385 895 111 439 1,658 7,123 Other counties 146 81 1,859 346 472 2,746 12,992 Total 4,440 4,886 24,881 11,484 7,571 46,611 211,738 Trondheim 1,489 - 7,060 6,715 1,049 14,397 54,706 The Group has no information on whether customers have implemented climate adaptation measures. Buildings constructed after 2010 and 2017 are required to comply with the building regulations TEK-10 and TEK-17, respectively, and are therefore likely to be more resilient to physical risks. The figures above do not take this into account.
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144SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Transition risk Eiendomsverdi has provided energy performance certificates for financed properties that hold such certificates, as well as estimated energy ratings for the remaining properties. For all properties, Eiendomsverdi has supplied estimated energy consumption, which has been used to estimate greenhouse gas emissions. The table below shows the balance of mortgages, loans to housing cooperatives, and loans for financing commercial buildings, distributed by the building’s energy rating. The figures include loans transferred to SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt. 2025 2024 Energy rating Households (NOKm) Share Accumulated share Commercial and cooperative housing (NOKm) Share Accumulated share Households (NOKm) Share Accumulated share Commercial and cooperative housing (NOKm) Share Accumulated share A (EPC) 2,863 2% 2% 1,405 5% 5% 2,303 1% 1% 1,568 6% 6% B (EPC) 16,907 9% 11% 2,961 11% 16% 14,184 8% 9% 3,472 13% 19% C (EPC) 10,343 6% 16% 1,944 7% 23% 9,222 5% 15% 1,814 7% 26% D (EPC) 11,521 6% 23% 2,863 10% 33% 10,003 6% 20% 3,158 12% 38% E (EPC) 11,742 6% 29% 1,321 5% 38% 10,372 6% 26% 1,218 5% 43% F (EPC) 15,512 8% 37% 1,055 4% 42% 14,000 8% 34% 788 3% 46% G (EPC) 18,603 10% 48% 1,276 5% 46% 16,774 10% 44% 522 2% 48% A (estimate) 4,575 2% 50% 0 0% 46% 486 0% 44% - 0% 48% B (estimate) 10,508 6% 56% 110 0% 47% 12,711 7% 51% 113 0% 48% C (estimate) 5,425 3% 59% 97 0% 47% 8,672 5% 56% 143 1% 49% D (estimate) 12,540 7% 65% 155 1% 48% 13,242 8% 64% 149 1% 49% E (estimate) 18,148 10% 75% 47 0% 48% 17,055 10% 73% 89 0% 50% F (estimate) 11,492 6% 82% 28 0% 48% 10,726 6% 79% 24 0% 50% G (estimate) 11,336 6% 88% 70 0% 48% 13,554 8% 87% 207 1% 50% Missing1) 22,573 12% 100% 14,319 52% 100% 22,575 13% 100% 13,041 50% 100% Total 184,087 27,651 175,880 26,306 1) Not all mortgaged properties have an estimated energy rating. Estimations are not made for commercial properties, holiday homes, plots of land, buildings under construction, garages, or residential properties lacking sufficient information. The table above shows that many dwellings have potential for energy efficiency improvements. The bank offers favourably priced green construction loans or green loans for energy-efficiency measures to customers wishing to upgrade their homes to a better energy rating.
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145SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT In addition, the Group owns or leases nearly 50 properties. Of these, 10 properties are considered significant for operations and have been risk-assessed based on physical and transition risks. Among these 10, two leased properties are flagged for a 200-year storm surge in 2090, which is beyond the lease horizon. Furthermore, the Group’s headquarters at Søndre Gate 4, which is also leased, is flagged for surface water risk, but at the lowest risk level. For several of the properties owned by the Group, measures have been implemented to improve energy efficiency, and a certification process in accordance with BREEAM In-Use is ongoing for several buildings. 2024 Energy rating Tenancy No. properities Value (NOKm) Total (sqm) Share (sqm) A Rental 1 14,187 40% C Rental 2 3,960 11% C Freehold 1 42 1,742 5% D Freehold 2 92 6,641 19% E Freehold 1 82 3,981 11% Unknown Rental 2 2,013 6% Unknown Freehold 1 109 3,165 9% 2025 Energy rating Tenancy No. properities Value (NOKm) Total (sqm) Share (sqm) A Rental 1 14,187 40% C Rental 2 3,960 11% C Freehold 1 42 1,742 5% D Freehold 2 92 6,641 19% E Freehold 1 82 3,981 11% Ukjent Rental 2 2,013 6% Ukjent Freehold 1 109 3,165 9% The Group generates income from financing oil- and gas-related activities. This industry is exposed to high transition risk. The table below shows the Group’s gross income from financing, loans, and guarantees, measured against the internal settlement interest rate, for oil- and gas-related activities, based on NACE codes from EFRAG’s draft sector classification ESRS SEC 1. 2024 NACE Industry Gross revenue from lending (NOKm) C 19.20 Manufacture of refined petroleum products - G 46.71 Wholesale of solid, liquid and gaseous fuels and related products 1.6 G 47.30 Retail sale of automotive fuel in specialised stores 0.1 H 49.50 Transport via pipeline - 2025 NACE Industry Gross revenue from lending (NOKm) C 19.20 Manufacture of refined petroleum products - G 46.71 Wholesale of solid, liquid and gaseous fuels and related products 0.1 G 47.30 Retail sale of automotive fuel in specialised stores 0 H 49.50 Transport via pipeline - Potential financial effects arising from climate risk Potential financial impacts related to transition risk have not been published for industries other than oil- and gas-related activities. The low, medium, and high rankings in the ESG model represent a relative assessment, based on threshold values for scoring. The insights are used to monitor engagements exposed to relatively high physical or transition risk Even if an engagement receives a high score in the ESG model, this does not necessarily imply that the engagement is considered to have increased credit risk. Climate risk is incorporated in the assessment of credit risk in the standard template for credit cases. The Group has not made any material provisions related to individual impairments or manual adjustments from Stage 1 to Stage 2 under IFRS 9 that can be directly attributed to climate risk.
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146SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT The Group’s assessment of stranded assets The Group’s physical assets mainly consist of a few properties. These properties are centrally located and are recorded well below their actual market value. None of these are assessed to have the risk of becoming stranded assets in the future. For a customer’s asset to become a stranded asset for the Group, the customer must default on their obligations, and the bank must take possession of the collateral. The Group has not made any significant provisions under IFRS 9 that can be directly linked to the effects of climate risk. Therefore, no assets have been identified that are expected to become stranded assets for the Group, either in the short term or leading up to 2050. Reporting of GHG-emissions scope 1, 2 and 3 The Group’s reporting on GHG-emissions is described in Notes 1-7 in the chapter on Climate change. Goal of the work on managing climate-related risks and opportunities The Group’s objectives for managing climate-related risks and opportunities are linked both to the potential to influence the external environment and to how the environment impacts the Group. This entails: • Identifying and managing climate risk as a driver of traditional risk types. • Achieving long-term sustainable profitability and growth through eff ective management of climate risk. • Supporting the successful transition of local businesses and private customers towards a lo w-emissions society.
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147SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Pollution Approach to the topic Financing of sectors such as agriculture, construction and civil engineering, and industry constitutes sources of the Group’s impact on pollution to soil, water and air, and will over time be integrated into the Group’s credit approval routines on an equal footing with climate and nature. Degradation of agricultural soil, ocean acidification, acid deposition, and a warmer and more volatile climate represent financial risks for several sectors, and thus also a risk for the Group. The management of the Group’s IROs related to pollution is closely linked to climate change as well as biodiversity and ecosystems. Assessment of pollution-related impacts and risks The Group’s IROs are concentrated in the sectors to which the Group is exposed. These sectors may potentially have significant impacts on climate, the environment and people if they are not subject to pollution-related requirements and expectations from authorities and other stakeholders. Over time, such impacts may result in increased credit risk, in line with other sustainability risks. The Group’s business model and strategy are not directly affected by identified impacts and risks; however, there is a need for insight into how customers manage pollution and which measures they have implemented to minimise their own impact on air, water and soil. Through financing and advisory services to these sectors, the Group will contribute to reducing its indirect impacts. The Group’s material IROs, where they are concentrated, and the time horizons over which they extend are presented in the tables to the right. Pollution from the procurement of goods and services has been assessed as immaterial in the updated double materiality assessment. This is described in more detail under General information. IMPACTS Value chain Time horizon Financed pollution to air, water, and soil Negative Downstream Medium-term Long-term RISKS Value chain Time horizons Credit risk in the loan portfolio Downstream Medium-term Long-term Defi cient ESG data, quality, and insight Upstream Downstream Medium-term Long-term Loss of customers to ESG requirements Downstream Short-term, Medium-term
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148SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT The process of implementing the Group’s double materiality assessment is described more fully under General information. Specific assessments related to pollution are also provided. Pollution-related impacts As a result of the Group’s exposure to sectors such as agriculture, the Group has an indirect negative impact related to pollution. These impacts arise directly from the Group’s business model and strategy. The Group’s material impacts are described in further detail below. Financied pollution of air, water and soil Through its exposure to sectors such as agriculture, oil and gas, transport, aquaculture and fisheries, the Group is an indirect contributor to pollution of air, water and soil. This may occur through the use of pesticides, potential runoff into waterways, the use of harmful chemicals, oil spills, and emissions of air pollutants such as NOx and SOx. The extent of the impacts will mainly be concentrated in the geographical areas where the activities take place, but may in some cases be more widespread. These impacts must be considered in conjunction with the Group’s impacts on climate change and biodiversity and ecosystems. Pollution-related risks None of the risks had material financial effects in 2025. There are no indications that the risks and opportunities entail a significant risk of material changes in the carrying amounts of assets or liabilities in the financial statements in the upcoming reporting period. There is uncertainty associated with the expected financial effects of the risks. For this reason, it has been decided to omit this information from this year’s reporting by applying the phase-in provisions in ESRS 1 Appendix C. The Group’s material risks are described below. Credit risk in the loan portfolio Pollution is primarily a risk arising from the Group’s financing activities and contributes to climate and environmental risk as a driver of credit risk. No specific analyses or assessments have been carried out regarding how pollution may affect credit quality or risk in the lending portfolio; however, it is recognised that pollution is a driver of climate change, ecosystem degradation and biodiversity loss. Deficient ESG data, quality and insight Poor ESG data, quality and insight may result in the Group: • Providing financing to customers that could expose the Group to undesirable r eputational and credit risk. • Making incorrect or incomplete risk assessments at both customer and sector level. • Hindering transition upstream and downstream, thereby pr eventing the Group from achieving its defined targets and ambitions. • Failing to allocate community dividends optimally to support the region in which the Group operates. The consequences of the abov e may have financial impacts in the medium to long term. Loss of customers due to ESG requirements To manage risk in the Group’s lending portfolios, the Group may impose sustainability- related requirements and expectations on customers in order to avoid situations where exposures must be written down or recognised as losses. These requirements go beyond the Group’s general sustainability-related expectations as described in the Group’s sustainability strategy and sustainability policy. By promoting stricter ESG requirements, the Group may risk losing customers to competitors that do not impose similar sustainability-related requirements and expectations. It is important to balance the Group’s requirements and expectations with constructive customer dialogue and competitive terms. This also applies to the Group’s other business areas. Targets and KPIs The Group’s transition plan for climate and nature has been completed and approved by the Board of Directors. The development of relevant metrics to manage the Group’s pollution-related IROs had not been finalised as at year-end. Pollution contributes to climate change and is a direct driver of impacts on biodiversity and ecosystems. The metrics for managing pollution shall take this interconnection into account. It is expected that the relevant metrics will be established during 2026 and 2027. Action plans and measures At the reporting date, no specific action plans have been developed to manage pollution- related IROs in accordance with the requirements of ESRS E2. The overarching action plan is the Group’s transition plan, but relevant metrics still need to be defined, followed by the specification of measures to achieve the established objectives. The development of action plans is expected to follow the same timeline as the metrics. Policies The Group’s overarching governance document related to pollution is the Group’s Sustainability Policy.
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149SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT At the reporting date, the Group does not have a guideline that specifically addresses pollution-related IROs. Guidelines in line with ESRS E2 and MDR-P will be developed as part of the ongoing work on the Group’s transition plan. These guidelines will be integrated with the guidelines for climate change and biodiversity and ecosystems, reflecting the interconnection of the impacts. In addition, other policies closely linked to pollution—such as the Procurement Policy and Credit Policy—require updates. These policies will help manage the Group’s downstream impacts related to pollution of air, water, and soil.
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150SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 1: Financial risks as a result of pollution Pollution-related risks are concentrated in the downstream value chain and relate to the risk to which the Group’s customers are exposed as a result of either causing pollution or being affected by it. This may lead to increased credit risk for the Group. No pollution- related opportunities have been identified. Reporting on ESRS E2-6, Expected financial effects of risks and opportunities related to pollution, has been omitted by applying the exemption in ESRS 1, Annex C.
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151SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Biodiversity and ecosystems Approach to the topic The interconnection between climate change and biodiversity and ecosystems is well illustrated in the IPCC’s Sixth Assessment Report, published in March 2023. Energy sources, land-use changes, and consumption patterns contribute to exacerbating the nature crisis, which is increasingly felt through, among other things, the rising frequency of extreme natural events in Norway and across Europe in recent years. Biodiversity and ecosystems were identified as material for the first time in 2024, and the Group continues to explore how nature-related IRO should be measured and managed. It is also recognised that the nature crisis, and its consequences, is in many respects as important to address as the climate crisis and its associated impacts. Assessment of IROs related to biodiversity and ecosystems The current impact of the Group’s IRO on biodiversity and ecosystems is relatively low. The Group nevertheless recognises that today’s actions may accelerate or slow the future consequences that biodiversity and ecosystems could have on the value chain, and indirectly on the Group’s earnings and costs. Biodiversity and ecosystems primarily have anticipated effects on the value chain, and on how the Group finances and provides services to its customers. The Group is still in the early stages of understanding future effects across all parts of the business. The Group depends on understanding its customers’ needs in order to adapt its operations. Over time, the anticipated future effects of biodiversity and ecosystems will influence the adaptation of the Group’s business and service models across various functions and business areas. Material IRO, where they are concentrated and the time horizons they span, are presented in the tables to the right. IMPACTS Value chain Time horizons Direct impact drivers of biodiversity loss Negative Upstream Downstream Long-term Impacts of the state of species Negative Upstream Downstream Long-term RISKS Value chain Time horizons Credit risk in the loan portfolio Downstream Medium-term Long-term Defi cient ESG data, quality and insight Upstream Downstream Medium-term Loss of customers to ESG requirements Downstream Short-term Medium-term OPPORTUNITIES Value chain Time horizons Increased innovation and development of business models and customer offering Downstream Short-term Medium-term The role of driver of the green transition All Short-term Medium-term
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152SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT The process underlying the implementation of the Group’s double materiality assessment is described more fully under General information. Specific assessments related to Biodiversity and ecosystems are also provided. Impacts on biodiversity and ecosystems Impacts on species status, land and land-use changes, as well as climate change, are material for industries such as commercial real estate, fisheries, agriculture, and construction. The Group contributes indirectly to the material impacts of these industries. In addition, the Group affects these impacts through the procurement of goods and services. A more detailed description of the Group’s material impacts is provided below. Impacts on the state of species National and international stakeholders rely on minimizing impacts on species’ status to maintain essential ecosystems and ecosystem services. The Group contributes indirectly to influencing species’ status through lending and other services that enable land- use changes, such as land- and sea-based aquaculture as well as the development of residential and commercial real estate. Direct impact drivers of biodiversity loss The primary drivers of biodiversity loss—climate change, pollution, and land-use change— interact as silo effects that reinforce each other, creating severe environmental, societal, and economic consequences. The Group’s financed emissions, pollution to air, water, and soil, and financing of industries that occupy land and sea areas constitute indirect contributors to biodiversity loss. Risks and opportunities linked to biodiversity and ecosystems The Group’s material risks and opportunities related to biodiversity and ecosystems are described below. None of these risks or opportunities had significant financial effects in 2025. There is no indication that they would lead to material changes in the carrying amounts of assets or liabilities in the financial statements in the forthcoming reporting period. There is uncertainty regarding the expected financial impact of these risks and opportunities. For this reason, this information has been omitted from this year’s reporting, in accordance with the phasing-in provision in ESRS 1, Annex C. Credit risk in the loan portfolio Natue risk is also a driver of credit risk and may potentially affect the credit risk of exposed industries over time. However, there are significant differences between sectors, with those for which land is a critical resource facing a higher likelihood of both impacting and being affected by nature risk. This does not mean that the Group’s customers currently have a particularly elevated natural risk, as no explicit analyses or assessments have yet been carried out regarding how biodiversity and ecosystems could directly or indirectly affect the loan portfolio. Deficient ESG data, quality and insight Poor ESG data, quality and insight may result in the Group: • Providing financing to customers that could expose the Group to undesirable r eputational and credit risk. • Making incorrect or incomplete risk assessments at both customer and sector level. • Hindering transition upstream and downstream, thereby pr eventing the Group from achieving its defined targets and ambitions. • Failing to allocate community dividends optimally to support the region in which the Group operates. The consequences of the abov e may have financial impacts in the medium to long term. Loss of customers due to ESG requirements To manage risk in the Group’s lending portfolios, the Group may impose sustainability- related requirements and expectations on customers in order to avoid situations where exposures must be written down or recognised as losses. These requirements go beyond the Group’s general sustainability-related expectations as described in the Group’s sustainability strategy and sustainability policy. By promoting stricter ESG requirements, the Group may risk losing customers to competitors that do not impose similar sustainability-related requirements and expectations. It is important to balance the Group’s requirements and expectations with constructive customer dialogue and competitive terms. This also applies to the Group’s other business areas. Increased innovation and development of business models and customer offering Adaptation and development of the Group’s business models and customer offerings may present an opportunity for increased cost efficiency as well as new financing solutions or service offerings. The Group has commercial opportunities linked to customers’ transition by providing financing, products, and advisory services. The Group already offers green products and services for both the retail and corporate markets. These products are not specifically tailored to biodiversity and ecosystems. The Group has observed increasing demand
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153SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT for green products from both larger and smaller companies and mortgage customers, particularly in relation to financing. Although green investments may help reduce customers’ vulnerability to climate and natural risks, they may also represent a financial risk if the investment cost is too high or the technology choice is inappropriate. Effective advisory services across all business areas of the Group are required to strengthen customers’ resilience to natural risk. In addition, increased innovation and development of business models and customer offerings will help enhance the Group’s brand, attract and retain skilled employees, and increase the Group’s overall competence diversity. The role of driver of the green transition The Group’s strategic ambition is to act as a driver of the green transition through its own operations, advisory services, products, and offerings. In addition, the Group’s knowledge and influence are to be leveraged to support the region and local businesses in the green transition. Profits distributed to society are to be allocated in a manner that contributes to the transformation of the region in which the Group operates. This approach is intended to attract new customers, equity and debt investors, and skilled employees to the Group. The opportunity is closely linked to innovation and the development of business models and customer offerings. The Group’s nature strategy A more detailed description of the Group’s business models is provided in General information. A systematic analysis of how the Group’s current business models address transition risk, physical risk, and systemic risk related to biodiversity and ecosystems has not yet been conducted. This analysis is planned as part of the implementation of the transition plan and other related initiatives. The Group recognises that its business models must be adapted to meet current and future customer needs. Needs related to biodiversity and ecosystems—including direct impact factors such as land use and GHG emissions—are expected to increase in importance in the coming years, as both retail and corporate customers increasingly realise economic benefits from green investments and climate- and nature-related adaptation. The Group’s transition plan The transition plan was approved by the Board in 2025 and is described in more detail in the Climate Change chapter. The plan addresses the Group’s direct impact on nature both upstream and downstream through supplier engagement and sector-level transition plans. In addition, the Group’s indirect impact on nature is managed through its influence on climate change. Targets and KPIs The Group’s transition plan for climate and nature has been completed and approved by the Board of Directors. Targets and KPIs related to the Group’s IRO on biodiversity and ecosystems are currently under development but were not finalised at year-end. It remains to be determined whether specific management indicators for biodiversity and ecosystems will be established, or whether the management of IRO will be integrated into the targets and KPIs for climate change. The indicators are expected to be in place during 2026 and 2027. Action plans and measures At the reporting date, no specific action plans have been developed to manage the Group’s IRO related to biodiversity and ecosystems in accordance with ESRS E4 requirements. The overarching action plan is the Group’s transition plan, but it remains necessary to define the relevant targets and KPIs, and subsequently establish measures to achieve the set objectives. The development of these action plans is expected to follow the same timeline as the KPIs. Policies The Group’s overarching governance document related to biodiversity and ecosystems is the Group’s Sustainability Policy. At the reporting date, the Group has no specific guideline addressing IRO related to biodiversity and ecosystems. Guidelines in accordance with ESRS E4 and MDR-P will be developed as part of the ongoing work on the Group’s transition plan. The guideline will help manage the Group’s IRO related to land-use changes, including deforestation, species status, and ecosystem services in both the Group’s operations and value chain. Other direct impact factors, such as climate change and pollution, will be linked to the biodiversity and ecosystems guideline. Several existing policies will either form part of or be indirectly linked to this guideline. This includes, for example, the Procurement Policy and Credit Policy, which are intended to manage the Group’s upstream impacts (e.g., sourcing and overuse of ecosystems) and downstream impacts (e.g., physical nature risks, transition risks, and ecosystem dependencies). Social consequences arising from impacts on biodiversity and ecosystems will be integrated into relevant guidelines applicable to the Group’s upstream and downstream activities.
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154SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 1: Financial risks and opportunities as a result of biodiversity and ecosystems It has been decided to omit reporting on ESRS E4-6 — Expected financial effects of risks and opportunities related to biodiversity and ecosystems — by applying the exemption in ESRS 1, Annex C. Processes to map natural risk as a driver for credit risk in the loan portfolio, as well as a potential source of innovation and development of customer offerings, will be implemented as a medium-term initiative.
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155SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Resource use and circular economy Approach to the topic Global climate and nature changes are leading to increasing scarcity of various resources. Over time, this may have both direct and indirect consequences for SpareBank 1 SMN in the form of costs and different types of risk. Resource use and circular economy were identified as material in last year’s double materiality assessment. Circularity is considered one of several solution strategies for national and international climate and nature challenges. In addition to reducing the Group’s climate and nature impact, circularity can contribute to cost-efficient operations, as well as foster changes in mindset and motivation among employees—fundamental prerequisites for the Group to achieve its financial objectives and strategic ambitions. Assessment of IROs related to resource use and circular economy In 2025, the Group has also implemented several pilot projects to assess the current effects of resource use and circular economy. These initiatives form part of the development of the Group’s circular economy roadmap. The results and lessons learned from these pilot projects are intended to feed into the Group’s overall transition efforts. The expected effects of the Group’s IRO related to resource use and circular economy are largely dependent on how climate and nature challenges evolve and are managed, both nationally and internationally, as well as how the associated risks materialise across the Group’s value chains. An overview of the Group’s material IRO, their focal areas, and the time horizons they cover is presented in the table to the right. IMPACTS Value chain Time horizons Waste Negative Upstream Downstream Medium-term Long-term Resource use Negative Upstream Downstream Medium-term Long-term RISKS Value chain Time horizons Credit risk in the loan portfolio Downstream Medium-term, Long-term Defi cient ESG data, quality and insight Upstream Downstream Medium-term Long-term Loss of customers to ESG requirements Downstream Short-term, Medium-term OPPORTUNITIES Value chain Time horizons Increased innovation and development of business models and customer offering Downstream Short-term Medium-term
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156SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT The process related to the implementation of of the Group’s double materiality assessment is described more fully under General information. Moreover, specific assessments related to Resource use and circular economy. Impacts on resource use and circular economy Circular economy is intended as a strategic solution to several of the climate and nature challenges arising from excessive resource use, and to help reduce impacts across the Group’s value chains. As a major player, the Group has the ability to influence suppliers and customers to take a position on these issues. This includes, for example, promoting circular economy considerations within the procurement process. A more detailed description of the Group’s material impacts is provided below. Waste Customer upstream and downstream waste generation and management has been identified as a material impact. For the Group, it is important to ensure that customers have robust routines and processes to manage both non-hazardous and hazardous waste, in order to prevent pollution and the spread of harmful environmental substances from, for example, landfilling and incineration. For the industries the Group finances, waste is a direct consequence of resource use and insufficient circularity and reuse. For the Group, waste represents an indirect consequence of financing these industries. Resource use Resource use has been identified as a direct impact the Group has through the procurement of goods and services necessary to ensure stable and efficient operations Notably, inventory, office supplies, and IT equipment represent major procurement categories of physical products where resource use in both production and maintenance is significant. By facilitating increased reuse and circularity in the procurement process and in the management of purchased goods and equipment, the Group can help reduce both direct and indirect resource use. Risks and opportunities related to resource use and circular economy Significant risks and opportunities related to resource use and the circular economy are described below. None of these risks or opportunities had material financial effects in 2025. There is no indication that they would result in significant risk of material changes in the carrying amounts of assets or liabilities in the financial statements in the upcoming reporting period. There is uncertainty regarding the expected financial effects of these risks and opportunities. For this reason, this information has been omitted from this year’s reporting, in accordance with the phased-in requirement in ESRS 1, Annex C. Credit risk in the loan portfolio Overuse of resources and lack of circularity are a direct driver of climate and nature- related risks in the Group’s lending portfolios. Exposure to sectors that contribute to excessive resource use, have low recycling rates, depend on scarce resources, or exhibit inadequate waste management could increase credit risk over the longer term. However, there are significant differences between sectors. This does not mean that the Group’s customers currently face elevated climate or nature-related risk as a result of poor circularity or excessive resource use. At present, no analyses or assessments have been conducted on how resource use and circular economy practices could directly or indirectly impact the lending portfolio. Deficient ESG data, quality and insight Poor ESG data, quality and insight may result in the Group: • Providing financing to customers that could expose the Group to undesirable r eputational and credit risk. • Making incorrect or incomplete risk assessments at both customer and sector level. • Hindering transition upstream and downstream, thereby pr eventing the Group from achieving its defined targets and ambitions. • Failing to allocate community dividends optimally to support the region in which the Group operates. The consequences of the abov e may have financial impacts in the medium to long term. Loss of customers due to ESG requirements To manage risk in the Group’s lending portfolios, the Group may impose sustainability- related requirements and expectations on customers in order to avoid situations where exposures must be written down or recognised as losses. These requirements go beyond the Group’s general sustainability-related expectations as described in the Group’s sustainability strategy and sustainability policy. By promoting stricter ESG requirements, the Group may risk losing customers to competitors that do not impose similar sustainability-related requirements and expectations. It is important to balance the Group’s requirements and expectations with constructive customer dialogue and competitive terms. This also applies to the Group’s other business areas.
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157SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Increased innovation and development of business models and customer offering Integrating resource efficiency and circular economy principles into the Group’s products and services can help reduce customers’ climate- and nature-related risks. Adapting and developing the Group’s business models and customer offerings may create opportunities for greater cost efficiency as well as new financing solutions and service offerings. Green investments, including those linked to circular economy initiatives, can help reduce customers’ vulnerability to climate and nature risks. At the same time, such investments may pose a financial risk for the customer if the investment costs are too high or if the chosen technology proves unsuitable. Effective advisory support across all business areas of the Group is therefore essential to increase customers’ resilience to climate- and nature- related risks. Moreover, increased innovation and the development of business models and customer offerings can strengthen the Group’s brand, attract and retain skilled employees, and enhance overall competence diversity within the organisation. The Group’s roadmap for circular economy In 2023, the Group established an internal project team with subject-matter experts from across business areas, tasked with developing a framework for circular transition within the Group. The project has since evolved from focusing solely on circular transition within the Group’s own operations to promoting value creation in external businesses by encouraging circular thinking and clarifying the Group’s role in value chains and societal development. In 2025, the field progressed nationally and internationally. During the year, a standard for circular economy was developed alongside a procurement guide aimed at integrating circular principles into purchasing processes. Additionally, the Group further operationalised its work through pilot projects to explore scaling opportunities and collaboration with external actors, generating added value and strengthening partnerships. Selected pilot projects include: • Circular credit card – a broad collaboration with multiple financial actors to collect and r ecycle expired bank cards. • Circular renovation – a project with external par tners focusing on reuse rather than new procurement. • Digital procurement guide – developed with suppliers to mak e circular principles practically applicable in purchasing processes. • Community initiatives – events organised under the Group’s social contribution pr ogramme have promoted circular economy as a theme, resulting in new collaborations with regional actors seeking to enhance their efforts in this area. The experiences from 2025 demonstrate that circular transition is not just about internal improvements but also about building relationships, structures, and shared understanding across actors. The way forward increasingly involves scaling solutions and contributing to an ecosystem where collaboration, competence, and innovation reinforce each other. The Group now clearly recognises its role as an enabler and driver in this work and will continue to develop tools, partnerships, and platforms to realise circular economy in practice—both internally and in collaboration with the region in which it operates. The Group’s roadmap for circular economy, including pilot projects and other initiatives, provides ongoing input and improvement points for the Group’s climate and nature transition plan. Targets and KPIs The Group’s climate and nature transition plan has been completed and approved by the Board. Management indicators related to the Group’s impact, risk, and opportunity (IRO) in circular economy and resource use are currently under development but were not finalised at year-end. It is still under consideration whether these IRO will be managed through separate indicators or integrated into the management indicators for climate change and/or biodiversity and ecosystems. This assessment is part of the indicator development process. The indicators are expected to be in place during 2026 and 2027. Action plans and measures Beyond the Group’s roadmap for circular economy, at the reporting date no specific action plans have been prepared to handle the Group’s IRO related to resource use and circular economy, in line with the requirements in ESRS E5 and the formal requirements in ESRS 2. The overall action plan for the area is the Group’s transition plan, and several of the measures can be integrated into specific action plans related to management indicators for climate change and biodiversity and ecosystems. It is expected that the preparation of such action plans will follow the same timeline as the completion of the management indicators, i.e. during 2026 and 2027. Policies The Group’s overarching governance document for resource use and circular economy is the Group’s sustainability policy. At the reporting date, there are no policies that explicitly address IROs related to resource use and circular economy, in line with ESRS E5 and MDR-P. Policies for this area will be developed as part of the ongoing work on the Group’s transition plan.
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158SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT However, a circular economy standard has been developed with the purpose of operationalising principles for circularity in the business. The standard is based on the nine R-strategies and the Global Circularity Protocol (GCP), and is intended to reduce waste and thereby both climate and nature impacts by maximising the utility value of the resources used by the Group. The standard describes a methodology for piloting and scaling pilot projects in SpareBank 1 SMN which, where relevant, will be implemented in procurement processes and consumption patterns to strengthen the Group’s circular practices.
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159SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 1: Resource use The note provides insight into the Group’s resource use in its own operations and upstream value chain. Resource use occurs indirectly through the input factors in purchased goods and services. The share of biological materials is considered minimal, as is both weight and degree of circularity. The table below shows the Group’s resource use disaggregated by significant purchases of physical products. The GHG-emissions associated with these purchases are described in the section Climate Change. Total purchases measured by weight include both expensed and capitalised purchases. 2025 2024 Category Purchased goods (kg) Purchased goods (per cent) Purchased goods (kg) Purchased goods (per cent) IT equipment 12,022.0 20.1 % 12,787.8 19.4 % PC/Laptop 465.6 3.9 % 453.7 3.5 % Monitor 1,495.7 12.4 % 1,561.2 12.2 % Keyboard 47.6 0. 4 % 145.1 1.1 % Mouse 91.5 0.8 % 97.3 0.8 % Headset 6.4 0.1 % 47.1 0.4 % Phone 91.2 0.8 % 101.2 0.8 % Printers 2,797.8 23.3 % 3,233.7 25.3 % Other IT equipment1) 7,026.2 58.4 % 7,148.6 55.9 % Furniture and fixtures2) 42,285.5 70.8 % 37,590.9 57.0 % Office supplies3) 5,395.4 9.0 % 15,626.2 23.7 % Total purchased goods 59,702.9 100% 66,004.9 100% 1) Other IT equipment includes, among other things, wall mounts for monitors, docking stations, various cables, network equ- ipment, chargers, and other meeting room equipment. The category also includes expensed and capitalized purchases from subsidiaries that are not fractioned. 2) Desks and chairs for workstations and meeting rooms, seating groups, as well as cables, cable baskets, desk mounts, and soundproofing elements. Additionally, the category includes purchased quiet rooms (Podbooths) in the group’s office premises. 3) Pens, staples, batteries, copy paper, envelopes, sticky notes and pads, as well as other paper products. Marketing materials in the form of promotional items and clothing are also included as part of the office supplies category. To calculate weight per procurement category, estimated weight-per-currency factors have been used. These factors are derived from extracts of invoice and supplier information. In cases where the exact weight of a given product is unavailable, the average weight for a specific category or a generic weight for the product—based on its length, height, width, and material—has been applied. Invoice and supplier information originates from the parent company, as the Group’s largest suppliers and agreements within the above procurement categories are used across the Group. For this reason, the estimated weight-per-currency factors also apply to purchases made by subsidiaries. In addition, the majority of costs and the volume of purchased products occur in the parent company. When estimating the weight of purchases by subsidiaries, average factors per category have been applied for materiality reasons. Any purchases made by Group functions that are subsequently re-invoiced to subsidiaries have been eliminated to avoid double counting. This applies only to the category of furniture and fixtures.
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160SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | ENVIRONMENT Note 2: Financial risks and opportunities as a result of resource use and circular economy It has been decided to omit reporting on ESRS E5-6 Expected financial effects of risks and opportunities related to resource use and circular economy by recourse to the exemption provided for in ESRS 1 Appendix C. Processes will be established for identifying how resource use and circular economy impact climate and nature-related risk, and the consequences for credit risk, in the Group’s portfolios. In addition, circular economy will be further examined as an opportunity for innovation and development of the customer offering.
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Social Group employees 162 Approach to the topic 162 Assessment of IROs related to employees 162 Impacts on employees 163 Risks and opportunities related to employees 164 Employee dialogue 165 Concerns and whistleblowing channels 165 Supporting employees’ human rights 166 Employee’s rights 167 Remuneration 168 Targets and KPIs 169 Action plans and measures 170 Policies 171 Note 1: Own employees 172 Note 2: Position level and age distribution 174 Note 3: Skills development 175 Note 4: Health, safety and environment 177 Note 5: Remuneration disparities 178 Note 6: Work-related complaints 179 Workers in the value chain 180 Approach to the topic 180 Assessment of impact and risk related to workers in the value chain 180 Impact on workers in the value chain 181 Risk related to workers in the value chain 181 Dialogue with the Group’s value chains 181 Purchases 182 Corporate market 184 Targets and KPIs 186 Action plans and measures 186 Policies 187 Consumers and end-users 188 Approach to the topic 188 Assessment of IROs related to consumers and end-users 189 Impacts on consumers and end-users 189 Risks and opportunities related to consumers and end-users 190 Customer dialogue 191 Retail market 191 EiendomsMegler 1 Midt-Norge 192 Market dialogue 193 Anti-fraud 193 Personal data protection 194 Targets and KPIs 195 Action plans and measures 196 Policies 197 Community dividend 198 Approach to the topic 198 From gifts to one of the largest private contributors in the region 198 Organisation and allocation 199 Strategic direction 199 Key project in 2025: “Public health and community celebration towards the 2025 Ski W orld Championships” 200 Targets and KPIs 201 Action plans and measures 201 Policies 201 Note 1: Allocation to community dividend 202 Transparency Act 204 Report on remuneration and other emoluments to senior personell 205
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162SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Group employees Approach to the topic The Group’s HR strategy clarifies the direction, targets, plans, and framework within the area of People and Organisation. The HR strategy has defined clear objectives and action plans across four distinct areas: organisation, people, leadership, and culture. The Group’s management of IROs may lead to adjustments in the HR strategy. The HR strategy, together with its associated action plans, is based on the Group’s strategies and business objectives, relevant drivers, and regulatory requirements. Further development of initiatives established in 2024 has been a key focus area in 2025. • In 2025, the implementation of One SMN 2.0 has been a central focus. The work has particularly targeted the r ollout of new work processes and the establishment of cross-functional units to realise a more integrated Group. Systematic efforts have been made to develop new ways of working and strengthen process management. • "The Academy", the Group's skills development programme, has been fur ther developed into a more integrated learning arena, with clearer content categories, enhanced support for learning pathways, and a strengthened technological platform. • In 2025, a more comprehensive framework f or analysis was established, with a focus on management indicators relating to sickness absence, competence, and staffing. Sickness absence has been prioritised, and the Group has introduced more systematic follow-up, clearer allocation of responsibilities, and preventive measures to reduce absence and strengthen the working environment and employee wellbeing through earlier interventions and better insight into causal relationships. • A restructuring of the HSE-function was carried out in 2025, with clearer responsibilities, increased pr ofessional support, and extensive training across the Group. A comprehensive risk mapping has also been initiated to ensure effective management of health, safety, and the environment. As part of the Group’s strategy update, the HR strategy will be revised in 2026. The objective is to ensure an even stronger link between the Group strategy, IROs, regulatory requirements, and priorities in the areas of organisation, leadership, culture, and employee development. This will form the basis for a consolidated strategic HR-framework. Identifying IRO related to employees The Group’s material IRO, where they are concentrated and the time horizons they span, are presented in the tables to the right. IMPACTS Value Chain Time Horizons Working Conditions Positive Negative Own operations Short-term Medium-term Inequality and discrimination Negative Own operations Short-term Medium-term Professional development Positive Own operations All Diversity and inclusion Positive Own operations Short-term Medium-term RISKS Value Chain Time Horizons Lack of sustainability competence Own operations Medium-term Long-term Inability to attract competent people Own operations Short-term Medium-term Increased sickness absence Own operations All OPPORTUNITIES Value Chain Time Horizons Major operator All All Focus on mental health Own operations All Focus on diversity and inclusion Own operations Short-term Medium-term
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163SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL The impacts stem from the Group’s strategy and business models. Inequality and discrimination, as well as diversity and inclusion, affect various employee groups, as working conditions and professional development are impacts that reach all employees in a large Group, regardless of business area. The impacts on the Group’s employees, both positive and negative, are factors that shape and adapt the Group’s strategies and business models. All employees (both employees and non-employees) who could potentially be affected are included in the Group’s double materiality assessment. This encompasses all types of employees listed in the table below. No risk of forced labour or child labour has been identified in any of the Group’s business units or operational areas. Type of employee Description Permanent Permanent employees have an employment contract with the group that is indefinite. Most employees are employed full-time, with part-time employees often having agreements related to temporary part-time work, such as for schooling or a plan for transitioning to full-time. Full-time Part-time Non-employee Non-employees work for the group but are formally employed by another company, often a staffing agency. Non-employees are defined as hired substitutes. Temporary worker Hired substitutes from staffing agencies. Temporary employee Employees on a temporary basis through time-limited or project-based contracts. Apprentices Apprentices are employ ed in a training program that lasts for 2 years. After completing the apprenticeship, they take a professional examination. Trainee EiendomsMegler 1 Midt-Norge has had a trainee program since 2012, where students at Handelshøyskolen BI have the opportunity to be a trainee alongside their real estate studies to gain relevant work experience. Upon completing and passing their studies, they may be offered employment as a licensed real estate agent. They are considered temporary employees until full employment is offered. Consultants Hired consultants for long-term projects or other needs on a fixed per centage of full-time over a specified period. Other temporary Other temporary employees who ha ve a fixed-term employment contract with the group. The double materiality assessment has not provided further insight into whether certain employees are more exposed to impacts and risks than others. The process is described in more detail under General Information. Impacts on employees The Group is concerned to minimise potential negative impacts and maximise the positive impact to enable employees to perform as well as possible. The double materiality assessment identifies an opportunity to impact employees positively by offering good and secure employment, professional development, and a diverse and inclusive work environment. This also entails the potential negative impact has on a lack of balance between work and leisure. Importance is also attached to reducing gender differences and preventing harassment Working conditions As a large regional employer, the Group aims to provide secure frameworks for its employees. The rationale for considering that the Group has a positive impact on employees’ working conditions is: • The Group’s size, well-diversified income base, and financial strength contribute to job security , even in challenging times. • The employees have access to a broad o ffering in terms of entertainment, physical health, professional development and social arenas in the region due to the Group’s position in the community • Vertical and horizontal career opportunities in a gr oup operating in several sectors. • Pride in working in a group which contributes substantial funds to various projects in Central Norway . The Group also has a potential negative impact on employees, as it operates in an industry where working hours and the balance between work and leisure are a known challenge. Flexibility is applied in relation to holidays, time off in lieu, and remote work to mitigate this challenge. Inequality and discrimination Gender inequality and discrimination based on religion, ethnicity, sexual orientation, disability, or other factors constitute a potential negative impact. This may, for example, lead to employees resigning or experiencing psychological distress. Discrimination can occur in recruitment processes, salary negotiations, or other work-related situations. The Group has a workforce composed of employees from diverse backgrounds and works continuously to reduce the risk of discrimination. Employee surveys indicate a low reported incidence of discrimination. Reporting and handling of any cases is based on established processes and guidelines, as well as a business culture and work environment that promote openness and integrity. Professional development Professional development is increasingly an expectation when choosing an employer. Competence is crucial for the Group to meet future needs, requirements, and expectations from customers, authorities, and owners. Employees’ professional development should be tailored to their role and area of expertise.
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164SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Diversity and inclusion As Central Norway’s largest financial services group, the Group has a potential positive impact on employees through a diverse and inclusive work environment. This can enhance the ability to attract and retain competent staff, reduce sickness absence, and improve employees’ mental health. Impacts resulting from the Group’s transition plan for climate and environment The Group’s transition plan is designed to strengthen the Group without major changes to the organisational structure. The plan aims to contribute to a more diverse Group with broader competence in business areas and functions that currently lack sufficient expertise in climate and nature. This need will be addressed through role-specific sustainability training for employees whose roles will increasingly involve sustainability- related tasks. Risks and opportunities related to employees Material risks and opportunities related to the Group’s employees are described below. None of these risks or opportunities had material financial effects in 2025. There is no indication that they entail a risk of material changes in the carrying values of assets or liabilities in the financial statements for the upcoming reporting period. There is uncertainty regarding the expected financial effects of these risks and opportunities. Accordingly, this information has been omitted from this year’s reporting in accordance with the phased-in disclosure requirements of ESRS 1, Appendix C. Lack of sustainability competence Lack competence could cause and accelerate other risks facing the Group: • Incorrect or inadequate credit assessments • Unintentional greenwashing in advice or marketing • Repeated breaches of sustainability-related regulations • Failure to safeguard privacy and customer data • Inability to develop and sell green products and services • Failure to integrate ESG risk into the Group’s risk management Inability to attract competent people Businesses’ work on sustainability is increasingly considered when choosing an employer, particularly among younger employees. At the top of the list from the YPAI (Young Professional Attraction Index) are social factors such as the work environment, pay and incentives, work–life balance, and career and development opportunities. In the longer term, employees with different competencies than those currently available in the Group will be required. The inability to attract new, and develop existing employees could affect the Group’s innovation capacity, its ability to approach issues from diverse perspectives, and its ability to deliver excellent customer experiences. While the Group can develop existing employees, the addition of new skills and experience will be essential for development and profitable growth. Increased sickness absence If more employees are absent without notice due to long-term illness, critical key functions may experience inefficiency, or in the worst case, operational shutdown. This applies to both customer-facing functions (industry and customer officers) and administrative functions (HR, accounting, or risk management). In functions where tasks are more easily transferable, increased sickness absence can create a negative spiral, where higher workloads and additional overtime further increase absences. This may have adverse consequences for employees’ working conditions and result in higher costs for the Group. Major operator The Group, with its various business units and as part of the SpareBank 1 Alliance, has the opportunity to safeguard and develop employees’ working and remuneration conditions across multiple areas through comprehensive insight into several industries. In addition, the Group’s vertical and horizontal career opportunities across its businesses can serve as a motivating factor, helping to ensure that the Group maintains relevant competencies in key positions. Focus on mental health Good physical and mental health is essential for employees to perform well, and it is therefore important to ensure a sound psychosocial and ergonomic work environment. This focus is a prerequisite for employee wellbeing and for maintaining high quality in work tasks. Focus on diversity and inclusion The Group’s advisers encounter a variety of challenges, where there is rarely a single clear solution. Nuanced perspectives from multiple employees with diverse backgrounds help ensure sound decision-making and the delivery of the best customer experiences. Research, meta-analyses, and practice all indicate that diversity and equality across the Group, from employee level to Group management, positively impact innovation, professional and personal development in the workplace, as well as profitability and growth.
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165SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Employee dialogue The Group is committed to maintaining an open and respectful culture in which employees feel heard and valued. This involves fostering a work environment characterised by psychological safety, development, and wellbeing. Employee dialogue is a central element of this, ensuring that employees’ perspectives, opinions, and concerns are taken seriously. In 2025, the Group continued to strengthen and systematise employee dialogue as an integral part of its due diligence assessments. Effective and ongoing dialogue with employees and their representatives is crucial for identifying and managing material, actual, and potential IROs, and for ensuring that employees’ perspectives are considered in the Group’s decision-making. People and Organisation is responsible for employee dialogue and for ensuring that the insights gained are applied in the management of IROs. To promote a positive work environment, clear channels and structures for employee dialogue have been established. In addition to regular dialogue and employee follow-up by the Group’s managers, this includes regular meetings with employee representatives and union delegates at various levels of the organisation. Alongside formal structures, informal dialogue between management and employees, and their representatives, is encouraged. Within the Group, the bank, SpareBank 1 Regnskapshuset, and SpareBank 1 Finans Midt-Norge are bound by the financial sector agreements under the Main and Central Agreements (NHO/Finans Norge, Finansforbundet, and LO Handel og Kontor). The bank and Regnskapshuset have their own company agreements, while Finans follows the bank’s agreement. The bank’s company agreement was revised and modernised in 2025. These agreements regulate several aspects related to employee rights and dialogue. They cover key employment conditions such as working hours, pay, holidays, and rights during organisational changes. The agreements also define important points of interaction between employee representatives and the enterprise. Various types of employee dialogue take place at multiple levels and with differing frequency. Several of these levels are described below. Management considers the dialogue to be effective and constructive. Meetings and workings groups Regular meetings between management and employee representatives provide an important platform for dialogue. The Group CEO holds regular meetings with the chief union representative on various topics concerning the Group’s employees. Quarterly meetings are also held in liaison committees and health, safety, and environment (HSE) committees, which serve as important forums for management and employee representatives to discuss key issues. These meetings cover current matters such as working conditions, HSE, and strategic decisions that impact employees. The Group’s employees are engaged through work environment surveys and engagement assessments, as well as in the development of health, safety, and welfare initiatives. Annual safety inspections are also conducted across all workplaces, where employees can provide input on improvements to working conditions. All employee involvement is designed to ensure that employees’ needs regarding working conditions are heard and considered, and that they participate in decisions directly affecting their daily work. Questionnaire surveys and feedback The Group conducts regular employee surveys to gain a comprehensive understanding of employees’ work situation, wellbeing, and engagement. Response rates remain stable at around 80 per cent. The results are continuously analysed to identify trends and areas for improvement, forming the basis for targeted measures at both Group and unit levels. The surveys allow employees to provide anonymous feedback to both their manager and HR. They also include indicators related to bullying and harassment, as well as access to whistleblowing channels. Reports are directed straight to HR for further follow-up. Employees are also encouraged to provide feedback through other channels, such as direct dialogue with managers, the intranet, and internal communication platforms. In the autumn of 2025, the Group conducted an expanded employee survey to gain a more comprehensive and in-depth picture of key work environment and culture topics. The results were followed up throughout the autumn and winter, with particular emphasis on strong leadership anchoring and clear follow-up within the management team and across the various units. This work has strengthened the foundation for systematic improvements and more targeted measures in culture, work environment, and leadership. Exposed employees The Group works actively to ensure that groups of exposed employees are not discriminated against and that they can express their opinions and perspectives on an equal footing with other employees. Exposed employees are defined as those who may potentially be particularly vulnerable to the Group’s negative impacts. Examples include women (with regard to pay differences and equality), persons with disabilities, foreign employees, or hired-in temporary workers. This includes equal treatment in terms of pay and employment conditions during recruitment and when hiring staff. The Group does not have dedicated processes for exposed employees, but they have equal access to existing channels to express their opinions and perspectives, just like other employees. In 2025, hired-in workers were, for practical and technical reasons, unable to participate in the pulse surveys in Winningtemp. Concerns and whistleblowing channels The Group recognises the importance of having clear and secure whistleblowing channels where employees can raise concerns and needs. Direct communication channels and whistleblowing mechanisms have been established, providing employees with multiple avenues to express themselves.
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166SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Whistleblowing cases are defined as reportable concerns. This refers to matters that contravene legal requirements, the Group’s written ethical guidelines, or ethical norms. Examples include harassment, discrimination, data privacy breaches, unsafe working conditions, or employee safety issues that pose a risk to life and health. Direct communication Employees can raise their concerns and needs directly with their immediate manager or with HR. The Group encourages direct dialogue to ensure that viewpoints are communicated promptly and challenges are addressed effectively. Emphasis is placed on fostering a work environment characterised by psychological safety, where employees can express their opinions without fear of reprisal. Whistleblowing channels The Group has also established whistleblowing channels that allow employees to report reportable concerns anonymously. In addition to internal channels, employees can use the Group’s external whistleblowing portal, operated by KPMG. All reports, regardless of channel, are taken seriously and handled confidentially, with clear procedures in place for follow-up, investigation, and resolution. Three reports were submitted through the external whistleblowing channel in 2025. Employees are made aware of the Group’s whistleblowing channels through the induction programme, ethics training, and information provided on the Group’s intranet. The Group does not conduct dedicated surveys to assess whether employees are familiar with the channels or trust the structures and processes. Employee dialogue helps ensure that the whistleblowing channels are adequate and meet employees’ needs. The Group’s whistleblowing procedure aims to safeguard employees’ right to report reportable concerns. It defines what constitutes a reportable concern, emphasises employees’ right to report, and in certain cases, their duty to report. The procedure specifies whom to report to, how to submit a report, and how reports are handled. The HR Director and the Group’s Legal Director are responsible for following up on reports. Upon receipt of a report, they jointly assess the appropriate course of action. The first step is to gather documentation and conduct interviews as necessary to clarify the matter. If the report concerns the actions or omissions of specific individuals, and the case has been concluded, the person concerned will be informed immediately. The individual who submitted the report will receive feedback on the outcome, provided the report was not anonymous and such feedback does not conflict with applicable law. The procedure also outlines how documentation is to be stored and the requirements for deleting records in accordance with legal requirements. Supporting employees' human rights In the Group’s work to uphold fundamental human rights, an internal assessment of matters related to decent working conditions has been conducted. Attention has been focused on the following areas: • Health, safety, and environment • Personal data protection for employ ees • Access to reportable concerns (described under Concerns and Whistleblowing Channels) • Remuneration • Hiring-in and use of substitutes • ILO core conventions, with focus on two main categories: • Prohibition of discrimination • Freedom of association and the right to collective bargaining No serious breaches o f labour rights or human rights have arisen or been notified by the Group’s employees in the course of the reporting period. More information on how the Group manages human rights in the value chain and of consumers are described in Workers in the value chain and Consumers and end-users respectively. Health, safety and environment In 2025, particular focus was placed on first aid. All financial offices are equipped with defibrillators and have completed training in their use, as well as basic first aid courses. A new training programme for employee safety representatives has also been introduced, and all safety representatives are currently participating. Safety inspections were conducted at all office locations in 2025. These inspections assess the suitability of office premises, indoor climate (noise, temperature, lighting, ventilation), fire safety, ergonomics, workload, and the general work environment. The assessments indicate a generally good working environment, with some findings related to ergonomics, indoor climate, and training, which are being systematically addressed. The organisational tool Winningtemp is also used to measure perceived workload, which may indicate an increased risk of illness and health challenges. Identified issues are followed up with the manager of the relevant department or location, and, where appropriate, directly with the employees concerned. Personal data protection for employees Prior to the implementation of IT solutions that entail a high risk to employees’ rights and freedoms, a Data Protection Impact Assessment (DPIA) is conducted in accordance with the General Data Protection Regulation (GDPR).
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167SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL When revising the company agreement with employee representatives, the section on workload, sales, and volume statistics was modernised. Statistics containing personal data about employees must only be used in compliance with data protection regulations. The purpose of collecting, processing, and any changes to such data must be defined in guidelines and approved by the negotiation committee. There are work processes where certain personal data is still processed outside these systems. In such cases, the Group has clear guidelines for classifying and protecting documents through password protection and encryption. Semi-annual reminders are sent to managers and employees to ensure compliance with these guidelines. Remuneration The Group’s analyses of salary levels, taking into account the financial sector and comparable banks, show that the Group’s employees are paid at levels comparable to those in other banks and financial institutions. Employee representatives review the average adjustments in the local wage settlement annually and have insight into the allocations among their members. Analyses of gender pay equality have also been conducted. These analyses have not identified any disparities directly attributable to gender. Nevertheless, the ratio of women’s to men’s pay (excluding Group management) was 89.0 per cent at the end of the year. Analyses have also been carried out to compare salary levels for employees at the same position level. In cases where differences cannot be explained by performance, competence, or behaviour, this is taken into account when allocating salary resources. Hiring-in and use of substitutes The Group uses temporary workers to ensure adequate staffing during periods of increased workload or employee leave. Temporary staffing needs may also arise when permanent employees are on furlough or sick leave. The use of temporary workers is in accordance with the new regulations for hiring from staffing agencies. An agreement has been made with employee representatives allowing temporary hires without being restricted by the limits imposed by the Working Environment Act. The Group’s use of temporary workers, including compliance with the requirement for equal treatment in terms of pay and employment conditions, is reviewed annually with employee representatives. Analyses and controls have been conducted to ensure equal treatment. The Hay framework, which is used for job comparisons among other purposes, has been applied in this work. These controls have not identified any discrepancies. Discrimination The International Labour Organization (ILO) core conventions on discrimination in employment focus on promoting equal treatment and prohibiting any form of discrimination. The conventions forbid discrimination based on race, colour, gender, religion, political opinion, and national or social origin. The Group’s fundamental principle is zero tolerance for discrimination. In line with its duty to act and report, the Group, in collaboration with employee representatives in each company, assesses risks of discrimination, analyses underlying causes, implements measures, and evaluates the outcomes of these measures. Employee's rights The Group is committed to ensuring good working conditions and employees’ rights. A total of 87 per cent of the Group’s employees are covered by collective bargaining agreements, which contribute to favourable pay and working conditions. Local arrangements for SpareBank 1 SMN are regulated through company and supplementary agreements. In 2025, the company agreements in the bank were revised and modernised in cooperation with the local trade unions, Finansforbundet and Handel og Kontor SMN. The aim was to make the agreements more relevant by clarifying, harmonising and adapting them to current practices. All employees are also covered by group life and accident, travel and treatment insurance. Through the collective bargaining agreements the employees have a contractual early retirement pension arrangement which can be taken out upon reaching age 62. All employees have an employee representative. Collective bargaining coverage Social dialogue Coverage rate Employees – EEA (for countries with >50 empl. representing >10% total empl.) Employees – Non- EEA (estimate for regions with >50 empl. representing >10% total empl) Workplace representation (EEA only) (for countries with >50 empl. representing >10% total empl) 2025 2024 2025 2024 2025 2024 0 - 19 % 20 - 39 % 40 - 59 % 60 - 79 % 80 - 100 % Norway Norway Norway Norway The majority of employees are members of Finansforbundet and LO Finans, but some employees are also members of other trade unions with which the Group is not bound by collective agreements. The company agreement in the bank was revised and modernised in 2025 without material changes. All employees are covered by social benefit schemes through NAV, which provide financial support in connection with life events such as illness, unemployment, childbirth and retirement. In addition, employees receive full pay during sick leave and authorised absence. To ensure good working conditions, workplace facilitation and design are essential to ensure that offices are accessible to all employees.
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168SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL All employees participate in annual performance and development reviews and salary discussions, during which topics such as career development, job responsibilities, remuneration and competence are discussed. This is an important measure to ensure balanced and clear alignment of expectations between manager and employee. Emphasis is also placed on fostering a healthy feedback culture that extends beyond the scheduled reviews, ensuring that employees always have the opportunity to raise relevant matters with their manager. The Group is also committed to supporting employees on leave and recognises the importance of accommodating employees through different life phases. All employees are entitled to parental leave, and employees on parental leave receive full pay during the leave period. To ensure that employees on leave do not fall behind in salary development, employees who have been on leave for more than five months receive a salary increase of 1.7 per cent upon returning to work. This follows from central collective agreements and is intended to ensure continuity and fairness in salary development for the Group’s employees. Considerable emphasis is also placed on maintaining contact with employees on leave so that they feel included and informed about developments within the Group. This includes regular updates, meetings and opportunities to participate in relevant training and competence development activities. During 2025, 3.8 per cent of the Group’s employees took parental leave: 3.9 per cent women and 3.8 per cent men. Flexible working arrangements and facilitation upon return from leave are intended to ensure as smooth a transition back to work as possible. The aim is to create a supportive and inclusive working environment where all employees, regardless of life situation, can thrive and contribute. The Group continuously works to facilitate the workplace so that all employees can contribute on equal terms, regardless of disabilities or physical challenges. No data are collected or recorded on whether the Group’s employees have disabilities or other challenges, in accordance with the General Data Protection Regulation. Remuneration The Group’s remuneration policy applies to all managers and employees. Each company within the Group shall document and maintain its remuneration schemes in accordance with the Group’s remuneration policy. The Board of Directors has approved the remuneration policy following a recommendation from the Group’s remuneration committee. There is a need for expertise and labour related to customer-facing, governance-oriented and operational activities, and competition for skilled employees is intense across all parts of the business. The Group depends on offering competitive remuneration schemes in order to recruit and retain employees with the expertise required to achieve the Group’s strategic objectives and ambitions. The remuneration policy provides the framework for this and serves as an important strategic instrument. The remuneration policy shall promote performance and contribute to sound risk management and control within the Group, reduce the likelihood of undesirable risk-taking, and help prevent conflicts of interest. In addition, it provides guidance on remuneration across the different business areas, ensuring professionalism and a consistent approach to the governance of remuneration as a management tool. In addition to supporting the achievement of the Group’s strategic objectives and ambitions, the remuneration schemes shall be designed to fulfil other key objectives of risk management: • Reduce the likelihood of undesirable risk-taking • Encourage efficient use of capital • Reduce the risk of failures in internal control • Ensure sound and effective management of sustainability risk The Group’s o verall objectives for the current strategic period form the basis of the remuneration policy. To ensure fair remuneration and competitive schemes, positions within the Group are evaluated in a systematic and objective manner using the Korn Ferry framework. Such job evaluations form the basis of the Group’s remuneration system, which consists of a structure with defined job levels and salary potential. The main components of the job evaluation are the position’s responsibilities, complexity and competence requirements. The remuneration system enables the Group to: • Develop a robust salary sy stem across all job levels • Identify career development opportunities for emplo yees with key competencies • Benchmark remuneration practices within the financial industry, both within the SpareBank 1 Alliance and in the external labour mark et Remuneration shall be determined in accordance with the principle of equal pay and independently of gender, race, ethnic origin, political beliefs, sexual orientation, age or other discriminatory factors. This means that the Group’s employees shall receive equal pay for the same work or work of equal value, regardless of the factors mentioned above. The Group maintains an ongoing focus on diversity, inclusion and equal opportunities in recruitment, career development and equal pay. The Group has established minimum salary levels for certain job grades corresponding to salary steps 34 and 37 in the industry-wide salary scale (the central collective agreement between NHO/Finance Norway and the Finance Sector Union of Norway). The Group is committed to complying with the provisions of the Working Environment Act concerning equal treatment between permanent employees and temporary agency workers. The Group maintains regular dialogue with the staffing agencies it uses and provides the necessary information to ensure equal treatment.
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169SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Targets and KPIs In addition to supporting the Group’s strategic objectives and ambitions, the Group’s employee-related objectives shall also support other objectives within areas such as climate and nature, and governance. The Group has for many years applied various key performance indicators to measure progress in diversity, equality and competence development. During the year, new key performance indicators have been developed to manage the Group’s IROs related to its own workforce. Key performance indicator Base year Base value Unit of measurement Division Scope Target Target- year Result 2025 Result 2024 Percieved work-life balance (WinningTemp) 2024 6.8 Score Absolute HR Own ops 7.5 2027 7.2 6.8 Equal pay (Group level) 2024 89.3 % Percent R elative HR Own ops 95% 2030 88.7 % 89.3 % Leaders (excl. Gr oup CEO) 2024 87.7 % Percent R elative HR Own ops 95% 2030 88.9 % 87.7 % Retail market (customer-facing positions) 2024 96.8 % Percent R elative HR Own ops 95% 2030 93.1 % 96.8 % Corporate market (customer-facing positions) 2024 90.7 % Percent R elative HR Own ops 95% 2030 90.2 % 90.7 % Accountants 2024 95.0 % Percent R elative HR Own ops 95% 2030 94.9 % 95.0 % Other employees 2024 91.8 % Percent R elative HR Own ops 95% 2030 90.4 % 91.8 % Sick leave 2024 5.2 % Percent R elative HR Own ops < 5,4% 2028 5,6% 5% Other work-related complaints 2024 10 Units Absolute HR Own ops 8 2027 12 10 Incidents of discrimination, including harassment 2024 3 Units Absolute HR Own ops 0 2026 2 3 Completion rate of mandatory competency enchance- ment 2024 90% Percent Relative HR Own ops 95% 2025 94.1 % 89.6 % Definitions of the key performance indicators are described under Key Figures in the chapter This is SpareBank 1 SMN.
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170SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Action plans and measures The People and Organisation area has, in the same way as the key performance indicators, maintained various action plans and measures dedicated to managing and supporting employees. In 2025, these were adapted and adjusted to address the Group’s IRO. This is intended to help operationalise relevant measures to achieve the Group’s objectives. Key performance indicator Key actions taken in the reporting year Achieved results Future planned actions Time horizon Expected outcomes Percieved work-life balance (WinningTemp) • Further developed support tools aimed at strengthening coping skills, reducing stress and promoting balance. • Implemented a governance mechanism for monitoring and prioritising various HSE initiatives. • Conducted training and provided managerial support related to follow -up of sickness absence. • Implemented AI-based support tools to streamline w ork tasks and processes. • Improved absolute scores on relevant questions in Winningtemp. • Contributed to increased awareness of work–life balance in management groups and teams. • Continue and strengthen HSE initiatives with a focus on workload, recovery and organisation of work. • Maintain managerial support and training with emphasis on early dialogue and follow -up. Short- term • Increased perceiv ed balance between work and leisure. • Improved accessibility and use of digital support tools. • Enhanced managerial support in managing workload. Equal pay (Group level) • Increase the number of women in leadership and specialist roles in order to reduce structural drivers of pay disparities. Historical decline over time, with only minor changes from 2024 to 2025. • Role evaluation conducted across the Group. Medium- term Greater systematic alignment between pay and work of equal value. Sick leave • Further developed support tools aimed at strengthening coping skills, reducing stress and promoting balance. • Implemented a governance mechanism for monitoring and prioritising various HSE initiatives. • Conducted training and provided managerial support related to follow -up of sickness absence. • Implemented AI-based support tools to streamline w ork tasks and processes. Sick leave increased during 2025. • Continue and strengthen HSE initiatives with a focus on workload, recovery and organisation of work. • Maintain managerial support and training with emphasis on early dialogue and follow -up. Short- term • Enhanced managerial support in managing workload. • Increased consistency and more systematised follow -up and prevention. Other work-r elated complaints • Carried out risk assessments related to violence and threats in collaboration with the occupational health service. • Established and operated an AKAN forum to enable early prevention and handling of unwanted incidents. • Expanded ongoing employee surveys and followed up findings. • Initiated improvements in the employee journey to reduce risk and enhance quality. • More systematic and consistent handling of deviations and complaints. • Earlier detection of issues with potential implications for the working environment. • Increased awareness related to substance use, violence, threats and data protection. • Implement a register for conflict -of-interest disclosures to strengthen integrity and transparency . • Structure and systematise follow-up processes within HSE, AKAN and the working environment. • Increase focus on the psychosocial working environment. • Improve reporting routines and data quality. Medium- term • Gradual improvement in handling and follow -up processes. • Strengthened risk assessments and working -environment processes. • More pr edictable and consistent practice in HSE and AKAN work. • Expected reduction in the number of deviations and complaints. Incidents of discrimination, including harassment • Increased attention to available internal and external whistleblowing channels. Reduction in number of incidents • Maintain continued focus on promoting awareness of whistleblowing channels. Short- term • Strengthen the ability to identify and capture a greater number of relevant cases of discrimination and harassment. Completion rate of mandatory competency enchancement • Continued enforcement of the reminder regime introduced in spring/summer 2024, prior to deadline. • Increased completion rate compared with 2024. • Introduce a reminder regime for incomplete mandatory training that accommodates employees returning from leave/sick leave, as well as new hires. Short- term Achieved targeted completion rate
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171SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Policies The Group has several policies addressing IRO related to employees. All policies follow recognised national and international standards to the extent relevant. All policies are available to the Group’s employees through internal systems and the intranet. Where relevant to external stakeholders, the policies are also available on the Group’s website. The Head of HR is responsible for all policies in this area. Discrimination policy As an employer, the Group is committed to preventing discrimination and unequal treatment in all aspects of employees’ working conditions. The Group’s anti-discrimination policy forms part of the Group’s Code of Conduct. The Code of Conduct establishes a zero-tolerance approach to discrimination and describes employees’ right to report concerns and the available whistleblowing channels. Employees are informed of the Group’s zero tolerance for discrimination upon hiring and through annual ethics training and updates. Remuneration policy The Group’s remuneration policy, which applies to both employees and managers, is designed to ensure fair and competitive compensation for all staff. Different types of remuneration are managed to incentivise achievement of the Group’s strategic goals and ambitions, while also attracting and retaining skilled employees. The policy provides guidance on remuneration for all employees across the Group, covering both fixed and variable pay in connection with new hires, salary reviews, and departures. It also defines the role and responsibilities of the Group’s Remuneration Committee, as well as remuneration for senior executives, material risk takers, employees in control functions, and the Board. The Board approves the Group’s remuneration policy, which must at all times comply with applicable legislation. Policy on protecting fundamental human rights and decent working conditions The policy outlines how human rights, including labour rights, are safeguarded within the Group’s own workforce, among business partners, and across supply chains. It is based on the OECD Guidelines for Multinational Enterprises. Due diligence assessments are to be conducted regularly, risk-based, and proportionate, taking into account the size, nature, and context of the business, as well as the severity and likelihood of negative impacts on fundamental human rights and decent working conditions. For the Group’s own operations, assessments are based on established requirements and how these are implemented in practice. The Board approves the policy and the framework for due diligence assessments, while the boards of subsidiaries follow up within their own companies. The CEO is responsible for compliance, risk assessments, and resource prioritisation, with follow-up delegated to the Group Director of Finance and the Group Sustainability and Governance Officer. Managers and CEOs of subsidiaries are responsible for compliance within their respective areas. Over time, the guidelines will also provide direction for identifying and mapping negative impacts relating to the Group’s customers. Policies on health, environment and safety Recording of incidents and non-compliances is carried out directly by employees or their immediate manager in the Group’s quality system. Subsequent prioritisation and handling of each case depends on its nature, scope, and severity. The Group’s HSE guidelines seeks to form a framework for a safe and health-promoting work environment. Procedures are in place to identify and manage risks, as well as to prevent accidents and health hazards. All employees and temporary staff are subject to the Group’s HSE policies, including associated routines, systems, and processes.
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172SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Note 1: Own employees This note presents the composition of the Group’s workforce by gender, contract types, employment arrangements and work tasks. It also provides insight into the extent to which the Group relies on temporary employees and non-employees in its workforce. The data is compiled using information from the Group’s HR system and includes permanent employees, temporary employees and non-employees. A work year is defined as a full-time position of 37.5 hours per week. Work years for part-time employees and on- call substitutes are calculated based on actual hours worked relative to a full-time position. The figures are as at year-end. Each table specifies whether the figures are presented as headcount or work years. Non-employees are part of the Group’s workforce to the extent that they are hired through staffing agencies to perform tasks for employees who are temporarily absent for various reasons. Non-employees are therefore presented separately in several tables to distinguish between employees who are employed by the Group and individuals who perform work for the Group without being directly employed. Gender distribution employees 1,2,3,4) 2025 2024 Count Percentage Count Percentage Women 1,058 56% 1,056 56% Men 841 44% 820 44% Total employees 1,899 100% 1,876 100% 1) Head-count 2) Only employees with an employment contract with the Group 3) Temporary employees are included. Of these, 39 are apprentices and trainees who are in a training program within the Group 4) This figure is also reported as the average total employees in the financial statements' note 20 – personnel expenses Gender distribution non-employees 1) 2025 2024 Count Percentage Count Percentage Women 59 39% 32 46% Men 93 61% 38 54% Total employees 152 100% 70 100% 1) Head-count Contract types distributed by gender (2025) 1) Permanent Temporary2) Non- employees3) Total Women 1,001 56% 26 43% 16 43% 1,043 55% Men 786 44% 35 57% 21 57% 842 45% Total employees 1,787 100% 61 100% 37 100% 1,885 100% 1) FTE's 2) Consultants hired through consulting agencies or self-employed contractors are not included in the figures 3) Numbers are time-lagged, and represents data as of november, collected at the end of the year Contract types distributed by gender (2024) 1) Permanent Temporary 2) Non- employees3) Total Women 1,004 57% 25 40% 15 45% 1,044 56% Men 767 43% 38 60% 18 55% 823 44% Total employees 1,771 100% 64 100% 32 100% 1,868 100% 1) FTE's 2) Consultants hired through consulting agencies or self-employed contractors are not included in the figures 3) Numbers are time-lagged, and represents data as of november, collected at the end of the year Employment type distributed by gender (2025) 1) Full-time 2) Part-time 3) Non- employees4) Total employees Women 986 55% 41 72% 16 43% 1,043 55% Men 804 45% 16 28% 21 57% 841 45% Total employees 1,790 100% 58 100% 37 100% 1,885 100% 1) FTE's 2) Full-time employees are employees who is employed in a 100 percent position 3) Part-time employees are employees who is employed in a reduced position 4) Non-employees do not have defined employment percentages and are hired for varying periods based on needs
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173SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Employment type distributed by gender (2024) 1) Full-time 2) Part-time 3) Non- employees4) Total employees Women 989 56% 41 72% 15 45 % 1,044 56% Men 789 44% 16 28% 18 55% 823 44% Total employees 1,778 100% 57 100% 32 100 % 1,868 100% 1) FTE's 2) Full-time employees are employees who is employed in a 100 percent position 3) Part-time employees are employees who is employed in a reduced position 4) Non-employees do not have defined employment percentages and are hired for varying periods based on needs Distribution based on business areas 1,2) 2025 2024 Count Percentage Count Percentage Retail market (bank)3) 435 23% 527 28% Corporate market (bank)3) 196 10% 219 12% Accounting 581 31% 600 32% Realtor 269 14% 257 14% SpareBank 1 Finans Midt-Norge 56 3% 56 3% Other business areas4) 348 18% 208 11% Total employees 1,885 100% 1,867 100% 1) FTE's 2) Includes non-employees 3) Business areas also include support and administrative functions 4) Group shared functions and SpareBank 1 Kvartalet SMN Turnover 1,2,3) 2025 2024 Count Percentage Count Percentage Total number of employees 01.01 1,824 1,727 Women 1,018 56% 980 57% Men 778 44% 747 43% New hires 188 251 Women 93 49% 142 57% Men 94 51% 109 43% Departures 180 163 Women 92 51% 92 56% Men 88 49% 71 44% Total number of employees 31.12 1,830 1,806 Women 1,019 56% 1,026 57% Men 784 44% 780 43% Turnover 9.85% 9.23% 1) Head-count 2) Small discrepancies are due to internal mobility within the Group 3) Only applicable to employees with employment contract in the Group During the reporting period, 180 employees left the Group, corresponding to a turnover rate of 9.85 per cent. Turnover is calculated based on the number of employees who left the Group during the reporting period (including retirements and managed departures) divided by the average number of employees during the reporting period.
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174SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Note 2: Position level and age distribution The Group’s diversity in terms of age and gender among employees, including Group executive management, other managers and other employees, is presented in the table below. The figures are given as number of employees, regardless of employment percentage. 2025 2024 Age Gender Management 1) Other leaders 2) Other employees 3,4) Total employees Management 1) Other leaders 2) Other employees 3,4) Total employees < 30 years Women 0 0% 2 1% 182 10% 184 9% 0 0% 2 1% 195 11% 197 10% Men 0 0% 1 1% 204 12% 205 10% 3 0% 5 2% 227 13% 232 12% 30 - 50 years Women 5 16% 66 33% 464 27% 535 27% 8 9% 77 38% 464 27% 549 28% Men 11 35% 63 32% 340 20% 414 21% 8 23% 67 33% 312 18% 395 20% > 50 years Women 3 10% 27 14% 344 20% 374 19% 16 23% 23 11% 316 19% 342 18% Men 12 39% 40 20% 204 12% 256 13% 11 46% 30 15% 194 11% 232 12% Sum Women 8 26% 95 48% 990 57% 1093 56% 24 31% 102 50% 975 57% 1088 56% Men 23 74% 104 52% 748 43% 875 44% 0 69% 102 50% 733 43% 859 44% 1) Group executive management and management in the Group's subsidiaries. Managers in subsidiaries without specific management groups, are included in the category "Other managers" 2) Middle managers, department heads, and other employees with leadership responsibilities who are not part of management. Also including specialists and professionals with critical roles who do not have direct strategic decisionmaking authority 3) Employees who are not included in other categories. 4) Includes non-employees
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175SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Note 3: Skills development In order to meet the industry’s increasing complexity and rapid changes, the Group invests in continuous skills development. Today’s workers expect an employer that offers ongoing professional development. In 2025, the Group prioritised strengthening its learning culture in order to facilitate the continuous development of employees. This is intended to support employees’ future career opportunities. The objective is for employees to have tasks and responsibilities aligned with their competencies. The Group emphasises that employees should recognise the value of skills development beyond mandatory requirements, and employees are encouraged to provide input on topics they consider relevant both to their own role and to the Group as a whole. During the year, the Academy established a foundation for a more structured and professionalised approach to development. The offering has been systematised, and onboarding programmes for new employees and managers have been updated. This has contributed to greater predictability and control in skills development, thereby establishing a solid foundation for further development in 2026. The purpose of the Academy is to serve as the Group’s development arena. The Academy’s competence pyramid may be illustrated as follows: Self-realization Personal career development Future nice-to-have competencies Nice-to-have competencies Current necessary competencies Legal and regulatory requirements Competence Pyramid Mandatory Voluntary Future necessary competencies The Group has carried out a broad range of skills development activities, ranging from basic training in digital tools to advanced leadership development programmes. The use of digital learning platforms has increased, and Videocation has established itself as a key resource with a wide range of courses. At the same time, the Group has strengthened its cooperation with external educational institutions, including industry programmes in sustainability and technology in collaboration with BI and NTNU. This provides employees with up-to-date knowledge and insights that are important for addressing future work tasks. Leadership development has been a priority area in 2025. The Group has implemented targeted programmes that provide leaders with greater self-awareness and tools to manage change and complexity. In addition, considerable emphasis has been placed on professionalising onboarding programmes so that new employees are integrated more quickly, experience a sense of mastery at an earlier stage, and gain a clear understanding of the Group’s values, objectives and expectations. Advisers in both the retail and corporate segments have completed training in professional disciplines, products, advisory services and ethics to ensure high quality, trust and confidence in customer interactions. Authorised advisers have completed the required 15 hours of continuing education to meet statutory requirements, covering topics such as good business practice, measures for customers facing financial challenges, sustainability, ethics, anti-money laundering, and professional and product updates. In addition, employees have participated in training in data and information security as well as mandatory topics such as personal data protection. In 2025, all employees were offered courses in ethics, anti-money laundering and counter-terrorist financing, data and cyber security, and artificial intelligence. Ethics, data protection and cyber security have remained central themes in training, while the Group has also introduced new learning opportunities related to artificial intelligence and digital tools. In this context, one employee has commenced an industrial PhD in data and artificial intelligence at NTNU. This marks an important step towards building specialised expertise in areas that will be critical for the Group in the future. The Group’s work on skills development has also received external recognition. SpareBank 1 SMN was named “Apprenticeship Company of the Year” by the Vocational Training Board of Trøndelag for its work with apprentices in office and administrative subjects and sales. Future priorities The Academy will be further developed and will increasingly contribute to addressing identified change needs. Efforts will also be made to create greater synergies across business areas to ensure that skills development becomes an even more integrated part of employees’ day-to-day work.
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176SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL The Group plans to launch a new, employee-adapted learning portal designed to provide a more efficient learning experience while also highlighting voluntary learning opportunities aimed at supporting self-realisation and career development. The Group will continue to prioritise skills and expertise in artificial intelligence and data, both in terms of general competence related to Group-wide AI tools and more specialised competence linked to the implementation of business-specific solutions. Development projects within this area will be prioritised in 2026. Hours devoted to skills development across the Group’s professional and business areas are presented in the table below. The table includes only completed skills development activities, and learning opportunities offered through platforms such as Videocation are not included in the figures. Formal skills development provided under the auspices of the Group and/or the SpareBank 1 Alliance is fully covered in the table. Hours of skill development 1) Business areas Gender 2025 2024 Retail market (bank) Women 7,312 7,587 Men 6,834 6,450 Corporate market (bank) Women 1,987 1,913 Men 2,382 1,899 Realtor Women 1,161 1,711 Men 1,440 2,031 Accounting Women 12,447 15,177 Men 5,234 7,188 Financing and leasing (SpareBank 1 Finans Midt- Norge) Women 138 139 Men 209 206 Group shared functions Women 1,530 1,251 Men 1,427 788 Total number of hours Women 24,576 27,779 Men 17,527 18,561 Total 42,102 46,340 1) Estimated time spent per course is defined for each individual course and serves as the basis for calculating skill development hours, regardless of the actual time spent by the employee on the given course. A correction has been made to the reported training hours for 2024. Estimated training hours have been removed in full, and only recorded training hours are now included. The purpose of this correction is to ensure comparability between different periods in internal and external reporting and follow-up. The total number of hours is in reality higher, but parts of the skills development hours are subject to missing data or significant estimation uncertainty. The limitations and assumptions are outlined below. • Informal skills development sessions on Teams, both internally and within the alliance, are not included due to the absence o f routines for tracking participation. • In-person courses with smaller groups (e.g., departments) ar e not included due to lack of registration. • Hours related to professional authorizations, such as Cer tified Public Accountant (CPA) and Authorized Financial Advisor (FinAut), are included to the extent they can be extracted from third-party systems. Remaining hours are not estimated due to high estimation uncertainty. Average skills development hours by gender are presented in the table below. The purpose is to assess whether gender affects the distribution of professional development. However, since different genders hold different roles with varying requirements and needs for skills development, this figure alone is not fully representative. This limitation is due to constraints in the underlying data. 2025 Gender Skill development hours Employees 1) Average number of skill development per employee Women 24,576 1,117 22.0 Men 17,527 934 18.8 Total 42,102 2,051 20.5 1) Includes all types of employees 2024 Gender Skill development hours Employees 1) Average number of skill development per employee Women 27,779 1,088 25.5 Men 18,561 858 21.6 Total 46,340 1,946 23.8 1) Includes all types of employees
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177SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Note 4: Health, safety and environment Through systematic HES work, the Group actively works to reduce risks of hazards and accidents, as well as to promote positive and health-enhancing factors in the work environment. In 2025, particular focus was placed on first aid. All financial offices are equipped with defibrillators and have completed training in their use, as well as basic first aid courses. A new training programme for safety representatives has also been introduced, and all safety representatives are currently undergoing this training. The Group has an agreement with Falck Norway as an approved occupational health service. Falck acts as an advisory body in HES work, particularly regarding ergonomic and psychosocial work environment issues. All employees are covered by the scheme, and Falck actively contributes to follow-up. Musculoskeletal disorders are the most significant work-related risk in the industry. Many employees have repetitive working positions and long days at the computer, which increases the risk. Annual safety rounds are conducted to map these and other HES- related issues. The safety rounds show that, while the Group faces ergonomic challenges, the workplaces are generally well adapted with appropriate equipment, which reduces risk. The assessments indicate a generally good work environment, with some findings related to ergonomics, indoor climate, and training. These are systematically followed up. All undesired events and deviations are recorded in the Group’s quality system for handling and follow-up. Sensitive personal data must not be recorded. Where anonymisation is required, both internal and external whistleblowing channels can be used. The table below shows sickness absence in the Group, work-related injuries and illnesses— both in absolute numbers and per million hours worked—as well as lost working time measured in working days. Number of hours Sick leave and work-related injuries and ill health 2025 2024 Women 7.8 % 7.5 % Men 3.0 % 3.0 % Total sick leave1) 5.6 % 5.2 % Number of recordable work-r elated injuries and ill health 0 0 Rate of recordable work-related injuries and ill health2) 0% 0% Number of days lost to work-related injuries and ill health 0 0 Days lost to work-related injuries and ill health - rate 0% 0% 1) Sick-leave includes both regular sick leave and work-related injuries and ill health 2) Number of recordable work-related injuries and ill health per million work hours No fatalities resulting from work-related injury or illness have been recorded in the course of the reporting period.
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178SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Note 5: Remuneration disparities Wage differences between genders are defined as the difference between the average salary of women and men. For 2025, the difference in average salary between women and men is 13 per cent, meaning that women, on average, earn 87 per cent of what men earn. The wage differences are influenced by several objective factors, including job level, experience, education, and seniority. Measures have been established to reduce gender pay gaps through fair pay structures, regular salary analyses, and in the recruitment process. 2025 2024 Women's share of men's salary (incl. Group management) 86.9 % 86.8 % Women's share of men's salary 88. 7 % 89.3 % Total annual remuneration ratio 8.00 8.04 It is important to note the following definitions and assumptions: • Remuneration ratio: Reflects the salary level o f the highest-paid individual in the Group divided by the median salary (excluding the highest-paid employee) of all employees in the Group. • Median salary: Includes all employees except the highest-paid individual in the Gr oup. This provides a more representative picture of salary levels in the organisation than the average salary, as it is not affected by large disparities in pay. This measure also includes managers and employees who are not part of Group management. • Brokers in EiendomsMegler 1 Midt-Norge are not included in the calculations due to significant inconsistencies in the data arising fr om a commission-based salary model. The wage differences are not considered to be materially different from the rest of the Group. Analyses of salary data provide insight into the Group’s pay structures and help identify areas for improvement in the remuneration policy.
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179SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Note 6: Work-related complaints The table below presents the number of work-related incidents and/or complaints; the number of serious violations of employees’ human rights; and any related fines, sanctions, or orders. Incidents related to discrimination, including harassment, are reported separately. The number of cases may be subject to deviations if incidents have not been reported through the Group’s whistleblowing channels, or have otherwise not been brought to the attention of the immediate manager, employee representatives, or the People and Organisation department. 2025 2024 Incidents of discrimination, including harassment (count) 2 3 Other complaints and issues1) 12 10 Severe violations of human rights 0 0 Fines, penalties and compensation (in NOK)2) 0 0 1) Conditions in violation of legal regulations, the group's code of conduct or ethical standards. 2) As a result of the Group not having received fines or paid compensation, there is no reference to the financial statements. The Group maintains a zero-tolerance policy for discrimination and harassment, with the goal of ensuring a safe and inclusive working environment for all employees. Reported incidents are handled professionally and confidentially. Necessary measures are implemented to restore a safe and secure working environment for those affected by such incidents. To prevent such occurrences, the Group works systematically with management and employee training, clear ethical standards, and well-established whistleblowing channels. Workplace data and risk assessments are also actively used to identify areas requiring follow-up.
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180SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Workers in the value chain Approach to the topic The Group strives for responsible and robust value chains to reduce both the Group’s own impact and the risk of disruptions in critical infrastructure on which the Group depends to maintain efficient and secure operations. The Group has just over 2,500 suppliers, ranging from small regional operators to large multinational companies, giving it indirect business connections across many industries and countries. In addition, the Group has numerous personal and corporate customers that collectively cover most industries in Norway. The Group’s value chain is limited to first-order business relationships, meaning that the Group directly manages its own customers and suppliers, but not customers’ customers or suppliers’ suppliers. The Group’s approach to the value chain is described in more detail under the sustainability reporting principles in General Information. The Group has no suppliers or corporate customers with head offices in countries with a high risk of breaches of labour and human rights. Certain industries, however, are associated with an increased risk that workers may be subjected to social challenges, either systematically or unintentionally. The suppliers and corporate customers have their respective value chains, which through multiple layers may extend to industries, products, countries, or other areas that carry a risk of breaches of labour and human rights. This delimitation does not absolve the Group of responsibility for the underlying value chains, but it allows the Group to prioritise those operators where it has the greatest leverage. The Group is therefore dependent on suppliers and corporate customers having appropriate policies and procedures for managing their own value chains. A responsible first-order value chain is essential to minimise the risk of the Group indirectly causing breaches of labour and human rights. The Group is also subject to the provisions of the Transparency Act, and the reporting under ESRS S2 reflects the Group’s work to comply with the requirements set out by the Act. Assessment of impact and risk related to workers in the value chain The Group’s material impacts on workers, where they are concentrated, and the time horizons they span are presented in the table below. IMPACTS Value Chain Time Horizons Working conditions Negative Upstream Downstream Medium-term Long-term RISKS Value Chain Time Horizons Breaches of labour and human rights in the value chain Upstream Downstream Medium-term Long-term
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181SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Value chains are a natural aspect of all businesses, and the impact on working conditions of workers in the value chain stems directly from the Group’s business models and strategy. Requirements have for some time been imposed on the Group’s suppliers upon entering into contracts, and the Group’s policies on ESG risk, along with the ESG model, contribute to objective assessments of the Group’s corporate customers. These value chains are where the impacts and risks are considered to be greatest. Future adaptations of the above practices will depend both on the outcomes of the Group’s due diligence assessments and on potential requirements and expectations from the Group’s external stakeholders. Workers in the value chain include both employees and non-employees. All workers in the value chain who have the potential to be materially impacted by the Group’s activities are included in the double materiality assessment. The Group’s impacts or risks are not assigned to a single specific industry or type of worker, but are instead centred around industries with known challenges related to worker and human rights. As part of the Group’s double materiality assessment, an overarching assessment has been conducted of certain industries with a higher potential for exposure to negative impacts than others. This assessment is also based on experience from the Group’s reporting under the Transparency Act. The double materiality assessment has not provided further insight into whether some workers in the value chain are more exposed to impacts and risks than others. The process is described in more detail under General information. Identification of upstream impacts is based on the Group’s due diligence assessments. Procurement categories such as IT, food, cleaning services and office furniture have been identified as categories with medium to high risk of negative impact on human rights. These suppliers are primarily located in the Nordic region, with value chains extending across large parts of the world. Identification of downstream impacts has to a larger extent been assessed based on information from public sources. Impact on workers in the value chain The Group is dependent on well-functioning value chains, and just as the Group is dependent on its employees, so too are the companies in the value chains dependent on theirs. The Group’s impact is indirect, and the Group has no positive impact. The impact is identified as potentially negative, since the Group purchases goods and services from, and finances, advises, and provides other services to, various companies across different sectors. A more detailed description of the Group’s material impact is provided below. Working conditions Several industries in the value chains have, and have had, various work-related challenges. These challenges relate, for example, to excessive use of overtime, poor pay conditions, and lack of opportunity to organise in labour unions. As a purchaser, capital provider, and adviser, the Group has a potential negative impact on the working conditions of workers in the value chain. Risk related to workers in the value chain The risk related to workers in the value chain is described below. In 2025, it has had no material financial effects. There is no indication that the risk entails a significant likelihood of material changes in the recognised values of assets or liabilities in the financial statements in the upcoming reporting period. The expected financial effects of the risk are subject to uncertainty. For this reason, it has been decided to omit this information from this year’s reporting, in accordance with the phased-in disclosure requirement of ESRS 1 Appendix C. Breaches of labour and human rights in the value chain The Group’s value chains consist of industries which, in the first order, are primarily located in the Nordic region. For certain procurement categories and industries, the risk is assessed as medium or high based on surveys conducted in connection with the Group’s due diligence assessments in the upstream value chain. Just as breaches of labour and human rights exist upstream, they are also present in the industries which the Group finances, advises, and provides other services to. The risk is greatest in the value chains of the Group’s suppliers and customers. Although the risk is primarily indirect, this does not reduce its significance. Breaches of labour and human rights, whether direct or indirect, may result in reputational loss, loss of customers or employees, as well as financial consequences in the form of claims for damages, redress, or sanctions. Dialogue with the Group's value chains The Group’s dialogue with the value chain varies in both form and nature depending on the business area. Below is an overview of the type of dialogue conducted in the different business areas, as well as the whistleblowing channels available to workers in the value chain, suppliers, and customers. In the corporate market, dialogue takes place indirectly with workers in the value chain, where the management of the customers or other similar representatives often serve as the primary points of contact.
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182SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Purchases The Group is a significant purchaser of goods and services, both locally and nationally. Together with the SpareBank 1 Alliance, the Group has both the responsibility and the opportunity to minimise the potential negative impact and the risk of breaches of human rights in the value chain. Dialogue with suppliers takes place in two ways: • Locally, within the Group’s purchasing department • Centrally, within SpareBank 1 Utvikling’s purchasing department The Group striv es to maintain good dialogue with all suppliers. In recent years, the focus has been on suppliers with a higher risk of breaching human rights. At the central level, a proprietary tool linked to sustainability is used, together with the OECD Guidelines, for risk identification purposes. The Group Director of Economic Crime and Business Support holds overall responsibility for the Group’s involvement in and dialogue with suppliers, including workers in the value chain. Purchases in SpareBank 1 SMN The Group strives for accountability and operates under firmly anchored policies for sustainable procurement, proprietary qualification criteria, and a requirement to sign ethical guidelines. These are aligned with the ILO Conventions, as well as guidance on environmental, social, and ethical business practices in procurement. In 2025, the Group has continued its work of imposing stricter requirements on the Group’s local suppliers. Suppliers were screened against multiple sources to identify potential links to human rights breaches in the value chain. The screening included international indices such as the Human Development Index, the EU’s list of sector-specific identified breaches, and Anskaffelser.no’s high-risk supplier list. Artificial intelligence has also been applied in the screening processes. The Group’s supplier portfolio has been reviewed to identify high-risk suppliers. All high- risk suppliers are being followed up, and direct dialogue is conducted where required. The following industries have been identified as high-risk for breaches of labour and human rights: • Food • Cleaning • Marketing material and clothing • IT The majority of the Group’s own suppliers are initially assessed as lo w-risk regarding their own operations, most of which are based in Norway or other Nordic countries. No findings indicating actual breaches have been identified. A parallel effort is underway to commit all existing suppliers, regardless of size or risk, to sign the Group’s ethical guidelines. For new procurements, close dialogue is maintained throughout the procurement process. In cases where the Group does not set qualification requirements, suppliers are encouraged to work on improvements to meet future requirements. Once a contractual relationship is established, dialogue meetings are held to which both workers and managers are invited. In cases where a supplier does not wish to sign the Group’s ethical guidelines, a questionnaire has been developed, which, together with dialogue, forms the basis for the Group’s risk assessment of the supplier. Purchases in SpareBank 1 Alliance Most of the Group’s largest suppliers operate at the alliance level, and contracts are therefore entered into centrally. Allianseinnkjøp is the SpareBank 1 Alliance’s centre of expertise for sustainable procurement and is legally subordinate to SpareBank 1 Utvikling DA (SB1U). Procurement managers at the regional banks are part of a joint procurement committee. The regional banks act both as orderers and approvers of central-level procurements. Allianseinnkjøp documents the processes and keeps the procurement committee informed of status and progress. Allianseinnkjøp is responsible for procuring goods and services, enters into supplier agreements on behalf of the Alliance, and monitors sustainability risks associated with these agreements. In 2025, SB1U procured goods and services worth approximately NOK 2 billion from just under 600 unique suppliers. The largest procurement categories are: • Software and licenses • Cloud services • IT-services • Consultancy and recruiting services • Media agency services • Pension and insurance • Facility management Due diligence assessments are conducted regularly and are proportionate to the size and natur e of the business, the context in which the business operates, and the severity and likelihood of negative impacts on fundamental human rights and decent working conditions. Below is a brief account of how SB1U conducts due diligence on relevant business areas. The account follows the structure of the OECD Due Diligence Guidance for Responsible Business Conduct and the sequence outlined in the Act.
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183SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Anchoring in SpareBank 1 Utvikling's guidelines and management systems Sustainability in the supply chain is anchored in governing documents, standard sustainability annexes in supplier agreements, and SB1U’s annual action plans. The standard sustainability annex is designed to ensure that requirements and expectations regarding climate and environment, social conditions, and business ethics are integrated into all supplier agreements. The annex is currently under revision to improve operational applicability in procurement processes and to strengthen suppliers’ legal obligations. A new version of the standard annex is expected to be implemented in 2026. Alliance Procurement holds primary responsibility for delivering on established management indicators in the supply chain and follows its own action plan to achieve this. In the 2025 action plan, KPIs were defined for various focus areas to structure and enhance the quality of work on sustainability in SB1U’s supply chain. The following areas have been defined as focus areas: • Risk mapping • Broad-based surveys • Supplier follow-up • Standard sustainability attachment Mapping and assessment of actual and potential negative impacts SB1U initiated an internal project in October 2025. A comprehensive, risk-based mapping of all suppliers and business partners with contract values exceeding NOK 100,000 was carried out. A total of 248 companies were included in the broad survey, which covered the following risk areas: • Human rights and labour rights • Public disclosures on due diligence assessments • GHG-accounts and transition plans By the end of 2025, 100 per cent of SB1U’s supplier base had been screened. In addition, 338 suppliers with contract values below NOK 100,000 w ere assessed through a simplified screening. This included mapping of industry, geography, potential links to recorded human rights violations, and selected risk factors. The methodology for mapping and assessment was based on open sources and risk- based evaluations, reflecting what is reasonable to assume from the available information. The work was conducted in accordance with the OECD Guidelines for Responsible Business Conduct and the standard for due diligence assessments. Measures to stop, prevent or mitigate negative impacts SB1U has implemented several targeted measures to prevent and mitigate negative impacts in the supply chain, in line with the company’s priorities and due diligence assessments. Through the delivery of the internal project mentioned above, a total of 586 suppliers were mapped for negative impacts in the company’s supply chain, in accordance with Step 2 of the OECD due diligence guidelines. The main findings are as follows. Suppliers with purchases under NOK 100,000 No direct links to concrete breaches were found among these suppliers. However, several belong to categories requiring particular attention. Eleven suppliers provide products associated with an elevated risk of human rights or labour rights violations in the supply chain. In total, 23 suppliers were also identified as operating either within industries in Norway with increased social risk or distributing goods where supply chain risk is elevated. In addition, several IT service providers were identified, which may have delivery centres in low-cost countries where social risk factors are elevated. Allianseinnkjøp will assess the need for follow-up with these suppliers. This will depend, among other things, on whether actual breaches are identified, potential contract renewals, as well as capacity and prioritisation regarding follow-up of supplier items exceeding NOK 100,000. Suppliers with purchases over NOK 100,000 These suppliers were screened against multiple sources to uncover possible links to human rights breaches in the supply chain. This included potential connections to ongoing conflicts in Myanmar, Palestine, and Ukraine, and areas with a very high risk of systematic forced labour, such as Myanmar and Xinjiang. The screening included sanctions lists and various company listings (UN and civil society organisations) accused of activities in different conflict zones. Some suppliers with global operations and value chains were “flagged” due to supply chain risk, indicating an elevated risk that the goods and services procured could have direct or indirect links to severe human rights violations. The main findings and recommendations from the project will form the basis for Allianseinnkjøp’s 2026 action plan for sustainability in the supply chain, where the most prominent risks will be followed up. Supplier follow-up SB1U has conducted direct follow-up of selected suppliers, including in response to changes in diversity, equity, and inclusion programmes at large U.S. companies. One of the companies, providing consultancy services to SB1U, was asked to explain how these
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184SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL changes impact their operations in Norway. Another similar company was followed up through the Hellios FSQS Nord platform. Both companies provided documentation that was assessed as satisfactory. As part of the internal follow-up work, SB1U has also updated its standard sustainability annex for supplier agreements with clear expectations that suppliers should integrate diversity, equity, and inclusion into their operations and be able to document concrete measures against structural discrimination upon request. Allianseinnkjøp monitors developments and any media coverage related to these topics on an ongoing basis. In new contract agreements, including renewals, the standard sustainability annex is included, and/or the expectation that the supplier conducts due diligence assessments is addressed and documented. Stakeholder dialogue Stakeholder involvement and dialogue are an integral part of the Alliance’s supplier strategy. Stakeholders are individuals or groups who can influence, or be influenced by, the Group or the Alliance’s procurement activities. For suppliers in high-risk sectors, the focus has previously been on surveys in the form of in-depth assessments, with dialogue primarily aimed at documenting compliance with regulatory requirements. SB1U’s owner banks are the company’s most important stakeholders, as they are its largest customers. Dialogue with these stakeholders takes place through multiple channels, including information sharing via the intranet, internal reports, meetings, and direct conversations. SB1U’s stakeholder dialogue with external parties has previously been deprioritised for various reasons, including capacity constraints and lack of data. SB1U aims to increase the prioritisation of stakeholder dialogue from next year, including dialogue with civil society organisations where deemed appropriate. Remediation and compensation SB1U has established mechanisms to manage non-compliance and ensure remediation where necessary. Although no actual breaches have been identified among suppliers, several operate in sectors known to have elevated risk. This obliges SB1U to act proactively and responsibly should actual breaches occur. When non-compliance or deviations from requirements are identified, a stepwise follow-up process is applied. This includes dialogue with the supplier, a request for documentation, and implementation of corrective measures. If deviations are not addressed within a reasonable timeframe, termination of the business relationship may be considered. This procedure has been clarified and communicated to suppliers in an updated version of the standard sustainability attachment. Through participation in industry network meetings, SB1U gains insight into current issues, opportunities for knowledge sharing, and the ability to engage in joint measures aimed at specific suppliers or supplier sectors. Collectively, these measures ensure that any need for remediation or compensation can be managed in a responsible and documentable manner. Whistleblowing channels Stakeholders can direct questions to Group Purchases and Alliance Purchases both in writing and verbally. Requests may relate to general information or information about a specific supplier, product, or service. For written inquiries, the response deadline is three weeks. The Group Sustainability Officer is responsible for responding to any inquiries. No external assessments have been conducted regarding the effectiveness of the whistleblowing channels. For censurable findings related to workers in the value chain, the Group’s purchasing department must be notified. This can be done via the Group’s various contact points, including chat, telephone, and smn.no. For censurable findings concerning Alliance suppliers, the Purchasing Committee must be notified. This should be done through ad-hoc meetings, internal reports, and quarterly meetings. Corporate market In the corporate market, dialogue with workers in the value chain is largely indirect, conducted through advisers’ contact with the management of the customer companies or external actors, such as accountants and insurance providers. When this chapter refers to customers, it concerns companies to which the Group either provides services and/or to which it is exposed. Assessment of social conditions is an integral part of the credit assessment of the Group’s corporate customers. This is carried out using the ESG model developed by the SpareBank 1 Alliance, and is applied to all exposures above NOK 5 million for the agriculture sector, and above NOK 10 million for other sectors. The assessment is conducted by the customer officer, and the industry officer may be consulted if required. In this assessment, objective factors such as human rights and working conditions are evaluated and form part of the final classification of the customer’s social risk on a scale from one to ten. The classification considers both the current and future situation. This assessment is updated every two years, and must be updated annually if the customer is classified as high ESG risk (including environmental and governance-related assessments). At the reporting date, 90 per cent of the bank’s corporate portfolio has been assessed, excluding agriculture. Including agriculture, this figure is 79 per cent.
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185SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Industries and activities that violate human rights, labour rights, or involve child labour or forced labour are excluded. The Group is committed to complying with ILO Conventions 100 and 111 regarding fair remuneration and non-discrimination. Neither SpareBank 1 Finans Midt-Norge nor SpareBank 1 Regnskapshuset SMN have specific procedures for assessing the working conditions of customers’ employees when providing services and/or financing. In cases where the Group’s corporate or accounting advisers become aware of serious breaches that contravene the Group’s sustainability strategy or policy, the Group has the option to terminate the contract or engagement. This could, for example, concern breaches of pay conditions or irresponsible use of foreign labour. Where there is reason to believe that the Group’s products or services have directly or indirectly contributed to breaches of labour and/or human rights for workers in the value chain, it is possible to submit a claim for remediation via the Group’s whistleblowing channels. No such claims were registered during the reporting period. The overarching responsibility for ensuring that the Bank’s Corporate Banking division, SpareBank 1 Finans Midt-Norge, and SpareBank 1 Regnskapshuset SMN follow current procedures and processes related to customer management rests, respectively, with the Group Director of Corporate Banking, the Managing Director of SpareBank 1 Finans Midt- Norge, and the Quality Department of SpareBank 1 Regnskapshuset SMN. Whistleblowing channels No dedicated whistleblowing channels have been established for workers in the value chain. Workers in the value chain have the opportunity to contact the Group through various points of contact if they need to raise concerns or submit reports related to working conditions. This can be done via e-mail, chat, or telephone, as well as through the Bank’s complaint channels or the Financial Services Complaints Board. At present, it is not possible to submit anonymous reports to the Group. All reports or complaints received will be handled in accordance with standard confidentiality rules and applicable regulations. No assessments have been conducted regarding the effectiveness of the whistleblowing channels, and information on whether workers in the value chain trust these channels is not available.
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186SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Targets and KPIs In 2025, management indicators were developed to monitor the handling of the Group’s material impacts, risks, and opportunities (IRO). These indicators cover both the upstream and downstream value chains. Key performance indicator Base year Base value Unit of measurement Division Scope Target Target- year Result 2025 Result 20241) Assessment of suppliers with increased potential risks related to human and labour rights 2025 52% Percent Relative Property and procurement Upstream 100% 2027 52% N/A Suppliers with purchases > 100 K NOK where the Code of Conduct (CoC) has been signed 2025 34% Percent Relative Property and procurement Upstream 95% 2028 26% N/A 1) N/A = Not available As of the end of the year, no dedicated management indicator has been developed to monitor the Group’s downstream impacts and risks. During the year, processes have been implemented—among other measures through CRD VI and EBA GL—to identify social risks (as part of ESG risk) in the Group’s lending portfolios. It has been decided to use the insights gained to establish relevant management indicators in the coming period. Definitions of the KPIs are described under Key Figures in the chapter This is SpareBank 1 SMN. Actions plans and measures The Group is, through a number of international standards, obliged to conduct ongoing due diligence assessments to prevent and address actual and potential breaches of labour and human rights. The Group’s action plans are designed to help achieve its objectives. Measures undertaken during the current year, as well as planned actions, are presented in the table below. Key performance indicator Key actions taken in the reporting year Achieved results Future planned actions Time horizon Expected outcomes Assessment of suppliers with increased potential risks related to human and labour rights • Updated overview of all suppliers • Classified suppliers according to risk in line with the procedure • Collected documentation from suppliers All critical suppliers have been mapped. • Subsequent risk assessment of mapped critical suppliers Medium-term 100 per cent mapping of suppliers with increased potential risk Suppliers with purchases > 100 K NOK where the Code of Conduct (CoC) has been signed • Integrate the CoC into all contract templates • Prioritize high -risk suppliers • Ensure follo w-up and internal alignment with employees involved in pr ocurement 26 per cent signed • Training • Clarify the CoC as a qualification requirement Medium-term 95 per cent signed
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187SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Policies The Group’s overarching governance documents related to workers in the value chain are the Group’s sustainability strategy and sustainability policy. The Group has several policies that address its impact and risk. Each policy follows recognised national and international standards to the extent relevant. All policies are accessible to the Group’s employees via internal systems. To the extent they are relevant for external stakeholders, the policies are made available on the Group’s website. The Group’s policies are reviewed at least annually and updated as necessary. Requirements for suppliers regarding sustainability and business ethics The policies cover the Group’s suppliers and business partners. The objective is to establish an upstream value chain with a conscious approach to sustainability risk. This includes, among other things, knowledge of and compliance with the UN Guiding Principles on Business and Human Rights, which encompass the ILO’s eight core conventions. It is expected that these policies are communicated and adhered to throughout the supplier’s own value chains. Suppliers are made aware of the Group’s requirements, expectations, and conditions through dialogue during the tender process and in contract annexes. The annexes set out the Group’s requirements and expectations for suppliers and business partners regarding climate and environment, social conditions, and corporate governance. Upon request, suppliers and business partners must be able to demonstrate compliance. This gives the Group the right to impose sanctions or terminate the contract in the event of material breaches. Policy on protecting fundamental human rights and decent working conditions The policy outlines how human rights, including labour rights, are safeguarded within the Group’s own workforce, among business partners, and across supply chains. It is based on the OECD Guidelines for Multinational Enterprises. Due diligence assessments are to be conducted regularly, risk-based, and proportionate, taking into account the size, nature, and context of the business, as well as the severity and likelihood of negative impacts on fundamental human rights and decent working conditions. For the Group’s own operations, assessments are based on established requirements and how these are implemented in practice. The Board approves the policy and the framework for due diligence assessments, while the boards of subsidiaries follow up within their own companies. The CEO is responsible for compliance, risk assessments, and resource prioritisation, with follow-up delegated to the Group Director of Finance and the Group Sustainability and Governance Officer. Managers and CEOs of subsidiaries are responsible for compliance within their respective areas. Over time, the guidelines will also provide direction for identifying and mapping negative impacts relating to the Group’s customers. Guidelines for managing ESG risk in the corporate market The guideline provides a framework for integrating ESG risk, including social risk, into the assessment of the client’s and engagement’s overall credit risk. ESG risk shall be described in the same way as other potential risk drivers and given significant weight in credit approval. The ESG model developed by the SpareBank 1 Alliance is a key tool in this assessment. A comprehensive evaluation of the client’s current situation and future outlook shall be conducted. Continuous assessment of activities and industries excluded from financing shall also be carried out, based on the bank’s principles for ethics, sustainability, corporate governance, and social conditions in the businesses. Companies that do not respect fundamental human rights, make use of child labour, or breach expectations regarding equality and diversity are excluded.
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188SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Consumers and end-users Approach to the topic The Group’s long-term profitability and competitiveness depend on both existing and new customers. The Group shall contribute to the success of private and corporate customers in Central Norway, which means that, with a diversified product offering, the Group shall provide customers with value beyond what a traditional bank is able to offer. In connection with the Group’s double materiality assessment conducted in 2024, several areas were identified that the Group has experienced as important for its customers. With a local presence in the region, the Group shall have the expertise and experience customers require regarding banking services, accounting, and brokerage. At the same time, the Group plays an important role in safeguarding customers’ digital and financial security through responsible handling of personal data and anti-fraud measures. In an increasingly digitalised world, where the quality of information varies, customers are increasingly making use of information published by the Group across various media channels. The Group’s material IROs, their focal points, and the time horizons they cover are presented in the table to the right. Entity-specific reporting This chapter contains entity-specific reporting related to fraud and data privacy. Since the Group’s first materiality assessment in 2020, fraud has been a material topic alongside the management of money laundering, terrorist financing, and corruption. Data privacy has also been a material topic since 2020. Due to the absence of guidance in the CSRD, both fraud and data privacy, along with their associated impacts and risks, are reported in this chapter using the requirements set out in ESRS 1, Appendix AR 1–5. IMPACTS Value chain Time horizons Breaches of personal data protection Negative Downstream All Fraud Negative Downstream All Lack of social inclusion Negative Downstream All Access to quality information Positive Downstream All RISKS Value chain Time horizons Greenwashing Downstream Medium-term Long-term Poor protection of personal data, including personal and customer information Downstream All Poor processes for combating fraud Downstream All OPPORTUNITIES Value chain Time horizons Local presence and identity Downstream All
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189SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Assessment of IROs related to consumers and end-users The Group is dependent on its customers, and both positive and negative impacts stem directly from the Group’s business models and strategy. The Group has for a long time devoted resources to managing identified impacts resulting from both requirements and expectations from external and internal stakeholders. • Personal data protection is incorporated in the Group’s procedur es and processes for handling personal data. • Fraud prevention has, in line with developments in this ar ea, received increased attention • Prevention of greenwashing has f or several years been a focus in external marketing and communication. Future adaptations will depend on regulatory requirements, expectations from external stakeholders, and adjustments to the Group’s double materiality assessment. Consumers and end-users are defined as current or potential customers whom the Group impacts either through services or marketing. All IROs are directed at the retail market, but certain IROs also relate to the Group’s corporate customers. Customers may be impacted negatively as a result of fraud, loss of personal data, or through the Group’s marketing, communication, and sales strategies. Customers may be impacted positively through access to quality information. All customers with the potential to be impacted by the Group are also included in the double materiality assessment. Several of the Group’s IROs can be linked to specific customer segments. Over several years, the Group has acquired knowledge regarding which customers have a higher inherent risk of being exposed to attempted fraud than others, for example the elderly. A lack of social inclusion is likely to affect vulnerable groups such as first-time home buyers, immigrants, low-paid workers, or people covered by social support schemes through NAV. Other impacts have the potential to affect all existing and potential retail customers. This applies to breaches of personal data protection and access to quality information. During 2025, several measures were implemented to mitigate the Group’s actual and potential impacts on fraud and personal data protection. These are described in more detail in the chapters on Anti-Fraud and Personal Data Protection. The double materiality assessment has not provided further insight into whether some consumers or end-users are more exposed to impacts and risks than others. The process is described in more detail under General Information. Impacts on consumers and end-users The Group is committed to assisting customers in the best possible manner by minimising the Group’s negative impacts and maximising its positive impacts. Breaches of personal data protection As processor, the Group depends on managing large volumes of personal and customer data in order to assist customers in everything from everyday tasks to substantial investments. This includes both situations where the Group itself acts as the data controller, and situations where processing tasks are outsourced. Personal and customer data that goes astray could potentially be misused by criminals or other dishonest actors to gain advantages at the expense of the Group’s customers. Fraud The Group’s operations have an inherent negative impact on customers with regard to fraud. This means that both retail and corporate customers may be used by criminals as intermediaries, for example by being manipulated to carry out transactions in good faith. Tools used include fake websites and invoices, manipulated or fraudulent communications from or to CEOs and directors, or exploiting emotions. Numerous measures have been implemented to address this growing social problem. The Group conducts controls, processes, and investigations to stop suspicious transactions. In addition, customers’ resilience is strengthened through culture building, advisory services, and digital and physical information sharing. The importance of the Group’s efforts to prevent customer fraud has been clearly confirmed through the double materiality assessment. Lack of social inclusion The Group’s compliance with the capital requirements framework entails a requirement for a moderate risk profile and low probability of default among customers offered loans. With a large amount of retail customers in the region, the Group serves a diverse customer base with varying life situations and needs. Some customers have limited access to financing due to insufficient equity, lack of payment capacity, or debt problems. This may, for example, apply to foreign workers, first-time home buyers, single persons, low-income earners, or recipients of public support schemes through NAV. The Group’s financial soundness requirements may result in certain customers being unable to establish themselves in the same way as others.
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190SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Access to quality information With its broad catchment area, the Group considers it part of its societal role to share reliable information on topics that are important to its customers. Through the Group’s websites, advisers, and other communication channels, information is provided on a range of subjects, including the detection of attempted fraud, advice related to foreign travel, saving tips, pensions, debt issues, accounting, house purchases and sales, as well as guidance for business owners. Risks and opportunities related to consumers and end- users The Group’s material risks and opportunities are described below. The risk referred to as Poor processes for combating fraud had a material financial impact in 2025. In the course of 2025, customer fraud has resulted in operational losses of NOK 9.9 million for the Group. No other risks or opportunities have had material financial effects during the reporting period. There is no indication that the risks and opportunities entail a significant risk of material changes in the carrying amounts of assets or liabilities in the financial statements in the coming reporting period. The expected financial effects of the risks and opportunities are subject to uncertainty. For this reason, it has been decided to omit this information from this year’s reporting by application of the phased-in disclosure requirement in ESRS 1 Appendix C. Greenwashing The Group produces various types of marketing communication, and information is shared on social media and websites. In the Group’s customer dialogue with both retail and corporate customers, there is a risk of greenwashing occurring. This risk increases in line with the general public’s competence and awareness of sustainability as a topic among various stakeholders. Erroneous and/or unverifiable marketing communication is a potential risk in an increasingly accountability-focused society. Financial consequences may arise in the form of fines and sanctions, but also as a result of distrust among customers, employees, and owners. Over time, this could lead to more complex financial impacts. If employees, whether in an advisory or marketing capacity, communicate sustainability information without the necessary competence, it may provide customers with an incorrect basis for decision-making. This could result in greenwashing and breaches of financial contract and marketing legislation. Such breaches could impose direct and indirect financial consequences on the Group in the form of fines and reputational loss. Poor protection of personal data, including personal and customer information The Group is dependent on the trust of, among others, customers and supervisory authorities, and is therefore committed to ensuring that personal data is handled securely in accordance with applicable legislation at all times. Failure to safeguard personal and customer data could, depending on the severity, result in customer complaints, fines, or loss of customers. Poor processes for combating fraud The financial gains achieved by criminals through fraud are laundered and used for terrorist financing and other types of organised crime. Customer losses resulting from fraud are borne by the Group as operational losses if the attempted fraud could or should have been prevented by the Group. The risk related to money laundering and terrorist financing arises from criminal actors deliberately using the Group’s infrastructure and systems to carry out criminal acts. The Group manages this risk through dedicated controls, processes and procedures in the area. The risk is described in more detail in the chapter Governance. Local presence and identity The Group’s local presence contributes to building and reinforcing its relationship with existing and potential customers. With 26 finance centres across the region, this local presence is intended to strengthen the SpareBank 1 SMN brand and increase market share in areas where competitors are unable to offer the same breadth of products and services, both physically and digitally.
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191SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Customer dialogue Customers have various contact points within the Group, and these contact points handle customers differently depending on purpose and need. How the Group engages in dialogue with consumers and end-users, primarily retail customers, is described below. Information on dialogue with corporate customers, and workers in the value chain, is provided in Workers in the value chain. Retail market In 2025, Retail Banking has continued efforts to enhance the value of customer meetings and strengthen its position as an advisory bank. Standard templates for customer meetings have been developed, and comprehensive training has been provided to all employees in Retail Banking, with a focus on quality, sound advice, and documentation of the advisory process. All customer interactions are to be based on the industry standard “Good Practice” developed by the finance industry through the Financial Industry’s Authorisation Scheme (FinAut). PURPOSE The purpose of these rules is to ensure that the customer’s interests and needs are safeguarded in the best possible way. 1 PROFESSIONALISM Customer interactions shall be honest and professional. The framework should be clear to the customer. When the customer’s choices are not based on advisory services, this shall be clearly communicated to the customer. PRIVACY Customer information shall be handled in a manner that ensures privacy and protects the customer’s rights. BASIS AND NEEDS ANALYSIS Customer interactions shall be based on a solid foundation. When providing advisory services, a comprehensive needs analysis shall be conducted. CONFLICT OF INTEREST The customer’s interests shall take precedence over the interests of the company and its employees. Confl icts of interest shall be identifi ed and mitigated. If this is not possible, the customer shall be clearly informed of the confl ict of interest before any agreement is RECOMMENDATION AND AGREEMENT The company shall make every effort to ensure that the customer understands the content of the agreement and its important implications. The customer shall be given suffi cient time to consider before the agreement is made. In the case of advisory services, the recommendation shall be based on the needs analysis. ADVISING AGAINST Solutions that are not compatible with the customer’s needs and interests shall be discouraged. FOLLOW-UP Any follow-up from the company or the customer shall be agreed upon. INFORMATION The information provided to the customer shall be accurate, complete, and not misleading. DOCUMENTATION The customer agreement and its basis shall be documented and stored. 2 3 4 5 6 7 8 9 10 Industry Standard GOOD PRACTICE for Advisory Services and Other Customer Interactions In the retail market, the Group primarily has direct contact with individual customers, except where the customer is represented by a power of attorney or legal guardian. Contact with the customer occurs either at the initiative of the bank or the customer. Dialogue takes place both physically and digitally, with the balance between the two adapted to the individual customer’s needs. This enables services to be tailored specifically for vulnerable customers. Customers who are not digitally enabled, or who have other specific needs, are served at the Group’s physical locations. They have access to the same products and services as customers who are primarily served through digital channels. All relevant customer interactions are, as a general rule, to be recorded in the CRM system to ensure that the customer receives the assistance and follow-up needed. This contributes to optimising customer follow-up within the responsibilities of Retail Banking. Storage of relevant customer interactions and meeting notes ensures that the bank can subsequently document and follow up on agreements or other enquiries. In 2025, Retail Banking has continued work on using AI to generate conversation and meeting notes. Positive experiences have been gained where advisors, with the help of AI, can more easily and efficiently produce high-quality records following customer interactions. This ensures that essential information is stored and improves customer follow-up. The overall responsibility for ensuring that Retail Banking follows applicable routines and processes related to customer dialogue rests with the Executive Director of Retail Banking. In written and digital communication, the language must be understandable and text and illustrations legible. Languages for communication are Norwegian Bokmål, Nynorsk, and English. Requirements for universal design are adhered to in the development of digital solutions. All customer information and dialogue are treated confidentially and in accordance with the General Data Protection Regulation (GDPR). Internal controls are conducted to ensure that all access to customer data occurs only in accordance with the valid legal basis for processing. A customer group with special confidentiality and protection needs is the category defined as “shielded customers”. These customers have been granted an address block following a threat assessment by Kripos. Access to this customer group is only available to selected employees trained in handling this category. To ensure that the services provided align with the customer’s wishes, customer surveys provided by external market research agencies and suppliers of market analyses are primarily used. In addition, in each individual market area, close dialogue is maintained with, among others, local associations and organisations, municipalities, and senior councils. This provides valuable insight for identifying customer needs and how services can be developed to meet these needs in the short and long term.
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192SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Whistleblowing channels Customers who wish to communicate their needs to the Group, whether regarding products or other enquiries, are encouraged in the first instance to contact their adviser or the customer service centre for banking, insurance, or pensions. If the customer is not satisfied, they may submit a complaint to the Group’s complaints service. The complaint is then received by dedicated complaints officers and will be responded to within 21 days. If the customer feels that the complaint is not resolved by the bank, they may contact the Financial Services Complaints Board. Information about the possibility to submit a customer complaint and a link to the electronic complaint form is available on the Group’s website. For non-digital customers, advisers at physical branch offices or the customer service centre can assist with submitting the complaint. At present, it is not possible to submit anonymous customer complaints to the Group. All complaints received will be handled in accordance with normal confidentiality and applicable regulations. Complaints officers ensure that complaints are addressed and that necessary measures are taken to prevent similar errors from occurring in the future. If required, the local branch manager and relevant departments will be involved in the matter. No assessments have been made regarding the effectiveness of whistleblowing channels, and information on whether customers trust these channels is not available. EiendomsMegler 1 Midt-Norge EiendomsMegler 1 Midt-Norge continuously works to be a professional actor in its dialogue with customers. As part of this, the company focuses on quality, sound advice, and correct templates in accordance with relevant laws and regulations for real estate brokerage. All customer dialogue shall be based on the “Good Real Estate Practice” standard in line with the Real Estate Brokerage Act and associated regulations. Within the company, contact with customers is primarily personal, but customers may also be represented through power of attorney or guardianship. Contact with the customer can be initiated by either the customer or the broker. Customer dialogue is conducted mainly through physical meetings, by telephone, and via SMS/email, while digital tools facilitate a smooth flow of necessary documents. Provision is made for physical documents in cases where the customer has specific needs, such as customers who are unable to use Bank-ID. All relevant customer dialogue shall as a general rule be recorded in the company’s customer management system to ensure that the customer receives the assistance and follow-up required. This helps to optimise customer follow-up throughout the sales process. Storing relevant customer dialogue and meeting minutes ensures that the broker can subsequently document and follow up on agreements and other matters relevant to the customer relationship during the sales process. The overall responsibility for ensuring compliance with applicable routines and processes related to customer dialogue lies with the professional manager at EiendomsMegler 1 Midt-Norge. All customer dialogue shall be conducted in a manner adapted to the individual customer. Written and digital communication must use clear language, and text and illustrations must be legible. The primary language of communication is Norwegian Bokmål, but it is adapted as needed. All customer information and dialogue between broker and customer is treated confidentially and in accordance with the General Data Protection Regulation (GDPR). Internal controls are conducted to ensure that all access to customer data occurs in accordance with a valid legal basis. One customer group has a particular need for confidentiality and protection. These customers have been granted an address block following a threat assessment by Kripos. Access to this customer group is only available to selected employees trained in handling this category of customers. To ensure that real estate services are delivered in line with the customer’s expectations, customer surveys are conducted during and after the sales process. These are actively used to ensure a good customer experience. In addition, in each market area there is close dialogue and agreements with local associations, organisations, and municipalities. This provides valuable insight into identifying customer needs and developing services that meet these needs in the short and medium term. Whistleblowing channels If the customer is not satisfied with the services provided, they are initially encouraged to contact their responsible broker or department manager regarding real estate services. If the customer remains dissatisfied after dialogue with the responsible broker, they may submit a complaint to the company’s professional department. The complaint will be handled by the professional department and answered as quickly as possible. If the customer feels that the complaint is not resolved, they may contact the Complaints Board for Real Estate Services. For non-digital customers, the professional department will refer them to the appropriate contact point at the board. It is currently not possible to submit anonymous customer complaints. All complaints will be handled in accordance with standard confidentiality rules and applicable regulations. The professional department ensures that complaints are addressed and that necessary measures are taken to prevent similar errors from occurring in the future. If necessary, the department manager and responsible broker will be involved in the complaint. No assessments have been made regarding the effectiveness of the complaint channels, and information on whether customers trust these channels is not available. If an error has resulted in financial loss for the customer, they will be compensated accordingly. The company’s professional manager is responsible for conducting this assessment.
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193SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Market dialogue The Group conducts dialogue and information activities for existing and potential customers through advertising in digital media, social media, e-mail, SMS, and online banking. The Group’s websites are central to this dialogue, as most activities direct customers to the websites where they can find more information about the Group’s products, services, and associated purchasing solutions. On both the websites and in the online bank, it is possible to schedule a meeting with an advisor or contact the Group via various chat solutions if the customer requires information. The Executive Director of Marketing, Communication, and Digital Sales has overall responsibility for market dialogue. The Group places great emphasis on presenting products and services in a clear and balanced manner, enabling customers to make conscious and informed decisions. In addition, the websites contain extensive information offering tips and advice for various financial situations, both for businesses and private individuals. Many of these topics are also communicated to customers through paid marketing, webinars, and customer events. Digital channels are an important platform for customer engagement and for fulfilling the role as a financial advisor and sparring partner for individuals and businesses in the region. Providing customers with accurate information regarding fraud and security is a priority area, and is addressed both through customer events and through information published on the websites and in the online bank. In addition, media contact is used to raise awareness of these topics. Many customers have experienced tighter finances in recent years. The bank has created a dedicated information page with advice on steps customers can take to gain control over their finances. These pages also make it easy to contact an advisor if extra assistance is needed to manage personal finances. Marketing must comply with good marketing practices and always be in accordance with applicable laws, regulations, guidelines, and industry standards relevant to the area. In case of violations, the Group may receive directives from regulatory authorities to make corrections. The dialogue should pay particular attention to vulnerable groups and must never aim to offer products that could increase vulnerability. This applies, for example, to credit cards or consumer loans offered to customers with high, unsecured debt. Marketing aimed at children and youth must be conducted with particular care, and all such activities must be approved by the immediate supervisor. Marketing must also not violate principles of equality regarding gender, ethnicity, or sexual orientation. Products and services should be marketed in a manner that ensures customers are informed of both advantages/opportunities and disadvantages/limitations. The Group maintains a high level of diligence with regard to ethics and its moral responsibility in marketing products and services. What is communicated, and the way it is communicated, is crucial for the customer to understand the message and to engage with the information provided by the Group. Some marketing is based on data the Group has about the customer, either through the customer relationship or via the customer’s behavior on the websites and in online banking. All such marketing is assessed in relation to the legal basis for processing and consent, to ensure that personal and detailed data are handled in accordance with applicable law. The purpose of data-driven customer communication is to provide customers with useful tips and advice in their relationship with the Group, whether concerning the use of services, relevant product changes, or the purchase of new products. All marketing must be assessed according to the Group’s routine for responsible marketing. This routine ensures that the Group’s marketing activities are carried out responsibly and in compliance with key laws such as the Marketing Act and the Financial Contracts Act. When personal data is used, it is assessed specifically in accordance with the routine for the processing of personal data in marketing. Whistleblowing channels Both customers and non-customers have the opportunity to submit complaints or report breaches via the Group’s websites. Access to this is available at the bottom of all pages. In addition, customers can find information on privacy, detailed personal data, and the use of cookies. The reporting channels are otherwise the same as those established by the business areas. Anti-fraud Fraud targeting bank customers has become a widespread societal phenomenon, with a large number of the bank’s customers experiencing attempted fraud in various forms each year. Since the bank began registering fraud cases in 2020, the number of cases has increased annually. At the same time, 2025 appears to mark a turning point in the bank’s handling of fraud against its own customers. In 2025, the bank reduced total operational losses due to fraud from NOK 23.6 million in 2024 to NOK 9.9 million in 2025, corresponding to a 58 percent reduction. The 2024 figure was originally NOK 22.5 million but increased by NOK 1.1 million due to subsequent losses. These retroactive adjustments are unusually high but are related to 2024 being an extraordinary year for fraud. In 2025, losses related to account-to-account fraud were reduced from NOK 12.3 million to NOK 1.24 million, a percentage decrease of 90 percent. Losses from card fraud were reduced from NOK 11.2 million to NOK 8.67 million over the same period, a decline of 23 percent. In 2024, the bank invested in a new security system, which in 2025 has significantly reduced fraud against customers’ accounts through unauthorised logins and unauthorised
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194SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL transactions. We note that both actual and perceived security for large transactions has increased considerably. Fraud targeting customers’ payment cards (through fake SMS and emails) continues to be widespread, although it has decreased slightly in 2025. Card fraud remains an attractive type of crime, unfortunately drawing highly skilled and adaptable criminal actors, as evidenced by the flexibility and continual changes in modus operandi. In 2025, SMN participated as advisers to the media in a major exposure of a global phishing network based in East Asia, providing the bank with unique insights into the technical sophistication of card fraudsters. Overall figures for registered fraud cases, complaints, police reports, and reported incidents show a clear downward trend in the extent of fraud compared with previous years. In 2025, 104 fraud cases were reported as suspicious transactions (ST) to the financial intelligence unit at Økokrim, a significant reduction from the previous year (281). Preventive measures SpareBank 1 SMN has multiple levels and measures related to fraud prevention, but works along two parallel tracks: preventive measures through information and knowledge directed at customers and potential victims, aimed at making the customer more resilient and resistant, and operational prevention through the development and operation of security systems that detect fraud. Personal data protection The rapid development of AI and an increasingly digitalised everyday life pose a growing risk of personal data being compromised for both businesses and individuals. The Group is subject to the Personal Data Act and GDPR, and through the Group’s services, large volumes of personal data are managed, processed, and held, with strict requirements for handling and safeguarding key data protection principles such as confidentiality, integrity, and availability. Compliance with data protection legislation is therefore critical for the Group’s trust and reputation. All employees have access to the Group’s data protection guidelines and detailed information, and all employees are required to familiarise themselves with their responsibilities regarding the handling of personal data in their daily work. The overall purpose of the Group’s data protection work is, through a systematic and risk- based approach, to: • safeguard the personal data of customers, emplo yees, and others; • support business operations by maintaining control over the pr ocessing of personal data at all times; • protect the Group’s reputation through correct handling o f personal data; and • ensure compliance with the Personal Data Act and GDPR. The Bank has appointed a dedicated Data Protection Officer (DPO) who advises the Group CE O on compliance with personal data processing requirements. Subsidiaries and product companies have their own data protection resources that collaborate with the DPO through professional networks. Data protection coordinators have been appointed in some of the Group’s business areas to serve as points of contact. These coordinators act as a link between operational data controllers and employees within each area of responsibility. Additionally, the Group has process and system owners for all IT systems, and an appointed head of data protection with operational responsibility to ensure that systems and related information architecture support applicable data protection requirements. The Bank’s DPO prepares quarterly and annual reports directly to the Board. The reporting provides an overview of deviations and inquiries concerning data subjects’ rights, areas of focus for the DPO, observations and experiences, as well as risk areas to be addressed in the ongoing data protection work. In 2025, the Group focused on training measures to raise awareness of personal data processing requirements within the organisation, specifically regarding data subjects’ rights. Significant resources have also been allocated to ensure responsible integration and use of AI in employees’ daily work and processes, for example through AI pilot projects in the retail and corporate markets. New products and processes from SpareBank 1 Utvikling, the Group’s primary data processor, have also been evaluated. In the second quarter, an internal audit of the Bank’s processing register was conducted. Relevant follow- up measures have been decided and scheduled. Plans for 2026 include continuing to strengthen collaboration with SpareBank 1 Utvikling, further training initiatives, enhancing first-line capabilities, and continuing internal awareness measures through competence development and updates related to, among other things, IT systems. Appropriate organisation of data protection work has been discussed throughout 2025 and is expected to be finalised in 2026. As a significant processor of personal data, employees must be aware of breaches of personal data security and maintain a low threshold for reporting deviations to the Norwegian Data Protection Authority (Datatilsynet). In 2025, the Group received four customer complaints regarding data protection and reported six incidents classified as leaks or losses of personal data to Datatilsynet. The Group did not receive any fines or orders from Datatilsynet in 2025. The Group’s obligations are anchored in the Policy on personal data protection
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195SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Targets and KPIs The Group’s IROs are the result of external expectations and strict regulatory requirements the Group has faced over an extended period. As a result, the Group has, in various forms, had KPIs for areas such as data protection, fraud, and greenwashing. During 2025, these KPIs have been specified and developed to monitor the management of the Group’s material IROs. Key performance indicator Base year Base value Unit of measurement Division Scope Target Target- year Result 2025 Result 20242) Deviations from the lending regulation used to finance and include young customers and first-time buyers 1) 2024 53% Percent Relative Retail market Downstream N/A N/A 52% 53% Recovery rate of unauthorised/fraudulent transactions 2024 43% Percent Relative Financial crime and business support Downstream 80% 2027 77% 43% Compliance with the restitution obligation in complaint cases related to fraud 2025 80% Percent Relative Financial crime and business support Downstream 95% 2027 80% N/A Number of breaches of privacy or loss of customer data reported to the DPA 2025 6 Units Absolute Compliance Downstream 0 2026 6 11 Number of privacy-related deviations registered in IMS 2025 242 Units Absolute Compliance Own ops 240 2026 242 N/A 1) The Bank aims to prioritise the use of the deviation quota for two groups: young customers and/or first-time buyers, and customers experiencing life events that affect their financial situation (e.g. relationship breakdown or temporary loss of income). At the reporting date, it is not possible at an aggregated level to distinguish between customers experiencing such life events and other customer groups. This is expected to improve following planned system changes in the upcoming period. In the longer term, the management indicator will include this group; consequently, no target has been set for the KPI. 2) N/A = Not available The role as an information provider (access to quality information) and Local presence and identity are areas that do not have dedicated targets or KPIs, but are implicitly included as part of the other KPIs Definitions of the governance indicators are described under Key Figures in the chapter This is SpareBank 1 SMN.
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196SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Action plans and measures The Group’s action plans are designed to support the achievement of the Group’s objectives. Measures implemented during the current year, as well as planned measures, are presented in the table below. Key performance indicator Key actions taken in the reporting year Achieved results Future planned actions Time horizon Expected outcomes Deviations from the lending regulation used to finance and include young customers and first-time buyers 1) • Prioritised groups incorporated into advisory procedure descriptions • All deviation cases decided at an overarching decision level, contributing to strengthened focus on routines and consistent assessments Improved routines and decision -making levels for deviation cases • Expand the per formance indicator to also measure customers experiencing life events that affect their financial situation, such as relationship breakdowns, temporary loss of income, etc. Medium-term Maintain a strong proportion of the deviation quota used for financial inclusion of young customers and those in the establishment phase. Recovery rate of unauthorised/fraudulent transactions • Close cooperation with the police and Økokrim in cases where funds are misappropriated • Staffed inbox and phone line for the anti -fraud team with alerts to/from the bank from 08:00–16:00 • Mapping and identification of latent customers within the bank, including isolation and reduction of potential harm • Implementation of real -time transaction-monitoring functionality aimed at fraud prevention Reduction in operational losses. Par t of the reduction can be attributed to a high recovery rate this year (77%). • Maintain key actions taken Short-term Reduction in operational losses by an additional 20 per cent Compliance with the restitution obligation in complaint cases related to fraud • Internal audit of account -related complaint cases • Quality improvement o f routines for handling complaint cases • Control point in the data flow that alerts when deadlines are exceeded Repayment obligation of 80 percent (including cases with missed deadlines due to suspected fraud). • Ongoing quality control Short-term Repayment obligation of 95 percent in cases not classified as (potential) fraud. Number of breaches of privacy or loss of customer data reported to the DPA • Continuous work internally and with suppliers to reduce the risk of notifiable deviations occurring Reduction in the number of notifiable deviations compared with previous years. • Continuous work internally and with suppliers to reduce the risk of notifiable deviations occurring Short-term Continued reduction in the number of notifiable deviations compared with previous years. Number of privacy-related deviations registered in IMS • Training to reduce the number of human errors that lead to deviations 240 deviations • Training to recognise and report deviations (with the aim of ensuring that more deviations are identified and reported) • Training to reduce the number of human errors that lead to deviations Short-term • More deviations are identified and reported • Reduction in the number of serious deviations
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197SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Policies The Group’s overarching governance documents related to consumers and end-users are the Group’s sustainability strategy and sustainability policy. The Group has several guidelines that address the Group’s IRO. All guidelines follow recognised national and international standards to the extent relevant. The guidelines are available to employees through internal systems, and where relevant to external stakeholders, they are accessible on the Group’s websites. The Group’s guidelines are reviewed at least annually and updated as needed. Policy anti-fraud The policy sets out guidelines for maintaining customers’ trust by identifying, managing, and preventing fraud. Fraud is defined as criminal deception under criminal law and encompasses both active acts and omissions. The policy contains governing principles and requirements regarding effectiveness, quality, training, risk assessment, and timely safeguarding of the customer in fraud situations. The policy establishes responsibilities and organisational structure, where the Board is responsible for setting the overarching strategy and objectives, as well as ensuring the administration’s risk management processes and internal controls. The Group CEO holds the highest administrative responsibility. Other Group directors have responsibilities corresponding to their respective areas of expertise. All employees are responsible for handling customers and cases with professionalism, quality, and efficiency, and for completing relevant training within the anti-fraud area. Policy on personal data protection The policy is intended to help identify the overarching requirements and obligations for the processing of personal data, as well as to describe internal organisation, responsibilities, and authority. The policy contains guiding principles and requirements related to maintaining an overview of different processing activities, training, risk assessments, Data Protection Impact Assessments (DPIAs), ensuring the customer’s timely right of access, handling of adverse events and deviations, controls, reporting, data processors, and outsourcing of operations. In addition, the policy defines the organisation and accountability for compliance with data protection regulations and the operationalisation of responsibility within the line organisation. All employees and contractors who have access to and/or process and manage personal data through the Group’s IT infrastructure and subsidiaries are covered by the policy. On the Group’s websites and in internal systems, there are separate privacy statements for customers and employees. These provide information on which personal data is collected, how it is handled, and the rights of customers and employees, respectively. Policy for utkontraktering av virksomhet The policy sets the framework for all outsourcing, including IT services and agreements on the use of cloud services, and applies across the Group, particularly to employees who own or manage agreements, systems, services, processes, or products. The purpose of the policy is to provide overarching principles and guidelines related to outsourcing, to support the Board’s requirements for corporate governance within the Group, and to ensure compliance with regulatory requirements. The policy’s principles and requirements for outsourcing cover the following areas: • What can be outsourced • Risk and vulnerability assessments • Written agreements and overvie w of agreements • Obligation to report to supervisory authorities • Follow-up In addition, the policy defines organisation and responsibility for pr oper organisation of the Group’s outsourced activities and functions, including the Board of Directors and the respective departments and business lines. Policy on responsible marketing The purpose of the guidelines is to ensure compliance with good marketing practices and applicable laws, regulations, guidance, and industry standards relevant to the area, including the Marketing Act and the Financial Contracts Act. The Group’s procedure for responsible marketing applies to all types of marketing, such as advertisements, films, podcasts, social media, e-mail, and marketing in online and mobile banking. The routine provides overarching guidance for the Group’s marketing activities regarding the advantages/opportunities and disadvantages/limitations of the Group’s products and services. Marketing directed at vulnerable groups, children and young people, and greenwashing is specifically addressed. This also applies to marketing of credit and debt products. The Group has a separate procedure for the processing of personal data in marketing.
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198SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Community dividend Approach to the topic The community has been the Group’s largest owner for more than 200 years. When Trondhjems Sparebank was founded in 1823, one of the objectives of the ownership model and community dividend was to enable even those with limited means to save and build their own security and future. The ownership model was based on the principle that depositors should not receive dividends. The grunnfond was to grow and secure local community ownership, and any future surplus was to be shared with the local community. In step with the extension of the Group’s catchment area through acquisitions, mergers, and organic growth, the Mid- Norwegian community remains the Group’s largest owner. The Group has a materially positive impact as a Contributor in the region. This entails that its profits are used to help develop the region of which the Group is a part. Entity-specific reporting Community dividend has been identified as a material area with its own impacts in the implementation of the Group’s double materiality assessment. Due to the lack of a direct link between the Group’s impacts and AR16, reporting on community dividend follows the requirements of ESRS 1 Appendix AR 1-5. In the reporting of policies, action plans and measures, as well as targets and key performance indicators, the formal requirements of ESRS 2 have been applied. From gifts to one of the largest private contributors in the region The objects clause of the bank 200 years ago was: "“…to encourage the common people to save so that the less for tunate might have something to engage in by starting a business, entering into marriage, in time of distress or in troublesome old age.” Since 1847, parts o f the profit have been allocated to non-profit and charitable purposes to build and develop the region. For more than 100 years, the Group has, through community dividend, been a mainstay for the region. In step with growth and financial soundness, the Group has developed into a community builder capable of creating significant benefits for the community. The Group is reliant on, and committed to, the development of the region. This includes everything from voluntary work and talent development to cultural experiences, quality of life, business development, and employment. The Group recognises the importance of supporting future generations and prioritises initiatives that benefit children and young people. Funds from the community dividend are intended to support projects that build and develop Mid-Norway. They are aimed at strengthening community and business development by building knowledge, a culture of innovation, and capital. This enables new investments and lays the foundation for new jobs. It is proposed to allocate NOK 968 million of the Group’s net profit to community dividend. Of this, NOK 350 million is proposed for investment in various projects in the region, while a further NOK 618 million is to be transferred to Sparebankstiftelsen SMN, the community’s “savings account.” The community’s ownership stake in the Group is 41.5 per cent, distributed as follows: the community 33.2 per cent, Sparebankstiftelsen SMN 3.4 per cent, and Sparebankstiftinga Søre Sunnmøre 4.9 per cent.
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199SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL The community is SpareBank 1 SMN largest owner Total equity The community 33,2% EC-holders 58,5 % Sparebankstiftinga Søre Sunnmøre 4.9 % Sparebankstiftelsen SMN 3.4 % Organisation and allocation It follows from the Financial Institutions Act section 10-7 that community dividend is to be allocated to non-profit causes that benefit as many as possible. The allocations are in the public domain at smn.no. The Supervisory Board sets, upon the Board of Directors’ recommendation, both the level of community dividend and the split between allocation to non-profit donations and transfers to Sparebankstiftelsen SMN. Where the share of community dividend allocated to donations is concerned, the Board of Directors adopts the overarching strategies and long-term priorities for distribution. The Board of Directors has authorised the Group CEO to manage the total amount of community dividend available for distribution within the other limits and mandates adopted by the Board of Directors. Allocations to individual projects that exceed NOK 10 million are decided by the Board of Directors. The Group CEO and the community dividend fund’s administration are authorised to decide individual allocations up to this level. All applications for support from the fund are considered on an ongoing basis, and are guaranteed a reply within a maximum of three weeks. Applications must be approved by at least two persons, who certify/order the disbursement of community dividend moneys to ensure due competence and the four-eyes principle. Strategic direction The community dividend strategy was anchored in the Board of Directors in 2022, and is based on more than 10,000 inputs from individuals, firms and organisations in Mid Norway. In December 2023 the strategy was renewed with minor changes for the period 2024 to 2026. Focal areas defined here are community-building, sport and outdoor recreation, art and culture, driving the green transition along with innovation and value creation. Among the changes for the new strategy period is a shift in the distribution of community dividend moneys in a more sustainable direction in order to underpin the role of driver of the green transition in Mid-Norway. The ambition to strengthen Mid-Norway through awards which help to: • prevent outsiderness • create living local communities • make the region a leader in sustainable innovation and green transition The endeav our to create new jobs in Mid Norway has increased. Ahead the Group wants to be an important actor for entrepreneurs in Mid-Norway – ranging from budding entrepreneurs at upper secondary school to more established entrepreneurial entities – and to heighten our commitment to the role of arena builder, innovator, investor and driver of green transition through collaboration with a variety partners and business associations.
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200SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Key project in 2025: “Public health and community celebration towards the 2025 Ski World Championships” In 2025, the objective has been to demonstrate that values extend beyond money, by encouraging more people to engage in physical activity to promote public and mental health in the lead-up to and during the 2025 Ski World Championships. Overall, these activities reached more than 68,000 individuals across the region before and during the Championships. This represents a contribution to improving public health and is intended to create long-term value for local communities throughout Mid-Norway. Before the Championships, the goal was to engage people in the region to be physically active, while also raising awareness around youth and mental health. Family and activity days were organised, valuable advice was provided to clubs and associations, and events for young people were fully attended, with a focus on mental health and sound financial habits. During the Championships, activities took place in the family areas at Litjåsen in Granåsen and at Søndre gate 4. Children and young people were able to participate in ski trails, visit open medal and art exhibitions, and enjoy entertainment on stage for all ages. Several themed meetings for adults were also held. During the Championship week, community dividend contributed approximately NOK 35 million to ensure that activities and experiences at the various venues could be carried out, as well as providing support and collaboration with clubs and associations that facilitated activities during the Ski World Championships. Throughout 2025, support was provided to numerous clubs and associations to promote inclusion and public health. Community dividend allocated NOK 5 million to a Solidarity Fund, contributed funds to humanitarian initiatives, and promoted equal opportunities for children, youth, and women through a collaborative project with RBK.
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201SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Targets and KPIs To be able to fulfil its role as a community builder, it is crucial to have sufficient capital for major initiatives that create new, positive environments and leave a lasting legacy. Community dividend is therefore managed in a way that supports the region of which the Group is part, with the aim of establishing a solid foundation for future value creation and increased community dividend. The area has several internal management indicators for monitoring the allocations made throughout the year. However, management indicators to follow up on the Group’s IRO related to community dividend have yet to be developed. This work is scheduled to continue in 2026. Action plans and measures No action plans or measures have been developed to address the IRO related to community dividend. These will be prepared in 2026, together with targets and KPIs. Policies In order to ensure that the funds awarded to projects are allocated correctly, strict procedures underlie disbursement, case handing, allocation and controls. The Supervisory Board adopts the distribution of community dividend, and authorises the Board of Directors to manage the funds within the bounds of such authority. Furthermore, the executive director of Marketing, Communications and Digital Sales receives authorisation from the Group CEO to approve budget proposals and focal areas presented by the head of community dividend.
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202SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Note 1: Allocation of community dividend The community dividend allocation for 2025 amounted to NOK 240 million. In 2025, 3,927 applications were processed, of which 1,787 were approved. The total requested amount was NOK 601 million, and NOK 336 million was granted to charitable and community-benefiting purposes in 2025. Focal area1) Amounts applied for (NOKm) Amounts granted (NOKm) 2) Processed applications Approved applications 2025 2024 2025 2024 2025 2024 2025 2024 Regional community 111.6 105.9 20.3 56.3 745 1,016 320 490 Sports and outdoor recreation 225.4 262.8 136.2 71.4 907 1,743 510 804 Art and culture 120.3 111.5 46.6 56.4 1,723 1,090 698 466 Driving the green transition 15.1 17.4 5.2 10.2 160 172 117 123 Innovation and value creation 128.8 174.7 105.6 123.4 392 320 142 135 Total 601.3 672.3 336.3 331.9 3,927 4,341 1,787 2,018 1) The Community Portal on smn.no is structured according to the focal areas of community dividend. Discrepancies between the figures in the portal and the table are due to the fact that allocations are only published in the portal after approval, when the funds are fully utilized, or adjusted for any remaining funds that are returned after two years. This creates a time lag, and figures for previous periods in the portal are subject to adjustments 2) NOK 22,4 million has been used for the operation and administration of the community dividend. This represents the discrepancy between the granted amounts for various focal areas and the total amount From 2025, the management of the community dividend funds has been tightened to ensure that nearly all allocated funds are disbursed by the end of the year. However, many projects and purposes receive multi-year allocations. In these cases, funds may be allocated and approved but remain in the community dividend account awaiting future disbursements. As of 31 December 2025, the account balance was NOK 325 million. Allocation Future obligations amount to NOK 267 million and consist of cases that have been decided but not yet paid. In a smaller portion of these cases, applications have been received, and dialogue with the organisations regarding further cooperation is ongoing. These amounts are therefore recorded as provisions for 2026. Decisions regarding transfers of the community dividend are made by the General Meeting in March, with transfers to the gift fund occurring when a decision has been made. To ensure administration and ongoing operations of the community dividend during this period, a provision of NOK 5 million has been set aside for operating costs, and NOK 13 million for disbursement of funds for applications received in the first quarter. These provisions are based on historical operating costs and requested amounts. 2025 fund allocations Within the various focus areas, the Group has supported numerous projects using community dividend funds. Within regional community, funds were allocated to the improvement and construction of playgrounds of all sizes, as well as initiatives that provide inclusive experiences for all. Resources were earmarked for a Solidarity Fund to enable low-income families to participate in activities, in collaboration with the Sports Associations in Trøndelag and Møre og Romsdal. Equal opportunities were further promoted through a joint project with RBK, focusing on development programmes for children and youth, as well as initiatives supporting women and women’s health. In sports and outdoor recreation, funding was provided for grassroots sports and activities for children and youth, the development and upgrading of sports and outdoor facilities, and the implementation of events and measures that promote inclusion, public health, and volunteering. Significant resources were also allocated to the main project of the year, the Ski World Championships 2025.
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203SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL In arts and culture, support was given to small-scale projects such as seminars, markets, local choirs, and equipment for various cultural and artistic events, as well as larger initiatives including Studentersamfundet, Blues in Hell, Molde Jazz, Trondheim Calling, and Olavsfest. All allocations within the green initiatives area supported one of the UN Sustainable Development Goals. In 2025, support was provided for activities such as beach clean-ups and volunteer initiatives by local organisations, environmental certification (Miljøfyrtårn) for small and medium- sized enterprises, and other relevant initiatives aimed at promoting sustainability and skills development. In innovation and value creation, the objective has been to stimulate creativity and value creation in the region by providing risk capital for early- stage investments and establishing arenas for knowledge and competence sharing. These initiatives aim to help growth companies succeed and support entrepreneurs through partnerships with innovation clusters and networks. Through initiatives such as Såkorn1 Midt and the SpareBank 1 SMN Utvikling Foundation, the community dividend has contributed capital and investments to socially beneficial business and development projects, seed investments, and other charitable purposes involving ownership. Additionally, through an expanded collaboration with NTNU, including in the field of artificial intelligence, the community dividend aims to make the region more attractive to students, increase interest in innovation and entrepreneurship, and provide capital for student-driven projects and ideas, as well as initiatives from NTNU staff.
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204SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Transparency Act The Group’s report in keeping with the Transparency Act (LOV-2021-06-18-99) will be available on the Group’s webpages by 30 June 2026.
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205SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SOCIAL Report on remuneration and other emoluments to senior personnel The Group’s report in keeping with the Public Limited Liabilities Act, section 6-16b, on remuneration and other emoluments to senior personnel is available on the Group’s webpages. The report contains an account of sustainability-related benefits to senior personnel in line with ESRS 2 GOV-3.
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t Governance Business conduct 207 Approach to the topic 207 Assessment of IROs related to business conduct 207 Impacts on business conduct 208 Risks and opportunities related to business conduct 209 Anti-money laundring and terrorist financing 209 Anti-corruption 210 Data- and cybersecurity 211 Targets and KPIs 212 Action plans and measures 212 Policies 213 Note 1: Skills development 215
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207SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GOVERNANCE Business conduct Approach to the topic The Group’s vision statement – Together we make things happen – has long helped shape the Group’s culture and its values of Wholehearted, Responsible, Likeable and Capable. SpareBank 1 SMN’s corporate culture is defined as the sum of its employees’ conduct. This is why the bank emphasises clear communication to group employees of its expectations regarding conduct, working environment, culture, expertise and quality. In 2021, a group-wide culture-building project, aiming to create a shared, unifying organisational culture for all employees, was conducted. The drivers and aims of the project were: • to identify group-wide priorities while preserving the distinctive characteristics of the individual business ar eas, • a desire to realise synergies and promote collaboration to build trust acr oss the Group, • to understand what motivates employees and what makes them committed and proud, and • a desire to restore and strengthen a sense of belonging within Spar eBank 1 SMN after the Covid 19 pandemic. This formed the basis for the Group’s cultural objectives: • Create customer value • Shape the future • Be a team player The Group ensures that employ ees are thoroughly familiar with the cultural objectives and their implications. The objectives were relevant when they were launched, and remain relevant today. Recent organisational initiatives like the One SMN 2.0 project and the new finance centre structure are about shaping the future and creating an optimal customer experience. The Group is dependent on customer trust and confidence, and to maintain these it needs to uphold high quality standards in all areas, from advisory services to cybersecurity. The Group defines quality as meeting the expectations of external and internal stakeholders. There is a strong focus on training employees in the bank’s corporate culture. Measures include an annual ethics update which includes reflection tasks targeting ethical issues. The aim is to raise awareness of relevant topics an everyday work context. Employees are also coached in personal data protection, cybersecurity, anti-money laundering and anti- terrorist financing, as well as applicable legislation. The purpose of these measures is to ensure responsible operational execution. When evaluating individual employee remuneration, conduct is one of three considered criteria. The Group’s values, shared cultural objectives and quality expectations are key in the assessment of this criterion. Further information on employee remuneration can be found in the chapter on the Group employees. Assessment of IROs related to business conduct The current effects of the Group’s business conduct-related IROs stem directly from the Group’s business models and strategies, and are primarily determined by regulatory and operational framework conditions, including the risk of money laundering and corruption, data security and cybersecurity. Anticipated effects are also linked to developments in these threats and risks. To inspire trust and communicate reliability, the Group has to keep up with frequent societal changes, adjusting its operations and expectations accordingly. Societal changes may also necessitate minor or major adjustments to business models and strategies, both at group level and in specific business areas. The tables on the next page present the Group’s material IROs, their focus and their timeframes. Entity-specific reporting This chapter contains entity-specific reporting because material topics related to money laundering and terrorist financing are not regulated in the ESRS. The same applies to data security and cybersecurity. Due to a lack of guidance, the Group will report on its work in the areas of money laundering, terrorist financing, data security and cybersecurity – as well as related impacts and risks – in this chapter based on the entity-specific reporting requirements in ESRS 1 Appendix AR 1-5.
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208SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GOVERNANCE IMPACTS Value chain Time horizon Corruption and bribery Negative Own operations Downstream All Money laundering and terrorist fi nancing Negative Own operations Downstream All Poor data- and cyber-security Negative Upstream Own operations Medium-term Long-term Poor animal welfare Negative Downstream Medium-term Long-term RISKS Value chain Time horizon Poor processes for combating money laundering and terrorist fi nancing Own operations Downstream All Disloyal employees Own operations All Breaches of IT security Own operations All Breaches of legislation All All Unrealistic ambitions Own operations Long-term OPPORTUNITIES Value chain Time horizon Role of driver of green transition All Short-term Medium-term Impacts on business conduct As a provider of financial services, the Group has an inherent negative impact with regard to various types of financial crime, including money laundering, terrorist financing, corruption and bribery. All IROs are a combination of external expectations and stringent regulatory requirements to which the Group is, or becomes, subject. A more detailed description of the Group’s material impacts is provided below. Corruption and bribery Professional, law-abiding employees are key to the Group’s ability to perform its role. Every day, a considerable volume of transactions and other financial information is processed across the Group, and there is an inherent risk that financial systems could be manipulated and that breaches of financial trust could occur both in the bank’s own operations and among its customers. The Group has a potential negative impact related to corruption and bribery. Money laundering and terrorist financing The Group has a responsibility to promote stability and confidence in the financial system. Effective management of this impact is crucial to retaining society’s trust and safeguarding the stability and reliability of economic structures and systems. The Group faces an inherent potential negative impact linked to money laundering and terrorist financing. This impact relates to the nature of banking operations and the fact that the Group’s systems, processes and payment solutions could be exploited for criminal purposes. Impacts in this area could extend beyond Norway’s borders. The Group’s fraud-related impacts are described further in the section on Consumers and end users. Poor data security and cybersecurity Global geopolitical tensions and evolving conflicts equate to an ever more challenging digital threat landscape. The Group’s ongoing investment in cybersecurity and security culture, including staff knowledge, attitudes and conduct, is key to the Group’s ability to maintain operational stability and continuity. Outages and disruptions of digital infrastructure – whether long or short – are likely to impact stakeholders negatively and result in financial losses and/or loss of trust. The Group’s impacts related to personal data protection are described in the section on Consumers and end users. Poor animal welfare As one of Norway’s largest agricultural banks, the Group has a responsibility to ensure that its customers’ animal husbandry is compliant with applicable legislation, rules and
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209SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GOVERNANCE guidelines. As a provider of financing and advice to farm operators in its region, the Group could potentially have a negative impact on animal welfare. Irresponsible animal husbandry and poor animal welfare are closely interlinked with financial problems, and may entail breach of animals’ five freedoms or undermine compliance with slaughter, transport, import and export procedures. Risks and opportunities related to business conduct The Group’s material risks and opportunities related to business conduct are described below. None of these risks or opportunities had material financial impacts in 2025. There is no indication that risks and opportunities entail a significant risk of material changes in the balance sheet values of assets or liabilities in the financial accounts for the forthcoming reporting period. The anticipated financial effects of identified risks and opportunities are uncertain. Accordingly, the Group has omitted this information from its 2025 sustainability statement based on the phased-in disclosure requirement in ESRS 1 Appendix C. Poor processes for combating money laundering and terrorist financing Money laundering and terrorist financing are complex risks and impact several of the Group’s business areas. In the absence of effective controls and response processes, these risks could lead to the Group’s involuntary involvement in criminal acts. Criminals are using ever more complex methods, and the Group risks financial loss linked to loss of reputation and trust, or in the form of penalties imposed by regulatory authorities. The Group’s fraud-related risk is described in the section on Consumers and end users. Disloyal employees The Group is utterly dependent on having trustworthy employees, as banking operations carry an inherent risk of corruption and bribery. Many of the bank’s employees have access to personal data and financially sensitive information. If disloyal staff improperly abuse their access to acquire information or funds, the Group may suffer direct and/or indirect financial losses. Breaches of IT security The Group’s services and interfaces are increasingly being digitalised at the same time as the bank’s threat landscape is evolving. Disruptions or interruptions in the Group’s IT infrastructure may result in downtime in critical systems, digital robberies, bank runs, loss of confidential information and service delays or outages. Such incidents can have complex financial consequences both for the Group and its customers. While such risk is closely linked to the risk of failing to protect personal data and customer data, there are nuances which necessitate a differentiated risk management approach. Data-related risks are discussed in the section on Consumers and end users. Breaches of legislation The Group is subject to a constant flow of new and updated regulations in areas such as IT, capital adequacy, sustainability, risk management, money laundering and terrorist financing. Breaches may occur as a result of human error in combination with deficient procedures, processes or controls. The financial consequences will usually mirror the degree of seriousness involved. While some breaches will only trigger small fines, larger, more serious breaches will entail heavier losses for the bank. In addition, breaches can have more complex financial consequences due to their ripple effects. Unrealistic ambitions The Group is committed to adopting ambitious but realistic targets. This is also relevant to the broader regional transformation in which the Group is participating. However, there is a risk that set targets may not be achieved. Such a failure may have financial consequences including loss of reputation or penalties imposed by supervisory authorities under increasingly stringent regulatory requirements. Role as a promoter of the green transition The Group’s strategic ambition is to drive the green transition forward through its own operations, advisory services, products and services. In addition, the Group’s knowledge and influence will be leveraged to support the region and business community in the green transition. The community dividend will be allocated in support of transformation in the region. Incorporating this ambition into the bank’s culture will help motivate employees, reinforce the existing culture of innovation and accelerate internal transformation. Anti-money laundering and terrorist financing Preventing and combating financial crime is a key measure for alleviating the Group’s inherent impact linked to money laundering and terrorist financing. Financial crime, including money laundering and terrorist financing, is a steadily increasing problem for Norway’s welfare state, and a threat to trusting, healthy business conduct. As the largest financial services group in its region, and as a major operator at national level, the Group plays an important role in preventing the community and customers from becoming involved in or harmed by financial crime. The complexity of the work is increased by professionalisation among criminals and a constant flow of new methods and types of crime, including in digital form. The Norwegian Police’s threat assessment for 2025 describes how criminal actors and networks earn large sums of money from crime every year. To launder their profits, they use both legal financial infrastructures and other infrastructures suited to illegal cash flows. Profits are used to fund private consumption and new and more extensive criminal activity.
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210SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GOVERNANCE Criminals use professional facilitators to exploit legal structures to launder the proceeds of crime and reinvest these in legal businesses. The Group is seeing a rise in the number of complex cases involving misuse of legal structures and professional actors and facilitators. The Group’s companies have a statutory obligation to implement measures to combat money laundering and terrorist financing. Governing documents were updated, revised and considered by the Board of Directors in June 2025. These documents set out requirements and guidance for operational efforts to combat money laundering and terrorist financing. Customer due diligence measures targeting money laundering and terrorist financing are implemented both when establishing customer relationships and as part of ongoing customer monitoring. Internal controls are performed and status reports are submitted to the Board of Directors on a quarterly basis. At the start of 2025, specialist functions responsible for the bank’s money laundering and terrorist financing work were brought together in a new organisational unit – Economic Crime and Business Support. Further organisational changes were made during the year, including the consolidation of all operational departments into a single unit. This was a key step in strengthening the bank’s specialist functions. In addition, substantial resources were invested in the ‘New AML Platform’ project, which is developing a new anti-money laundering system. The project has taken longer than planned, and will continue into 2026. The purpose of the project is to ensure compliance with regulatory requirements and to create robust, comprehensive customer processes. The project encompasses customer establishment, risk classification, ongoing customer monitoring and transaction monitoring. The Group’s employees completed digital training focused on anti-money laundering and terrorist financing in 2025. The course topics encompassed money laundering and terrorist financing in general, as well as dedicated modules devoted to mules, trends and origin of funds. The modules were allocated to employees based on their roles, and the completion rate was 97 per cent. In addition, specialist training and immersion days were provided both internally and under the auspices of the SpareBank 1 Alliance. The Group’s employees also attended relevant external courses and conferences. In 2025, 15,196 matter files were opened, comprising 23,791 transactions flagged for further checks by the bank’s transaction monitoring system. Some 759 suspicious-transaction reports (‘MT reports’) were submitted to the financial intelligence unit of the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (Økokrim). The bank’s subsidiaries submitted a total of 123 MT reports in 2025. Anti-corruption The Group has a declared zero-tolerance policy with respect to all forms of corruption and bribery as defined in the United Nations Convention against Corruption. The objective is to prevent, detect and deal with incidents of corruption or bribery by means of guiding documents, procedures, processes and training measures for group employees, including hired-in consultants and temporary employees. All employees receive annual training on the Group’s zero tolerance policy on corruption and bribery, as well as the code of conduct. If actions in the form of corruption or bribery are detected, the matter is reported to the police for further investigation. The Group also conducts its own enquiries in advance of or after any police report. Such enquiries are carried out by a limited group of employees and/or external partners. The Group’s policy on internal malpractices and corruption is reviewed annually and is considered by the Board of Directors at least every third year. The Board discussed the policy in 2025. Risk-based internal controls have been established to prevent corruption and bribery. Particular emphasis is given to internal controls in procurements, granting of credit, the community dividend and gifts/hospitality expenses. Where non-conformances or censurable conditions contrary to the code of conduct are identified in connection with internal controls or otherwise, they must be reported through established reporting and whistleblowing channels. Quality non-conformances are reported to group management on a quarterly basis. The Group’s whistleblowing policy addresses employees’ whistleblowing-related rights and duties, how to file whistleblowing reports, how reports must be processed, and who is responsible for follow-up. The policy is discussed in greater detail under Policies below and in the chapter on Group employees. Whistleblowing reports can be submitted anonymously through an external channel. Training All authorised advisers in the retail and corporate banking operations completed ethics training through the financial industry’s authorisation scheme in 2025. Advisers must complete this annual update to be permitted to provide advisory services on behalf of SpareBank 1 SMN. 1,717 group employees were required to complete a mandatory review of the Group’s code of conduct in the autumn of 2025. 1,572 employees completed the course, corresponding to a completion rate of 92 per cent. A monitoring, reminder and reporting procedure has been introduced for employees who have not yet completed the review.
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211SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GOVERNANCE Data security and cybersecurity Data security and cybersecurity are closely linked to other security challenges in today’s digital society, including geopolitics, global and local value chains, and crisis management. The Group’s reputation, and the trust and confidence it enjoys in the market, are impacted by the Group’s digital defences and robustness in the face of cyberattacks by criminal actors. Customers see data security and cybersecurity as a basic prerequisite for their chosen banking solution, and any quality or compliance deficiencies could cost the bank both existing and new customers. Data security and cybersecurity are ongoing, very high priorities for the Group. They are central to the delivery of high-quality services, compliance with applicable laws and regulations, maintaining trust in and the credibility of the Group as a financial institution, and safeguarding customer security optimally. Threat landscape in 2025 Geopolitical instability has characterised the bank’s threat landscape for several years, and did so again in 2025, not least in the form of the ongoing wars in Ukraine and Gaza. Concern remains that warring parties in these conflicts could impact the Group’s services or shared financial infrastructure through targeted or random digital attacks. At present, a strained economic situation is placing increased pressure on both individuals and financial institutions. The prevailing conditions are also relevant to the data security and cybersecurity threat landscape, and the bank is therefore working to strengthen and maintain digital resilience. The Group and the SpareBank 1 Alliance experienced several denial-of-service attacks in 2025. The motivating factors behind such attacks are frequently political, and the attacks often take a different form than financially motivated attacks. The goal of the threat actors is to sabotage or create unrest and uncertainty about the stability and availability of banking services. Focus and priorities On 1 July 2025, the Digital Operational Resilience Act (DORA) came into force in Norway, and has had an impact on both the setting of security priorities and the Group’s required capacity in terms of digital security. DORA, which has been implemented in Norwegian law through the Act relating to Digital Operational Resilience in the Financial Sector, has replaced the ICT Regulations. Accordingly, DORA is now the leading authority on information security and digital resilience in the Norwegian financial sector. The Act defines and harmonises detailed requirements related to the financial industry’s management and assessment of ICT risks with the aim of strengthening the financial industry’s operational digital resilience to digital threats and incidents. The Group will be audited regularly by both internal and external auditors for compliance with DORA, in the same way as the Group was previously audited for compliance with the ICT Regulations. Security in digital value chains was a high priority in 2025. Digital value chains are complex, may cross national borders and include several levels of sub-contractors. Maintaining an overview of digital infrastructure and its components is challenging, as multiple systems have to function together and communicate despite different suppliers being used. Criminals will continue to try to exploit a lack of overview in supply chains, and it is therefore important to monitor security closely, including among the Group’s suppliers. Card and BankID information remains attractive to criminal actors, whose goal is to misuse it for their own gain. The Group therefore gives high priority to security architecture and new security solutions. The SpareBank 1 Alliance continued to invest in expertise and capacity-building in the area of cybersecurity in 2025 in response to stricter requirements concerning digital resilience and ICT risk. Security assessments and experience are shared in the expert group for security and preparedness, which consists of security specialists from different companies in the Alliance. The Group focuses on data security and cybersecurity at a technical, human and organisational level. In addition to technical security measures, work is done to promote a robust security culture through attitude-building, awareness-raising and training. The SpareBank 1 Alliance’s existing expertise and awareness programme for information security – Passopp – aims to fortify the security culture and is mandatory for group employees. Results are used actively in the planning and prioritisation of future skills- and attitude-building courses in the security field. In 2025, training measures focused on the national threat and risk landscape, how AI is impacting threats and security risk, insiders and personnel security, security during holidays and general security considerations when travelling and working in public spaces. In total, 94 per cent of the Group’s employees have completed all courses. At the organisational level, the Group has high capacity to maintain operational continuity and protect its services. IT security related to physical bank premises, coordination and cloud services is a particular priority. The IT and Security Department (ITS) supervises the Group’s IT security, and generally performs operational tasks in this area. Among other things, ITS administers access control to systems and data, physical server security, correct access levels for employees, software to protect systems and services against unauthorised access, and backups of locally stored data. The Group also works closely with SpareBank 1 Utvikling as its executing partner in several areas. Data security and cybersecurity constitute one area in which operational tasks, including continuous monitoring of bank systems and 24/7 incident management, are handled by SpareBank 1 Utvikling. SpareBank 1 Utvikling and its sub-contractor Sopra Steria maintain a shared client and server platform for the SpareBank 1 Alliance. Among other things, this ensures that newer versions of operating systems are used and that operating systems are updated with general updates at least once a month, and immediately with any security updates.
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212SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GOVERNANCE Targets and KPIs During the year, the Group developed new KPIs to manage the Group’s material IROs in the area of corporate governance. These KPIs are presented in the table below and cover the areas of data security and cybersecurity, anti-corruption, anti-money laundering and anti-terrorist financing. The risk of unrealistic ambitions does not have a dedicated objective or KPI, but is reflected in other objectives and KPIs. This also applies to the risk of regulatory breaches and the possibilities offered by the Group’s corporate culture. Key performance indicator Base year Base value Unit of measurement Division Scope Target Target- year Result 2025 Result 2024 Incidents that have resulted in information being compromised, leading to unacceptable consequences in line with the BIA 2024 0 Units Absolute Technology and development Own ops Upstream 0 Every year 0 0 Incidents that result in downtime of operational systems, leading to unacceptable consequences with the BIA 2024 0 Units Absolute Technology and development Own ops Upstream 0 Every year 0 0 No KPIs have yet been developed for anti-corruption, anti-money laundering or anti-terrorist financing. These KPIs will be finalised in 2026. Definitions of the KPIs are can be found Key figures in the chapter This is SpareBank 1 SMN. Action plans and measures Action plans have been prepared to ensure that the Group’s objectives linked to the above KPIs are met. Management of the Group’s IROs has already been implemented by several of the business areas responsible for the IROs. Several steps were taken in 2025, as summarised in the table below and as described in detail in the relevant chapters above. Key performance indicator Key actions taken in the reporting year Achieved results Future planned actions Time horizon Expected outcomes Incidents that have resulted in information being compromised, leading to unacceptable consequences in line with the BIA • Operationalization of DORA • Hired subject-matter responsible Digital Resilience • Completed implementation of DORA • Subject-matter responsible hired in 2Q 2025 • Continuous work internally and with suppliers to reduce the risk of notifiable deviations occurring Short-term Continued reduction in the number of notifiable deviations compared with previous years. Incidents that result in downtime of operational systems, leading to unacceptable consequences with the BIA • Operationalization of DORA • Introduction of the system owner role The system owner role has been defined and implemented for several of the group’s critical IT systems. • Training to recognise and report deviations (with the aim of ensuring that more deviations are identified and reported) • Training to reduce the number of human errors that lead to deviations Short-term • More deviations are identified and reported • Reduction in the number of serious deviations
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213SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GOVERNANCE Policies The Group has adopted various policies which address the Group’s material IROs. All policies are available to the employees through internal systems, and individual roles and responsibilities are clearly defined . Where policies are relevant to external stakeholders, they are published on the Group’s website. The Group’s policies are reviewed at least once a year and updated if necessary. Policy on measures to combat money laundering and terrorist financing The purpose of anti-money laundering work is to prevent and detect money laundering and terrorist financing pursuant to applicable rules and regulations. The Group implements measures to ensure its ongoing compliance with relevant legislative requirements. The policy, which applies to all obliged entities within the Group, operationalises various overarching principles governing risk assessments, procedures, customer measures, training programmes, reporting, exchange of information and personal data. The Group is required to update its anti-money laundering procedures regularly, and does so when indicated by new risk assessments. Relevant procedures and policies are reviewed at least once a year. Policy on internal malpractices and corruption This policy sets out the overarching requirements and guidance adopted by group management with regard to internal controls and communication procedures in order to prevent, detect and manage the risk of internal malpractices and corruption. The policy is designed to ensure predictability and equal treatment in cases potentially involving internal malpractice and/or corruption. The policy applies to all employees and consultants who perform tasks on behalf of the Group. Breaches of the policy will result in penalties for the individual(s) concerned. Reports must be filed via the Group’s internal whistleblowing channel, as discussed in the chapter on Group employees. The Group’s guiding principles related to internal malpractices and corruption are as follows: • The Group practises zero tolerance for all forms of internal malpractice and corruption. • The Group practises zero tolerance for all forms of self-dealing. • The Group and group employees shall not use internal malpractices or corruption to promote the Gr oup’s or their own interests. • The Group shall proactively promote ethical standards and measur es to prevent internal malpractices and corruption • The Group and group employees shall actively help to pr event internal malpractices and corruption. • The Group shall not make political contributions in the form of monetary suppor t to political parties or causes. • The Group and group employees shall act with particular diligence and car e in dealings with authorities and public officials, including in connection with public procurement processes and applications for approvals, permits and licences. • An absolute prohibition applies to the falsification of financial statements, other reports in the public domain, r eports submitted to public authorities and all other documentation. Skills development and training measures are integrated into the Group’s annual ethics update, the onboarding of new employees and other awareness-raising activities. A fuller descriptions is provided in Note 1: Skills development. While the policy on internal malpractices and corruption has not been drawn up with the United Nations Convention against Corruption in mind, it does comply with various Convention requirements. Any future updates of the policy will take the Convention’s provisions into consideration. The Group considers that, as at the reporting date, the policy is adequate to meet internal and external stakeholder requirements and expectations related to internal malpractices and corruption. Policy on information security and digital resilience The objectives of the policy are to ensure a systematic, risk-based approach to information security requirements and procedures, continuous improvement and strengthening of the Group’s digital resilience, fewer vulnerabilities and reduced risk of information security incidents. The policy is designed to ensure that information security- related goals and principles support the Group’s strategic objectives and promote digitalisation and the use of data-driven insights. The policy sets out general security requirements such as security architecture, IT systems and IT infrastructure, information classification, security culture, access control, and the development and use of AI. There are also dedicated principles for the deployment of AI within the Group. The policy is updated regularly in response to changes in the threat landscape, regulatory changes and new technological advances, including new AI solutions. The Group has a dedicated policy on the outsourcing of IT services. Decisions to outsource critical or important services require board approval, and are notified to Finanstilsynet (the Norwegian Financial Supervisory Authority). A more detailed description is provided in the section on Consumers and end users. Code of conduct The Group’s code of conduct addresses attitudes and values, and is designed to promote awareness of and compliance with the ethical standards applicable to employees
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214SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GOVERNANCE and employee representatives in their daily decision-making. All employees (including consultants and temporary employees) who represent the Group are subject to the policy rules and are expected to familiarise themselves with them and to act in accordance with them. The bank has adopted four governing principles – confidentiality, financial independence, loyalty and personal integrity – and 10 ethical rules of conduct, as follows: • We observe the duty of confidentiality • We maintain professional relationships with customer s, suppliers, competitors and others • We avoid conduct which could harm the Group’s reputation • We maintain our impartiality and are sensitive to conflicts of inter est • We keep our personal finances in order • We actively promote a positive working envir onment characterised by mutual trust and respect • We communicate carefully and intentionally • We report personal commercial or boar d activities which require group approval • We comply with the Group’s whistleblowing procedures • We practise zero tolerance for corruption Employees who disco ver non-conformances or breaches of the Group’s code of conduct have a right, and in some cases a duty, to report these. Such reports must be filed using the same procedures and channels as those available for reporting other non- conformances and breaches. Whistleblowing policy The purpose of this policy is to ensure that the right of workers to report censurable conditions is respected. Examples of censurable conditions include: • danger to life or health • danger to the climate or environment • corruption or other financial criminality • abuse of authority • unsatisfactory working environment • harassment, discrimination • breach of personal data security • material breach of the bank’s management and control procedures • deficient compliance with the Group’s policies and procedures Statements about circumstances relating solely to an emplo yee’s own working conditions are not considered whistleblowing unless the circumstances are covered by the list above. The whistleblowing policy describes the right of employees – and, in relevant circumstances, their duty – to file internal and external whistleblowing reports, with whom reports must be filed, what form reports must take and how reports are processed, including confidentiality requirements and protection against retaliation. Policy on sustainable agriculture The policy is designed to ensure that the Group’s financing of the agriculture sector – including farming, forestry, animal husbandry and refinement of raw materials – helps ensure that farm properties are passed on in a better condition than when they were taken over. Animal husbandry is the primary occupation of many farm operators financed by the Group, and the policy seeks to ensure that the Group promotes improved animal welfare by supporting increased investment by farm operators in new buildings and conversion projects which meet and exceed statutory requirements. The policy contains guidance on what the bank will finance, where animal husbandry must be practised pursuant to applicable legislation, and the five freedoms of animals. It also requires the Group’s agriculture advisers, when giving advice and granting credit, to consider the potential risk of maltreatment and serious neglect in supervision and/or care, as well as financial challenges as a driver of poor animal welfare.
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215SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | GOVERNANCE Note 1: Skills development The tables below deal with skills development in the areas of business conduct and economic crime, including corruption, bribery, anti-money laundering and terrorist financing. The figures show the number of hours devoted to skills development in specific areas relevant to the risk of money laundering, terrorist financing and corruption. These hours are a part of the overall skills development programme described in Note 3: Skills development, under Group employees. Update on the Group’s code of conduct Each year, all group employees complete a mandatory ethics update as part of promoting ethical awareness and professional integrity and ensuring responsible performance of the Group’s business activities. The 2025 ethics update focused on a review of the Group’s code of conduct. FCBS1) Functions-at- risk2) Group management Other Total Completed training 39 767 3 105 914 Offered training 42 828 3 114 987 Completion rate 91% 92% 90% 93% 93% 1) Financial crime and business support 2) Employees with access to customer systems, control systems, or who, in the course of their work, have a legitimate need for such systems. Anti-money laundering and anti-terrorist financing are part of their responsibilities. The definition applies only for external reporting purposes. The Group’s governing bodies are considered to have strong expertise related to ethics and business conduct. All members of group management have completed the 2025 ethics update. The members of the Board of Directors have not completed the 2025 ethics update, but are considered to have adequate expertise from their current or previous management roles in various sizable companies and industries with high ethical standards. The Board of Directors is highly familiar with the Group’s ethical framework. Ethical issues are discussed and considered by group management, the risk committee and the Board of Directors as needed. Further information about governing bodies can be found in the General information section. Update on anti-money laundering and terrorist financing Employees who have direct access to customer systems and/or control systems or who otherwise require such access in the course of their work are exposed to elevated corruption risk and money laundering risk. Such employees therefore complete advanced training focused on anti-money laundering and terrorist financing. FCBS1) Functions-at- risk2) Group management Other Total Completed training 413 1,249 6 158 1,825 Offered training 448 1,361 15 165 1,989 Completion rate 94% 96% 73% 93% 95% 1) Financial crime and business support 2) Employees with access to customer systems, control systems, or who, in the course of their work, have a legitimate need for such systems. Anti-money laundering and anti-terrorist financing are part of their responsibilities. The definition applies only for external reporting purposes. All members of the Board of Directors completed a general update on anti-money laundering and terrorist financing during the reporting period.
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Financial results Financial results 217 Macroeconomic conditions 217 Accounts 2025 217 Results from business areas 222 Balance sheet, funding and liquidity 224 Outlook 226
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217SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS Financial results Macroeconomic conditions 2025 was characterised by uncertainty, particularly in relation to global trade barriers. The second quarter of the year in particular was marked by volatility in both the equity and bond markets, although these recovered somewhat towards the end of the first half of the year. Future macroeconomic developments are unclear due to ongoing geopolitical unrest, and market uncertainty is being fed by protectionist measures that could hamper international trade and economic growth. Norges Bank cut its base rate twice in 2025, to 4.00 per cent at the end of the year. In December, Norges Bank stated that restrictive monetary policy is still necessary, but the forecast for 2026 indicates one or two reductions in the base rate over the course of the year. Value creation in the mainland economy increased by 1.8 per cent compared to 2024. Inflation in Norway as measured by the consumer price index (CPI) amounted to 3.2 per cent in 2025, up 0.1 percentage points from 2024. Annual growth in the consumer price index adjusted for changes in indirect taxes and excluding energy products (CPI-ATE) fell from 3.7 per cent in 2024 to 3.1 per cent in 2025. Twelve-month growth in credit to households (C2) rose from 3.7 per cent in 2024 to 4.8 per cent in 2025. Norges Bank expects credit growth of 4.5 per cent in 2026. Regional: Trøndelag and Møre og Romsdal Unemployment rose slightly in 2025, starting from very low levels. The proportion of the labour force that was completely unemployed was 1.9 per cent in Trøndelag and 1.8 per cent in Møre og Romsdal at year-end. Nationally, the proportion was 2.1 per cent in December. SpareBank 1 SMN’s industry indicator for the second half of 2025 shows that conditions remain challenging in the construction sector. Production has declined by four percent over the past year, and low levels of housing starts and new home sales continue to characterize the market. Although parts of the construction sector are better positioned and expect high activity going forward, the industry is still considered exposed due to difficult conditions in the building market. The outlook has therefore been revised down to neutral. In the agricultural sector, market balance is sound, and increased investment appetite and positive development are expected. A global focus on food security and sustainable production supports favorable market prospects. Profitability in agriculture has improved, and companies are increasingly optimistic about the future. Overall, businesses report less optimism than in previous business cycle surveys. However, interest rate cuts and increased consumption contribute to a neutral outlook for the business sector in Central Norway for 2026. Accounts 2025 (Consolidated figures. Figures in brackets refer to the corresponding period in 2024 unless otherwise stated.) • Pre-tax profit: NOK 5,449 million (NOK 5,647 million). • Net profit: NOK 4,367 million (NOK 4,591 million). • Return on equity: 14.8 per cent (16.6 per cent). • Net of the NOK 452 million gain on the merger between Fremtind and Eika F orsikring, the net profit would have been NOK 4,139 million in 2024, and the re-turn on equity would have been 15.0 per cent. • Lending growth is up 3.8 per cent (5.5 per cent) and deposit growth is up 3. 7 per cent (6.0 per cent) over the past 12 months. • Lending to the bank’s retail customers has increased by 4. 7 per cent (4.8 per cent) over the past 12 months. • Lending to corporate clients has increased by 2.3 per cent (9.2 per cent) over the past 12 months. • Lending to wage earners accounted for 68 per cent (68 per cent) of loans. • Deposits from retail customers have incr eased by 8.4 per cent (7.5 per cent) over the past 12 months. • Deposits from corporate clients are up 1.8 per cent (10.5 per cent) over the past 12 months. • Net profit from ownership interests: NOK 1,017 million (NOK 1,254 million). • Net profit from financial instruments (including dividends): NOK 106 million (NOK 103 million). • Losses on loans and guarantees totalled NOK 140 million (NOK 176 million), corresponding to 0.06 per cent (0.07 per cent) of gross lending. • Book value per EC: NOK 138.30 (NOK 128.09).
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218SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS 2025 results SpareBank 1 SMN achieved a net profit of NOK 4,367 million (NOK 4,591 million) and an equity return of 14.8 per cent (16.6 per cent) in 2025. Adjusted for the gain on the merger between Fremtind and Eika Forsikring, the equity return would have been 15.0 per cent in 2024. Profit per equity certificate was NOK 19.08 (NOK 20.10). Net interest income was NOK 5,343 million (NOK 5,373 million). This represents a reduction of 0.6 per cent compared to 2024, which included an extra inter-est day. The base rate was 4.50 per cent throughout 2024. Norges Bank cut the base rate to 4.25 per cent in June 2025 and further to 4.00 per cent in Sep-tember 2025. The average base rate was 4.29 per cent in 2025. Average three-month NIBOR fell from 4.72 per cent in 2024 to 4.39 per cent in 2025. Net commission and other income amounted to NOK 2,602 million (NOK 2,392 million). Income from accounting services and real estate brokerage increased by NOK 40 million and NOK 61 million, respectively, from 2024. Income from credit cards fell by NOK 27 million, primarily driven by changes to the commis-sion model for credit cards and unsecured debt which mean that a larger proportion of profits is retained by Kredittbanken. Commission income excluding captive mortgage companies increased by NOK 123 million, corresponding to 5.8 per cent. Increased volumes sold to SpareBank 1 Boligkreditt, higher margins on associated loans and changes to the commission model boosted commission income from captive mortgage companies by NOK 87 million compared to 2024. Net profit from ownership interests was NOK 1,017 million (NOK 1,254 million) in 2025. The 2024 profit included a non-recurring gain of NOK 452 million on the merger between the insurance companies Fremtind and Eika. The underlying increase in profit from associated companies is mainly attributable to a stronger profit contribution from SpareBank 1 Gruppen. Net profit from financial instruments, including dividends, totalled NOK 106 million (NOK 103 mil-lion). This includes NOK 42 million in recognised income stemming from the SB1 Markets transaction. The Group’s expenses amounted to NOK 3,479 million (NOK 3,300 million). Of the NOK 179 million increase in expenses, NOK 116 million is attributable to the bank. Adjusted for non- recurring costs linked to Tieto in Q2 2025, the expenses of the bank and the Group grew by 3.3 per cent and 4.0 per cent, respec-tively, in 2025. Losses on loans and guarantees remained at a moderate level in 2025, at NOK 140 million (NOK 176 million). There was a net reversal of NOK 5 million on loans to the bank’s retail customers in 2025 (net reversal of NOK 10 million in 2024). As regards the bank’s corporate clients and SpareBank 1 Finans Midt-Norge, losses on loans and guarantees amounted to NOK 109 million (NOK 62 million) and NOK 36 million (NOK 20 million), respectively, in 2025. Lending growth in the Group was 3.8 per cent (5.5 per cent) over the past 12 months. Loans to retail customers were up 4.7 per cent, while loans to corporate clients rose by 2.3 per cent. Deposits increased by 3.7 per cent in 2025 (6.0 per cent in 2024). Retail deposits grew by 8.4 per cent, while deposits from cor-porate clients increased by 1.8 per cent. Proposed profit distribution It is the Group’s profit net of interest on hybrid capital and the profit share of non- controlling interests which forms the basis for distributing the annual profit, and the distribution is made by the parent bank. The profit is split between the ownerless capital and the equity certificate capital based on their relative shares of equity. The profit per equity certificate to-talled NOK 19.08. Based on the bank’s robust capitalisation, regulatory changes and the prospect of profitable operation, the Board of Directors is proposing a dividend of NOK 13.50 per equity certificate. This equates to a payout ratio of 69 per cent of the Group’s profit excluding interest on hybrid capital. The bank’s long-term dividend policy of distributing around 50 per cent of available profits remains unchanged. The Board of Directors is also proposing that NOK 968 million be set aside as a community dividend. Of this amount, NOK 350 million will be transferred to donations for charitable purposes and NOK 618 million to Sparebankstiftelsen SMN. NOK 464 million and NOK 230 million are to be transferred to the divi-dend equalisation fund and ownerless capital, respectively. 2025 2024 Profit for the year, Group 4,367 4,591 Interest hybrid capital (after tax) -161 -137 Profit for the year excl inter est hybrid capital, group 4,205 4,454 Profit, subsidiaries -381 -387 Dividend, subsidiaries 204 117 Profit, associated companies -1,060 -1,254 Dividend, associated companies 583 201 Group eliminations 13 14 Profit for the year excl inter est hybrid capital, Parent bank 3,565 3,146 Distribution of profit 2025 2025 Profit for the year excl interest hybrid capital, Parent bank 3,565 3,146 Transferred to/from re valuation reserve 44 -139 Profit for distribution 3,609 3,007 Dividends 1,947 1,803 Equalisation fund 464 206 Saving Bank’s fund 230 102 Gifts 968 896 Total distributed 3,609 3,007
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219SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS The parent bank’s available profit include dividends received from subsidiaries, associated companies and joint ventures, and has been adjusted for interest expenses on hybrid capital. Subsidiaries are fully consolidated in the group accounts, while the share of profit/loss from associated companies and joint ventures is consolidated using the equity method. Dividends from subsidiaries and associated companies are therefore not included in the consolidated results. The annual profit available for distribution reflects changes of NOK 44 million in the unrealised gains reserve. The total distributable amount is therefore NOK 3,609 million. After distribution of the profit for 2025, the ratio of equity certificate capital to total equity remains 66.8 per cent. Net interest income Net interest income was NOK 5,343 million (NOK 5,373 million). Following a significant increase in the base rate from the autumn of 2021 to December 2023, the base rate was kept unchanged at 4.50 per cent throughout 2024. Norges Bank cut the base rate to 4.25 per cent in June 2025 and further to 4.00 per cent in September 2025. NIBOR fell over the course of the year, from an average of 4.72 per cent in 2024 to 4.39 per cent in 2025. At the end of the year, three-month NIBOR stood at 4.07 per cent. Average margins on loans in the retail market increased from 2024 to 2025. This is mainly attributable to the notification period for interest rate changes in a falling interest rate market and the fact that the money market premium was low throughout the year. Deposit margins in the retail market had an oppo-site effect, with a decline resulting from the notification period for interest rate changes and low money market premiums. As regards loans to the bank’s corporate clients, the lending margin fell by 0.1 percentage points compared to 2024. Deposit margins for the bank’s corporate clients were largely unchanged. Lending growth for both retail customers and corporate clients contributed to increased net interest income. In addition, high interest rates had a positive impact on the return on the bank’s equity. Commission and other operating income SpareBank 1 SMN’s strategy of leveraging the breadth of the Group and improving coordination across the various business areas remains unchanged. The strategy is being operationalised, not least, through co-location in finance centres. High product coverage among customers is contributing to a capi-tal-efficient and diversified income stream and high customer satisfaction. Commission and other income (NOKm) 2025 2024 Endring Payment transmission income 336 354 -18 Credit cards 44 71 -27 Commissions savings and asset mgmt 56 49 7 Commissions insurance 310 263 47 Guarantee commissions 70 65 5 Estate agency 566 505 61 Accountancy services 772 733 40 Other commissions 74 67 8 Commissions ex. Bolig/Næringskreditt 2,228 2,106 122 Commissions Boligkreditt (cov. bonds) 360 272 88 Commissions Næringskreditt (cov. bonds) 14 14 - Total commission income 2,602 2,392 210 Commission income excluding captive mortgage companies was up NOK 122 million year-on-year, with revenue from real estate brokerage and accounting services making particularly strong contributions. Insurance revenue developed very positively. Overall, commission income excluding captive mortgage companies increased by 5.8 per cent compared to 2024. Following the establishment of Kredittbanken, the commission model for credit cards and unsecured debt has been amended to allow a greater share of profits to be retained by Kredittbanken. As regards loans sold to SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt, the bank receives commission equivalent to the lending rate less financing and operating costs in the companies. The increase of NOK 88 million is attributable to the previously mentioned notification period for interest rate changes in 2025, which increased lending margins, and to SpareBank 1 Boligkreditt’s revised commission model.
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220SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS Return on financial investments The return on financial instruments totalled NOK 80 million (NOK 70 million) in 2025. Capital gains on shares totalling NOK 108 million (NOK 90 million) are attributable to the Swedbank transaction linked to the establishment of SB1 Markets, the sale of shares in Eksportfinans and unrealised changes in value in other parts of the portfolio. Financial instruments, including bonds and derivatives, generated capital losses of NOK 47 million (capital losses of NOK 120 million), while foreign exchange transactions produced revenues of NOK 19 million (NOK 100 million). Return on financial instruments (NOKm) 2025 2024 Endring Net gain/(loss) on stocks 108 90 18 Net gain/(loss) on financial instruments -47 -120 73 Net gain/(loss) on forex 19 100 -81 Net return on financial instruments 80 70 10 Associated companies SpareBank 1 SMN has a broad and well-diversified revenue platform. The Group offers its customers a broad range of products from various companies. These companies are owned either directly or indirectly via SpareBank 1 Gruppen. This structure secures both commission income and a share of the profits of the various companies. The total share of profit from the product companies and other associated companies amounted to NOK 1,017 million (NOK 1,254 million) in 2025. Income from investment in associated companies (NOKm, SMN’s share in parentheses) 2025 2024 Endring SpareBank 1 Gruppen (19,5%) 446 226 219 Gain insurance merger Fremtind/Eika - 452 -452 SpareBank 1 Boligkreditt (22,8%) 105 129 -24 SpareBank 1 Næringskreditt (14,8%) 9 14 -6 BN Bank (35,0%) 291 302 -11 SB1 Markets (31,9%) 74 89 -16 Kredittbanken ASA (15,1%) 7 -10 17 SpareBank 1 Betaling (20,5%) -6 -19 13 SpareBank 1 Forvaltning (21,7%) 58 54 4 Other companies 35 15 19 Total associated companies 1,017 1,254 -237 The SpareBank 1 Alliance The SpareBank 1 Alliance is Norway’s second-largest financial group. The alliance is a banking and product collaboration which aims to secure member banks of the SpareBank 1 Alliance economies of scale and access to competitive financial services and products. The operation of the Alliance is based on ownership of SpareBank 1 Gruppen, which owns and manages product companies, as well as ownership of SpareBank 1 Utvikling, which develops joint services. SpareBank 1 Gruppen achieved a profit of NOK 4,307 million (NOK 2,202 million) in 2025, with SpareBank 1 SMN’s share of the majority’s profit amounting to NOK 446 million (NOK 225 million). The merger between Fremtind Forsikring and Eika Forsikring generated an accounting gain of NOK 452 million in the third quarter of 2024. The total profit contribution from SpareBank 1 Gruppen in 2024 was thus NOK 678 million. The most important companies in SpareBank 1 Gruppen (SpareBank 1 Gruppen’s ownership interest): • Fremtind Forsikring (51.4 per cent) is a general and personal insurance company headquartered in Oslo. The company reported a post-tax profit of NOK 3,662 million (NOK 2,148 million) in 2025. • SpareBank 1 Forsikring (100 per cent) is a pension company headquar tered in Oslo. The company mainly provides defined-contribution occupational pensions, group disability cover and private pension plans. SpareBank 1 Forsikring achieved a profit of NOK 418 million (NOK 355 million) in 2025. • SpareBank 1 Factoring (100 per cent) offer s administrative and financial factoring. The company is headquartered in Ålesund. The 2025 annual profit totalled NOK 77 million (NOK 87 million). • Kredinor (69.0 per cent) is Norway’s lar gest debt collection company, and is a subsidiary of SpareBank 1 Gruppen. The company reported a profit of NOK 442 million (NOK -205 mil-lion) in 2025. SpareBank 1 Forvaltning delivers products and services to a broad range of clients in the asset management and securities services segments. The company’s profit in 2025 was NOK 267 million (NOK 248 million). SpareBank 1 Boligkreditt is a captive mortgage company which issues covered bonds secured by mortgages to achieve stable financing with low financing costs. The compa- ny’s annual profit in 2025 was NOK 549 million (NOK 614 million). SpareBank 1 Næringskreditt is a captive mortgage company which issues covered bonds secured by mortgages over commercial property to achieve stable financing with low fi- nancing costs. The company’s 2025 annual profit was NOK 69 million (NOK 98 million). Kredittbanken provides unsecured financing to the retail market. The company’s profit was NOK 44 million (NOK -54 million) in 2025.
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221SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS BN Bank offers mortgages and loans for commercial property and has its main market in Eastern Norway. The company’s profit for 2025 totalled NOK 872 mil-lion (NOK 903 million). SB1 Markets is a Nordic investment firm. The company provides services related to share and credit analysis, share and bond trading, and corporate finance. The company’s profit in 2025 amounted to NOK 203 million (NOK 224 million). SpareBank 1 Betaling holds and administers the SpareBank 1 banks’ shareholdings in Vipps AS and Stø AS. The company’s profit was NOK 14 million (NOK -148 million) in 2025. Operating expenses The Group targets a cost-income ratio below 40 per cent for the bank and below 85 per cent for the subsidiaries EiendomsMegler 1 Midt-Norge and Spare-Bank 1 Regnskapshuset. The cost-income ratio is defined as operating expenses as a proportion of net interest income + commission + other income. The bank’s cost-income ratio was 36.0 per cent in 2025 (34.5 per cent). The corresponding figures for EiendomsMegler 1 and Regnskapshuset were 86.6 per cent (86.2 per cent) and 87.5 per cent (90.3 per cent), respectively. Operating expenses (NOKm) 2025 2024 Endring Personnel expenses 2,089 1,981 108 IT costs 478 410 68 Marketing 89 104 -15 Ordinary depreciation 187 183 4 Operating expenses, real properties 52 48 3 Purchased services 293 298 -5 Other operating expense 291 275 16 Total operating expenses 3,479 3,300 179 The Group’s costs rose by NOK 179 million year-on-year, equating to an increase of 5.4 per cent. NOK 63 million of the Group’s cost increase is attributable to subsidiaries, with EiendomsMegler 1 Midt-Norge accounting for NOK 51 million of this amount. The key factors were a strong year for real estate brokerage and the acquisition of Norion Næringsmegling. The bank’s expenses increased by 5.5 per cent from 2024 to 2025. Adjusted for an additional payment to TietoEvry totalling NOK 47 million, the bank’s cost growth amounted to NOK 69 million, or 3.3 per cent. Wage inflation, additional employees and discounted equity certificates for group management in-creased the bank’s personnel costs by NOK 60 million compared to 2024. In 2026, only half of employees who leave will be replaced, which will help to dampen cost growth. Losses on loans and guarantees The Group’s losses on loans and guarantees totalled NOK 140 million (NOK 176 million) in 2025, comprising NOK 104 million in losses on the bank’s loans and guarantees and NOK 36 million relating to SpareBank 1 Finans Midt-Norge. The annual loss breaks down into net reversals totalling NOK 60 million (NOK 7 million) in Stages 1 and 2, and NOK 200 million (NOK 169 million) in losses in Stage 3. Losses over the course of the year equated to 0.06 per cent of total loans (0.07 per cent). Losses (NOKm) 2025 2024 Endring RM, parent bank -5 36 -40 CM, parent bank 109 120 -11 SpareBank 1 Finans Midt-Norge 36 20 16 Total impairment losses 140 176 -35 Total impairment losses on loans and guarantees as at 31 December 2025 amounted to NOK 982 million (NOK 981 million), corresponding to 0.38 per cent (0.39 per cent) of gross lending. The credit quality of the bank’s loan portfolio is good. The portfolio is divided into NOK 172.5 billion (NOK 167.4 billion) in Stages 1 and 2 and NOK 2.3 billion (NOK 2.2 billion) in Stage 3. Stage 3 accounts for 0.88 per cent (0.89 per cent) of gross lending, including loans sold to captive mortgage companies.
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222SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS Results from business areas Retail market The bank’s retail customers are served by around 400 employees spread across 45 branches, who advise the group’s customers on financing, savings and investment, insurance and everyday banking services. The Retail Banking business’s loan portfolio totals NOK 169 billion, while the deposit portfolio totals NOK 67 billion. The Group has a 31 per cent market share in the residential mortgages segment in its core market areas of Trøndelag and Møre og Romsdal, while its share of the national market is just over 5 per cent. The Retail Banking business prioritises balanced growth, as reflected in developments in 2025, with 4.7 per cent lending growth and 8.4 per cent deposit growth. Focusing on deposits in advisory services fortifies the bank’s earnings and increases customers’ financial security in the form of increased buffer capital. Profit and loss account (NOKm) 2025 2024 Net interest 2,288 2,242 Comission income and other income 917 796 Total income 3,205 3,039 Total operating expenses 1,383 1,278 Ordinary operating profit 1,822 1,761 Loss on loans, guarantees etc. -5 18 Result before tax including held for sale 1,827 1,743 Balance Loans and advances to customers 169,199 161,582 Adv.of this sold to SB1 Boligkreditt and SB1 Næringskreditt -72,735 -67,431 Deposits to customers 72,228 66,630 EiendomsMegler 1 Midt-Norge is a subsidiary of SpareBank 1 SMN. SpareBank 1 Nordmøre has a minority ownership interest. EiendomsMegler 1 Midt-Norge owns Norion Næringsmegling and Brauten Eiendom. The company is part of the EiendomsMegler 1 Alliance, Norway’s largest provider of real estate brokerage services. EiendomsMegler 1 Midt-Norge has approximately 260 employees spread across around 30 offices throughout Trøndelag and Møre og Romsdal. The compa-nies assist customers with purchases, sales, consulting and project management in the areas of secondhand housing, commercial property, newbuilds, rentals and agricultural brokerage. Brauten Eiendom has specialist expertise in the area of real estate structuring. The company completes around 7,000 transactions annually in its core market area, representing a market share of just under 40 per cent in Trøndelag and Møre og Romsdal. The majority of transactions are in the secondhand housing market. The market region around Trondheim accounts for just over 40 per cent of the total regional market. Newbuilds and commercial brokerage account for around 15 per cent of total revenue. The company is the largest stake-holder in the EiendomsMegler 1 Alliance. EiendomsMegler 1 Midt-Norge delivered revenues of NOK 569 million and an annual profit of NOK 76 million in 2025. EiendomsMegler 1 Midt-Norge (92,4%) 2025 2024 Total revenues 569 512 Total operating expenses 493 442 Pre-tax profit (NOKm) 76 71 Operating margin 13% 14%
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223SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS Corporate market Corporate banking is the Group’s second-largest business area, with approximately 190 employees distributed between the head office and district offices in the Group’s oper- ating regions. The Corporate Banking business delivers deposit, financing, payment, insurance and pension services and products to a broad range of clients in the public, corporate and agricultural sectors. The credit quality of the loan portfolio is good. The bankruptcy rate in the region fell slightly year-on-year, and losses on loans and guarantees were moder-ate in 2025. Increased investment in Trondheim and greater coordination with SpareBank 1 Regnskapshuset SMN will help the Corporate Banking business win market share in Central Norway. The Oslo operation is developing as planned and has already contributed to lending growth in selected sectors where SpareBank 1 SMN has expertise and experience. Profit and loss account (NOKm) 2025 2024 Net interest 2,643 2,524 Comission income and other income 411 353 Total income 3,053 2,877 Total operating expenses 742 700 Ordinary operating profit 2,312 2,177 Loss on loans, guarantees etc. 109 138 Result before tax including held for sale 2,203 2,039 Balance Loans and advances to customers 75,584 73,915 Adv.of this sold to SB1 Boligkreditt and SB1 Næringskreditt -1,801 -1,817 Deposits to customers 72,893 71,628 SpareBank 1 Regnskapshuset SMN has approximately 600 employees spread across 45 locations in Trøndelag, Møre og Romsdal, Innlandet and Oslo. The company is a full-service financial and technology provider and is one of the five largest accounting industry firms in Norway. In addition to traditional accounting and advisory services, the company offers specialist services in the segments tax, business management, transaction ad-visory, HR and sustainability advisory, as well as sales and advisory services related to the selection and implementation of various IT solutions. The company has approximately 12,000 customers across all sectors, the vast majority of which are in the SME market. In addition, the company has a Key Account Department with a service model tailored to clients generating more than NOK 100 million in revenue or requiring specialist support in service de-livery. The accounting industry is changing rapidly, and the company is focused on offering service models and services that simplify everyday operations for clients. The company has achieved increased accessibility and relevance through a joint service model with the Corporate Banking business focused on banking and accounting. Regnskapshuset is creating value for clients and owners by integrating new technologies into its accounting systems and ensuring that both ac-counting advisers and clients use efficient working methods. The company’s broad service portfolio, which combines traditional accounting with specialist units, gives clients a full range of assistance, from A to Z. SpareBank 1 Regnskapshuset SMN (93,3%) 2025 2,025 Total revenues 850 808 Total operating expenses 744 730 Pre-tax profit (NOKm) 106 78 Operating margin 12% 10% SpareBank 1 Finans Midt-Norge operates in Eastern Norway, Western Norway and Central Norway, and has a loan portfolio totalling NOK 13.7 billion. The company has around 60 employees and offers leasing, commercial loans, loan secured by fixed charges and invoice sales to private and corporate customers in Norway. The company markets its products through its owner banks, intermediaries and direct sales. In 2024, a dedicated distribution agreement was entered into with Sparebanken Møre relating to private customers. The majority of transactions occur in the secondhand market. The proportion of financed objects with electric powertrains is increasing in both the private and corporate markets. The company’s credit policy contains clear guidance on various requirements applicable to businesses, products and sectors, and there is a special focus on sustainability to ensure that SpareBank 1 Finans Midt-Norge enables customers to make more sustainable choices when making purchases. For example, particularly polluting objects are not fi-nanced. For green items, separate products with favourable terms are offered. The company achieved revenues of NOK 459 million and an annual profit of NOK 288 million in 2025. SpareBank 1 Finans Midt-Norge (64,8%) 2025 2,025 Total revenues 459 453 Total operating expenses 136 136 Pre-tax profit (NOKm) 36 20 Operating margin 288 298
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224SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS Balance sheet, funding and liquidity Total assets The Group’s assets totalled NOK 242.9 billion as at 31 December 2025 (247.7 billion as at 31 December 2024), and thus shrank by -1.9 per cent over the past 12 months. As at 31 December 2025, loans totalling NOK 74.5 billion (NOK 69.2 billion) had been sold by SpareBank 1 SMN to SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt. These loans are not recognised as loans in the bank’s balance sheet. The comments on lending growth encompass loans sold to SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt. Loans Over the past 12 months, gross lending volume increased by NOK 9.6 billion, corresponding to 3.8 per cent (5.5 per cent), and was NOK 258.9 billion (NOK 249.4 billion) at the end of the year. Lending to the bank’s retail customers increased by 4.7 per cent in 2025. Total lending to retail customers amounted to NOK 169.2 billion (NOK 161.6 billion) at the end of Q4 2025. Loans to the bank’s corporate clients increased by 2.3 per cent in 2025. The bank’s corporate loans totalled NOK 75.6 billion (NOK 73.9 billion) as at 31 De-cember 2025. SpareBank 1 Finans’ gross lending volume was NOK 13.7 billion (NOK 13.2 billion) at the end of 2025. (For a breakdown by sector, see note 8.) Deposits Customer deposits amounted to NOK 146.2 billion (NOK 140.9 billion) at 31 December 2025. Retail deposits increased by 8.4 per cent, bringing total retail deposits to NOK 72.2 billion (NOK 66.6 billion) at year-end. Corporate deposits increased by 1.8 per cent. Total corporate deposits were NOK 72.9 billion (NOK 71.6 billion) as at 31 December 2025. Customer deposits also comprise approximately NOK 1.0 billion employed in the bank’s liquidity management vis-à-vis large institutions by the finance de-partment. (For a breakdown by sector, see note 9.) Funding and liquidity SpareBank 1 SMN has good liquidity and good access to funding. The bank follows a conservative liquidity strategy, with liquidity reserves sufficient to ensure the bank’s survival for 12 months of ordinary operations without new external funding. The bank must maintain sufficient liquidity buffers to withstand periods of limited access to market funding. The Liquidity Coverage Ratio (LCR) measures the size of a bank’s liquid assets relative to net liquidity outflow 30 days ahead, given a stress situation. The LCR has been calculated at 156 per cent (183 per cent) as at 31 December 2025. The Group’s deposit-to-loan ratio, including SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt, was 56 per cent (57 per cent) at the end of the year. The bank is well-diversified among different funding sources and products. The proportion of the bank’s total money market funding with a maturity of more than one year was 84 per cent (83 per cent) at year-end. SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt are important sources of funding for the bank, and loans totalling NOK 75 billion (NOK 69 billion) had been sold to the captive mortgage companies as at 31 December 2025. As at year-end 2025, SpareBank 1 SMN had issued NOK 15.4 billion in senior non-preferred debt (SNP). Non-preferred MREL totalled 31.8 per cent as at 31 December 2025, and SpareBank 1 SMN satisfies the non-preference requirement by a good margin. Rating The bank is rated Aa3 (outlook stable) by Moody’s. Solidity The Common Equity Tier 1 capital ratio was 16.8 per cent as at 31 December 2025 (18.3 per cent as at 31 December 2024). The Financial Supervisory Authority of Norway (Finanstilsynet) has adopted a new Pillar 2 requirement (P2R) of 1.6 per cent of the Group’s calcula-tion basis, representing a cut of 0.1 percentage points in the previous Pillar 2 requirement. At least 56.25 per cent of the requirement must be cov-ered by CET1 capital, while 75 per cent must be covered by Tier 1 capital. Finanstilsynet has also decided to reduce the expected capital require-ment margin (P2G) from at least 1.25 per cent to at least 1.00 per cent of the Group’s calculation basis. In response to the above, the Board of Directors adopted a new long-term target for SpareBank 1 SMN’s CET1 capital ratio on 18 December 2025, ef-fective as of 31 December 2025. The target has been set at a minimum of 15.9 per cent. SpareBank 1 SMN has been subject to a temporary Pillar 2 capital premium of 0.7 percentage points since 30 April 2022, based on IRB models for corporate clients. Effective as of Q4 2025, the bank has adopted revised IRB models for corporate clients in accordance with conditions set by Finanstilsynet. The tem-porary premium of 0.7 percentage points has lapsed as of the same date. The new models increase the risk weights for the corporate sector and expand the calculation basis. The net effect of discontinuation of the temporary capital requirement and the expanded calculation basis is approximately neutral.
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225SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS The bank’s leverage ratio of 7.0 percent as at 31 December 2025 (7.0 percent as at 31 December 2024) demonstrates the bank’s solvency. See note 4 for de-tails. The bank’s equity certificate (MING) The book value per equity certificate was NOK 138.30 as at 31 December 2025 (NOK 128.09 as at 31 December 2024), while the full-year profit per equity certificate was NOK 19.08 (NOK 20.10). The price/earnings ratio was 10.80 (8.32), and the price/book ratio was 1.49 (1.34). Insurance policy for board members and the CEO Liability insurance has been taken out for members of the Board of Directors and the CEO. The policy covers insured persons’ liability for any economic loss suffered as a result of any claim brought in the insured period based on allegedly liabil-ity-inducing acts or omissions. In addition to covering the economic loss, the policy also covers the cost of necessary proceedings to resolve the question of liability in damages, provided that the damages claim falls within the scope of the policy. The policy also covers reasonable and necessary expenditure on ad-visers in the event of a public investigation. Such expenses are expenses incurred by the insured person before a claim is brought against him or her. Further, the policy covers any claim directed at an insured person by, or on behalf of, an employee based on discrimination, harassment or other illegality committed during the period of employment, or on failure to introduce or implement an adequate personnel policy or procedures.
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226SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | FINANCIAL RESULTS Outlook SpareBank 1 SMN delivered a strong performance in 2025, driven by robust underlying operations, low losses and strong profit contributions from ownership interests. The Group is achieving its financial targets, with a return on equity of 14.8 per cent and a proposed dividend payout ratio of 69 per cent. Ongoing uncertainty about macroeconomic developments is creating scope for variable growth, inflation and interest rates. SpareBank 1 SMN’s strategy of steering a steady course and maintaining a robust, diversified revenue platform is expected to hold up well even if interest rates fall. SpareBank 1 SMN has a broad and robust lending portfolio of high credit quality. 68 per cent of lending exposure is to households. The bank has good liquidity and access to funding. There are few signs of reduced credit quality, as reflected in continued low losses. The Group’s objective of growing its market share remains unchanged. This objective will be operationalised in selected geographies and sectors, supported by synergies across the Group’s business areas. In 2025, SpareBank 1 SMN implemented a new organisational structure and intensified its focus on the fi-nance centre model. These measures are expected to boost coordination and lending growth above national credit growth in 2026. The bank’s cost growth – adjusted for an additional payment to TietoEvry – totalled 3.3 per cent in 2025. The Board of Directors expects the bank’s cost growth to fall further in 2026. One measure in this regard is that the bank will only replace half of all employees who leave going forward. This policy will take full effect in 2027, when around 45 full-time equivalents will equate to a saving of NOK 55 million. Cost growth in the bank’s subsidiaries is driven by ac-tivity levels, and will thus mirror market conditions to a greater degree. The Group’s long-term targeted CET1 capital ratio is 15.9 per cent. At the end of the fourth quarter, the CET1 capital ratio was 16.8 per cent. SpareBank 1 SMN is well-positioned to deliver on its growth targets while maintaining robust dividend capacity. The market in Central Norway is characterised by a large number of players, and competition is expected to intensify further. SpareBank 1 SMN is in a strong position thanks to its local presence in 26 finance centres, leading digital services and in-depth knowledge of the business community in the region. The combination of a market-leading position, strong expertise and a role as a community-builder for more than 200 years means that the Group is well-positioned to withstand increased competition. SpareBank 1 SMN aims to be among the best performers in the Nordic region, and the Group’s overall financial goal of delivering a return on equity above 13 per cent over time remains unchanged. The Board of Directors is satisfied with the results achieved in 2025 and expects 2026 to be another good year for the Group. Trondheim, 3 March 2026 Board of Directors in SpareBank 1 SMN Kjell Bjordal Christian Stav Mette Kamsvåg board chair deputy chair Freddy Aursø Nina Olufsen Ingrid Finboe Svendsen Kristian Sætre Inge Lindseth Christina Straub Employee rep. Employee rep. Jan-Frode Janson Group CEO
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227SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SUSTAINABILITY AUDITOR’S REPORT PricewaterhouseCoopers AS, org.no.: 987 009 713 MVA, Statsautoriserte revisorer, medlemmer av Den norske Revisorforening og autorisert regnskapsførerselskap Advokatfirmaet PricewaterhouseCoopers AS, Org.no.: 988 371 084 MVA, Medlemmer av Advokatforeningen. advokatfirmaet@pwc.com PwC Tax Services AS, Org.no.: 962 066 321 MVA, Autorisert regnskapsførerselskap, Medlem av Regnskap Norge Brattørkaia 17B, 7010 Trondheim, T: 02316 (+47 952 60 000) www.pwc.no To the Supervisory Board of SpareBank 1 SMN Independent Sustainability Auditor’s Limited Assurance Report Limited Assurance Conclusion We have conducted a limited assurance engagement on the consolidated sustainability statement of SpareBank 1 SMN (the «Company») included in the chapter "Sustainability report" of the Board of Directors’ report (the «Sustainability Statement»), as at 31 December 2025 and for the year then ended. Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that causes us to believe that the Sustainability Statement is not prepared, in all material respects, in accordance with the Norwegian Accounting Act section 2-3, including: • compliance with the European Sustainability Reporting Standards (ESRS), including that the process carried out by the Company to identify the information reported in the Sustainability Statement (the «Process») is in accordance with the description set out in the chapter "The group's double materiality assessment"; and • compliance of the disclosures in the chapter "EU Taxonomy" of the Sustainability Statement with Article 8 of EU Regulation 2020/852 (the «Taxonomy Regulation»). Basis for Conclusion We conducted our limited assurance engagement in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of historical financial information («ISAE 3000 (Revised)»), issued by the International Auditing and Assurance Standards Board. We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion. Our responsibilities under this standard are further described in the Sustainability Auditor’s Responsibilities section of our report. Our Independence and Quality Management We have complied with the independence and other ethical requirements as required by relevant laws and regulations in Norway and the International Code of Ethics for Professional Accountants (including International Independence Standards) issued by the International Ethics Standards Board for Accountants (IESBA Code), which is founded on fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional behaviour. The firm applies International Standard on Quality Management 1, which requires the firm to design, implement and operate a system of quality management including policies or procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements. Responsibilities for the Sustainability Statement The Board of Directors and the Managing Director (Management) are responsible for designing and implementing a process to identify the information reported in the Sustainability Statement in accordance with the ESRS and for disclosing this Process in the chapter "The group's double materiality assessment" of the Sustainability Statement. This responsibility includes: • understanding the context in which the Group's activities and business relationships take place and developing an understanding of its affected stakeholders; • the identification of the actual and potential impacts (both negative and positive) related to sustainability matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the Group’s financial 2 / 3 position, financial performance, cash flows, access to finance or cost of capital over the short-, medium-, or long- term; • the assessment of the materiality of the identified impacts, risks and opportunities related to sustainability matters by selecting and applying appropriate thresholds; and • making assumptions that are reasonable in the circumstances. Management is further responsible for the preparation of the Sustainability Statement, in accordance with the Norwegian Accounting Act section 2-3, including: • compliance with the ESRS; • preparing the disclosures in the chapter "EU Taxonomy" of the Sustainability Statement, in compliance with the Taxonomy Regulation; • designing, implementing and maintaining such internal control that Management determines is necessary to enable the preparation of the Sustainability Statement that is free from material misstatement, whether due to fraud or error; and • the selection and application of appropriate sustainability reporting methods and making assumptions and estimates that are reasonable in the circumstances. Inherent limitations in preparing the Sustainability Statement In reporting forward-looking information in accordance with ESRS, Management is required to prepare the forward- looking information on the basis of disclosed assumptions about events that may occur in the future and possible future actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as expected. Sustainability Auditor’s Responsibilities Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole. As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement and maintain professional scepticism throughout the engagement. Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include: • Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process; • Considering whether the information identified addresses the applicable disclosure requirements of the ESRS; and • Designing and performing procedures to evaluate whether the Process is consistent with the Company’s description of its Process set out in the chapter "The group's double materiality assessment". Our other responsibilities in respect of the Sustainability Statement include: • Identifying where material misstatements are likely to arise, whether due to fraud or error; and • Designing and performing procedures responsive to where material misstatements are likely to arise in the Sustainability Statement. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Summary of the Work Performed A limited assurance engagement involves performing procedures to obtain evidence about the Sustainability Statement. The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed.
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228SPAREBANK 1 SMN | ANNUAL REPORT 2025 | REPORT OF THE BOARD OF DIRECTORS | SUSTAINABILITY AUDITOR’S REPORT 3 / 3 The nature, timing and extent of procedures selected depend on professional judgement, including the identification of disclosures where material misstatements are likely to arise in the Sustainability Statement, whether due to fraud or error. In conducting our limited assurance engagement, with respect to the Process, we: • Obtained an understanding of the Process by: o performing inquiries to understand the sources of the information used by management (e.g., stakeholder engagement, business plans and strategy documents); and o reviewing the Company’s internal documentation of its Process; and • Evaluated whether the evidence obtained from our procedures with respect to the Process implemented by the Company was consistent with the description of the Process set out in the chapter "The group's double materiality assessment". In conducting our limited assurance engagement, with respect to the Sustainability Statement, we: • Obtained an understanding of the Group’s reporting processes relevant to the preparation of its Sustainability Statement by: o Obtaining an understanding of the Group’s control environment, processes and information system relevant to the preparation of the Sustainability Statement, but not for the purpose of providing a conclusion on the effectiveness of the Group’s internal control; and o Obtaining an understanding of the Group’s risk assessment process; • Evaluated whether the information identified by the Process is included in the Sustainability Statement; • Evaluated whether the structure and the presentation of the Sustainability Statement is in accordance with the ESRS; • Performed inquiries of relevant personnel and analytical procedures on selected information in the Sustainability Statement; • Performed substantive assurance procedures on selected information in the Sustainability Statement; • Where applicable, compared disclosures in the Sustainability Statement with the corresponding disclosures in the financial statements and other sections of the Board of Directors’ report; • Evaluated the methods, assumptions and data for developing estimates and forward-looking information; • Obtained an understanding of the Company’s process to identify taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclosures in the Sustainability Statement; • Evaluated whether information about the identified taxonomy-eligible and taxonomy-aligned economic activities is included in the Sustainability Statement; and • Performed inquiries of relevant personnel, analytical procedures and substantive procedures on selected taxonomy disclosures included in the Sustainability Statement. Trondheim, 3 March 2026 PricewaterhouseCoopers AS Marius Fevaag Larsen State Authorised Public Accountant – Sustainability Auditor Note: This translation from Norwegian has been prepared for information purposes only.
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3 Annual financial statements Income statement 230 Statement of financial position 232 Statement of changes in equity 235 Cash flow statement 239 Notes to the annual financial statement 241 Financial summary (Group) 359 Equity capital certificate 364
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230SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | INCOME STATEMENT 230 Income statement Parent bank Group 2024 2025 (NOKm) Note 2025 2024 11,122 11,072 Interest income effective interest method 17 11,644 11,685 1,883 1,982 Other interest income 17 1,975 1,875 8,180 8,265 Interest expenses 17 8,276 8,187 4,824 4,789 Net interest 4 5,343 5,373 1,315 1,451 Commission income 18 1,757 1,611 135 155 Commission expenses 18 243 224 65 62 Other operating income 18 1,088 1,006 1,245 1,358 Commission income and other income 4 2,602 2,392 361 812 Dividends 19.44 25 33 - - Income from investment in related companies 19.39 1,017 1,254 45 33 Net return on financial investments 19 81 70 406 845 Net return on financial investments 4 1,123 1,357 6,475 6,993 Total income 9,068 9,123 1,012 1,072 Staff costs 20.22 2,089 1,981 1,084 1,140 Other operating expenses 21,31,32,33 1,390 1,319 2,096 2,212 Total operating expenses 4 3,479 3,300 4,379 4,781 Result before losses 5,589 5,823 156 105 Loss on loans, guarantees etc. 4.1 140 176 4,223 4,676 Result before tax 5,449 5,647 940 958 Tax charge 23 1,072 1,054 - - Result investment held for sale, after tax 39 -11 -2 3,283 3,718 Net profit 4,367 4,591 137 153 Attributable to additional Tier 1 Capital holders 161 146 2,101 2,381 Attributable to Equity capital certificate holders 2,751 2,898 1,044 1,183 Attributable to the saving bank reserve 1,367 1,442 Attributable to non-controlling interests 88 106 3,283 3,718 Net profit 4,367 4,591 Profit/diluted profit per ECC 19.08 20.10
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231SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | INCOME STATEMENT 231 Other comprehensive income Parent bank Group 2024 2025 (NOKm) Note 2025 2024 3,283 3,718 Net profit 4,367 4,591 Items that will not be reclassified to profit/loss - - 70 -22 Actuarial gains and losses pensions 22 -22 70 -17 5 Tax 5 -17 - - Share of other comprehensive income of associates and joint v enture 9 9 52 -16 Total -8 62 Items that will be reclassified to profit/loss -4 -12 Value changes on loans measured at fair value -12 -4 - - Share of other comprehensive income of associates and joint v enture 87 -148 -4 -12 Total 75 -153 48 -28 Net other comprehensive income 67 -91 3,331 3,690 Total comprehensive income 4,434 4,500 137 153 Attributable to additional Tier 1 Capital holders 161 146 2,134 2,363 Attributable to Equity capital certificate holders 2,796 2,909 1,060 1,174 Attributable to the saving bank reserve 1,389 1,339 - - Attributable to non-controlling interests 88 106 3,331 3,690 Total comprehensive Income 4,434 4,500
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232SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | STATEMENT OF FINANCIAL POSITION 232 Statement of financial position Parent bank Group 31 Dec 2024 31 Dec 2025 (NOKm) Note 31 Dec 2025 31 Dec 2024 654 56 Cash and receivables from central banks 12.24 56 654 19,785 13,317 Deposits with and loans to credit institutions 7,12,13,24,26 2,226 9,166 166,312 170,059 Net loans to and receivables from customers 4,8,9,10,11, 12,13,24,25,26 183,495 179,254 36,649 35,219 Fixed-income CDs and bonds 12,13,24,25,27 35,219 36,650 7,231 5,621 Derivatives 12,24,25,28,29 5,621 7,231 708 838 Shares, units and other equity interests 24,25,30 1,328 1,170 6,789 7,362 Investment in related companies 39,40,41,44 11,234 10,084 2,225 2,391 Investment in group companies 39.41 - - 98 98 Investment held for sale 30.39 175 190 797 775 Intangible assets 31 1,251 1,230 1,479 1,662 Other assets 4,12,22,23,24,26,32,33,34 2,308 2,069 242,726 237,398 Total assets 14,15 242,914 247,699
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233SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | STATEMENT OF FINANCIAL POSITION 233 Parent bank Group 31 Dec 2024 31 Dec 2025 (NOKm) Note 31 Dec 2025 31 Dec 2024 13,940 9,584 Deposits from credit institutions 7,24,26 9,584 13,941 141,485 146,778 Deposits from and debt to customers 4,24,26,35 146,165 140,897 36,570 29,121 Debt created by issue of securities 24,26,29,36 29,121 36,570 13,352 15,392 Subordinated debt 24,26,29,36 15,392 13,352 6,152 4,481 Derivatives 24,26,27,30 4,481 6,152 2,673 2,577 Other liabilities 22,23,24,25,26,37 3,457 3,527 - - Investment held for sale 39 1 2 2,656 2,770 Subordinated loan capital 16 2,848 2,735 216,829 210,703 Total liabilities 211,049 217,175 2,884 2,884 Equity capital certificates 43 2,884 2,884 -0 -0 Own holding of ECCs 43 -0 -0 2,422 2,422 Premium fund 2,422 2,422 8,721 9,168 Dividend equalisation fund 9,168 8,721 1,803 1,947 Recommended dividends 1,947 1,803 896 968 Provision for gifts 968 896 6,984 7,205 Ownerless capital 7,205 6,984 245 201 Unrealised gains reserve 201 245 - - Other equity capital 4,375 3,709 1,943 1,900 Additional Tier 1 Capital 5,38 1,996 2,039 - - Non-controlling interests 700 821 25,898 26,695 Total equity capital 5 31,865 30,523 242,726 237,398 Total liabilities and equity 14,15 242,914 247,699
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234SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | STATEMENT OF FINANCIAL POSITION 234 Trondheim, 3 March 2026 The Board of Directors of SpareBank 1 SMN Kjell Bjordal Christian Stav Mette Kamsvåg Board chair Deputy chair Freddy Aursø Nina Olufsen Ingrid Finboe Svendsen Kristian Sætre Inge Lindseth Christina Straub Employee rep. Employee rep. Jan-Frode Janson Group CEO
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235SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | STATEMENT OF CHANGES IN EQUITY 235 Statement of changes in equity Accounting policy Proposed dividends on equity certificates and gifts are recognised as equity capital in the period to the declaration of dividends by the bank’s Supervisory Board. Parent bank (2024) Issued equity Earned equity (NOKm) EC capital Premium fund Ownerless capital Equalisation fund Dividend and gifts Unrealised gains reserve Other equity Additional Tier 1 Capital Total equity Equity at 1 January 2024 2,884 2,422 6,865 8,482 2,591 106 - 1,800 25,150 Net profit - - 119 239 2,698 139 -49 137 3,283 Other comprehensive income Value changes on loans measured at fair value - - - - - - -4 - -4 Actuarial gains (losses), pensions - - - - - - 52 - 52 Other comprehensive income - - - - - - 48 - 48 Total comprehensive income - - 119 239 2,698 139 -1 137 3,331 Transactions with owners Dividend declared for 2023 - - - - -1,730 - - - -1,730 To be disbursed from gift fund - - - - -860 - - - -860 Additional Tier 1 Capital - - - - - - - 450 450 Buyback Additional Tier 1 Capital issued - - - - - - - -307 -307 Interest payments additional Tier 1 capital - - - - - - - -137 -137 Purchase and sale of own ECCs 0 - - 1 - - - - 1 Direct recognitions in equity - - - - - - 1 - 1 Total transactions with owners 0 - - 1 -2,591 - 1 6 -2,583 Equity at 31 December 2024 2,884 2,422 6,984 8,721 2,698 245 - 1,943 25,898
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236SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | STATEMENT OF CHANGES IN EQUITY 236 Parent bank (2025) Issued equity Earned equity (NOKm) EC capital Premium fund Ownerless capital Equalisation fund Dividend and gifts Unrealised gains reserve Other equity Additional Tier 1 Capital Total equity Equity at 1 January 2025 2,884 2,422 6,984 8,721 2,698 245 - 1,943 25,898 Net profit - - 221 446 2,915 -44 27 153 3,718 Other comprehensive income Value changes on loans measured at fair value - - - - - - -12 - -12 Actuarial gains (losses), pensions - - - - - - -16 - -16 Other comprehensive income - - - - - - -28 - -28 Total comprehensive income - - 221 446 2,915 -44 -1 153 3,690 Transactions with owners Dividend declared for 2024 - - - - -1,803 - - - -1,803 To be disbursed from gift fund - - - - -896 - - - -896 Additional Tier 1 Capital - - - - - - - 150 150 Buyback Additional Tier 1 Capital issued - - - - - - - -193 -193 Interest payments additional Tier 1 capital - - - - - - - -153 -153 Purchase and sale of own ECCs 0 - - 1 - - - - 1 Direct recognitions in equity - - - - - - 1 - 1 Total transactions with owners 0 - - 1 -2,698 - 1 -196 -2,893 Equity at 31 December 2025 2,884 2,422 7,205 9,168 2,915 201 - 1,900 26,695
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237SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | STATEMENT OF CHANGES IN EQUITY 237 Group (2024) Attributable to parent company equity holders Issued equity Earned equity (NOKm) EC capital Premium fund Ownerless capital Equalisation fund Dividend and gifts Unrealised gains reserve Other equity Additional Tier 1 Capital NCI 1) Total equity Equity at 1 January 2024 2,884 2,422 6,865 8,482 2,591 106 2,677 1,903 666 28,597 Net profit - - 119 239 2,698 139 1,145 146 106 4,591 Other comprehensive income Share of other comprehensive income of associates and joint v entures - - - - - - -139 - - -139 Value changes on loans measured at fair value - - - - - - -4 - - -4 Actuarial gains (losses), pensions - - - - - - 52 - - 52 Other comprehensive income - - - - - - -91 - - -91 Total comprehensive income - - 119 239 2,698 139 1,053 146 106 4,500 Transactions with owners Dividend declared for 2023 - - - - -1,730 - - - - -1,730 To be disbursed from gift fund - - - - -860 - - - - -860 Additional Tier 1 capital issued - - - - - - - 450 - 450 Buyback additional Tier 1 Capital issued - - - - - - - -315 - -315 Interest payments additional Tier 1 capital - - - - - - - -146 - -146 Purchase and sale of own ECCs 0 - - 1 - - - - - 1 Direct recognitions in equity - - - - - - 0 - - 0 Other transactions from associates and joint ventures - - - - - - -21 - - -21 Change in non-controlling interests - - - - - - - - 48 48 Total transactions with owners 0 - - 1 -2,591 - -21 -10 48 -2,573 Equity at 31 December 2024 2,884 2,422 6,984 8,721 2,698 245 3,709 2,039 821 30,523 1) Non-Controlling Interests
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238SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | STATEMENT OF CHANGES IN EQUITY 238 Group (2025) Attributable to parent company equity holders Issued equity Earned equity (NOKm) EC capital Premium fund Ownerless capital Equalisation fund Dividend and gifts Unrealised gains reserve Other equity Additional Tier 1 Capital NCI 1) Total equity Equity at 1 January 2025 2,884 2,422 6,984 8,721 2,698 245 3,709 2,039 821 30,523 Net profit - - 221 446 2,915 -44 580 161 88 4,367 Other comprehensive income Share of other comprehensive income of associates and joint v entures - - - - - - 95 - - 95 Value changes on loans measured at fair value - - - - - - -12 - - -12 Actuarial gains (losses), pensions - - - - - - -16 - - -16 Other comprehensive income - - - - - - 67 - - 67 Total comprehensive income - - 221 446 2,915 -44 647 161 88 4,434 Transactions with owners Dividend declared for 2023 - - - - -1,803 - - - - -1,803 To be disbursed from gift fund - - - - -896 - - - - -896 Additional Tier 1 capital issued - - - - - - - 150 - 150 Buyback additional Tier 1 Capital issued - - - - - - - -193 - -193 Interest payments additional Tier 1 capital - - - - - - - -161 - -161 Purchase and sale of own ECCs 0 - - 1 - - - - - 1 Direct recognitions in equity - - - - - - 6 - - 6 Other transactions from associates and joint ventures - - - - - - 12 - - 12 Change in non-controlling interests - - - - - - - - -209 -209 Total transactions with owners 0 - - 1 -2,698 - 18 -204 -209 -3,092 Equity at 31 December 2025 2,884 2,422 7,205 9,168 2,915 201 4,375 1,996 700 31,865 1) Non-Controlling Interests
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239SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | CASH FLOW STATEMENT 239 Cash flow statement Parent bank Group 2024 2025 (NOKm) 2025 2024 -9,987 -3,904 Decrease/(increase) loans to customers -4,448 -10,458 10,324 10,386 Interest receipts from loans to customers 11,034 10,961 -538 6,470 Decrease/(increase) loans credit institutions 6,942 -414 1,017 1,105 Interest receipts from loans to credit institutions 1,017 919 8,048 5,378 Increase/(decrease) deposits from customers 5,353 8,034 -4,974 -5,217 Interest payment on deposits from customers -5,171 -4,926 748 -4,316 Increase/(decrease) debt to credit institutions -4,316 748 -551 -507 Interest payment on debt to credit institutions -507 -551 -1,902 1,829 Increase/(decrease) in short term investments 1,862 -1,765 1,579 1,566 Interest receipts from short term investments 1,507 1,466 -766 -92 Increase/(decrease) in derivatives -92 -766 -837 -867 Interest receipts from derivatives -867 -837 1,221 1,256 Increase/(decrease) in other claims 2,580 2,424 -2,737 -3,382 Increase/(decrease) in other debts -4,992 -3,959 646 9,704 A) Net change in liquidity from operations 9,902 877 -176 -62 Gross investment buildings/operating assets -148 -241 117 196 Dividends from subsidiaries - - -37 - Paid-in capital from reduction in ownership of subsidiaries - - -97 -166 Payment of capital due to increase in shareholding in subsidiaries - - - - Dividends from associated companies and joint ventures 583 201 200 174 Proceeds from sale of shares of associated companies and joint v entures 190 198 -717 -744 Payment for purchase of shares o f associated companies and joint ventures -744 -717 - - Proceeds from shares held for sale 4 -80 43 33 Dividends from other businesses 25 33 1,411 265 Reduction/sale of shares and ownership inter ests 286 1,382 -1,175 -357 Increase/purchase of shares and owner ship interests -382 -1,208 -432 -662 B) Net change in liquidity from investments -186 -432
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240SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | CASH FLOW STATEMENT 240 7,589 3,535 Debt raised by issuance of covered bonds 3,535 7,589 -4,820 -9,325 Repayment of issued cover ed bonds -9,325 -4,820 -1,430 -1,480 Interest payment on covered bonds issued -1,480 -1,430 900 100 Debt raised by issuance of subordinated debt 100 902 -400 - Payments of issued subordinated debt - -400 -187 -159 Interest payment on subordinated debt -165 -194 1 1 Proceeds from sale or issue of treasury shar es 1 1 -1,730 -1,803 Dividends cleared -1,803 -1,730 201 583 Dividends paid to non-controlling interests -77 -9 -860 -896 Disbused from gift fund -896 -860 143 150 Additional Tier 1 Capital issued 150 450 - -193 Repayment of Additional Tier 1 Capital -193 -315 -137 -153 Interest payments Additional Tier 1 capital -161 -146 -731 -9,641 C) Net change in liquidity from financial activities -10,314 -962 -517 -598 A) + B) + C) Net changes in cash and cash equivalents -598 -517 1,172 654 Cash and cash equivalents at 1.1 654 1,172 654 56 Cash and cash equivalents at end of the year 56 654 -517 -598 Net changes in cash and cash equivalents -598 -517
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Notes to the annual financial statements Note 1 - General information 242 Note 2 - Accounting principles 243 Note 3 - Critical estimates and assessments concerning the use of accounting principles 244 Note 4 - Operating segments 249 Note 5 - Capital adequacy and capital management 251 Note 6 - Risk factors 255 Credit risk Note 7 - Credit institutions - loans and advances 259 Note 8 - Loans and advances to customers 261 Note 9 - Derecognition of financial assets 273 Note 10 - Losses on loans and guarantees 275 Note 11 - Credit risk exposure for each internal risk rating 287 Note 12 - Maximum credit risk exposure 289 Note 13 - Credit quality per class of financial assets 294 Market risk Note 14 - Market risk related to interest rate risk 298 Note 15 - Market risk related to currency exposure 299 Liquidity risk Note 16 - Liquidity risk 300 Income Statement Note 17 - Net interest income 302 Note 18 - Net commission income and other income 303 Note 19 - Net return on financial investments 304 Note 20 - Personnel expenses 305 Note 21 - Other operating expenses 306 Note 22 - Pension 307 Note 23 - Income tax 309 Statement of Financial Position Note 24 - Categories of financial assets and financial liabilities 312 Note 25 - Measurement of fair value of financial instruments 314 Note 26 - Fair value of financial instruments at amortised cost 317 Note 27 - Money market certificates and bonds 320 Note 28 - Financial derivatives 321 Note 29 - Hedge accounting for debt created by issue of securities 323 Note 30 - Shares, units and other equity interest 325 Note 31 - Intangible assets 328 Note 32 - Property, plant and equipment 330 Note 33 - Leases 332 Note 34 - Other assets 336 Note 35 - Deposits from and liabilities to customers 337 Note 36 - Debt securities in issue 339 Note 37 - Other debt and liabilities 342 Note 38 - Subordinated debt and hybrid capital issue 344 Note 39 - Investments in owner interests 346 Additional information Note 40 - Business acquisitions/business combinations 352 Note 41 - Significant transactions with related companies 353 Note 42 - ECC capital and ownership structure 355 Note 43 - Earnings per ECC 357 Note 44 - Events after the balance sheet date 358
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242SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 1: General information Description of the business See the chapter This is SpareBank 1 SMN presented in the annual report. The SpareBank 1 SMN Group SpareBank 1 SMN’s head office is in Trondheim, no. 4 Søndre gate. The Bank’s market areas are essentially Trøndelag and Nordvestlandet. The Group accounts for 2025 were approved by the Board of Directors on 3 March 2026.
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243SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 2: Accounting principles Basis for preparing the annual accounts The Bank and Group accounts for 2025 for SpareBank 1 SMN have been prepared in conformity with International Financial Reporting Standards IFRS®Accounting Standards as approved by the EU (IFRS). These include interpretations from the International Financial Reporting Interpretations. Committee (IFRIC) and its predecessor, the Interpretations Committee. The measurement base for both the parent bank and Group accounts is historical cost with the exception of financial assets measured at fair value as described in note 24. The accounts are presented based on IFRS standards and interpretations mandatory for accounts presented as at 31 December 2025. Principal accounting prinsiples SpareBank 1 SMN has described the accounting policies under each note to the annual accounts. The following accounting policies has been assessed by management as principal accounting policies: • Accounting policies for Loans to customers (note 8) and Losses on loans (note 10) • Accounting Policies for Net interest income (note 17) and Net commision income (note 18) • Accounting Policies for Debt securities (note 36) and Hedge accounting (note 29) General accounting policies Consolidation The consolidated accounts include the Bank and all subsidiaries which are not due for divestment in the near future and are therefore to be classified as held for sale under IFRS 5. All undertakings controlled by the Bank, i.e. where the Bank has the power to control the undertaking’s financial and operational principles with the intention of achieving benefits from the undertaking’s activities, are regarded as subsidiaries. Subsidiaries are consolidated from the date on which the Bank has taken over control, and are deconsolidated as of the date on which the Bank relinquishes control. Mutual balance sheet items and all significant profit elements are eliminated. Upon takeover of control of an enterprise (business combination), all identifiable assets and liabilities are recognised at fair value in accordance with IFRS 3. A positive difference between the fair value of the consideration and the fair value of identifiable assets and liabilities is recorded as goodwill, while any negative difference is taken to income upon purchase. Accounting for goodwill after first-time recognition is described under the section on intangible assets. All intra-Group transactions are eliminated in the preparation of the consolidated accounts. The non-controlling interests’ share of the Group result is to be presented on a separate line under profit after tax in the income statement. In the statement of changes in equity, the non-controlling interests’ share is shown as a separate item. Presentation currency The presentation currency is the Norwegian krone (NOK), which is also the bank’s functional currency. All amounts are stated in millions of kroner unless otherwise specified. Transactions and holdings in foreign currency Transactions in foreign currency are converted to Norwegian kroner at the transaction exchange rate. Gains and losses on executed transactions or on conversion of holdings of monetary items on the balance sheet date are recognised in profit/loss. Gains and losses on conversion of items other than monetary items are recognised in the same way as the appurtenant balance sheet item. Changes in accounting policies The Group has assessed the impact of amended accounting standards and interpretations (IFRSs) issued by the IASB and IFRSs approved by the EU with effect from 1 January 2025 or later. The Group has assessed that the application of these has not had a significant impact on the Group accounts for 2025. Furthermore, the Group has assessed the impact of new or changed accounting standards and interpretations (IFRS) issued by the IASB which have not yet been effective. The Group does not expect any significant impact on future periods from the adoption of these changes.
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244SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 3: Critical estimates and assessments concerning the use of accounting principles In the preparation of the Group accounts the management makes accounting estimates, discretionary assessments and assumptions that bear on the effect of the application of the accounting principles and hence the amounts booked for assets, liabilities, income and expenses. Estimates and discretionary assessments are evaluated continuously and are based on empirical experience and expectations of events which, as of the balance sheet date, are deemed likely to occur in the future. Losses on loans and guarantees The Bank rescores its loan portfolio monthly. Customers showing objective evidence of loss due to payment default, impaired creditworthiness or other objective criteria are subject to individual assessment and calculation of loss. Should the Bank’s calculations show that the present value of the discounted cash flow based on the effective interest rate at the time of estimation is below the book value of the loan, the loan is assigned to stage 3 and a write-down is performed for the calculated loss. A high degree of discretionary judgement is required in order to assess evidence of loss, and the estimation of amounts and timing of future cash flows with a view to determining a calculated loss is affected by this judgement. Changes in these factors could affect the size of the provision for loss. In cases where collateral values are tied to specific objects or industries that are in crisis, collateral will have to be realised in illiquid markets, and in such cases assessment of collateral values may be encumbered with considerable uncertainty. For loans in stage 1 and 2 a calculation is made of the expected credit loss using the bank’s loss model based on estimates of probability of default (PD) and loss given default (LGD), as well as exposure (EAD). The bank uses the same PD model as in IRB, but with unbiased calibration, i.e. without safety margins, as a basis for assessment of increased credit risk. The PD estimate represents a 12-month probability. Write-downs for exposures in stage 1 will be calculation of one-year’s expected loss, while for exposures in stage 2, loss is calculated over lifetime. The most important input factors in the bank’s loss model that contribute to significant changes in the loss estimate and are subject to a high degree of discretionary judgement are the following: • Use of forward-looking information and pr ojection of macroeconomic variables for multiple scenarios on a probability-weighted basis. • Establishing what constitutes a significant increase in credit risk for a loan. Use of forward-looking information Measurement of expected credit loss for each stage requires both information on events and current conditions as well as expected events and future economic conditions. Estimation and use of forward-looking information requires a high degree of discretionary judgement. Each macroeconomic scenario that is utilised includes a projection for a five-year period. For engagements where the credit risk is assessed to have increased significantly since approval (stage 2), loss estimates for the period after year 5 are based on year 5 in terms of the level of PD and LGD. Our estimate of expected credit loss at stage 1 and 2 is a probability-weighted average of three scenarios: Base Case, Best Case and Worst Case. The model that computes model write-downs is based on two macro variables – interest rate level (three-month NIBOR) and unemployment (Statistics Norway’s Labour Force Survey, AKU). The assumptions in the baseline scenario are based on the assumptions in Norges Bank’s Monetary Policy Report 4/25 however the bank make its own assessment of the assumptions. The bank has assumed a long-term NIBOR rate of 3.5 per cent, which is higher than Norges Bank’s projection. Combined with a higher unemployment estimate, this results in a weaker base scenario than that assumed by Norges Bank. The downside scenario is characterised by high interest rates and high unemployment and is largely based on the Financial Supervisory Authority’s stress test presented in Financial Outlook, June 2025. The upside scenario represents a situation with low interest rates and low unemployment. Calculation of the Group’s total model-based impairments is based on sub-calculations of ECL for five portfolios. For each portfolio, separate assumptions are defined regarding how the macroeconomic variables interest rate and unemployment affect PD and LGD. The relationships between the macroeconomic variables and PD are developed using regression analysis and simulation, while the relationships between the macroeconomic variables and LGD are largely based on expert assessments and discretionary judgement. The relationships between the level of the macroeconomic variables and the level of PD in the model are recalibrated annually based on updated default statistics up to and including the preceding calendar year. The five portfolios are: • Residential mortgages • Other retail loans • Agriculture • Industries with large balance sheets / high long-term debt ratios (real estate, shipping, offshore, aquacultur e, fishery) • Industries with smaller balance sheets / low long-term debt ratios (other industries) The criteria for classification of an exposure to stage 2 (“significantly incr eased credit risk since approval”) have been amended during the quarter. A new criterion has been introduced whereby a credit exposure is classified to stage 2 based on a defined PD level, irrespective of the change in PD since approval. The threshold corresponds to the entry point for classification in the weakest non-default risk class. The remaining criteria
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245SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS for classification to stage 2 are unchanged and include customers with 30–90 days past due, loans with a significant increase in PD after discounting, customers with payment relief classified as forbearance, and customers included on the bank’s watch list for enhanced monitoring. In addition, customers within the building and construction industry (including industry segments with significant exposure to building and construction) and certain segments within fisheries are generally assessed to have experienced a significant increase in credit risk since approval and are therefore classified to stage 2 or stage 3. Expected credit loss (ECL) as at 31 December 2025 is calculated as a combination of 80 per cent base scenario, 10 per cent downside scenario and 10 per cent upside scenario (80/10/10 per cent). As a result of validation and quality assurance of the ECL model, changes have been made to key assumptions affecting the impairment level during the quarter. These include (impact on impairment level in parentheses) expected developments in EAD during the simulation period (reduced), the relationship between macroeconomic assumptions and estimated PD levels during the simulation period (increased), and calibration of estimated LGD levels during the simulation period (reduced). In addition, the introduction of the new PD- related criterion for classification to stage 2 has, as expected, increased the calculated impairment level. The effect of changes in assumptions in 2025 is presented on the line “Change due to updated assumptions in the impairment model” in Note 10. As at 31 December 2025, this amounts in total to NOK 121 million for the bank and NOK 147 million for the Group in reduced impairments. The scenarios are weighted with a basis in our best estimate of the probability of the various outcomes represented. The estimates are updated quarterly and were as follows as per the estimates at 31 December: Portfolio 2025 2024 Base Case Worst Case Best Case Base Case Worst Case Best Case Retail Market 80% 10% 10% 80% 10% 10% Corporate excl. Agriculture and offshore 80% 10% 10% 80% 10% 10% Agriculture 80% 10% 10% 80% 10% 10%
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246SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Sensitivities The first part of the table below show total calculated expected credit loss as of 31 December 2025 in each of the three scenarios, distributed in the portfolios retail market (RM) corporate market (CM), and agriculture which adds up to parent bank. In addition the subsidiary SpareBank 1 Finans Midt-Norge (SB1 Finans MN) is included. ECL for the parent bank and the subsidiary is summed up in the column ”Total Group”. The second part of the table show the ECL distributed by portfolio using the scenario weight applied, in addition to a alternative weighting where worst case have been doubled. If the downside scenario’s probability were doubled at the expense of the baseline scenario at year end this would have entailed an increase in loss provisions of NOK 89 million for the parent bank and NOK 98 million for the Group. CM RM Agricul- ture Total parent SB 1 Finans MN CM SB 1 Finans MN RM Total group ECL base case 629 96 85 809 55 20 884 ECL worst case 1 252 276 167 1 695 116 51 1 862 ECL best case 454 76 65 595 37 16 648 ECL with scenario weights used 80/10/10 673 112 91 877 59 23 958 ECL alternative scenario weights 70/20/10 736 130 100 965 65 26 1 056 Change in ECL with alternative weights 62 18 8 89 6 3 98 The table reflects that there are some significant differences in underlying PD and LGD estimates in the different scenarios and that there are differentiated levels and level differences between the portfolios. At Group level, the ECL in the upside scenario, which largely reflects the loss and default picture in recent years, is about 73 per cent of the ECL in the expected scenario. The downside scenario gives more than double the ECL than in the expected scenario. Applied scenario weighting gives about 8 per cent higher ECL than in the expected scenario.
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247SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 247 Determination of significant increase in credit risk The assessment of what constitutes a significant increase in credit risk requires a large degree of discretionary judgement. Movements between stage 1 and stage 2 are based on whether the instrument’s credit risk on the balance sheet date has increased significantly relative to the date of first-time recognition. This assessment is done with a basis in the instrument’s economic 12-month PD, and not expected losses. The assessment is done for each individual instrument. Our assessment is performed at least quarterly, based on the following factors: 1. The bank uses both absolute and relative changes in PD as criteria for removal to stage 2. A change o f more than 150% in PD is considered to be a significant change in credit risk. In addition, the PD must at minimum be more than 0.6 percentage points. 2. An additional quantitative assessment is made based on whether the exposure has a significantly increased credit risk if it is subject to special monitoring or f orbearance 3. In addition, customers with payments between 30-90 days o verdue will in all cases be moved to stage 2. 4. From the fourth quarter of 2025 a ne w criteria has been introduced, whereby a credit exposure is classified to stage 2 based on a defined PD level, irrespective of the change in PD since approval. The threshold corresponds to the entry point for classification in the weakest non-default risk class. If any of the above factors indicate that a significant increase in credit risk has occurred, the instrument is moved from stage 1 to stage 2. See also note 10 on Losses on loans and note 6 on risk factors. Fair value of equity interests Assets recognised at fair value through profit and loss will mainly be securities traded in an active market. An active market is defined as a market where homogeneous products are traded, where willing buyers and sellers are normally present at all times, and where prices are accessible to the general public. Shares quoted in a regulated market place fit in with the definition of an active market. A market with a large spread between bid and ask prices and where trading is quiet may pose a challenge. Some key shares will be based on in-house valuations, transaction prices or external analyses of the company. Such shares are valued using acknowledged valuation techniques. These include the use of discounted cash flows or comparative pricing where similar, listed, companies are used (multiple pricing) to determine the value of the unlisted company. Such valuations may be encumbered with uncertainty. Any changes in assumptions may affect recognised values. Investments in private equity funds made in the subsidiary SpareBank 1 SMN Invest are valued based on net asset value (NAV) reported from the funds. The Group uses the «fair value option» for investments in private equity funds. Fair value is calculated based on valuation principles set out in IFRS 13 and guidelines for valuation in accordance with International Private Equity and Venture Capital (IPEV), see www.privateequityvaluation. com. Management has based its assessments on the information available in the market combined with best judgment. No new information has emerged on significant matters that had occurred or already existed on the balance sheet date as of 31.12.2025 and up to the Board’s consideration of the accounts on 3 March 2026. See also note 30 for specification of shares and equity interests. Fair value of financial derivatives and other financial instruments Fair value of derivatives is usually determined using valuation models where the price of the underlying, for example interest rates or exchange rates, is obtained in the market. When measuring financial instruments for which observable market data are not available, the Group makes assumptions regarding what market participants would use as the basis for valuing similar financial instruments. The valuations require extensive use of discretionary judgement inter alia when calculating liquidity risk, credit risk and volatility. Changes in these factors will affect the estimated fair value of the Group’s financial instruments. For further information, see note 25 Measurement of fair value of financial instruments. For options, volatilities will either be observed implicit v olatilities or estimated volatilities based on historical movements in the price of the underlying instrument. In cases where the Bank’s risk position is approximately neutral, middle rates will be used. “Neutral risk position” means for example that interest rate risk within a maturity band is virtually zero. Where market prices that are obtained are based on transactions with lower credit risk, this will be taken into account by amortising the original price difference measured against such transactions over the period to maturity. Goodwill The Group conducts tests to assess possible impairment of goodwill annually or in the event of indications of impairment. Assessment is based on the Group’s value in use. The recoverable amount from cash-flow-generating units is determined by calculating discounted future cash flows. The cash flows are based on historical earnings and expectations of future factors and include suppositions and estimates of uncertain factors. The outcome of the impairment tests depends on estimates of discount rates which are set discretionarily based on information available on the balance sheet date. Regarding goodwill, the portfolio is regarded as integrated in the Bank’s other lending and deposit operations, and, the lowest level for the cash generating unit is the segments Retail Market and Corporate Market. Goodwill has been allocated to the segments based on their share of the loan portfolio. A net cash flow is estimated based on earnings in the Bank’s loan and deposit portfolio. A five-year cash flow prognosis have been developed
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248SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 248 using expected growth, and a terminal value without growth thereafter. Cash flows are discounted with a discount rate (before tax rate) of 10 per cent. Calculations show that the value of discounted cash flows exceeds recognised goodwill by an ample margin. Other goodwill in the Group is calculated based on average earnings in the market area and is discounted at the risk-free interest rate + the risk premium for similar businesses (12- 14 per cent) Acquisitions Acquisition of another company is accounted for by the acquisition method. This method requires a full purchase price allocation (PPA) in which the purchase price is allocated to identified assets and liabilities in the acquired company. Excess values beyond those allocated to identified assets and liabilities are booked as goodwill. Any deficit values are, after careful assessment, recognised as income through profit/loss in the year of the acquisition (badwill). The analyses contain both concrete calculations and use of best judgement in arriving at the fairest possible value of the acquired companies at the time of acquisition. While some uncertainty invariably attends estimation items, they are supported by determinations of expected cash flows, comparable transactions in previous periods etc. See also note 40 on business acquisitions/business combinations. Companies held for sale SpareBank 1 SMN’s strategy is that ownership resulting from defaulted exposures should at the outset be of brief duration, normally not longer than one year. Work on selling such companies is continuously ongoing, and for accounting purposes they are classified as held for sale. See also note 39 Investments in owner interests. Sale of loan portfolios In the sale of loan portfolios to SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt, the Group considers whether the criteria for derecognition under IAS 39 are met. At the end of the accounting year all transferred portfolios were derecognised from the parent bank’s balance sheet. See also note 9 on derecognition of financial assets. Assets taken over As part of the processing of defaulted loans and guarantees, the bank in some cases takes over assets that have been pledged as security for such engagements. Upon takeover, the assets are valued at the expected realisable value. Any deviation from the balance sheet value of a defaulted or written-down commitment at the time of the takeover is classified as a loan write-down. Assets taken over are entered in the balance sheet according to their nature. On final disposal, the deviation from the balance sheet value is recognised in the accounts according to the nature of the asset.
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249SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 249 Note 4: Operating segments Accounting policy SpareBank 1 SMN has Retail Banking and Corporate Banking, along with the most important subsidiaries and associates as its primary reporting segments. The Group presents a sectoral and industry distribution of loans and deposits as its secondary reporting format. The Group’s segment reporting is in conformity with IFRS 8. For the subsidiaries the figures refer to the respective company accounts, while for associates and joint ventures incorporated by the equity method the Group’s profit share is stated, after tax, as well as book value of the investment at Group level. Group (2025) Profit and loss account (NOKm) RM CM EM 1 SB 1 Finans MN SB 1 Regnskaps- huset SMN Other 1) Uncollated Total Net interest 1,868 2,314 2 558 4 - 597 5,343 Interest from allocated capital 420 329 - - - - -749 - Total interest income 2,288 2,643 2 558 4 - -152 5,343 Comission income and other income 916 399 566 -99 846 - -26 2,602 Net return on financial investments 1 12 1 - - 1,017 92 1,123 Total income 3,205 3,053 569 459 850 1,017 -86 9,068 Total operating expenses 1,383 742 493 136 744 - -18 3,479 Ordinary operating profit 1,822 2,312 76 323 106 1,017 -68 5,589 Loss on loans, guarantees etc. -5 109 - 36 - - -0 140 Result before tax 1,827 2,203 76 288 106 1,017 -68 5,449
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250SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Group (2024) Profit and loss account (NOKm) RM CM EM 1 SB 1 Finans MN SB 1 Regnskaps- huset SMN Other1) Uncollated Total Net interest 1,888 2,219 6 549 4 - 708 5,373 Interest from allocated capital 354 305 - - - - -659 - Total interest income 2,242 2,524 6 549 4 - 49 5,373 Comission income and other income 807 346 505 -96 804 - 26 2,392 Net return on financial investments -11 7 1 - - 1,254 106 1,357 Total income 3,039 2,877 512 453 808 1,254 179 9,123 Total operating expenses 1,278 700 442 136 730 - 15 3,300 Ordinary operating profit 1,761 2,177 71 317 78 1,254 165 5,823 Loss on loans, guarantees etc. 18 138 - 20 - - -0 176 Result before tax 1,743 2,039 71 298 78 1,254 165 5,647 1) Specification of other (NOKm) 2025 2024 SpareBank 1 Gruppen 446 226 Gain from merger Fremtind/Eika - 452 SpareBank 1 Boligkreditt 105 129 SpareBank 1 Næringskreditt 9 14 BN Bank 291 302 SB1 Markets 74 89 Kredittbanken 7 -10 SpareBank 1 Betaling -6 -19 SpareBank 1 Forvaltning 58 54 Other companies 35 15 Income from investment in associates and joint ventures 1,017 1,254
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251SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 5: Capital adequacy Capital adequacy is calculated and reported in accordance with the EU capital requirements regulations for banks and investment firms (CRR/CRD). SpareBank 1 SMN utilises the Internal Rating Based Approach (IRB) for credit risk. Advanced IRB approach is used for the corporate portfolios. Use of IRB imposes wide-ranging requirements on the bank’s organisational set-up, competence, risk models and risk management systems. As of 31 december 2025 the overall minimum requirement on CET1 capital is 14.0 per cent. The capital conservation buffer requirement is 2.5 per cent, the systemic risk requirement for Norwegian IRB-banks is 4.5 per cent and the Norwegian countercyclical buffer is 2.5 per cent. These requirements are additional to the requirement of 4.5 per cent CET1 capital. In addition, the financial supervisory authority has set a Pillar 2 requirement for SpareBank 1 SMN (P2R) of 1.6 per cent of the Group’s calculation basis, representing a cut of 0.1 percentage points in the previous Pillar 2 requirement. At least 56.25 per cent of the requirement must be covered by CET1 capital, while 75 per cent must be covered by Tier 1 capital. Finanstilsynet has also decided to reduce the expected capital requirement margin (P2G) from at least 1.25 per cent to at least 1.00 per cent of the Group’s calculation basis. In response to the above, the Board of Directors adopted a new long- term target for its CET1 capital ratio on 18 December 2025, effective as of 31 December 2025. The target has been set at a minimum of 15.9 per cent. SpareBank 1 SMN has been subject to a temporary Pillar 2 capital premium of 0.7 percentage points since 30 April 2022, based on IRB models for corporate clients. Effective as of Q4 2025, the bank has adopted revised IRB models for corporate clients in accordance with conditions set by Finanstilsynet. The temporary premium of 0.7 percentage points has lapsed as of the same date. In accordance with the CRR/CRD regulation, from 1 July 2025, the average risk weights for exsposures secured by residential properties may not be lower than 25 per cent. As of 31 December 2025, the average risk weights have been adjusted upwards to 25 per cent for both the parent bank and the Group. The systemic risk buffer stands at 4.5 per cent for the Norwegian exposures. For exposures in other countries, the particular country’s systemic buffer rate shall be employed. As of 31 December 2025 the effective rate for the group is 4.44 per cent. The countercyclical buffer is calculated using differentiated rates. For exposures in other countries the countercyclical buffer rate set by the authorities in the country concerned is applied. If that country has not set a rate, the same rate as for exposures in Norway is applied unless the Ministry of Finance sets another rate. As of 31 December 2025 both the parent bank and the Group is below the capital deduction threshold such that the Norwegian rate is applied to all relevant exposures.
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252SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Parent Bank Group 31 Dec 2024 31 Dec 2025 (NOKm) 31 Dec 2025 31 Dec 2024 25,898 26,695 Total book equity 31,865 30,523 -1,943 -1,900 Additional Tier 1 capital instruments included in total equity -1,996 -2,039 -771 -753 Deferred taxes, goodwill and other intangible assets -1,637 -2,272 -2,698 -2,915 Deduction for allocated dividends and gifts -2,915 -2,698 - - Non-controlling interests recognised in other equity capital -700 -821 - - Non-controlling interests eligible for inclusion in CET1 capital 535 700 -58 -53 Value adjustments due to requirements for prudent valuation -73 -78 -407 -367 Positive value of adjusted expected loss under IRB Approach -524 -641 - - Cash flow hedge reserve - -2 -350 -350 Deduction for common equity Tier 1 capital in significant investments in financial institutions -1,228 -264 19,670 20,358 Common equity Tier 1 capital 23,328 22,409 1,800 1,900 Additional Tier 1 capital instruments 2,452 2,409 -49 -49 Deduction for significant investments in financial institutions -49 -49 21,422 22,208 Tier 1 capital 25,731 24,769 - - Supplementary capital in excess of core capital - - 2,650 2,750 Subordinated capital 3,457 3,465 -230 -230 Deduction for significant investments in financial institutions -230 -230 2,420 2,520 Additional Tier 2 capital instruments 3,227 3,235 23,842 24,728 Total eligible capital 28,958 28,004
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253SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Parent Bank Group 31 Dec 2024 31 Dec 2025 (NOKm) 31 Dec 2025 31 Dec 2024 Minimum requirements subordinated capital 17,015 19,214 Specialised enterprises 21,884 20,514 12,252 15,045 Corporate 15,677 12,422 21,185 22,949 Mass market exposure, property 35,775 39,806 1,498 2,019 Other mass market 2,071 1,540 19,411 - Equity positions IRB - - 71,361 59,226 Total credit risk IRB 75,407 74,283 15 15 Central government 305 324 1,450 1,306 Covered bonds 1,794 2,100 4,540 5,371 Institutions 2,758 3,327 1,032 586 Local and regional authorities, state-owned enterprises 828 1,177 3,145 1,568 Corporate 4,172 6,895 216 13 Mass market 8,493 9,141 840 3,083 Exposures secured on real property 4,717 1,592 - 9 Defaulted exposures 478 - 889 14,695 Equity positions 7,017 5,946 1,682 1,560 Other assets 2,618 2,734 13,810 28,206 Total credit risk standardised approach 33,180 33,235 409 470 Debt risk 495 405 - 90 Equity risk 181 137 - - Currency risk and risk exposure for settlement/deliver y 35 13 7,859 9,206 Operational risk 14,013 13,125 463 456 Credit value adjustment risk (CVA) 1,316 1,424 - 4,684 Modified risk weights - residential and commercial property (macr oprudential tools) 14,645 - 93,902 102,337 Minimum requirements subordinated capital 139,273 122,622 7,512 8,187 Risk weighted assets (RWA) 11,142 9,810 4,226 4,605 Minimum requirement on CET1 capital, 4.5 per cent 6,267 5,518
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254SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Capital Buffers 2,348 2,558 Capital conservation buffer, 2.5 per cent 3,482 3,066 4,179 4,554 Systemic risk buffer, 4.44 per cent 6,184 5,444 2,348 2,558 Countercyclical buffer, 1.0 per cent 3,482 3,066 8,874 9,671 Total buffer requirements on CET1 capital 13,147 11,576 6,571 6,082 Available CET1 capital after buffer requirements 3,914 5,315 Capital adequacy 20.9 % 19.9 % Common equity Tier 1 capital ratio 16.8 % 18.3 % 22.8 % 21.7 % Tier 1 capital ratio 18.5 % 20.2 % 25.4 % 24.2 % Capital ratio 20.8 % 22.8 % Leverage ratio 235,069 235,450 Balance sheet items 347,411 342,557 8,473 16,668 Off-balance sheet items 18,816 10,145 -513 -468 Regulatory adjustments -647 -768 243,028 251,650 Calculation basis for leverage ratio 365,580 351,934 21,422 22,208 Core capital 25,731 24,769 8.8 % 8.8 % Leverage Ratio 7 .0 % 7.0 %
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255SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 6: Risk factors Risk management SpareBank 1 SMN aims to maintain a moderate risk profile and to apply risk monitoring of such high quality that no single event will seriously impair the Group’s financial position. The Group’s risk profile is quantified through targets for rating, concentration, riskadjusted return, probability of default, loss ratios, expected loss, necessary economic capital, regulatory capital adequacy, and liquidity-related regulatory requirements. The principles underlying SpareBank 1 SMN’s risk management are laid down in the risk management policy. The Group gives much emphasis to identifying, measuring, managing and monitoring central risks in such a way that the Group progresses in line with its adopted risk profile and strategies. The bank’s three lines of defence against financial loss or impaired reputation comprise: 1. Prudent risk limits which reduce the probability of a bank-specific event , and a good internal control function which ensure compliance with the limits. 2. The period’s financial result, a buffer to absorb volatility and loss within the adopted risk appetite, and which allow s time to make adjustments in business plans/risk profile. 3. Sufficient liquidity and equity capital to manage unexpected events and crises. Risk management within the Group is intended to support the Gr oup’s strategic development and target attainment. The risk management regime is also designed to ensure financial stability and prudent asset management. This will be achieved through: • A strong organisation culture featuring high risk-management awar eness • A sound understanding of the risks that drive earnings and risk costs, thereb y creating a better basis for decision-making • Striving for an optimal use of capital within the adopted business strategy • Avoiding unexpected negative ev ents which could be seriously detrimental to the Group’s financial position • Exploiting synergies and diversification effects The Gr oup’s risk is quantified inter alia by calculating expected loss and the need for riskadjusted capital (economic capital) to meet unexpected losses. Expected loss is the amount which statistically can be expected to be lost in a 12-month period. Risk-adjusted capital is the volume of capital the Group considers it needs to meet the actual risk incurred by the Group. The Board of Directors has decided that the riskadjusted capital should cover 99.9 per cent of all possible unexpected losses. Statistical methods are employed to compute expected loss and risk-adjusted capital, but the calculation requires expert assessments in some cases. In the case of risk types where no recognised methods of calculating capital needs are available, the Group defines risk management limits that limit loss risk in accordance with the adopted risk appetite. For further details see the Group’s Pillar III reporting which is available on the bank’s website. The Group has incorporated ESG in steering documents, including risk management policy, credit strategy and credit policy. ESG risk, including climate risk, is considered a driver of financial risk and reputational risk. The Group’s overall risk exposure and risk trend are monitored on a continual basis. Status and development are reported on by way of periodic risk reports to the administration and the Board of Directors. Overall risk monitoring and reporting are performed by Risk Management which is independent of the Group’s business lines. Credit risk Credit risk is the risk of loss resulting from the inability or unwillingness of customers or counterparties to honour their commitments to the Group. The Group is exposed to credit risk through all customer and counterparty receivables. The main exposure is through ordinary lending and leasing activities, but the Group’s credit risk also has a bearing on the liquidity reserve portfolio through counterparty risk arising from interest rate and foreign exchange derivatives. Credit risk associated with the Group’s lending activity is the risk area with the highest requirement as to capital, both under internal assessments and capital requirement calculations under the CRR. Through its annual review of the bank’s credit strategy, the board of directors concretises the Group’s risk appetite by establishing thresholds and limits for the bank’s credit portfolio. The limits define the lending activity’s boundaries. Deviations with respect to thresholds obliges the credit manager to comment on the deviation to the board of directors and in most cases to prepare action plans in order to reduce risk. The bank’s credit strategy and credit policy are derived from the bank’s main strategy, and contain guidelines for the risk profile, including credit quality and concentration risk. Concentration risk is managed by distribution between Retail Banking and Corporate Banking, limits on the size of loan and loss ratio on single exposures, limits on maximum exposure for the twenty largest grouped exposures, limits on maximum exposure within industries and a limit that ensures industry diversification among the 20 largest customers. Compliance with credit strategy and thresholds and limits adopted by the board of directors is monitored on a continual basis by the Group Credit Committee and reported quarterly to the board of directors by way of the risk report.
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256SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS The Board of Directors delegates lending authorisation to the Group CEO. The Group CEO can further delegate authorisations below divisional director level. Lending authorisations are graded in relation to exposure size and risk profile. The bank has a department dedicated to credit support which assists in or takes over dealings with customers who are clearly unable, or are highly likely to become unable, to service their debts unless action is taken beyond ordinary follow-up. The bank’s exposure to climate risk is mapped by means of qualitative assessments of physical risk and transition risk at industry level, and through the requirement of ESG scoring of all credit cases above NOK 10m for corporate customers. In addition, the bank has estimated greenhouse gas emissions from the bank’s loan customers. Transition plans have been prepared towards a low emissions society for all significant industries in the bank. The transition plans communicate expectations and requirements we place on our customers. Strategies and policies are regularly assessed to ensure that measures against climate risk in the loan portfolio are adequate with reference to risk appetite. The bank has in 2025 not applied exclusion of industries or customer Groups as a tool to curb climate risk. The bank’s risk classification system was developed to quantify credit risk, and thus to enable management of the bank’s loan portfolio in keeping with the bank’s credit strategy and to measure risk-adjusted return. The bank has approval to use internal models in its risk management and capital calculation (IRB) with respect to loans and guarantees to the mass market and undertakings. Approval to use the advanced IRB approach was given by Finanstilsynet in 2015. The bank uses IRB models for risk classification, capital allocation, risk pricing and portfolio management. Several technical changes are made related to the IRB-approach in 2025: • 30 June 2025: The Bank reports according to CRR3. No significant effects from the change fr om CRR2 for the banks risk assesment or solidity in the short term. • 30 September 2025: Risk weight floor for residential loans increased from 20 per cent to 25 per cent . In isolation, this entailed a reduction in the CET1 ratio of 1.4 percentage points for the group. • 31 December 2025: Approval of revised IRB-models f or corporates, with buffer conditions. The bank has adopted the new models in accordance with the conditions. New models leads to increased capital requirements, approximately at the level of the temporary Pillar 2 margin of 0.7 per cent of the risk weighted assets. The temporary margin of 0.7 percentage points has lapsed as of the same date. The risk classification system (IRB) builds on the following main components: 1. Probability of Default (PD) The bank’s credit models are based on statistical computations of probability of default. The calculations are based on scoring models that take into account financial position and internal and external behavioural data. The models are partly point-in-time oriented, and reflect the probability of default in the course of the next 12 months under current economic conditions. The models are calibrated against a long-term outcome. Customers are assigned to one of nine risk classes based on PD, in addition to two risk classes for exposures in default and/or subject to impairment write down. The models are validated on an ongoing basis and at least once per year both with respect to their ability to rank customers and to estimate PD levels. The validation results confirm that the models’ accuracy meets internal criteria and international recommendations. The bank has also developed a cashflow-based PD model used for exposures to commercial property lease. The bank will apply to Finanstilsynet for permission to use this model in its capital calculation (IRB). 2. Exposure at Default (EAD) EAD is an estimation of the size of an exposure in the event of, and at the time of, a counterparty’s default. For drawing rights, a conversion factor (CF) is used to estimate how much of the present unutilised credit ceiling will have been utilised at a future default date. For guarantees, a government-determined CF is used to estimate what portion of issued guarantees will be brought to bear upon default. The CF is validated monthly for drawing rights in the retail market and corporate market. The bank’s EAD model takes account of differences both between products and customer types. 3. Loss Given Default (LGD) LGD-models estimate the proportion of a loan that is expected to be lost in the event of default, and the estimate takes into account economic downturns. The model follows a workout approach, and the estimate is a function of the probability of recovery (defaults resolved without realisation), and the expected recovered value of the collateral (given realisation). The model is used both regulatoryly and financially. LGD is modelled separately for corporate and retail customers, the estimates are calibrated to long-term outcomes, downturn-adjusted, and safety margins are added for uncertainty. The three above-mentioned parameters (PD, EAD and LGD) underlie the Group’s portfolio classification and statistical calculation of expected loss (EL) and need for economic capital and regulatory capital.
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257SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 257 Counterparty risk Counterparty risk in derivatives trading is managed through ISDA and CSA contracts set up with financial institutions that are the bank’s largest counterparties. ISDA contracts regulate settlements between financial counterparties. The CSA contracts limit maximum exposure through market evaluation of the portfolio and margin calls when the change in portfolio value exceeds the maximum agreed limit or threshold amount. The bank will continue to enter CSA contracts with financial counterparties to manage counterparty risk. See note 12 for a further description of these contracts. Counterparty risk for customers is hedged through use of cash depots or other collateral which, at all times, have to exceed the market value of the customer’s portfolio. Specific procedures have been established for calling for further collateral or to close positions if market values exceed 80 per cent of the collateral. Market risk Market risk is a generic term for the risk of loss and reduction of future incomes as a result of changes in observable rates or prices of financial instruments. Market risk arises at SpareBank 1 SMN mainly in connection with the bank’s investments in bonds, CDs and shares, including funding. SpareBank 1 has outsourced customer trading in fixed income and foreign currency instruments to SB1 Markets. This customer activity, and SB1 Markets’ use of the bank’s balance sheet, also affect the bank’s market risk. Market risk is managed through limits for investments in shares, bonds and positions in the fixed income and currency markets. The Group’s strategy for market risk lays the basis for management reporting, control and follow-up of compliance with limits and guidelines. The bank limits market risk through active use of hedging instruments. Uncovered market risk must be managed within assigned limits. Limits are reviewed at least once a year and adopted yearly by the bank’s Board of Directors. Compliance with the limits is monitored by Risk Management, and exposures relative to the adopted limits are reported quarterly to the Board of Directors. Interest rate risk is the risk of loss due to changes in interest rates in financial markets. The risk on all interest rate positions can be viewed in terms of the change in value of interest rate instruments resulting from a rate change of 1 percentage point across the entire interest rate curve on all balance sheet items. The Group utilises analyses showing the effect of this change for various maturity bands, with separate limits applying to interest rate exposure within each maturity band and across all maturity bands as a whole, including EVE and NII for interest rate risk in the banking book. Interest rate lock-ins on the Group’s instruments are essentially short, and the Group’s interest rate risk is low to moderate. Spread risk is the risk of loss as a result of changes in market value/fair value of bonds due to general changes in credit spreads. The bond portfolio is managed based on an evaluation of the individual issuers. In addition, the bank has a separate limit for overall spread risk and for the business lines. The bank calculates spread risk based on Finanstilsynet’s module for market and credit risk. The loss potential for the individual credit exposure is calculated with a basis in rating and duration. Exchange rate risk is the risk of loss resulting from exchange rate movements. The Group measures exchange rate risk on the basis of net positions in the various currencies. Limits on exchange rate risk are expressed in limits for the maximum aggregate foreign exchange position in individual currencies. Equity risk is the risk of loss on positions as a result of changes in share prices. Limits are set for the various portfolios as well as limits for total equity risk. Shares in subsidiaries and shares forming part of a consolidated or strategic assessment are not included. Liquidity risk Liquidity risk is the risk that the Group will be unable to refinance its debt or unable to finance increases in its assets. The bank’s most important source of finance is customer deposits. At end-2025 the Group’s ratio of deposits to loans was 56 per cent, including loans sold to SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt, compared with 57 per cent at end-2024. (Group figures). The bank reduces its liquidity risk by diversifying funding across a variety of markets, funding sources, maturities and instruments, and by employing long-term funding. Excessive concentration of maturities heightens vulnerability with regard to refinancing. The Group seeks to mitigate such risk by applying defined limits. The bank’s finance division is responsible for the Group’s financing and liquidity management. Compliance with limits is monitored by Risk Management which reports monthly to the board of directors, but breached limits can be reported on an ongoing basis. The Group manages its liquidity on an overall basis by assigning responsibility for funding both the bank and the subsidiaries to the finance division. Governance is based in the Group’s overall liquidity strategy which is reviewed and adopted by the board at least once each year. The liquidity strategy reflects the Group’s moderate risk profile. As a part of the strategy, emergency plans have been drawn up both for the Group and the SpareBank 1 Alliance to handle the liquidity situation in periods of turbulent capital markets. These take into account periods of both bank-specific and system-related crisis scenarios as well as a combination of the two. The bank shall have a holding of liquid assets sufficient to cover a minimum of 12 months’ ordinary operation without access to external funding and to withstand a house price fall of 30 per cent. The bank shall in addition have an adequate liquidity buffer consisting of assets that meet the LCR requirements, and which in volume at all times ensures that the bank is above the minimum requirement. The average residual maturity on debt created by issue of securities at the end of 2025 was 2.4 years. The overall LCR at the same point was 156 per cent. The LCR in norwegian kroner and euro was 117 per cent and 1,357 per cent respectively. Access to funding has been satisfactory in 2025. The Group has issued green bonds worth NOK 18bn, down from 24bn in 2024.
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258SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 258 The Group’s liquidity situation as of 31 December 2025 is considered satisfactory. Operational risk Operational risk can be defined as the risk of loss resulting from: • People: Breaches of procedures/guidelines, inadequate competence, unclear policy , strategy or procedures, internal malpractices • Systems: Failure of ICT or other systems • External causes: Criminality, natural disaster, other external causes Operational risk is a risk category that captures the gr eat majority of costs associated with quality lapses in the Group’s current activity. Management of operational risk has acquired increased importance in the financial industry in recent years. Contributory factors are internationalisation, strong technological development and steadily growing demands from customers, public authorities and other interest Groups. Many substantial loss events in the international financial industry have originated in failures in this risk area. Identification, management and control of operational risk are an integral part of managerial responsibility at all levels of SpareBank 1 SMN. Managers’ most important aids in this work are professional insight and leadership skills along with action plans, control procedures and good follow-up systems. A systematic programme of risk assessments also contributes to increased knowledge and awareness of current needs for improvement in one’s own unit. Any weaknesses and improvements are reported to higher levels in the organisation. SpareBank 1 SMN attaches importance to authorisation structures, good descriptions of procedures and clear definition of responsibilities in supply contracts between the respective divisions as elements in a framework for handling operational risk. The management views the undertaking’s IT systems as central to operations, to accounting for and to the reporting of executed transactions, as well as to providing a basis for important estimates and calculations. The IT systems are mainly standardised, and their management and operation are largely outsourced to service suppliers. Process and risk analyses are carried out in all material areas of activity in the bank. In these analyses a risk assessment is made at process level to obtain an overview of the largest operational risks related to the bank’s business and support processes. Upon the introduction of new products, services, systems or processes a risk assessment and quality assurance are undertaken. A number of the bank’s specialist areas are involved in this process. They include risk management, compliance, legal affairs, data protection officer, AML and information security. This risk assessment contributes to keeping operational risk related to new products, services, systems and processes to an acceptable level. The bank uses a Governance, Risk and Compliance (GRC) system as a tool to improve the monitoring of risk, events and areas for improvement. An important area is event registration where these are employed for learning and improvement purposes. A structured process has been established involving follow-up of events with the responsible areas. Personnel with quality responsibilities and specialist responsibilities are involved to identify the need for measures such as process improvements, procedural changes and training needs. The system is also an important tool for registering and following up on areas for improvement that are identified by controls performed by the first and second line, as well as areas for improvement pointed out in reviews by the internal auditor. Operational losses are reported periodically to the Board of Directors. The Board of Directors receives each year from the internal audit and the statutory auditor an independent assessment of the Group’s risk and of whether the internal control functions in an appropriate and adequate manner. The Board of Directors considers operational risk in the undertaking to be moderate, including the risk related to the accounting and reporting process. For further information see the bank’s Pillar 3 reporting which is available at smn.no and the following notes: • Note 12: Maximum credit risk exposure • Note 13: Credit quality per class of financial assets • Note 14: Market risk related to interest rate risk • Note 15: Market risk related to currency exposur e
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259SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 259 Note 7: Credit institutions- loans and advances Parent Bank Group 31 Dec 2024 31 Dec 2025 Loans and advances to credit institutions (NOK million) 31 Dec 2025 31 Dec 2024 14,270 13,317 Loans and advances without agreed maturity or notice of withdrawal 2,226 3,651 5,515 - Loans and advances with agreed maturity or notice of withdrawal - 5,515 19,785 13,317 Total 2,226 9,166 Specification of loans and receivables on key currencies 3 13 CAD 13 3 5 5 CHF 5 5 991 649 EUR 649 991 539 389 GBP 389 539 9 4 JPY 4 9 18,141 12,113 NOK 1,022 7,523 20 4 SEK 4 20 41 119 USD 119 41 35 21 Other 21 35 19,785 13,317 Total 2,226 9,166 5.6 % 5.5 % Average rate credit institutions 5.8 % 5.1 % 31 Dec 2024 31 Dec 2025 Deposits from credit institutions (NOK million) 31 Dec 2025 31 Dec 2024 9,593 8,080 Deposits without agreed maturity or notice of withdrawal 8,080 9,594 4,347 1,504 Deposits with agreed maturity or notice of withdrawal 1,504 4,347 13,940 9,584 Total 9,584 13,941
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260SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 260 Specification of deposits on key currencies 653 805 EUR 805 653 30 - GBP - 30 1 1 JPY 1 1 13,215 8,687 NOK 8,687 13,216 0 86 SEK 86 0 34 0 USD 0 34 7 5 Other 5 7 13,940 9,584 Total 9,584 13,941 4.2 % 5.5 % Average rate credit institutions 5.5 % 4.2 % 31 Dec 2024 31 Dec 2025 Other commitments to credit institutions (NOK million) 31 Dec 2025 31 Dec 2024 2,174 1,746 Unutilised credits 1,746 2,174 20 20 Financial guarantees 20 20 2,194 1,767 Total 1,767 2,194 Deposits from and loans to credit institutions with mainly floating interest. The average interest rate is calculated based on the interest income/expense of the holding accounts’ average balance for the given year. This is, however, limited to holding in NOK denominated accounts.
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261SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 8: Loans and advances to customers Accounting policy Loans held in “hold to collect” business models are measured at amortised cost. Amortised cost is acquisition cost less repayments of principal, plus or minus cumulative amortisation resulting from the effective interest rate method, with deductions for loss provisions. The effective interest rate is the interest rate which precisely discounts estimated future cash in- or out-payments over the financial instrument’s expected lifetime. The Bank sells only parts of the loans qualified for transfer to SpareBank 1 Boligkreditt. Loans included in business models (portfolios) with loans qualifying for transfer are therefore held both to collect cash flows and for sales. The Bank therefore classify all residential mortgages at fair value over other comprehensive income. Fair value on such loans at initial recognition are measured at the transaction price, without reduction for 12 month expected credit loss. Fixed interest loans to customers are recognised at fair value. Gains and losses due to changes in fair value are recognised in the income statement as fair value changes. Accrued interest and premiums/discounts are recognised as interest. Interest rate risk on fixed interest loans is managed through interest rate swaps which are recognised at fair value. It is the Group’s view that recognising fixed interest loans at fair value provides more relevant information on carrying values. Parent Bank Group 31 Dec 2024 31 Dec 2025 (NOK million) 31 Dec 2025 31 Dec 2024 167,077 170,862 Gross Loans 184,387 180,102 765 803 Write-downs for expected cr edit losses 891 848 166,312 170,059 Net loans to and advances to customers 183,495 179,254 Additional information 67,830 73,303 Loans sold to SpareBank 1 Boligkreditt 73,303 67,830 994 1,051 - Of which loans to employees 1,849 1,807 1,419 1,234 Loans sold to SpareBank 1 Næringskreditt 1,234 1,419 103 104 Subordinated loan capital other financial institutions - - 2,202 2,308 Loans to employees 1) 3,703 3,625 1) Interest rate subsidies on loans to employees are included in net interest income. The lending rate for employees is 75 per cent of the best mortgage rate for other customers.
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262SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 262 Loans and commitments specified by type Parent Bank Group 31 Dec 2024 31 Dec 2025 Loans and commitments specified by type (NOK million) 31 Dec 2025 31 Dec 2024 Gross loans and advances - - Financial lease 4,619 4,237 17,799 16,652 Bank overdraft and operating credit 16,652 17,799 3,790 2,953 Construction loans 2,953 3,790 145,489 151,257 Amortizing loan 160,162 154,276 167,077 170,862 Total gross loans to and receivables from customer s 184,387 180,102 Other commitments 4,845 5,184 Financial guarantees, of which: 5,184 4,845 1,288 1,121 Payment guarantees 1,121 1,288 1,260 1,281 Performance guarantees 1,281 1,260 810 552 Loan guarantees 552 810 73 76 Guarantees for taxes 76 73 1,413 2,154 Other guarantee commitments 2,154 1,413 1,285 886 Unutilised guarantee commitments 886 1,285 13,124 14,152 Unutilised credits 14,399 13,377 9,926 14,781 Loans approvals (not discounted) 14,937 10,053 20 22 Documentary credits 22 20 29,199 35,024 Total other commitments 35,428 29,578 196,277 205,887 Total loans and commitments 219,814 209,680
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263SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 263 Loans and other commitments specified by sector and industry Parent bank 31 Dec 2025 31 Dec 2024 NOK million Gross loans Other commitments Total loans and commitments Gross loans Other commitments Total loans and commitments Wage earners 94,733 15,860 110,593 92,082 12,606 104,688 Public administration 4 1,034 1,038 37 868 905 Agriculture and forestry 13,190 1,090 14,280 13,029 1,106 14,134 Fisheries and hunting 6,150 997 7,147 6,055 772 6,827 Sea farming industries 3,820 544 4,364 3,835 602 4,437 Manufacturing 3,817 2,858 6,675 3,697 2,826 6,523 Construction, power and water supply 4,868 1,363 6,232 4,996 2,026 7,022 Retail trade, hotels and restaurants 3,560 1,868 5,428 3,266 1,834 5,100 Maritime sector and offshore 685 991 1,677 4,043 1,342 5,385 Property management 24,281 3,555 27,837 23,427 1,089 24,515 Business services 4,432 1,474 5,905 4,965 1,859 6,824 Transport and other services provision 10,159 2,565 12,723 6,099 1,368 7,467 Other sectors 1,163 824 1,987 1,548 903 2,451 Total 170,862 35,024 205,887 167,077 29,199 196,277
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264SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 264 Group 31 Dec 2025 31 Dec 2024 NOK million Gross loans Other commitments Total loans and commitments Gross loans Other commitments Total loans and commitments Wage earners 102,040 16,074 118,114 99,329 12,814 112,143 Public administration 33 1,035 1,068 62 868 930 Agriculture and forestry 13,752 1,107 14,858 13,519 1,120 14,639 Fisheries and hunting 6,177 998 7,175 6,085 773 6,858 Sea farming industries 4,297 558 4,855 4,144 610 4,755 Manufacturing 4,559 2,879 7,438 4,362 2,845 7,207 Construction, power and water supply 6,184 1,402 7,586 6,332 2,064 8,396 Retail trade, hotels and restaurants 4,304 1,890 6,194 4,201 1,860 6,061 Maritime sector and offshore 749 993 1,743 4,043 1,342 5,385 Property management 24,408 3,559 27,967 23,546 1,092 24,638 Business services 5,258 1,501 6,759 5,701 1,883 7,584 Transport and other services provision 11,550 2,605 14,155 7,311 1,403 8,714 Other sectors 1,076 825 1,901 1,466 904 2,369 Total 184,387 35,428 219,814 180,102 29,578 209,680
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265SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 265 Loans and other commitments specified by geographic area Parent bank 31 Dec 2025 31 Dec 2024 NOK million Gross loans Other commitments Total loans and commitments Gross loans Other commitments Total loans and commitments Trøndelag 99,809 17,900 117,710 97,986 15,679 113,665 Møre og Romsdal 37,730 9,781 47,512 38,733 8,271 47,003 Nordland 2,849 156 3,005 2,788 117 2,905 Oslo 13,112 3,888 17,001 11,314 2,519 13,833 Rest of Norway 17,084 3,262 20,346 15,969 2,563 18,532 Abroad 277 36 314 288 51 339 Total 170,862 35,024 205,887 167,077 29,199 196,277 Group 31 Dec 2025 31 Dec 2024 NOK million Gross loans Other commitments Total loans and commitments Gross loans Other commitments Total loans and commitments Trøndelag 104,894 18,056 122,950 102,447 15,813 118,260 Møre og Romsdal 40,886 9,874 50,760 41,734 8,357 50,091 Nordland 4,101 193 4,294 3,047 125 3,171 Oslo 13,356 3,896 17,252 11,580 2,526 14,107 Rest of Norway 17,332 3,269 20,602 21,005 2,707 23,712 Abroad 3,817 140 3,957 288 51 339 Total 184,387 35,428 219,814 180,102 29,578 209,680
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266SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Gross loans sold to SpareBank 1 Boligkreditt 31 Dec 2025 31 Dec 2024 NOK million Gross loans Other commitments Total loans and commitments Gross loans Other commitments Total loans and commitments Trøndelag 42,222 1,734 43,955 39,592 1,415 41,008 Møre og Romsdal 14,247 656 14,904 13,178 569 13,747 Nordland 400 7 408 373 3 376 Oslo 5,251 160 5,410 4,452 85 4,538 Rest of Norway 11,141 238 11,379 10,168 153 10,321 Abroad 43 2 44 66 1 67 Total 73,303 2,797 76,100 67,830 2,226 70,056 Gross loans sold to SpareBank 1 Næringskreditt 31 Dec 2025 31 Dec 2024 NOK million Gross loans Other commitments Total loans and commitments Gross loans Other commitments Total loans and commitments Trøndelag 934 6 940 1,109 - 1,109 Møre og Romsdal 86 0 87 97 - 97 Nordland - - - - - - Oslo 208 1 210 213 - 213 Rest of Norway 5 0 5 - - - Abroad - - - - - - Total 1,234 8 1,241 1,419 - 1,419
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267SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Loans to and claims on customers related to financial leases NOK million 31 Dec 2025 31 Dec 2024 Gross advances related to financial leasing - Maturity less than 1 year 171 153 - Maturity more than 1 year and less than 5 years 2,778 2,490 - Maturity more than 5 years 1,557 1,486 Total gross claims 4,506 4,129 Received income related to financial leasing, not yet earned 113 108 Net investments related to financial leasing 4,619 4,237 Net investments in financial leasing can be broken down as follo ws: - Maturity less than 1 year 183 166 - Maturity more than 1 year and less than 5 years 2,855 2,563 - Maturity more than 5 years 1,581 1,508 Total net claims 4,619 4,237 Loans and other commitments to customers specified by risk group The Bank calculates probability of default (PD) for all customers in the loan portfolio at the time of approval. The probability of default is calculated on the basis of key figures related to earnings, leverage and behaviour. The probability of default forms the basis for key metrics used in the customer risk classification process. In addition, the risk class is used to assign each individual customer to a risk group. See Note 11 for the classification of risk classes. Customers are rescored monthly in the Bank’s portfolio management system. Other commitments include documentary credits, guarantees, undrawn credit facilities and loan commitments. Commitment follow-up is performed based on the size of the exposure, risk level and migration. Risk-based pricing of corporate exposures is based on expected loss and the required economic capital for each individual exposure. The Bank uses macro-based stress tests to estimate impairment requirements related to objective events that have not impacted portfolio quality at the reporting date. The risk group “loss exposed and/or defaulted” consists of customers with defaults exceeding 90 days and/or objective evidence of impairment resulting in reduced future cash flows available to service the exposure. See Note 10: Losses on loans and guarantees for a more detailed description of these exposures.
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268SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Parent bank (2025) Neither default or credit impaired NOK million Lowest risk Low risk Medium risk High risk Highest risk Default and credit impaired Total Gross Loans Fair value through OCI 81,384 9,713 2,716 725 1,280 828 96,644 Stage 1 81,256 8,643 1,254 201 - - 91,355 Stage 2 128 1,069 1,462 523 1,280 - 4,462 Stage 3 - - - - - 828 828 Amortised cost 29,254 17,668 13,724 1,847 810 1,175 64,478 Stage 1 29,123 16,590 10,162 826 - - 56,701 Stage 2 131 1,078 3,562 1,020 810 - 6,602 Stage 3 - - - - - 1,175 1,175 Fair value through Profit and Loss 8,138 1,142 273 77 89 20 9,740 Total Gross Loans 118,776 28,522 16,714 2,649 2,180 2,023 170,862 Other Commitments 21,918 8,256 4,206 394 107 143 35,024 Stage 1 21,913 7,583 2,975 277 10 - 32,757 Stage 2 5 674 1,231 118 96 - 2,124 Stage 3 - - - - - 143 143 Total loans and other commitments 140,694 36,779 20,919 3,043 2,286 2,165 205,887
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269SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Parent bank (2024) Neither default or credit impaired NOK million Lowest risk Low risk Medium risk High risk Highest risk Default and credit impaired Total Gross Loans Fair value through OCI 78,304 9,148 2,639 696 1,313 762 92,863 Stage 1 78,152 8,085 1,124 185 208 - 87,754 Stage 2 152 1,063 1,515 511 1,106 - 4,346 Stage 3 - - - - - 762 762 Amortised cost 27,795 15,694 15,829 1,994 1,100 1,232 63,645 Stage 1 27,534 14,167 12,404 1,118 250 - 55,473 Stage 2 261 1,527 3,425 875 851 - 6,939 Stage 3 - - - - - 1,232 1,232 Fair value through Profit and Loss 8,743 1,320 351 63 72 21 10,570 Total Gross Loans 114,843 26,163 18,819 2,752 2,485 2,015 167,077 Other Commitments 18,289 6,081 4,269 232 160 167 29,199 Stage 1 17,846 5,636 3,269 108 59 - 26,918 Stage 2 443 445 1,000 125 101 - 2,114 Stage 3 - - - - - 167 167 Total loans and other commitments 133,132 32,244 23,089 2,985 2,645 2,182 196,277
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270SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Group (2025) Neither default or credit impaired NOK million Lowest risk Low risk Medium risk High risk Highest risk Default and credit impaired Total Gross Loans Fair value through OCI 81,384 9,713 2,716 725 1,280 828 96,644 Stage 1 81,256 8,643 1,254 201 - - 91,355 Stage 2 128 1,069 1,462 523 1,280 - 4,462 Stage 3 - - - - - 828 828 Amortised cost 29,635 20,748 21,631 3,137 1,507 1,448 78,106 Stage 1 29,504 19,303 17,038 1,519 - - 67,364 Stage 2 131 1,445 4,592 1,618 1,507 - 9,294 Stage 3 - - - - - 1,448 1,448 Fair value through Profit and Loss 8,034 1,142 273 77 89 20 9,636 Total Gross Loans 119,053 31,603 24,620 3,939 2,877 2,295 184,387 Other Commitments 21,918 8,256 4,609 394 107 143 35,428 Stage 1 21,913 7,583 3,181 277 10 - 32,963 Stage 2 5 674 1,429 118 96 - 2,322 Stage 3 - - - - - 143 143 Total loans and other commitments 140,971 39,859 29,229 4,333 2,983 2,438 219,814
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271SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Group (2024) Neither default or credit impaired NOK million Lowest risk Low risk Medium risk High risk Highest risk Default and credit impaired Total Gross Loans Fair value through OCI 78,304 9,148 2,639 696 1,313 762 92,863 Stage 1 78,152 8,085 1,124 185 208 - 87,754 Stage 2 152 1,063 1,515 511 1,106 - 4,346 Stage 3 - - - - - 762 762 Amortised cost 28,013 18,356 23,797 3,194 1,943 1,469 76,772 Stage 1 27,752 16,372 19,235 1,820 250 - 65,428 Stage 2 261 1,984 4,562 1,374 1,694 - 9,876 Stage 3 - - - - - 1,469 1,469 Fair value through Profit and Loss 8,640 1,320 351 63 72 21 10,467 Total Gross Loans 114,958 28,825 26,787 3,952 3,328 2,251 180,102 Other Commitments 18,289 6,081 4,649 232 160 167 29,578 Stage 1 17,846 5,636 3,468 108 59 - 27,117 Stage 2 443 445 1,180 125 101 - 2,294 Stage 3 - - - - - 167 167 Total loans and other commitments 133,247 34,906 31,436 4,184 3,488 2,418 209,680
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272SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Gross loans and commitments sold to SpareBank 1 Boligkreditt 31 Dec 2025 31 Dec 2024 (NOK million) Gross loans Other commitments Total loans and commitments Gross loans Other commitments Total loans and commitments Lowest risk 63,638 2,769 66,407 57,946 2,219 60,165 Low risk 7,422 21 7,443 7,523 2 7,526 Medium risk 1,481 4 1,485 1,538 3 1,541 High risk 386 1 387 418 0 418 Highest risk 321 1 322 353 - 353 Default and written down 55 1 56 52 - 52 Total 73,303 2,797 76,100 67,830 2,224 70,054 Gross loans and commitments sold to SpareBank 1 Næringskreditt 31 Dec 2025 31 Dec 2024 (NOK million) Gross loans Other commitments Total loans and commitments Gross loans Other commitments Total loans and commitments Lowest risk 1,049 7 1,056 1,073 - 1,073 Low risk 29 0 29 182 - 182 Medium risk 156 1 157 163 - 163 High risk - - - - - - Highest risk - - - - - - Default and written down - - - - - - Total 1,234 8 1,241 1,419 - 1,419
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273SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 9: Derecognition of financial assets As part of its ordinary operations, the Bank carries out transactions that result in the sale of financial assets. Such financial assets are primarily transferred through the sale of residential mortgage loans to SpareBank 1 Boligkreditt or commercial real estate loans to SpareBank 1 Næringskreditt. The consideration received for loans sold to SpareBank 1 Boligkreditt AS and SpareBank 1 Næringskreditt AS corresponds to book value and is assessed to be consistent with the fair value of the loans at the time of sale. Pursuant to servicing agreements entered into with the mortgage companies, the Bank services the loans and maintains customer relationships. The Bank receives consideration in the form of commissions for the obligations associated with servicing the loans. The mortgage companies may sell loans acquired from the Bank, in which case the Bank’s right to service the customers and receive commissions is transferred together with the loans. If the Bank is unable to service the customers, the right to servicing and related commissions may cease. Furthermore, the Bank may hold options to repurchase loans subject to specified conditions. If the mortgage companies incur losses on acquired loans, they have a limited right to set off such losses against commissions payable to all banks that have sold loans. Consequently, there is limited continuing involvement related to the sold loans through the potential limited set-off of losses against commissions. However, this possibility of set-off is not considered to be of such a nature as to alter the conclusion that substantially all the risks and rewards of ownership have been transferred. The Bank’s maximum exposure to loss is represented by the highest amount that could be required to be covered under the agreements. The Bank has assessed the accounting implications and concluded that substantially all the risks and rewards of ownership related to the sold loans have been transferred to the mortgage companies. This results in full derecognition of the sold loans. The Bank recognises separately any rights and obligations created or retained in connection with the sale as assets or liabilities. Commissions received are presented as commission income. SpareBank 1 Boligkreditt SpareBank 1 Boligkreditt AS is owned by savings banks that are part of the SpareBank 1-alliansen. The Bank held an ownership interest of 22.83 per cent as at 31 December 2025 (23.16 per cent as at 31 December 2024). The purpose of the mortgage company is to secure stable, long-term funding for residential mortgages for the alliance banks at competitive prices. The covered bonds (OMF) issued by SpareBank 1 Boligkreditt have an Aaa rating from Moody’s. SpareBank 1 Boligkreditt AS acquires residential mortgage loans and issues covered bonds in accordance with the regulatory framework established in 2007. As a shareholder, the Bank can sell loans to the company, and as part of the Bank’s funding strategy, loans have been transferred to the company. Loans sold to SpareBank 1 Boligkreditt AS are secured by residential property within 75 per cent of the property value. The sold loans are legally owned by SpareBank 1 Boligkreditt AS, and beyond the right to service the loans and receive commission, as well as the right to repurchase wholly or partially written-down loans, the Bank has no right to use the loans. The Bank services the sold loans and receives a commission based on the net return on the loans sold by the Bank less the costs incurred by the mortgage company. In 2025, residential mortgage loans with a net value of NOK 5.5 billion were purchased and sold (NOK 3.1 billion in 2024) to SpareBank 1 Boligkreditt. At the end of the financial year, a total of NOK 73.3 billion in residential mortgage loans had been derecognised and transferred to SpareBank 1 Boligkreditt (NOK 67.8 billion in 2024). Solidity The Bank has also entered into a shareholder agreement with the other shareholders of SpareBank 1 Boligkreditt AS. This agreement entails, among other things, that the Bank shall contribute to ensuring that SpareBank 1 Boligkreditt AS maintains a Common Equity Tier 1 (CET1) capital ratio at all times that meets the regulatory requirements set by the authorities (including buffer capital requirements and Pillar 2 requirements), and, if necessary, provide CET1 capital if the ratio falls below the required level. SpareBank 1 Boligkreditt AS has internal guidelines for CET1 capital adequacy that exceed the regulatory requirements, as well as a management buffer of 0.8 per cent. Based on a specific assessment, the Bank has chosen not to hold capital for this obligation, as the risk that the Bank will be required to contribute is considered to be very low. SpareBank 1 Næringskreditt SpareBank 1 Næringskreditt AS is owned by savings banks that are part of the SpareBank 1-alliansen. The Bank held an ownership interest of 14.8 per cent as at 31 December 2025 (12.7 per cent as at 31 December 2024). The purpose of the credit institution is to provide the alliance banks with stable, long-term financing of commercial real estate at competitive prices. SpareBank 1 Næringskreditt AS acquires loans secured on commercial real estate and issues covered bonds in accordance with the regulations established in 2007. The bonds are rated Aaa by Moody’s. As part of the Bank’s funding strategy, loans have been transferred to the company. Loans transferred to SpareBank 1 Næringskreditt AS are secured by mortgages on commercial real estate within 60 per cent of appraised value.
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274SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Total loans sold to SpareBank 1 Næringskreditt were reduced by NOK 185 million in 2025 (a reduction of NOK 330 million in 2024). In total, commercial real estate loans amounting to NOK 1.1 billion had been derecognised and transferred to SpareBank 1 Næringskreditt as at the end of the financial year (NOK 1.3 billion in 2024). Solidity The Bank has also entered into a shareholder agreement with the other shareholders of SpareBank 1 Næringskreditt AS. This agreement entails, among other things, that the Bank shall contribute to ensuring that SpareBank 1 Næringskreditt AS maintains a Common Equity Tier 1 (CET1) capital ratio at all times that meets the regulatory requirements set by the authorities (including buffer capital requirements and Pillar 2 requirements), and, if necessary, to provide core capital if the ratio falls below the required level. SpareBank 1 Næringskreditt AS has established internal guidelines for CET1 capital adequacy that exceed the regulatory requirements, as well as a management buffer of 0.4 per cent. Based on a specific assessment, the Bank has chosen not to hold capital for this obligation, as the risk of the Bank being required to contribute is considered to be very low.
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275SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 275 Note 10: Losses on loans and guarantees Accounting policy Loan loss provisions are recognised based on expected credit loss (ECL). The general model for provisions for loss of financial assets in IFRS 9 applies to both financial assets measured at amortised cost and to financial assets at fair value with changes in value through profit or loss, which are not impaired when purchased or issued. In addition, unused credit, loan commitments and financial guarantee contracts that are not measured at fair value through profit or loss are also included. Measurement of the provision for expected loss depends on whether credit risk has increased significantly since first- time recognition. Upon first-time recognition, and when credit risk has not increased significantly since first-time recognition, provision shall be made for expected loss occuring due to defaults that occur within 12 months. If credit risk has risen significantly, provision shall be made for expected loss across the entire life. Loss estimates are prepared quarterly, and build on data in the data warehouse which has historical accounting and customer data for the entire credit portfolio. The bank uses three macroeconomic scenarios to take into account non-linear aspects of expected losses. The various scenarios are used to adjust relevant parameters for calculating expected losses, and a probability-weighted average of expected losses under the respective scenarios is recognised as a loss. Loss estimates are computed based on 12-month and lifelong probability of default (PD), loss given default (LGD) and exposure at default (EAD). The data warehouse contains historical data for observed PD and observed LGD. This forms the basis for estimating future values for PD and LGD. In keeping with IFRS 9 the bank Groups its loans in three stages: Stage 1: This is the starting point for all financial assets covered by the general loss model. All assets that do not have significantly higher credit risk than at first-time recognition receive a loss provision corresponding to 12 months’ expected loss. All assets that are not transferred to stage 2 or 3 reside in this category. Stage 2: Stage 2 of the loss model encompasses assets that show a significant increase in credit risk since first-time recognition, but where objective evidence of loss is not present. For these assets a provision for expected loss over the entire lifetime is to be made. In this group we find accounts with a significant degree of credit deterioration, but which at the balance sheet date belong to customers classified as performing. As regards delineation against stage 1, the bank defines ‘significant degree of credit deterioration’ by taking basis in whether the exposure’s calculated probability of default shows a significant increase. SpareBank 1 SMN has decided to utilise both absolute and relative changes in PD as criteria for transfer to stage 2. The most important factor for a significant change in credit risk is the quantitative change in PD on the period end compared to the PD at first time recognition. A change in PD by more than 150 per cent is considered to be a significant change in credit risk. The change will have to be over 0.6 percentage points. In addition, customers with payments 30 days past due will be transferred to stage 2. A qualitative assessment is also done when engagements have been put on watch list or given forbearance. The thresholds for movement between Stage 1 and Stage 2 are symmetrical. After a financial asset has transferred to Stage 2, if its credit risk is no longer considered to have significantly increased relative to its initial recognition, the financial asset will move back to Stage 1. Stage 3: Stage 3 of the loss model encompasses assets that show a significant increase in credit risk since loan approval and where there is objective evidence of loss at the balance sheet date. For these assets a provision shall be made for expected loss over the entire lifetime. These are assets which under previous rules were defined as defaulted and written down. Impairment must be a result of one or more events occurring after first-time recognition (a loss event), and it must be possible to measure the result of the loss event(s) reliably. Objective evidence of impairment of a financial asset includes observable data which come to the Group’s knowledge on the following loss events: • significant financial difficulties on the part of the issuer or borrower • a not insignificant breach of contract, such as failure to pa y instalments and interest • the Group grants the borrower special terms in light of financial or legal aspects o f the borrower’s situation • the debtor is likely to start debt negotiation or other financial restructuring • due to financial problems, the active markets for the financial asset cease The Group assesses fir st whether individual objective evidence exists that individually significant financial assets have suffered impairment. Where there is objective evidence of impairment, the size of the impairment is measured as the difference between the asset’s carrying value and the present value of estimated future cash flows (excluding future credit losses that have not been incurred), discounted at the financial asset’s original effective interest rate. The carrying value of the asset is reduced through a provision account and the loss is recognised in the income statement.
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276SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Defaulted or non-performing loans Default is defined in two categories: 1) payment default or 2) default based on manual default marking; 1. Payment default is defined as material payment arrears or o verdrafts of more than 90 days’ duration. Threshold values for material arrears or overdrafts are set out in the Norwegian CRR/CRD IV regulations. 2. Default resulting from manual default marking is based to a larger degr ee on individual credit assessments, and to a lesser degree on automatic mechanisms. Events included in this category are provision for loss on a customer loan, bankruptcy/ debt restructuring, forbearance assessments, deferment of interest and instalment payments for more than 180 days, or other indications suggesting considerable doubt as to whether the borrower will perform his obligations. The default definition include a ‘waiting period’ during which borrowers are categorised as still in default after the default has been rectified. The waiting period is three months or 12 months depending on the underlying cause of the default. Furthermore, rules on default marking at Group level are introduced whereby corporate customers in default to a Group company will also be considered to be in default to the bank. For personal customers, threshold values are specified for default contagion in the Group. Where a defaulted exposure exceeds 20 per cent of total exposure, the exposure will be considered to be in default at Group level. Actual loan losses Write-down for actual losses (derecognition of book value) are made when the bank has no reasonable expectations to recover the asset in its whole or partially. Criteria for writedown are as follows: • Closed bankruptcy in limited liability companies • Confirmed chord / debt negotiations • Settlement for other companies with limited liability • Ended living at death • By lawful judgment • Collateral is realized The commitment will normally be placed on long-term monitoring in case the debtor should again become solvent and suable. Financial guarantees issued Financial guarantees are contracts that require the bank to reimburse the holder for a loss due to a specific debtor failure to pay in accordance with the terms is classified as issued financial guarantees. On initial recognition of issued financial guarantees, the guarantees are recognised in the balance sheet at the received consideration for the guarantee. Subsequent measurement assesses issued financials guarantees to the highest amount of the loss provision and the amount that was recognised at initial recognition less any cumulative income recognised in the income statement. When issuing financial guarantees, the consideration for the guarantee is recognised under ”Other liabilities” in the balance sheet. Revenue from issued financial guarantees and costs related to purchased financial guarantees is amortised over the duration of the instrument and presented as ”Commission income” or ”Commission expenses”. Changes in expected credit losses are included in the line «Losses on loans and guarantees» in the income statement. Loan commitments Expected credit losses are calculated for loan commitments and presented as ”Other liabilities” in the balance sheet. Changes in the provision for expected losses are presented in the line «Losses on loans and guarantees» in the income statement. For instruments that have both a drawn portion and an unutilised limit, expected credit losses are distributed pro-rata between provisions for loan losses and provisions in the balance sheet based on the relative proportion of exposure.
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277SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 277 Losses on loans and guarantees Parent bank 2025 2024 NOK million RM1) CM1) Totalt RM 1) CM1) Totalt Change in provision for expected credit losses −2 40 38 38 28 65 Actual loan losses on commitments exceeding provisions made 2 80 81 3 105 109 Recoveries on commitments previously written-off −5 −9 −15 −5 −13 −18 Losses for the period on loans and guarantees −5 109 105 36 120 156 1) RM = Retail market, CM = Corporate market Group 2025 2024 NOK million RM1) CM1) Totalt RM 1) CM1) Totalt Change in provision for expected credit losses 0 44 44 33 −14 19 Actual loan losses on commitments exceeding provisions made 12 99 111 9 166 175 Recoveries on commitments previously written-off −5 −10 −15 −5 −14 −19 Losses for the period on loans and guarantees 7 133 140 37 139 176 1) RM = Retail market, CM = Corporate market In 2025, the Group has written off NOK 124 million, which are still subject to enforcement activities, the corresponding figure for 2024 was NOK 140 million.
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278SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 278 Provision for losses on loans and guarantees Parent bank NOK million 1 Jan 25 Change in provision Net write-offs / recoveries 31 Dec 25 Loans as amortised cost- CM 718 46 −40 724 Loans as amortised cost- RM 27 0 −2 25 Loans at fair value over OCI- RM 97 −2 0 95 Loans at fair value over OCI- CM 57 −6 0 50 Provision for expected credit losses on loans and guarantees 899 38 −43 894 Presented as 0 0 0 0 Provision for loan losses 765 81 −43 803 Other debt- provisons 102 −31 0 71 Other comprehensive income - fair value adjustment 31 −12 0 19 NOK million 1 Jan 24 Change in provision Net write-offs / recoveries 31 Dec 24 Loans as amortised cost- CM 671 37 −31 677 Loans as amortised cost- RM 43 26 0 69 Loans at fair value over OCI- RM 137 12 0 149 Loans at fair value over OCI- CM 13 −9 0 4 Provision for expected credit losses on loans and guarantees 864 65 −31 899 Presented as 0 0 0 0 Provision for loan losses 776 20 −31 765 Other debt- provisons 53 50 0 102 Other comprehensive income - fair value adjustment 36 −4 0 31
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279SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 279 Group NOK million 1 Jan 25 Change in provision Net write-offs /recov- eries 31 Dec 25 Loans as amortised cost- CM 780 52 −43 790 Loans as amortised cost- RM 48 2 −2 47 Loans at fair value over OCI- RM 97 −2 0 95 Loans at fair value over OCI- CM 57 −6 0 50 Provision for expected credit losses on loans and guarantees 981 46 −45 982 Presented as 0 0 0 0 Provision for loan losses 848 88 −45 891 Other debt- provisons 102 −31 0 71 Other comprehensive income - fair value adjustment 31 −12 0 19 NOK million 1 Jan 24 Change in provision Net write-offs /recov- eries 31 Dec 24 Loans as amortised cost- CM 777 39 −77 739 Loans as amortised cost- RM 68 21 0 89 Loans at fair value over OCI- RM 137 12 0 149 Loans at fair value over OCI- CM 13 −9 0 4 Provision for expected credit losses on loans and guarantees 995 63 −77 981 Presented as 0 0 0 0 Provision for loan losses 907 18 −77 848 Other debt- provisons 53 50 0 102 Other comprehensive income - fair value adjustment 36 −4 0 31
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280SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 280 Parent bank 31 Dec 2025 31 Dec 2024 NOK million Stage 1 Stage 2 Stage 3 Total Stage 1 Stage 2 Stage 3 Total Retail market Opening balance 22 53 44 119 38 95 45 179 Transfer to (from) stage 1 7 -7 -0 - 16 -16 -0 - Transfer to (from) stage 2 -2 3 -0 - -4 5 -1 - Transfer to (from) stage 3 -0 -5 5 - -1 -9 10 - Net remeasurement of loss allowances -9 14 13 18 -16 36 25 45 Originations or purchases 10 14 2 26 14 20 2 36 Derecognitions -8 -18 -2 -27 -12 -26 -5 -42 Changes due to changed input assumptions -7 -9 -2 -18 1 -3 -4 -6 Actual loan losses - - -2 -2 - - -0 -0 Closing balance 14 45 57 115 36 103 72 211 Corporate Market Opening balance 169 328 180 678 160 267 205 633 Transfer to (from) stage 1 40 -40 -0 - 29 -29 -0 - Transfer to (from) stage 2 -12 16 -4 - -9 11 -2 - Transfer to (from) stage 3 -1 -7 9 - -7 -19 26 - Net remeasurement of loss allowances -31 90 144 203 -23 90 -49 18 Originations or purchases 87 61 2 150 70 57 3 131 Derecognitions -57 -106 -23 -186 -60 -108 -14 -181 Changes due to changed input assumptions -48 -46 -2 -97 -7 8 14 15 Actual loan losses - - -40 -40 - - -31 -31 Closing balance 146 296 266 707 155 278 152 585 Total accrual for loan losses 160 340 323 822 191 382 224 796
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281SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 281 Group 31 Dec 2025 31 Dec 2024 NOK million Stage 1 Stage 2 Stage 3 Total Stage 1 Stage 2 Stage 3 Total Retail market Opening balance 28 66 45 139 46 111 46 204 Transfer to (from) stage 1 10 -9 -0 - 19 -19 -1 - Transfer to (from) stage 2 -3 3 -1 - -5 6 -1 - Transfer to (from) stage 3 -0 -6 7 - -1 -11 12 - Net remeasurement of loss allowances -10 17 13 19 -19 41 25 47 Originations or purchases 12 17 2 31 17 23 2 42 Derecognitions -9 -21 -2 -32 -14 -29 -5 -48 Changes due to changed input assumptions -3 -12 -2 -18 -1 -7 -4 -13 Actual loan losses - - -2 -2 - - -0 -0 Closing balance 25 54 59 137 43 116 73 232 Corporate Market Opening balance 181 363 196 740 172 299 268 739 Transfer to (from) stage 1 45 -44 -0 - 34 -33 -0 - Transfer to (from) stage 2 -14 17 -4 - -10 13 -3 - Transfer to (from) stage 3 -1 -8 10 - -7 -20 27 - Net remeasurement of loss allowances -33 100 159 226 -25 98 -46 27 Originations or purchases 94 69 2 166 75 70 4 149 Derecognitions -59 -110 -24 -193 -62 -112 -14 -188 Changes due to changed input assumptions -56 -56 -11 -123 -10 -1 9 -2 Actual loan losses - - -43 -43 - - -77 -77 Closing balance 157 330 286 773 166 313 168 647 Total accrual for loan losses 182 384 345 911 209 429 241 879
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282SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 282 Accrual for losses on guarantees and unused credit lines Group 31 Dec 2025 31 Dec 2024 NOK million Stage 1 Stage 2 Stage 3 Total Stage 1 Stage 2 Stage 3 Total Opening balance 26 26 50 102 18 27 8 53 Transfer to (from) stage 1 4 −4 0 0 12 -12 -0 - Transfer to (from) stage 2 −1 1 0 0 -1 1 -0 - Transfer to (from) stage 3 0 −1 1 0 -0 -0 1 - Net remeasurement of loss allowances −9 2 −42 −49 -11 9 44 41 Originations or purchases 32 4 0 36 18 4 2 23 Derecognitions −7 −4 0 −11 -6 -4 -2 -12 Changes due to changed input assumptions −15 9 0 −6 -3 2 -2 -3 Actual loan losses 0 0 0 0 - - - - Closing balance 30 33 8 71 26 26 50 102 Of which Retail market 5 6 Corporate Market 67 96
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283SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 283 Provision for credit losses specified by industry Parent bank 31 Dec 2025 31 Dec 2024 NOK million Stage 1 Stage 2 Stage 3 Total Stage 1 Stage 2 Stage 3 Total Agriculture and forestry 2 43 36 81 2 49 28 80 Fisheries and hunting 6 47 5 57 9 65 18 92 Sea farming industries 14 2 11 27 7 2 1 9 Manufacturing 6 31 8 45 11 26 14 51 Construction, power and water supply 21 17 45 83 30 38 43 112 Retail trade, hotels and restaurants 11 24 3 39 12 33 14 59 Maritime sector 1 - - 1 1 - - 1 Property management 44 101 33 178 41 86 28 156 Business services 17 22 7 47 22 22 2 46 Transport and other services 17 15 112 144 25 10 27 62 Public administration 0 0 - 0 0 0 - 0 Other sectors 0 0 - 0 1 0 0 1 Wage earners 1 39 62 101 1 50 48 99 Total provision for losses on loans 140 340 323 803 160 382 224 765 loan loss allowance on loans at FVOCI 19 - - 19 31 - - 31 Total loan loss allowance 160 340 323 822 191 382 224 796
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284SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 284 Group 31 Dec 2025 31 Dec 2024 NOK million Stage 1 Stage 2 Stage 3 Total Stage 1 Stage 2 Stage 3 Total Agriculture and forestry 2 45 37 85 3 51 29 83 Fisheries and hunting 6 47 5 57 9 65 18 92 Sea farming industries 15 3 12 30 8 2 2 11 Manufacturing 8 36 10 55 13 31 17 61 Construction, power and water supply 21 28 48 97 30 57 45 133 Retail trade, hotels and restaurants 15 29 6 49 15 35 14 64 Maritime sector 2 - - 2 1 - - 1 Property management 45 101 33 179 41 87 28 156 Business services 21 25 11 57 24 24 10 58 Transport and other services 21 23 114 158 28 16 29 72 Public administration 0 0 - 0 0 0 - 0 Other sectors 0 0 0 0 1 0 0 1 Wage earners 6 47 68 122 7 62 49 117 Total provision for losses on loans 162 384 345 891 178 429 241 848 loan loss allowance on loans at FVOCI 19 - - 19 31 - - 31 Total loan loss allowance 182 384 345 911 209 429 241 879
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285SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 285 Gross loans Parent bank 31 Dec 2025 31 Dec 2024 NOK million Stage 1 Stage 2 Stage 3 Total Stage 1 Stage 2 Stage 3 Total Retail Market Opening balance 80,631 3,410 736 84,777 90,901 4,553 725 96,178 Transfer to stage 1 771 −753 −18 0 986 −955 −32 0 Transfer to stage 2 −1,192 1,253 −61 0 −1,808 1,852 −44 0 Transfer to stage 3 −45 −145 190 0 −125 −211 336 0 Net increase/decrease amount existing loans −1,938 −79 −29 −2,046 −2,207 −94 −37 −2,337 New loans 40,995 1,229 168 42,392 44,893 1,607 360 46,860 Derecognitions −35,588 −1,353 −210 −37,152 −41,895 −2,003 −320 −44,218 Financial assets with actual loan losses 0 0 −3 −3 0 0 −1 −1 Closing balance 83,633 3,562 773 87,968 90,744 4,749 988 96,481 Corporate Market Opening balance 62,596 7,876 1,258 71,730 47,327 6,988 1,165 55,480 Transfer to stage 1 1,600 −1,590 −10 0 1,259 −1,258 −1 0 Transfer to stage 2 −2,501 2,564 −62 0 −2,487 2,631 −144 0 Transfer to stage 3 −454 −91 545 0 −44 −342 386 0 Net increase/decrease amount existing loans −1,494 −397 −78 −1,969 −1,780 −253 0 −2,033 New loans 24,544 1,283 386 26,213 19,037 971 272 20,281 Derecognitions −19,864 −2,127 −756 −22,748 −10,827 −2,202 −627 −13,655 Financial assets with actual loan losses −5 −15 −53 −73 0 0 −46 −46 Closing balance 64,423 7,502 1,230 73,155 52,484 6,536 1,006 60,026 Closing balance amortized cost and FV through OCI 148,056 11,064 2,003 161,123 143,228 11,286 1,994 156,508 Fixed interest loans at FV 9,740 0 0 9,740 10,570 0 0 10,570 Total gross loans at the end of the period 157,796 11,064 2,003 170,862 153,797 11,286 1,994 167,077
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286SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 286 Parent bank 31 Dec 2025 31 Dec 2024 NOK million Stage 1 Stage 2 Stage 3 Total Stage 1 Stage 2 Stage 3 Total Retail Market Opening balance 86,807 4,358 855 92,021 96,963 5,474 825 103,263 Transfer to stage 1 1,020 −998 −22 0 1,229 −1,193 −36 0 Transfer to stage 2 −1,559 1,636 −77 0 −2,267 2,322 −55 0 Transfer to stage 3 −59 −217 276 0 −152 −267 419 0 Net increase/decrease amount existing loans −1,913 −147 −40 −2,100 −2,191 −170 −52 −2,414 New loans 44,108 1,447 182 45,737 47,975 1,825 371 50,171 Derecognitions −37,510 −1,659 −254 −39,424 −44,637 −2,293 −364 −47,294 Financial assets with actual loan losses 0 0 −3 −3 0 0 −1 −1 Closing balance 90,895 4,421 916 96,231 96,920 5,698 1,107 103,725 Corporate Market Opening balance 66,375 9,864 1,375 77,614 51,327 8,533 1,259 61,119 Transfer to stage 1 1,882 −1,867 −15 0 1,419 −1,412 −6 0 Transfer to stage 2 −2,769 2,847 −78 0 −2,835 2,995 −161 0 Transfer to stage 3 −479 −139 617 0 −79 −378 458 0 Net increase/decrease amount existing loans −1,532 −450 −93 −2,075 −1,867 −286 −14 −2,167 New loans 26,095 1,717 403 28,216 20,250 1,664 304 22,218 Derecognitions −21,744 −2,623 −797 −25,164 −11,953 −2,591 −670 −15,214 Financial assets with actual loan losses −5 −15 −53 −73 0 0 −46 −46 Closing balance 67,824 9,336 1,359 78,519 56,263 8,524 1,123 65,910 Closing balance amortized cost and FV through OCI 158,719 13,756 2,276 174,751 153,182 14,222 2,231 169,635 Fixed interest loans at FV 9,636 0 0 9,636 10,467 0 0 10,467 Total gross loans at the end of the period 168,355 13,756 2,276 184,387 163,649 14,222 2,231 180,102
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287SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 287 Note 11: Credit risk exposure for each internal risk rating The Bank uses a special classification system for monitoring credit risk in the portfolio. Risk classification is based on each individual exposure’s probability of default. In the table below this classification is collated with corresponding rating classes at Moody’s. Historical default data are Parent Bank figures showing the default ratio (DR) per credit quality step. The figures are an unweighted average of customers with normal scores in the period 2016-2025. Collateral cover represents the expected realisation value (RE value) of underlying collaterals. The value are determined using fixed models, and actual realisation value are validated to test their reliability of the model. In accordance with the capital requirements regulations the estimates are downturn estimates. Based on the collateral cover (RE value / EAD) the exposure is classified to one of seven classes, the best of which has a collateral cover above 120 per cent, and the lowest has a collateral cover below 20 per cent. Probability of default Collateral cover Credit quality step From To Moody’s Historical default Default 2025 Collateral class Lower limit Upper limit A 0.00% 0.10% Aaa-A3 0.02% 0.03% 1 120 0 B 0.10% 0.25% Baa1-Baa2 0.04% 0.07% 2 100 120 C 0.25% 0.50% Baa3 0.10% 0.10% 3 80 100 D 0.50% 0.75% Ba1 0.30% 0.31% 4 60 80 E 0.75% 1.25% Ba2 0.63% 0.49% 5 40 60 F 1.25% 2.50% 1.49% 1.49% 6 20 40 G 2.50% 5.00% Ba2-B1 2.39% 3.30% 7 0 20 H 5.00% 10.00% B1-B2 5.00% 6.11% I 10.00% 99.99% B3-Caa3 15.37% 18.80% J Default K Problem loans The Bank’s exposures are classified into risk groups based on credit quality step. Credit quality step Risk groups A - C Lowest risk D - E Low risk F - G Medium risk H High risk I Highest risk J - K Default and credit impaired
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288SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 288 Parent bank Average unhedged exposure Total exposure Average unhedged exposure Total exposure NOK million 31 Dec 2025 31 Dec 2025 31 Dec 2024 31 Dec 2024 Lowest risk 0.7 % 140,694 0.7 % 133,132 Low risk 3.2 % 36,779 1.5 % 32,244 Medium risk 4.1 % 20,919 2.4 % 23,089 High risk 2.3 % 3,043 2.5 % 2,985 Highest risk 2.3 % 2,286 3.4 % 2,653 Default and/or problem loans 5.8 % 2,165 6.1 % 2,174 Total 205,887 196,277 Group Average unhedged exposure Total exposure Average unhedged exposure Total exposure NOK million 31 Dec 2025 31 Dec 2025 31 Dec 2024 31 Dec 2024 Lowest risk 0.6 % 140,971 0.8 % 133,247 Low risk 3.0 % 39,859 1.4 % 34,906 Medium risk 3.0 % 29,229 1.8 % 31,436 High risk 1.6 % 4,333 1.8 % 4,184 Highest risk 1.8 % 2,983 2.6 % 3,496 Default and/or problem loans 5.2 % 2,438 5.5 % 2,410 Total 219,814 209,680 The realisation value of furnished collateral is determined such that they, on a conservative assessment, reflect the presumed realisation value in an economic downturn.
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289SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 289 Note 12: Maximum credit risk exposure The table below shows maximum exposure to credit risk for balance sheet components, including derivatives. Exposures are shown on a gross basis before collateral and permitted set-offs. For disclosure of classes of financial instruments where this is not spesified in the table below, see note 24: Categories of financial assets and financial liabilities. Parent bank (2025) NOK million Maximum exposure to credit risk, gross Provision for expected credit losses Collateral in property Collateral in securities Other collateral and netting agreements1) Maximum exposure to credit risk, net Assets Balances with central banks 56 - - - - 56 Loans and advances to credit institutions 13,317 - - - - 13,317 Loans and advances to customers at fair value through profit or loss 9,740 - 9,509 24 29 177 Loans and advances to customers at amortised cost 64,478 678 38,875 2,580 22,344 0 Loans and advances to customers at fair value through OCI 96,644 125 95,182 150 502 686 Securities and bonds 35,219 - - - 13,506 21,713 Derivatives 5,621 - - - 4,393 1,227 Earned income, not yet recieved 114 - - - - 114 Accounts receivable, securities 305 - - - - 305 Total assets 225,494 803 143,566 2,754 40,775 37,596 Liabilities Guarantee commitments and documentary credits 6,112 16 - - - 6,096 Unutilised credits and Loan approvals 30,679 55 2,487 116 583 27,437 Other exposures 6,391 - - - - 6,391 Total liabilities 43,182 71 2,487 116 583 39,925 Total credit risk exposure 268,677 77,521
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290SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 290 Parent bank (2024) NOK million Maximum exposure to credit risk, gross Provision for expected credit losses Collateral in property Collateral in securities Other collateral and netting agreements1) Maximum exposure to credit risk, net Assets Balances with central banks 651 - - - - 651 Loans and advances to credit institutions 19,785 - - - - 19,785 Loans and advances to customers at fair value through profit or loss 10,570 - 10,333 25 40 172 Loans and advances to customers at amortised cost 63,645 641 38,022 2,730 22,253 -0 Loans and advances to customers at fair value through OCI 92,863 348 91,489 80 509 436 Securities and bonds 36,649 - - - 14,911 21,738 Derivatives 7,231 - - - 4,754 2,477 Earned income, not yet recieved 187 - - - - 187 Accounts receivable, securities 221 - - - - 221 Total assets 231,802 989 139,844 2,836 43,790 45,667 Liabilities Guarantee commitments and documentary credits 6,169 62 - - - 6,108 Unutilised credits and Loan approvals 25,224 40 2,265 30 301 22,588 Other exposures 6,181 - - - - 6,181 Total liabilities 37,575 102 2,265 30 301 34,877 Total credit risk exposure 269,377 80,544
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291SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 291 Group (2025) NOK million Maximum exposure to credit risk, gross Provision for expected credit losses Collateral in property Collateral in securities Other collateral and netting agree- ments1) Maximum exposure to credit risk, net Assets Balances with central banks 56 - - - - 56 Loans and advances to credit institutions 2,226 - - - - 2,226 Loans and advances to customers at fair value through profit or loss 9,636 - 9,509 24 29 74 Loans and advances to customers at amortised cost 78,106 766 38,875 2,580 36,166 -281 Loans and advances to customers at fair value through OCI 96,644 125 95,182 150 502 686 Securities and bonds 35,219 - - - 13,506 21,713 Derivatives 5,621 - - - 4,393 1,227 Earned income, not yet recieved 138 - - - - 138 Accounts receivable, securities 305 - - - - 305 Total assets 227,952 891 143,566 2,754 54,596 26,145 Liabilities Guarantee commitments and documentary credits 6,112 16 - - - 6,096 Unutilised credits and Loan approvals 31,082 55 2,487 116 583 27,841 Other exposures 6,424 - - - - 6,424 Total liabilities 43,618 71 2,487 116 583 40,361 Total credit risk exposure 271,570 66,506
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292SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Group (2024) NOK million Maximum exposure to credit risk, gross Provision for expected credit losses Collateral in property Collateral in securities Other collateral and netting agreements1) Maximum exposure to credit risk, net Assets Balances with central banks 651 - - - - 651 Loans and advances to credit institutions 9,166 - - - - 9,166 Loans and advances to customers at fair value through profit or loss 10,467 - 10,333 25 40 69 Loans and advances to customers at amortised cost 76,772 559 38,022 2,730 35,401 60 Loans and advances to customers at fair value through OCI 92,863 348 91,489 80 509 436 Securities and bonds 36,650 - - - 14,911 21,739 Derivatives 7,231 - - - 4,754 2,477 Earned income, not yet recieved 211 - - - - 211 Accounts receivable, securities 221 - - - - 221 Total assets 234,233 907 139,844 2,836 55,616 35,030 Liabilities Guarantee commitments and documentary credits 6,169 62 - - - 6,108 Unutilised credits and Loan approvals 25,604 40 2,265 30 301 22,968 Other exposures 6,235 - - - - 6,235 Total liabilities 38,008 102 2,265 30 301 35,310 Total credit risk exposure 272,241 70,341 1) Other collateral includes cash, movables, ship and guarantees received. For covered bonds the cover pool comprises loans to customers in the company that has issued the bond. For derivatives, cash has been provided as collateral, in addition to bilateral ISDA agreements on netting of derivatives.
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293SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 293 The Bank’s maximum credit exposure is shown in the above table. SpareBank 1 SMN provides wholesale banking services to BN Bank and the Samspar banks. In this connection a guarantee agreement has been established which assures full settlement for exposures connected to these agreements. For retail and corporate customers, use is made of framework agreements requiring provision of collateral. Customers furnish cash deposits and/or assets as collateral for their trade in power and salmon derivatives at NASDAQ OMX Oslo ASA and Fish Pool ASA. SpareBank 1 SMN enters into standardised and mainly bilateral ISDA agreements on netting of derivatives with financial institutions as counterparties. Additionally the Bank has entered into supplementary agreements on provision of collateral (CSA) with the most central counterparties. As of 31 December 2024 the Bank has about 37 (37) active ISDA agreements. As from 1 March 2017 the Bank was required under EMIR to have in place a CSA with daily exchange of margin collateral etc. with all financial counterparties with which the bank deals domiciled (inter alia) in an EU meber state. The Bank only enters into agreements with cash as collateral. The Bank has delegated responsibility for handling these agreements to SEB Prime Collateral Services which handles margin requirements on behalf of the Bank. More about collateral and encumbrances in note 37 Other debt and liabilities. The collateral is measured at fair value, limited to maximum credit exposure for the individual counterparty. The Group has NOK 209 million exposures in stage 3 where no impairment charge has been made due to value of collateral, for 2024 the same amount was NOK 603 million.
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294SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 294 Note 13: Credit quality per class of financial assets The Bank handles the credit quality of financial assets by means of its internal guidlines for credit ratings. See section entitled credit risk under Note 6: Risk factors. The table below shows credit quality per class of assets for loan-related assets in the balance sheet, based on the Bank’s own credit rating system. The entire loan exposure is included when parts of the exposure are defaulted. Non-performance is defined in the note as default of payment of NOK 1,000 or more for more than 90 days. Parent bank (2025) Neither defaulted nor written down NOK million Notes Lowest risk Low risk Medium risk High risk Highest risk Defaulted or credit impaired Total Loans to and claims on credit institutions 7 13,317 - - - - - 13,317 Loans to and claims on customers 8 Retail market 82,915 9,100 2,072 485 1,067 793 96,431 Corporate market 35,861 19,422 14,641 2,164 1,113 1,230 74,431 Total 118,776 28,522 16,714 2,649 2,180 2,023 170,862 Financial investments 27 Quoted government and government guaranteed bonds 12,522 - - - - - 12,522 Quoted other bonds 15,307 1,900 100 - - - 17,307 Unquoted government and government guaranteed bonds 4,661 - - - - - 4,661 Unquoted other bonds 666 63 - - - - 729 Total 33,156 1,963 100 - - - 35,219 Total 165,249 30,485 16,813 2,649 2,180 2,023 219,398
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295SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 295 Parent bank (2024) Neither defaulted nor written down NOK million Notes Lowest risk Low risk Medium risk High risk Highest risk Defaulted or credit impaired Total Loans to and claims on credit institutions 7 19,785 - - - - - 19,785 Loans to and claims on customers 8 Retail market 89,315 10,932 3,445 849 1,555 1,011 107,107 Corporate market 25,528 15,231 15,375 1,903 930 1,004 59,970 Total 114,843 26,163 18,819 2,752 2,485 2,015 167,077 Financial investments 27 Quoted government and government guaranteed bonds 8,836 - - - - - 8,836 Quoted other bonds 19,031 690 2 - - - 19,723 Unquoted government and government guaranteed bonds 5,645 - - - - - 5,645 Unquoted other bonds 2,446 - - - - - 2,446 Total 35,957 690 2 - - - 36,649 Total 170,585 26,853 18,821 2,752 2,485 2,015 223,512
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296SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Group (2025) Neither defaulted nor written down NOK million Notes Lowest risk Low risk Medium risk High risk Highest risk Defaulted or credit impaired Total Loans to and claims on credit institutions 7 2,226 - - - - - 2,226 Loans to and claims on customers 8 Retail market 82,921 10,877 7,691 823 1,447 936 104,695 Corporate market 36,132 20,726 16,928 3,116 1,430 1,359 79,692 Total 119,053 31,603 24,620 3,939 2,877 2,295 184,387 Financial investments 27 Quoted government and government guaranteed bonds 12,522 - - - - - 12,522 Quoted other bonds 15,307 1,900 100 - - - 17,307 Unquoted government and government guaranteed bonds 4,661 - - - - - 4,661 Unquoted other bonds 666 63 - - - - 729 Total 33,156 1,963 100 - - - 35,219 Total 154,436 33,566 24,720 3,939 2,877 2,295 221,832
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297SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Group (2024) Neither defaulted nor written down NOK million Notes Lowest risk Low risk Medium risk High risk Highest risk Defaulted or credit impaired Total Loans to and claims on credit institutions 7 9,166 - - - - - 9,166 Loans to and claims on customers 8 Retail market 89,318 12,362 8,474 1,170 1,935 1,091 114,350 Corporate market 25,640 16,463 18,313 2,782 1,393 1,160 65,751 Total 114,958 28,825 26,787 3,952 3,328 2,251 180,102 Financial investments 27 Quoted government and government guaranteed bonds 8,836 - - - - - 8,836 Quoted other bonds 19,031 690 2 - - - 19,723 Unquoted government and government guaranteed bonds 5,645 - - - - - 5,645 Unquoted other bonds 2,447 - - - - - 2,447 Total 35,958 690 2 - - - 36,650 Total 160,082 29,515 26,789 3,952 3,328 2,251 225,918
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298SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 298 Note 14: Market risk related to interest rate risk This note is a sensitivity analysis based on relevant balance sheet items as of 31 December and thereafter for the year concerned. The Bank’s interest rate risk is calculated by simulating a parallel interest rate shift for the entire interest rate curve of two percentage point on all balance sheet items. Forfurther details regarding interest rate risk, see Note 6: Risk Factors. Interest rate risk, change 2 percentage point Basis risk Group (NOK million) 2025 2024 Currency NOK -102 -87 EUR 7 7 USD -5 -7 CHF -1 -1 GBP -2 -1 Other -0 -0 Total interest rate risk, effect on result befor e tax -102 -89 Total interest rate risk suggest that the Bank will have losses from an increase in this interest rate in 2025. The table below shows the effect of an interest rate curve shift on various time intervals and the associated gains or losses within the respective maturities. Interest rate risk, change 2 percentage point Interest rate curve risk, Group (NOK million) 2025 2024 Maturity 0 - 2 month -13 10 2 - 3 months -59 -81 3 - 6 months -36 -14 6 - 12 months -14 - 1 - 2 years 12 2 2 - 3 years 1 -5 3 - 4 years -4 1 4 - 5 years 7 -2 5 - 8 years 5 1 8 - 15 years 0 -1 Total interest rate risk, effect on result befor e tax -102 -89
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299SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 299 Note 15: Market risk related to currency exposure Foreign exchange risk arises when there are differences between the Group’s assets and liabilities in a given currency. Currency trading must at all times be conducted within adopted limits and authorisations. The Group’s limits define quantitative measures for maximum net foreign currency exposure, measured in Norwegian kroner. The Group has established limits for net exposure (expressed as the highest of the sum of long and short positions). Overnight exchange rate risk for spot trading in foreign currency must not, exceed NOK 150 million on an aggregate basis. Foreign exchange risk has been low throughout the year. For further details see note 6: Risk factors. Parent Bank Net foreign exchange exposure NOK Group 2024 2025 NOK million 2025 2024 -8 -10 EUR -10 -8 0 -0 USD -0 0 0 5 SEK 5 0 2 0 GBP 0 2 - - Other - - -4 -5 Total -5 -4 0.4 0.5 Result effect of 3% change 0.5 0.4
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300SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 16: Liquidity risk Liquidity risk is the risk that the Group will be unable to refinance its debt or unable to finance increases in its assets. See note 6: Risk factors for a detailed description. Group (Year-end 2025) NOK million On demand Below 3 months 3-12 months 1 - 5 yrs Above 5 yrs Total Cash flows related to liabilities2) Deposits from credit institutions 7,588 148 104 2,191 - 10,031 Deposits from and debt to customers 106,750 27,690 8,225 3,499 - 146,164 Debt created by issue of securities - 2,140 14,336 28,375 3,704 48,556 Derivatives - contractual cash flow out - 1,233 12,274 22,633 1,739 37,878 Other liabilities - 1,261 1,555 674 191 3,681 Subordinated loan capital1) - 49 139 3,078 - 3,266 Total cash flow, liabilities 114,339 32,521 36,634 60,450 5,634 249,578 Derivatives net cash flows Contractual cash flows out - 1,233 12,274 22,633 1,739 37,878 Contractual cash flows in - -818 -11,870 -23,056 -1,900 -37,645 Net contractual cash flows - 414 404 -423 -162 233 Does not include value adjustments for financial instruments at fair value. 1) For subordinated debt the call date is used for cash settlement 2) Contractual cash-flows include calculated interest and the total amount therefore deviate from recognised liabilities
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301SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Group (Year-end 2024) NOK million On demand Below 3 months 3-12 months 1 - 5 yrs Above 5 yrs Total Cash flows related to liabilities2) Debt to credit institutions 9,064 3,432 127 1,569 15 14,208 Deposits from and debt to customers 99,386 26,319 10,742 4,449 - 140,897 Debt created by issuance of securities - 194 10,621 42,481 1,600 54,896 Derivatives - contractual cash flow out - 641 13,693 29,303 1,254 44,891 Other liabilities - 986 1,595 625 269 3,475 Subordinated loan capital1) - 44 132 3,174 - 3,350 Total cash flow, liabilities 108,451 31,618 36,910 81,600 3,138 261,717 Derivatives net cash flows Contractual cash flows out - 641 13,693 29,303 1,254 44,891 Contractual cash flows in - -224 -13,023 -28,721 -1,344 -43,311 Net contractual cash flows - 417 671 582 -90 1,580 Does not include value adjustments for financial instruments at fair value. 1) For subordinated debt the call date is used for cash settlement 2) Contractual cash-flows include calculated interest and the total amount therefore deviate from recognised liabilities
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302SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 302 Note 17: Net interest income Accounting policy Interest income and expenses related to assets and liabilities which are measured at amortised cost or fair value over OCI are recognised in profit/ loss on an ongoing basis using the effective interest rate method. Charges connected to interest-bearing funding and lending are included in the computation of effective interest rate and are amortised over expected lifetime. For debt instruments assets at amortised cost which have been written down as a result of objective evidence of loss, interest is recognised as income based on the net capitalised amount. In the case of interest- bearing instruments measured at fair value in profit or loss, the market value will be classified as income from other financial investments. For interest-bearing instruments at amortised costs that are no included in hedging relationships, premiums/underpayments are amortised as interest income over the term of the contract. Parent Bank Group 2024 2025 NOK million 2025 2024 1,045 1,149 Interest income from loans to and claims on central banks and credit institutions (amortised cost) 553 443 5,621 5,599 Interest income from loans to and claims on customers (amortised cost) 6,742 6,763 4,456 4,325 Interest income from loans to and claims on customers (FV over OCI) 4,325 4,456 269 420 Interest income from loans to and claims on customers (FV over P&L) 420 269 1,614 1,562 Interest income from money market instruments, bonds and other fixed income securities (FV o ver P&L) 1,555 1,606 - - Other interest income 25 24 13,005 13,054 Total interest income 13,618 13,560 628 506 Interest expenses on liabilities to credit institutions 506 628 4,949 5,133 Interest expenses relating to deposits from and liabilities to customers 5,086 4,900 2,324 2,353 Interest expenses related to the issuance of securities 2,353 2,324 175 173 Interest expenses on subordinated debt 179 180 12 13 Other interest expenses 64 62 93 88 Guarantee fund levy 88 93 8,180 8,265 Total interest expense 8,276 8,187 4,824 4,789 Net interest income 5,343 5,373
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303SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 303 Note 18: Net commission income and other income Accounting policy Commission income and expenses are generally accrued in step with the provision of the service. Charges related to interest-bearing instruments are not entered as commission, but are included in the calculation of effective interest and recognised in profit/loss accordingly. Consultancy fees accrue in accordance with a consultancy agreement, usually in step with the provision of the service. The same applies to ongoing management services. Fees and charges in connection with the sale or mediation of financial instruments, property or other investment objects which do not generate balance sheet items in the Bank’s accounts are recognised in profit/loss when the transaction is completed. The Bank receives commission from SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt corresponding to the difference between the interest on the loan and the funding cost achieved by SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt. This shows as commission income in the Bank’s accounts. Parent Bank Group 2024 2025 NOK million 2025 2024 Commission income 73 80 Guarantee commission 80 73 - - Broker commission 318 304 62 87 Portfolio commission, savings products 87 62 272 360 Commission from SpareBank 1 Boligkreditt 360 272 14 14 Commission from SpareBank 1 Næringskreditt 14 14 550 522 Payment transmission services 518 546 263 310 Commission from insurance services 310 263 80 79 Other commission income 70 76 1,315 1,451 Total commission income 1,757 1,611 Commission expenses 120 138 Payment transmission services 139 121 15 17 Other commission expenses 104 103 135 155 Total commission expenses 243 224 Other operating income 45 49 Operating income real property 45 41 - - Property administration and sale of property 249 201 - - Securities trading - - - - Accountant’s fees 772 733 21 13 Other operating income 22 32 65 62 Total other operating income 1,088 1,006 1,245 1,358 Total net commision income and other operating income 2,602 2,392
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304SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 304 Note 19: Net return on financial investments Parent Bank Group 2024 2025 NOK million 2025 2024 Valued at fair value (FV) through profit/loss (P&L) −291 43 Value change in interest rate instruments 42 -293 Value change in derivatives/hedging 8 −13 Net value change in hedged bonds and derivatives 1) -13 8 27 32 Net value change in hedged fixed rate loans and derivatives 32 27 142 −107 Other derivatives -107 142 Income from equity instruments Income from owner interests 1,017 1,254 318 779 Dividend from owner instruments 1 3 Value change and gain/loss on owner instruments 45 1 43 33 Dividend from equity instruments 25 33 60 57 Value change and gain/loss on equity instruments 63 87 308 826 Total net income from financial assets and liabilities at FV over P&L 1,105 1,259 Valued at amortised cost −2 −1 Value change in interest rate instruments held to maturity -1 -2 −2 −1 Total net income from financial assets and liabilities at amortised cost -1 -2 99 19 Total net gain from currency trading 19 100 406 845 Total net return on financial investments 1,123 1,357 1) Fair value hedging 513 271 Changes in fair value on hedging instrument 271 513 −505 −284 Changes in fair value on hedging item -284 -505 8 −13 Net Gain or Loss from hedge accounting -13 8
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305SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 305 Note 20: Personnel expenses Parent Bank Group 2024 2025 NOK million 2025 2024 870 914 Wages 1,797 1,715 83 95 Pension costs (Note 22) 159 143 58 63 Social costs 134 123 1,012 1,072 Total personnel expenses 2,089 1,981 880 906 Average number of employees 1,888 1,807 841 857 Number of FTEs as at 31 December 1,672 1,660 896 915 Number of employees as at 31 December 1,899 1,876 For detailed information on emoluments to Group management during 2025, please see the Report on remuneration and emoluments to senior personell on smn.no
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306SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 306 Note 21: Other operating expenses Parent Bank Group 2024 2025 NOK million 2025 2024 338 400 IT costs 478 410 11 8 Postage and transport of valuables 9 13 84 69 Marketing 89 104 138 140 Ordinary depreciation (note 31, 32 and 33) 187 183 51 56 Operating expenses, real properties 52 48 252 229 Purchased services 293 298 211 238 Other operating expense 282 262 1,084 1,140 Total other operating expenses 1,390 1,319 Audit fees (NOK 1000) 2,188 1,392 Financial audit 5,719 6,213 1,659 3,771 Other attestations 4,107 1,834 - - Tax advice 14 31 1,076 843 Other non-audit services 966 1,238 4,922 6,006 Total incl. value added tax 10,806 9,317
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307SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 22: Pension Defined benefit scheme The SpareBank 1 SMN Group has a pension scheme for its employees that satisfies the requirements for mandatory occupational pensions. SpareBank 1 SMN previously operated a defined benefit pension scheme administered through its own pension fund, which provided entitlement to specified future pension benefits from the age of 67. The defined benefit scheme was terminated with effect from 1 January 2017, and the Group transitioned to a defined contribution scheme. Upon the transition to the defined contribution scheme, employees who were members of the defined benefit scheme received paid-up policies reflecting accrued rights under the defined benefit arrangement. The change resulted in a reduction in pension obligations, which was recognised as a settlement gain and reduced pension costs in 2016. Paid-up policies are managed by the pension fund, which since 2017 has operated as a paid-up policy fund. From 2025, SpareBank 1 SMN has derecognised the pension obligation related to the former defined benefit scheme from the financial statements, as it is assessed that there is no real obligation to cover any potential underfunding of the pension liabilities. In addition to the pension obligations covered by the pension fund, the Group has unfunded pension obligations that cannot be covered by the assets in the collective schemes. These obligations relate to individuals who are not members of the pension fund, supplementary pensions above 12 G, ordinary early retirement pensions, and early retirement pensions under the AFP (Contractual Early Retirement Pension) scheme. Defined contribution scheme Defined contribution pension schemes mean that the Group does not promise a future pension of a specified amount, but instead pays an annual contribution to the employees’ collective pension savings. The future pension will depend on the size of the contribution and the annual return on the pension savings. The Group has no further obligations related to employees’ work after the annual contribution has been paid. There is no provision for accrued pension obligations under such schemes. Defined contribution pension schemes are expensed as incurred. Any prepaid contributions are recognised as an asset (pension assets) to the extent that the contribution can be refunded or offset against future payments. Contributions are made to the pension plan for full-time employees, with contributions of seven per cent on income from 0–7.1 G and 15 per cent on income from 7.1–12 G. Pension premiums are expensed when incurred. Early retirement pension scheme (“AFP”) The banking and financial industry has established an agreement on the contractual early retirement pension scheme (AFP). The scheme covers early retirement pensions from age 62 to 67. The Bank’s responsibility is 100 per cent of the pension paid from age 62 to 64 and 60 per cent of the pension paid from age 65 to 67. Admission of new retirees ceased with effect from 31 December 2010. The Act on State Subsidies for Employees Taking Out Contractual Early Retirement Pensions in the Private Sector (AFP Subsidies Act) entered into force on 19 February 2010. Employees who take out AFP with effect from 2011 or later will receive benefits under the new scheme. The new AFP scheme represents a lifelong supplement to National Insurance and can be taken from age 62. Employees accumulate AFP entitlement at an annual rate of 0.314 per cent of pensionable income up to 7.1 G until age 62. Accrual under the new scheme is calculated based on the employee’s lifetime income, such that all previous working years are included in the qualifying basis. For accounting purposes, the new AFP scheme is considered a defined benefit multi- employer scheme. This entails that each employer accounts for its pro rata share of the scheme’s pension obligation, pension assets, and pension expense. If calculations of the individual components of the scheme and a consistent and reliable basis for allocation are not available, the new AFP scheme is accounted for as a defined contribution scheme. At the present time, no such basis exists, and the new AFP scheme is therefore accounted for as a defined contribution scheme. Accounting for the new AFP scheme as a defined benefit scheme will only occur once reliable measurement and allocation can be performed. The new scheme is financed with one-third of pension expenses covered by the State and two-thirds by the employers. Employers’ contributions are determined as a percentage of salary payments between 1 G and 7.1 G. In line with the recommendation of the Norwegian Accounting Standards Board, no provision has been made in the accounting year for the Group’s de facto AFP obligation. This is because the Joint Office for LO/NHO has not yet performed the necessary calculations.
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308SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Pension expense for the period Parent Bank Group 2024 2025 2025 2024 -7 0 Net pension cost related to defined benefit plans 0 -7 14 13 Early retirement pension scheme, new arrangement 22 23 76 82 Cost of defined contribution pension 137 127 83 95 Total pension cost 159 143 Changes in net pension liability on the balance sheet Parent Bank Group 2024 2025 2025 2024 -217 -294 Net pension liability in the balance sheet 1.1 -294 -217 -70 22 Actuarial gains and losses for the year 22 -70 -7 - Net defined-benefit costs in profit and loss account incl. Curtailment/ settlement - -7 -1 - Paid-in pension premium, defined-benefit schemes - -1 - 264 Derecognition of pension liability 264 - -294 -8 Net pension liability in the balance sheet 31.12 -8 -294 2024 2025 Financial status 31.12 2025 2024 512 8 Pension liability 8 512 -806 - Value of pension assets - -806 -294 8 Net pension liability before employer’s contribution 8 -294 0 0 Employer’s contribution 0 0 -294 8 Net pension liability after employer’s contribution 8 -294
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309SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 23: Tax Accounting policy Tax recorded in the income statement comprises tax in the period (payable tax) and deferred tax. Period tax is tax calculated on the taxable profit for the year. Deferred tax is accounted for by the liability method under IAS 12. Calculation of deferred tax is done using the tax rate in effect at any time. Liabilities or assets are calculated on temporary differences i.e. the difference between balance-sheet value and tax-related value of assets and liabilities. However, liabilities or assets are not calculated in the case of deferred tax on goodwill for which there is no deduction for tax purposes, nor on first-time-recognised items which affect neither the accounting nor the taxable profit. A deferred tax asset is calculated on a tax loss carry forward. Deferred tax assets are recognised only to the extent that there is expectation of future taxable profits that enable use of the tax asset. Withholding tax is presented as period tax. Wealth tax is presented as an operating expense in the Group accounts under IAS 12. Parent Bank Group 2024 2025 NOK million 2025 2024 4,223 4,676 Result before tax 5,449 5,548 -255 -736 +/- permanent differences -397 95 -97 337 +/- change in temporary differences as per specification 256 -217 - - + deficit carried forward -1 - 3,872 4,277 Year’s tax base/taxable income 5,307 5,426 968 1,069 Tax payable on profit for the year 1,163 1,047 -32 -38 Taxes on interest hybrid capital -40 -35 22 13 Excess/too little tax accrued previous year 20 30 958 1,044 Total taxes payable in statement of financial position 1,143 1,042 968 1,073 Tax payable on profit for the year 1,170 1,047 7 -78 +/- change in deferred tax -58 43 -33 -38 Taxes on interest hybrid capital -40 -36 940 958 Tax charge for the year 1,072 1,054 Change in net deferred tax liability 7 -78 Deferred tax shown through profit/loss -58 43 17 -5 Deferred tax shown through equity -5 17 24 -83 Total change in net deferred tax liability -64 61
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310SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 310 Composition of deferred tax carried in the balance sheet Parent Bank Group 2024 2025 NOK million 2025 2024 Temporary differences: 8 8 - Business assets 39 39 - - - Leasing items 498 417 288 - - Pension liability - 298 554 527 - Securities 527 554 802 529 - Hedge derivatives 529 802 112 95 - Other temporary differences 95 112 1,763 1,158 Total tax-increasing temporary differences 1,688 2,221 441 290 Deferred tax 419 554 Temporary differences: - - - Business assets - -0 - -8 - Pension liability -18 - 23 - - Securities - 23 -977 -666 - Hedge derivatives -666 -977 -1 -8 - Other temporary differences -16 -16 - - - Deficit carried forward -80 -92 -955 -683 Total tax-decreasing temporary differences -780 -1,061 -239 -171 Deferred tax asset -193 -265 202 119 Net deferred tax (-asset) 227 289 The above table comprises temporary differences from all consolidated companies shown gross. At the company level tax-increasing and tax-reducing temporary differences are shown net. At the Group-level recognition is on a gross basis in conformity with IAS 12 with each company being presented separately in the calculation of the Group’s tax benefit and deferred tax: 2025 2024 Tax benefit recorded 31 Dec 2 1 Deferred tax recorded 31 Dec -228 -290
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311SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Reconciliation of tax charge for the period recognised against profit and losses to profit before tax 2024 2025 NOK million 2025 2024 1,056 1,169 25 % of profit before tax 1,295 1,175 -64 -184 Non-taxable profit and loss items (permanent differences) -195 -75 -51 5 Tax effect of costs reflected in equity 5 -48 - -32 Too little taxes accrued previous year -33 2 941 958 Tax for the period recognised in the income statement 1,072 1,054 22% 20% Effective tax rate 20% 19%
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312SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 24: Categories of financial assets and financial liabilities Accounting policy Shares, sertificates, bonds and derivatives are classified at fair value through profit/loss. All financial instruments classified at fair value through profit/loss are measured at fair value, and any change in value from the opening balance is recognised as gain or losses from other financial investments. Financial assets held for trading purposes are characterised by the fact that instruments in the portfolio are traded frequently and that positions are established with the aim of short-term gain. Other such financial assets at fair value through profit or loss are investments which, on initial recognition, are designated at fair value through profit or loss Financial derivatives are presented as assets when fair value is positive, and as liabilities when fair value is negative. Group 2025 Financial instruments at fair value through profit or loss NOK million Designated as such upon initial recognition Mandatorily Held for trading Financial instruments at fair value through other comprehensive income Financial instruments measured at amortised cost Total Assets Cash and receivables from central banks - - - - 56 56 Deposits with and loans to credit institutions - - - - 2,226 2,226 Loans to and receivables from customers 9,637 - - 96,520 77,338 183,495 Shares, units and other equity interests - 1,070 259 - - 1,328 Fixed-income CDs and bonds - - 35,219 - - 35,219 Derivatives 1,227 - 4,394 - - 5,621 Earned income not yet received - - - - 138 138 Accounts receivable, securities - - - - 305 305 Total financial assets 10,864 1,070 39,871 96,520 80,064 228,389 Liabilities Deposits from credit institutions - - - - 9,584 9,584 Deposits from and debt to customers - - - - 146,165 146,165 Debt created by issue of securities - - - - 29,121 29,121 Derivatives 996 - 3,485 - - 4,481 Subordinated loan capital - - - - 2,848 2,848 Equity instruments - - - - - - Lease liabilities - - - - 460 460 Debt from securities - - - - 345 345 Total financial liabilities 996 - 3,485 - 188,523 193,004
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313SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 313 Group 2024 Financial instruments at fair value through profit or loss NOK million Designated as such upon initial recognition Mandatorily Held for trading Financial instruments at fair value through other comprehensive income Financial instruments measured at amortised cost Total Assets Cash and receivables from central banks - - - - 654 654 Deposits with and loans to credit institutions - - - - 9,166 9,166 Loans to and receivables from customers 10,468 - - 92,738 76,047 179,254 Shares, units and other equity interests - 770 280 - - 1,050 Fixed-income CDs and bonds - - 36,650 - - 36,650 Derivatives 1,271 - 5,960 - - 7,231 Earned income not yet received - - - - 211 211 Accounts receivable, securities - - - - 221 221 Total financial assets 11,739 770 42,890 92,738 86,300 234,437 Liabilities Deposits from credit institutions - - - - 13,941 13,941 Deposits from and debt to customers - - - - 140,897 140,897 Debt created by issue of securities - - - - 36,570 36,570 Derivatives 1,236 - 4,916 - - 6,152 Subordinated loan capital - - - - 2,735 2,735 Equity instruments - - - - - - Lease liabilities - - - - 403 403 Debt from securities - - - - 251 251 Total financial liabilities 1,236 - 4,916 - 194,797 200,949
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314SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 314 Note 25: Measurement of fair value of financial instruments Financial instruments at fair value are classified at various levels: Level 1: Valuation based on quoted prices in an active market Fair value of financial instruments that are traded in the active markets is based on market price on the balance sheet date. A market is considered active if market prices are easily and regularly available from a stock exchange, dealer, broker, industry Group, price-setting service or regulatory authority, and these prices represent actual and regularly occurring market transactions at an arm’s length. This category also includes quoted shares and Treasury bills. Level 2: Valuation based on observable market data Level 2 consists of instruments that are valued by the use of information that does not consist in quoted prices, but where the prices are directly or indirectly observable for the assets or liabilities concerned, and which also include quoted prices in non-active markets. Level 3: Valuation based on other than observable data If valuation data are not available for level 1 and 2, valuation methods are applied that are based on non-observable information. The Group’s assets and liabilities at 31 December 2025: Assets (NOK million) Level 1 Level 2 Level 3 Total Financial assets at FV through P&L - Derivatives - 5,621 - 5,621 - Bonds and money market certificates 3,534 31,685 - 35,219 - Equity instruments 259 94 975 1,328 - Fixed interest loans - - 9,637 9,637 Financial assets through OCI - Loans at FV through OCI - - 96,520 96,520 Total assets 3,793 37,400 107,132 148,325 Liabilities Level 1 Level 2 Level 3 Total Financial liabilities through P&L - Derivatives - 4,481 - 4,481 Total liabilities - 4,481 - 4,481 The Group’s assets and liabilities at 31 December 2024: Assets (NOK million) Level 1 Level 2 Level 3 Total Financial assets at FV through P&L - Derivatives - 7,231 - 7,231 - Bonds and money market certificates 2,680 33,971 - 36,650 - Equity instruments 280 107 663 1,050 - Fixed interest loans - - 10,468 10,468 Financial assets through OCI - Loans at FV through OCI - - 92,738 92,738 Total assets 2,959 41,309 103,870 148,137 Liabilities Level 1 Level 2 Level 3 Total Financial liabilities through P&L - Derivatives - 6,152 - 6,152 Total liabilities - 6,152 - 6,152
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315SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Changes in the instruments classified in level 3 as at 31 December 2025: NOK million Equity instruments through P&L Fixed interest loans Loans at FV through OCI Total Opening balance 1 January 25 663 10,468 92,738 103,870 Investment in the period 350 476 42,777 43,603 Disposals in the period -45 -1,158 -38,995 -40,198 Expected credit loss - - 2 2 Gain or loss on financial instruments 7 -149 -2 -144 Closing balance 31 December 25 975 9,637 96,520 107,132 Changes in the instruments classified in level 3 as at 31 December 2024: NOK million Equity instruments through P&L Fixed interest loans Loans at FV through OCI Total Opening balance 1 January 24 622 5,480 92,263 98,365 Investment in the period 38 5,995 40,293 46,327 Disposals in the period -4 -814 -39,808 -40,626 Expected credit loss - - -6 -6 Gain or loss on financial instruments 7 -194 -4 -192 Closing balance 31 December 24 662 10,468 92,738 103,870
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316SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 316 Valuation method The valuation method applied is adapted to each financial instrument, and is intended to utilise as much of the information that is available in the market as possible. The method for valuation of financial instruments in level 2 and 3 is described in the following: Fixed interest loans to customers (level 3) The loans consist for the most part of fixed interest loans denominated in Norwegian kroner. The value of the fixed interest loans is determined such that agreed interest flows are discounted over the term of the loan by a discount factor that is adjusted for margin requirements. The discount factor is raised by 10 points when calculating sensitivity. Loans at fair value through other comprehensive income (level 3) Mortgages at floating interest classified at fair value over other comprehensive income is valued based on nominal amount reduced by expected credit loss. Loans with no significant credit risk detoriation since first recognition is assessed at nominal amount. For loans with a significant increase in credit risk since first recognition or objective evidence of loss, the calculation of expected credit losses over the life of the asset is in line with loan losses for loans at amortised cost. Estimated fair value is the nominal amount reduced by expected lifetime credit loss. If the likelihood of the worst case scenario in the model is doubled, fair value is reduced by NOK 3 million. Short-term paper and bonds (level 2 and 3) Valuation on level 2 is based for the most part on observable market information in the form of interest rate curves, exchange rates and credit margins for the individual credit and the bond’s or certificate’s characteristics. For paper valued under level 3 the valuation is based on indicative prices from a third party or comparable paper. Equity instruments (level 3) Shares that are classified to level 3 include essentially investments in unquoted shares. Among other a total of NOK 618 million in Private Equity investments, property funds, hedge funds and unquoted shares through the company SpareBank SMN 1 Invest. The valuations are in all essentials based on reporting from managers of the funds who utilise cash flow based models or multiples when determining fair value. The Group does not have full access to information on all the elements in these valuations and is therefore unable to determine alternative assumptions. Financial derivatives (level 2) Financial derivatives at level 2 include for the most part currency futures and interest rate and exchange rate swaps. Valuation is based on observable interest rate curves. In addition the item includes derivatives related to FRAs. These are valued with a basis in observable prices in the market. Derivatives classified to level 2 also include equity derivatives related to SpareBank 1 Markets’ market-making activities. The bulk of these derivatives refer to the most sold shares on Oslo Børs, and the valuation is based on the price of the actual/underlying share and observable or calculated volatility. Sensitivity analyses, level 3 as at 31 December 2025: NOK million Book value Effect from change in reasonable possible alternative assumtions Fixed interest loans 9,637 -18 Equity instruments through profit/loss1) 975 - Loans at fair value through other comprehensive income 96,520 -3 1) As described above, the information to perform alternative calculations are not available
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317SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 26: Fair value of financial instruments at amortised cost Financial instruments measured at amortised cost Financial instruments that are not measured at fair value are recognised at amortised cost or are in a hedging relationship. Amortised cost entails valuing balance sheet items after initially agreed cash flows, adjusted for impairment. Amortised cost will not always be equal to the values that are in line with the market assessment of the same financial instruments. This is due to different perceptions of market conditions, risk and discount rates. Methods underlying the determination of fair value of financial instruments that are measured at amortised cost are described below: Loans to and claims on customers Current-rate loans are exposed to competition in the market, indicating that possible excess value in the portfolio will not be maintained over a long period. Fair value of current-rate loans is therefore set to amortised cost. The effect of changes in credit quality in the portfolio is accounted for through collectively assessed impairment writedowns, therefore giving a good expression of fair value in that part of the portfolio where individual write-down assessments have not been made. Individual write-downs are determined through an assessment of future cash flow, discounted by effective interest rate. Hence the discounted value gives a good expression of the fair value of these loans. Loans to and claims on credit institutions, Earned income not received, Debt to credit institutions and deposits from customers and debt from securities For loans to and claims on credit institutions, as well as debt to credit institutions and deposits from customers, fair value is estimated equal to amortised cost. Securities debt and subordinated debt The calculation of fair value in level 2 is based on observable market values such as on interest rate and spread curves where available.
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318SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Parent bank 31 Dec 2025 31 Dec 2024 NOK million Level1) Book value Fair Value Book value Fair Value Assets Loans to and claims on credit institutions 2 13,317 13,317 19,785 19,785 Loans to and claims on customers at amortised cost 2 63,800 63,940 63,004 63,164 Earned income not yet received 2 114 114 187 187 Accounts receivable, securities 2 305 305 221 221 Total financial assets at amortised cost 77,537 77,677 83,198 83,358 Liabilities Debt to credit institutions 2 9,584 9,584 13,940 13,940 Deposits from and debt to customers 2 146,778 146,778 141,485 141,485 Securities debt at amortised cost 2 4,458 4,457 5,457 5,457 Securities debt, hedging 2 24,663 24,662 31,112 31,112 Subordinated debt at amortised cost 2 5,809 5,808 5,719 5,718 Subordinated debt, hedging 2 9,583 9,582 7,634 7,633 Subordinated loan at amortised cost 2 2,670 2,769 2,656 2,671 Subordinated loan, hedging 2 - - - - Lease liabilities 2 262 262 307 307 Debt from securities 2 345 345 251 251 Total financial liabilities at amortised cost 204,152 204,248 208,563 208,574 1) Fair value is determined by using different methods in three levels. See note 25 for a definition of the levels.
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319SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 319 Group 31 Dec 2025 31 Dec 2024 NOK million Level1) Book value Fair Value Book value Fair Value Assets Loans to and claims on credit institutions 2 2,226 2,226 9,166 9,166 Loans to and claims on customers at amortised cost 2 77,340 77,518 76,049 76,227 Earned income not yet received 2 138 138 211 211 Accounts receivable, securities 2 305 305 221 221 Total financial assets at amortised cost 80,010 80,188 85,648 85,826 Liabilities Debt to credit institutions 2 9,584 9,584 13,941 13,941 Deposits from and debt to customers 2 146,165 146,165 140,897 140,897 Securities debt at amortised cost 2 4,458 4,457 5,457 5,457 Securities debt, hedging 2 24,663 24,662 31,112 31,112 Subordinated debt at amortised cost 2 5,809 5,808 5,719 5,718 Subordinated debt, hedging 2 9,583 9,582 7,634 7,633 Subordinated loan at amortised cost 2 2,848 2,848 2,735 2,750 Subordinated loan, hedging 2 - - - - Lease liabilities 2 441 441 460 460 Debt from securities 2 345 345 251 251 Total financial liabilities at amortised cost 203,896 203,892 208,207 208,218 1) Fair value is determined by using different methods in three levels. See note 25 for a definition of the levels.
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320SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 320 Note 27: Money market certificates and bonds Bonds and money market instruments are classified at fair value through profit/loss at 31 December 2025. Certificates and bonds by issuer sector Parent Bank Group 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 State 5,710 8,393 Nominal value 8,393 5,710 5,482 8,103 Book value 8,103 5,482 Other public sector 12,489 9,917 Nominal value 9,917 12,489 12,478 9,928 Book value 9,928 12,478 Financial enterprises 18,373 16,781 Nominal value 16,781 18,373 18,419 16,856 Book value 16,856 18,419 Non-financial enterprises 18 84 Nominal value 84 18 18 84 Book value 84 19 36,589 35,175 Total fixed income securities, nominal value 35,175 36,589 253 249 Accrued interest 249 253 36,649 35,219 Total fixed income securities, booked value 35,219 36,650
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321SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 321 Note 28: Financial derivatives All derivatives are booked at fair value through profit and loss. Gains are carried as assets and losses as liabilities in the case of all interest rate derivatives. This applies both to derivatives used for hedging purposes and held for trading purposes. The Bank does not employ cash flow hedging. The contract amount shows absolute values for all contracts. For at description of counterparty risk and market risk, see note 6: Risk factors. For further details concerning market risk linked to interest rate risk, see note 14: Market risk related to interest rate risk. For market risk related to currency exposure, see note 15: Market risk related to currency exposure. Parent bank FV through P&L (NOK million) 31 Dec 2025 31 Dec 2024 Contract amount Fair value Contract amount Fair value Currency instruments Assets Liabilities Assets Liabilities Foreign exchange derivatives (forwards) 3,011 86 -97 14,784 218 3 Currency swaps 4,711 205 -90 26,800 253 -247 FX-options - -7 7 262 -4 4 Total currency instruments 7,722 285 -180 41,846 467 -241 Interest rate instruments Interest rate swaps (including cross currency) 216,127 3,815 -2,856 254,490 5,101 -4,117 Short-term interest rate swaps (FRA) 1,000 0 - - 0 - Total interest rate instruments 217,127 3,815 -2,856 254,490 5,101 -4,117 Commodity-related contracts Stock-exchange-traded standardised forwar ds and futures contracts 605 66 -66 1,534 135 -135 Total commodity-related contracts 605 66 -66 1,534 135 -135 Hedging Interest rate instruments Interest rate swaps (including cross currency) 22,094 1,227 -996 45,489 1,271 -1,236 Total interest rate instruments 22,094 1,227 -996 45,489 1,271 -1,236 Total Total interest rate instruments 239,221 5,042 -3,852 299,978 6,373 -5,353 Total currency instruments 7,722 285 -180 41,846 467 -241 Total commodity-related contracts 605 66 -66 1,534 135 -135 Accrued interest - 228 -383 - 256 -423 Total financial derivatives 247,547 5,621 -4,481 343,359 7,231 -6,152
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322SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 322 Group FV through P&L (NOK million) 31 Dec 2025 31 Dec 2024 Contract amount Fair value Contract amount Fair value Currency instruments Assets Liabilities Assets Liabilities Foreign exchange derivatives (forwards) 3,011 86 -97 14,784 218 3 Currency swaps 4,711 205 -90 26,800 253 -247 FX-options - -7 7 262 -4 4 Total currency instruments 7,722 285 -180 41,846 467 -241 Interest rate instruments Interest rate swaps (including cross currency) 216,127 3,815 -2,856 254,490 5,101 -4,117 Short-term interest rate swaps (FRA) 1,000 0 - - 0 - Total interest rate instruments 217,127 3,815 -2,856 254,490 5,101 -4,117 Commodity-related contracts Stock-exchange-traded standardised forwar ds and futures contracts 605 66 -66 1,534 135 -135 Total commodity-related contracts 605 66 -66 1,534 135 -135 Hedging Interest rate instruments Interest rate swaps (including cross currency) 22,094 1,227 -996 45,489 1,271 -1,236 Total interest rate instruments 22,094 1,227 -996 45,489 1,271 -1,236 Total Total interest rate instruments 239,221 5,042 -3,852 299,978 6,373 -5,353 Total currency instruments 7,722 285 -180 41,846 467 -241 Total commodity-related contracts 605 66 -66 1,534 135 -135 Accrued interest 228 -383 256 -423 Total financial derivatives 247,547 5,621 -4,481 343,359 7,231 -6,152
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323SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 323 Note 29: Hedge accounting for debt created by issue of securities Accounting policy The Bank evaluates and documents the effectiveness of a hedge in accordance with IAS 39. The Bank employs fair value hedging to manage its interest rate risk. In its hedging operations the Bank protects against movements in the market interest rate. Changes in credit spread are not taken to account when measuring hedge effectiveness. In the case of fair value hedging, both the hedging instrument and the hedged object are recorded at fair value, and changes in these values from the opening balance are recognised in profit/ loss. The Bank has established hedge accounting in order to achieve accounting treatment that reflects how interest rate risk and foreign exchange risk are managed in the case of large long- term borrowings. See note 6 Risk factors for more information. The hedged objects consist exclusively of debt created by the issuance of financial instruments and are implemented in conformity with IFRS 9 by fair value hedging. For those debt instruments that are included in the hedging portfolio, separate interest rate and exchange rate swaps are entered into with corresponding principle and maturity structure. Inefficiency may nonetheless arise as a result of random market variations in the evaluation of object and instrument. The hedging instruments (interest rate and exchange rate swaps) are recognised at fair value, whereas the hedged objects are recognised at fair value in respect of the risks that are hedged (interest rate risk and exchange rate risk). Hedge inefficiency, defined as the difference between the value adjustment of the hedging instruments and the value adjustment of the hedged risks in the objects is recognised through profit/loss on an ongoing basis. Nominal amount 31 Dec 2025 Nominal amount 31 Dec 2024 Group (NOK million) Hedging instrument Hedging object Ineffectivity Hedging instrument Hedging object Ineffectivity Accounting line in Balance Sheet Derivatives Debt created by issuance of securities Derivatives Debt created by issuance of securities Debt at fixed interest Interest swap Interest swap Nominal NOK 10,930 10,930 - 10,010 10,010 - Interest and currency swap Interest and currency s wap Debt in currency at fixed interest Nominal EUR 19,976 19,976 - 37,817 37,817 - Nominal JPY 1,290 1,290 - 2,170 2,170 - Nominal CHF 2,225 2,225 - 2,195 2,195 - Book value 31 Dec 2025 Book value 31 Dec 2024 Hedging instrument Hedging object Ineffectivity in PL Hedging instrument Hedging object Ineffectivity in PL R ecorded amount Assets 1,227 1,271 Recorded amount Liabilities 996 33,918 1,236 38,746 Accumulated value changes ending balance 601 562 1,410 1,399 Accumulated value changes opening balance 860 833 896 894 Change in fair value -259 -271 12 513 505 8 Accounting line in profit and loss Net return on financial investments Net return on financial investments
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324SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 324 IBOR reform In recent years, reform of and alternatives to IBOR rates have become a priority area for governments across the world. However, there is uncertainty as to the timing and method for any changes. All SpareBank 1 SMN’s interest rate derivatives have IBOR rates as their benchmark, and thus could be affected by changes. The most significant positions are held in EURIBOR and NIBOR. The bank follows market developments closely, and participates in several projects in order to monitor and facilitate any changes. The table below shows exposure and nominal amount for derivatives in hedge relationships that may be affected by the IBOR reform, split on the IBOR rate in question. Nominal amount Interest- and currency instrument (NOK million) Hedging object Hedging instrument Net Exposure EURIBOR 3M - 9,500 -9,500 EURIBOR 6M - 308 -308 OIBOR 3M - 23,861 -23,861 Total - 33,669 -33,669
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325SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 30: Shares, units and other equity interest Parent Bank Group 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 At FV through P&L 280 259 Listed 259 280 194 357 Unlisted 975 783 474 616 Total shares and units 1,234 1,062 Subordinated bond 59 43 Listed 43 59 175 179 Unlisted 52 49 234 222 Total subordinated bond 94 107 Business held for sale - of which shares 98 98 Unlisted 175 190 98 98 Total shares held for sale (note 39) 175 190 338 302 Total listed companies 302 338 467 634 Total unlisted companies 1,202 1,022
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326SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 326 Specification (parent bank) Listed companies Company number Stake over 10 per cent Holding (no.) Acquisition cost (NOK 1000) Market value/book value (NOK 1000) Visa Inc. C-aksjer 63,536 6,750 226,541 HAVILA SHIPPING AS ORD. 882811972 25,098,138 11,986 20,079 Total quoted shares 18,737 246,619 SpareBank 1 Nordmøre 937899408 69,423 7,455 12,150 Total quoted credit institutions 7,455 12,150 Unlisted companies SpareBank 1 SMN pensjonskasse 977336007 325,704 VN Norge AS - SMN - oppgitt i milliard aksjer 821083052 28,688,772 37,338 13,094 Visa C preferanseaksje 1,298 652 6,621 SpareBank 1 Bank og Regnskap AS 917143501 308 2,487 3,864 Runde Miljøbygg AS 989736027 40,000 2,500 2,500 Other companies 2,595 5,027 Total unquoted shares and units 45,572 356,809 SpareBank 1 Sør-Norge 937895321 14,550 14,690 SpareBank 1 Nord-Norge 952706365 13,391 13,497 Sparebanken Norge 832554332 3,014 3,051 Landkreditt bank 980374181 2,575 2,588 SpareBank 1 Sogn og Fjordane 946670081 2,517 2,553 Other 6,450 6,460 Total quoted subordinated bonds 42,496 42,839 SpareBank 1 Finans Midt-Norge 938521549 124,300 127,895 SpareBank 1 Gruppen 975966372 48,750 49,250 DNB Bank 984851006 2,049 2,098 Total unquoted subordinated bonds 175,099 179,243 Total shares, units and equity capital certificates, parent bank 289,358 837,660
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327SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 327 Specification (Group) Unlisted companies Company number Stake over 10 per cent Holding (no.) Acquisition cost (NOK 1000) Market value/book value (NOK 1000) SIGNORD AS (Previous Viking Venture III) 992229667 16.80% 955,039 34,745 285,813 Salvesen & Thams AS 999104428 34,361 84,231 219,154 Proventure Seed III AS 924111895 25,658,825 21,810 17,628 Sonoclear AS (Previous BrainImage AS) 917956146 1,730,692 10,115 17,307 Sintef Venture V 920749984 146,910 22,458 15,098 Sintef Venture IV 912844889 51,465 12,205 13,321 Signord Klasse E 992229667 46,476 4,704 11,341 Proventure Seed II AS 913391136 16,200,268 11,794 7,656 Vectron Biosolutions AS 992779837 220,000 6,000 6,140 Novela Kapital AS 922061017 624,000 6,240 4,836 Sintef Venture IV B 927177021 65,700 4,845 4,474 Other companies 60,552 15,468 Total unquoted shares and units 279,700 618,235 Elimination of subordinated bond SpareBank 1 Finans Midt-Norge -124,300 -127,617 Total shares, units and equity capital certificates, Group 444,759 1,328,279
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328SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 328 Note 31: Intangible assets Accounting policy Intangible assets mainly comprise goodwill in the SpareBank 1 SMN Group. Other intangible assets will be recognised once the conditions for entry in the balance sheet are present. Goodwill arises as the difference between the fair value of the consideration upon purchase of a business and the fair value of identifiable assets and liabilities; see description under Consolidation. Goodwill is not amortised, but is subject to an annual depreciation test with a view to revealing any impairment, in keeping with IAS 36. Testing for value impairment is done at the lowest level at which cash flows can be identified. Intangible assets acquired separately are carried at cost. Useful economic life is either finite or infinite. Intangible assets with a finite economic life are depreciated over their economic life and tested for impairment upon any indication of impairment. The depreciation method and period are assessed at least once each year. Amounts recorded on the Bank’s assets are reviewed on the balance sheet date for any indications of value impairment. Should such indications be present, an estimate is made of the asset’s recoverable amount. Each year on the balance sheet date recoverable amounts on goodwill, assets with unlimited useful lifetime, and intangible assets not yet available for use, are computed. Write-downs are undertaken when the recorded value of an asset or cash-flow-generating entity exceeds the recoverable amount. Write-downs are recognised in profit/loss. Write-down of goodwill is not reversed. In the case of other assets, write-downs are reversed where there is a change in the estimates used to compute the recoverable amount. 2025 Parent Bank Group Other intan- gible assets Goodwill Total NOK million Total Goodwill Other intan- gible assets 190 665 855 Cost of acquisition at 1 January 1,399 1,125 274 0 - 0 Additions 45 44 1 -15 - -15 Disposals -15 - -15 182 665 847 Cost of acquisition at 31 December 1,436 1,169 267 58 - 58 Accumulated depreciation and write-downs as at 1 January 170 34 136 29 - 29 Current period’s depreciation 30 - 30 -15 - -15 Disposals -15 - -15 72 - 72 Accumulated depreciation and write-down as at 31 December 185 34 151 110 665 775 Book value as at 31 December 1,251 1,135 116
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329SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 329 2024 Parent Bank Group Other intan- gible assets Goodwill Total NOK million Total Goodwill Other intan- gible assets 182 665 847 Cost of acquisition at 1 January 1,372 1,112 260 13 - 13 Additions 32 13 19 -5 - -5 Disposals -5 - -5 190 665 855 Cost of acquisition at 31 December 1,399 1,125 274 35 - 35 Accumulated depreciation and write-downs as at 1 January 144 34 110 28 - 28 Current period’s depreciation 30 - 30 -5 - -5 Disposals -5 - -5 58 - 58 Accumulated depreciation and write-down as at 31 December 170 34 136 131 665 797 Book value as at 31 December 1,230 1,091 138
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330SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 330 Note 32: Property, plant and equipment Accounting policy Property, plant and equipment along with property used by the owner are accounted for under IAS 16. The investment is initially recognised at its acquisition cost and is thereafter depreciated on a linear basis over its expected useful life. When establishing a depreciation plan, the individual assets are to the necessary extent split up into components with differing useful life, with account being taken of estimated residual value. Property, plant and equipment items which individually are of little significance, for example computers and other office equipment, are not individually assessed for residual value, useful lifetime or value loss, but are assessed on a Group basis. Property used by the owner, according to the definition in IAS 40, is property that is mainly used by the Bank or its subsidiary for its own use. Property, plant and equipment which are depreciated are subject to a depreciation test in accordance with IAS 36 when circumstances so indicate. Property held in order to earn rentals or for capital appreciation is classified as investment property and is measured at fair value in accordance with IAS 40. The Group has no investment properties. 2025 Parent Bank Group Buildings and other real property Machinery, inventory and vehicles Total NOK million Total Machinery, inventory and vehicles Buildings and other real property 192 208 400 Cost of acquisition at 1 January 25 692 299 393 18 27 45 Additions 54 28 26 -2 -13 -15 Disposals -15 -13 -2 208 222 429 Cost of acquisition at 31 December 731 315 417 86 126 211 Accumulated depreciation and write-downs as at 1 January 401 206 195 14 25 39 Current period’s depreciation 49 29 20 -0 - -0 Current period’s write-down -0 - -0 -2 -5 -8 Disposals -8 -5 -2 98 145 243 Accumulated depreciation and write-down as at 31 December 442 230 213 110 77 187 Book value as at 31 December 25 289 85 204
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331SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 331 2024 Parent Bank Group Buildings and other real property Machinery, inventory and vehicles Total NOK million Total Machinery, inventory and vehicles Buildings and other real property 200 186 386 Cost of acquisition at 1 January 24 676 276 400 32 32 64 Additions 68 34 33 -40 -10 -51 Disposals -53 -13 -40 192 208 400 Cost of acquisition at 31 December 692 299 393 107 113 219 Accumulated depreciation and write-downs as at 1 January 401 191 210 12 23 35 Current period’s depreciation 45 27 18 -0 -0 -0 Current period’s write-down -0 -0 -0 -33 -10 -43 Disposals -45 -12 -33 86 126 211 Accumulated depreciation and write-down as at 31 December 401 206 195 106 82 188 Book value as at 31 December 24 290 92 198 Depreciation With a basis in acquisition cost less any residual value, assets are depreciated on a straight- line basis over expected lifetime as followsr: • Machinery 3-5 years • Fixtures 5-10 years • Technical installations 5-10 years • Means of transport 10 years • Buildings and other real property 25 years Collateral The Group has not provided security or accepted any other infringements on its right of disposal of its fixed tangible assets. Acquisition cost of depreciated assets The acquisition cost of fully depreciated assets still in use in the Bank in 2025 is NOK 120 million (NOK 178 million). Gross value of non-current assets temporarily out of operation The Group has no significant non-current assets out of operation as at 31 December 2025.
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332SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 33: Leases Accounting policy Identifying a lease At the inception of a contract, The Group assesses whether the contract is, or contains, a lease. A contract is, or contains, a lease if the contract conveys the right to control the use of an identified asset for a period of time in exchange for consideration. The Group as a lessee Separating components in the lease contract For contracts that constitute, or contain a lease, the Group separates lease components if it benefits from the use of each underlying asset either on its own or together with other resources that are readily available, and the underlying asset is neither highly dependent on, nor highly interrelated with, the other underlying assets in the contract. The Group then accounts for each lease component within the contract as a lease separately from non- lease components of the contract. Innregning av leieavtaler og innregningsunntak At the lease commencement date, the Group recognises a lease liability and corresponding right-of-use asset for all lease agreements in which it is the lessee, except for the following exemptions applied: • Short-term leases (defined as 12 months or less) • Low value assets For these leases, the Group recognises the lease payments as other operating expenses in the statement of profit or loss when they incur. Lease liabilities The lease liability is recognised at the commencement date of the lease. The Group measures the lease liability at the present value of the lease payments for the right to use the underlying asset during the lease term that are not paid at the commencement date. The lease term represents the non-cancellable period of the lease, together with periods covered by an option either to extend or to terminate the lease when the Group is reasonably certain to exercise this option. The lease payments included in the measurement comprise of: • Fixed lease payments (including in-substance fixed payments), less any lease incentiv es receivable • Variable lease payments that depend on an index or a rate, initially measured using the index or rate as at the commencement date • Amount expected to be payable by the Group under residual value guarantees • The exercise price of a purchase option, if the Gr oup is reasonably certain to exercise that option • Payments of penalties for terminating the lease, if the lease term reflects the Group e xercising an option to terminate the lease. The lease liability is subsequently measured by increasing the carrying amount to reflect interest on the lease liability, reducing the carrying amount to reflect the lease payments made and remeasuring the carrying amount to reflect any reassessment or lease modifications, or to reflect adjustments in lease payments due to an adjustment in an index or rate. The Group does not include variable lease payments in the lease liability. Instead, the Group recognises these variable lease expenses in profit or loss. The Group presents its lease liabilities as separate line items in the statement of financial position. Right-of-use assets The Group measures the right-of use asset at cost, less any accumulated depreciation and impairment losses, adjusted for any remeasurement of lease liabilities. The cost of the right-of-use asset comprise: • The amount of the initial measurement of the lease liability recognised • Any lease payments made at or before the commencement date, less any incentives receiv ed • Any initial direct costs incurred by the Group • An estimate of the costs to be incurred by the Group in dismantling and remo ving the underlying asset, restoring the site on which it is located or restoring the underlying asset to the condition required by the terms and conditions of the lease, unless those costs are incurred to produce inventories The Group applies the depreciation requirements in IAS 16 Property, Plant and Equipment in depreciating the right-of-use asset, except that the right-of-use asset is depreciated from the commencement date to the earlier of the lease term and the remaining useful life of the right-of-use asset. The Group applies IAS 36 Impairment of Assets to determine whether the right-of-use asset is impaired and to account for any impairment loss identified..
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333SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS The Group as a lessor Separating components in the lease contract For a contract that contains a lease component and one or more additional lease or nonlease components, The Group allocates the consideration in the contract applying the principles in IFRS 15 Revenue from Contracts with Customers. Recognition of leases and income For contracts where the Group acts as a lessor, it classifies each of its leases as either an operating lease or a finance lease. A lease is classified as a finance lease if it transfers substantially all the risks and rewards incidental to ownership of an underlying asset. A lease is classified as an operating lease if it does not transfer substantially all the risks and rewards incidental to ownership of an underlying asset. The Group as a lessor does not have any finance leases. Operating leases For operating leases, the Group recognises lease payments as other income, mainly on a straight-line basis, unless another systematic basis is more representative of the pattern in which benefit from the use of the underlying asset is diminished. The Group recognises costs incurred in earning the lease income in other operating expenses. The Group adds initial direct costs incurred in obtaining an operating lease to the carrying amount of the underlying asset and recognises those costs as an expense over the lease term on the same basis as the rental income. Recognition and discount rate IFRS 16 refers to two different methods of determining the discount rate for lease payments: • The rate implicit in the lease • The lessee’s incremental rate of borrowing, if the implicit rate is not readily determined L ease contracts covered by IFRS 16 vary as regards term and option structure. Moreover, assumptions must be made as to the opening value of the underlying assets. Both of these items make an implicit interest calculation more complicated than an incremental borrowing rate calculation. SpareBank 1 SMN has a framework for transfer pricing that is designed to provide as correct a picture as possible of how various balance sheet items, business lines, segments or regions in the bank contribute to the bank’s profitability. The starting point for the transfer pricing rates is the bank’s historical cost of funding. The Group’s cost of funding can be split up into a cost related to senior unsecured debt and a cost related to capital (hybrid capital and subordinated loan capital). The latter cost of funding shall, like other equity, be distributed on assets based on risk weights. The cost related to own funds (hybrid capital and subordinated loan capital) then appears as a further transfer price addition to the loan accounts. The bank also has indirect liquidity costs related to liquidity reserves. These are reserves that the bank is required to hold by the authorities along with reserves of surplus liquidity held by the bank for shorter periods. The liquidity reserves have a substantial negative return measured against the bank’s cost of funding. This cost is distributed on balance sheet items that create a need for liquidity reserves, and appear as a reduction from the transfer price interest for deposits and an addition as regards loans. Transfer pricing rate = Cost of Funding (CoF) + addition for liquidity reserve cost + addition for cost of capital In the transfer pricing the bank’s liquidity cost or cost of funding is distributed on assets and liabilities, and is actively utilised in the internal account. The transfer price is accordingly a well-established tool in the governance of the bank, and is regularly updated. The transfer price interest rate for an asset with the corresponding underlying, in this case commercial property, will therefore be a good representation of the incremental borrowing rate. This discount rate will include the material additions to the cost of funding, giving a more correct picture of the opportunity cost for the bank. This interest rate have been used as the discount rate for the Group’s leases coming under IFRS 16. A discount rate of 5.18 per cent has been used in 2025. Right-of-use assets are classified as non-current assets in the balance sheet whereas the lease liability is classified as other debt. The Group’s lease liability relates in all essentials to lease agreements for offices.
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334SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 334 Right-of-use assets Parent Bank Group 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 507 618 Acquisition cost 1 January 942 784 85 30 Addition of right-of-use assets 79 124 - -15 Disposals - 12 26 9 Transfers and reclassifications 12 27 618 642 Acquisition cost 31 December 1,033 947 256 321 Accumulated depreciation and impairment 1 January 503 401 67 72 Depreciation 109 101 -2 - Disposals -2 -2 321 393 Accumulated depreciation and impairment 31 December 610 501 297 249 Carrying amount of right-of-use assets 31 December 423 447 Lease liabilities Undiscounted lease liabilities and maturity of cash outflows in presented in the table below. 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 47 49 Less than 1 year 90 88 47 48 1-2 years 85 79 45 45 2-3 years 76 71 41 42 3-4 years 70 63 38 41 4-5 years 67 62 121 98 More than 5 years 191 209 338 324 Total undiscounted lease liabilities at 31 December 580 571
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335SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 335 Summary of lease liabilities Parent Bank Group 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 260 307 At initial application 01 January 454 406 110 26 New lease liabilities recognised in the year 90 128 -65 -70 Cash payments for the principal portion of the lease liability -101 -99 -13 -13 Cash payments for the interest portion of the lease liability -19 -18 13 13 Interest expense on lease liabilities 19 18 - - Other changes -1 25 307 262 Total lease liabilities at 31 December 442 461 67 45 Current lease liabilities (note 37) 83 82 240 217 Non-current lease liabilities (note 37) 359 378 -65 -70 Total cash outflows for leases -120 -116 Summary of other lease expenses recognised through P&L 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 14 16 Variable lease payments expensed in the period 18 17 1 1 Operating expenses in the period related to short-term leases (including short-term lo w value assets) 4 4 -0 -0 Operating expenses in the period related to low value assets (excluding shor t-term leases included above) - - 15 17 Total lease expenses included in other operating expenses 22 21
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336SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 336 Note 34: Other assets Parent Bank Group 31 Dec 2024 31 Dec 2025 (NOK million) 31 Dec 2025 31 Dec 2024 - - Deferred tax asset 2 1 188 187 Fixed assets 289 290 297 249 Right to use assets 423 447 187 114 Earned income not yet received 138 211 221 305 Accounts receivable, securities 305 221 296 - Pensions - 296 288 806 Other assets 1,151 602 1,479 1,662 Total other assets 2,308 2,069
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337SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 337 Note 35: Deposits from and liabilities to customers Accounting policy Customer deposits are recognised at amortised cost. Deposits from and liabilities to customers Parent Bank Group 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 97,280 104,784 Deposits from and liabilities to customers without agreed maturity 104,173 96,694 44,206 41,995 Deposits from and liabilities to customers with agreed maturity 41,992 44,204 141,485 146,778 Total deposits from and liabilities to customers 146,165 140,897 3.6 % 3.5 % Average interest rate 3.5 % 3.6 % Fixed interest deposits account for 4.0 per cent (5.9 per cent in 2024) Deposits specified by sector and industry 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 62,581 68,267 Wage earners 68,267 62,581 16,535 16,654 Public administration 16,654 16,535 2,638 2,805 Agriculture and forestry 2,805 2,638 1,658 2,004 Fisheries and hunting 2,004 1,658 1,538 861 Sea farming industries 861 1,538 3,041 4,117 Manufacturing 4,117 3,041 3,833 3,688 Construction, power and water supply 3,688 3,833 5,707 5,850 Retail trade, hotels and restaurants 5,850 5,707 655 802 Maritime sector 802 655 7,503 6,522 Property management 6,430 7,413 13,004 12,190 Business services 12,190 13,004 14,838 15,119 Transport and other services pro vision 14,615 14,360 7,954 7,899 Other sectors 7,882 7,933 141,485 146,778 Total deposits from customers brok en down by sector and industry 146,165 140,897
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338SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 338 Deposits specified by geographic area 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 84,392 88,909 Trøndelag 88,296 83,804 26,966 29,780 Møre og Romsdal 29,780 26,966 1,020 1,194 Nordland 1,194 1,020 11,941 11,909 Oslo 11,909 11,941 15,919 13,887 Other counties 13,887 15,919 1,247 1,100 Abroad 1,100 1,247 141,485 146,778 Total deposits broken down b y geographic area 146,165 140,897
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339SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 339 Note 36: Debt securities in issue Accounting policy Issued securities debt (senior loans) are measured at amortised cost or as financial liabilities specifically accounted for at fair value with changes in value recognised in profit or loss. As a general rule, hedge accounting (fair value hedging) is used when issuing bond debt with a fixed interest rate. In hedging, there is a clear, direct and documented connection between changes in the value of the hedged item (loan) and the hedging instrument (interest rate derivative). For the hedged item, changes in fair value related to the hedged risk are accounted for as a addition or deduction in capitalised securities debt and are recognised in the income statement under «Net return on financial investments». The hedging instruments are measured at fair value and the changes in fair value are recognised in the income statement on the same profit line as the hedging objects. Debt when issuing securities is presented including accrued interest. See note 29 for a more detailed description of hedge accounting. Parent Bank Group 31 Dec 2024 31 Dec 2025 (NOK million) 31 Dec 2025 31 Dec 2024 36,570 29,121 Bond debt 29,121 36,570 13,352 15,392 Senior non preferred 15,392 13,352 49,922 44,512 Total debt securities in issue 44,512 49,922 2.37% 2.39% Average interest, bond debt 2.39% 2.37% 4.65% 4.31% Average interest, senior non preferred 4.31% 4.65%
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340SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 340 Securities debt specified by maturity 1,2) Parent Bank Group 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 8,050 - 2025 - 8,050 12,713 11,648 2026 11,648 12,713 6,995 7,025 2027 7,025 6,995 11,304 11,282 2028 11,282 11,304 8,870 9,132 2029 9,132 8,870 841 2,839 2030 2,839 841 354 1,455 2031 1,455 354 295 296 2032 296 295 354 355 2033 355 354 177 177 2034 177 177 307 308 2035 308 307 330 - 2043 - 330 - 331 2044 331 - -102 -73 Currency agio -73 -102 -943 -653 Premium and discount, market value of structured bonds -653 -943 377 392 Accrued interest 392 377 49,922 44,512 Total securities debt 44,512 49,922 1) Maturity is final maturity, not call date 2) Deducting own bonds issued. Total nominal own holdings 31. December 2025: NOK 34 million (2024: NOK 1 million) Securities debt distributed on significant currencies 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 21,027 21,186 NOK 21,186 21,027 25,229 19,576 EUR 19,576 25,229 3,666 3,750 Other 3,750 3,666 49,922 44,512 Total securities debt 44,512 49,922
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341SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 341 Parent Bank and Group Change in securities debt 31 Dec 2025 Issued Fallen due/ redeemed Other changes 31 Dec 2024 Bond debt 29,505 77 6,974 -801 37,204 Adjustments -608 - - 270 -878 Accrued interest 223 - - -20 244 Total 29,121 77 6,974 -552 36,570 Change in senior non-preferred debt 31 Dec 2025 Issued Fallen due/ redeemed Other changes 31 Dec 2024 Senior non preferred 15,341 3,458 1,344 -159 13,386 Adjustments -118 - - 49 -167 Accrued interest 169 - - 35 134 Total 15,392 3,458 1,344 -74 13,352 Change in securities debt 31 Dec 2024 Issued Fallen due/ redeemed Other changes 31/12/2023 Bond debt 37,204 5,880 4,425 982 34,767 Adjustments -878 - - 645 -1,522 Accrued interest 244 - - 71 173 Total 36,570 5,880 4,425 1,697 33,417 Change in senior non-preferred debt 31 Dec 2024 Issued Fallen due/ redeemed Other changes 31/12/2023 Senior non preferred 13,386 1,709 686 18 12,344 Adjustments -167 - - -102 -65 Accrued interest 134 - - -3 136 Total 13,352 1,709 686 -86 12,415
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342SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 37: Other debt and liabilities Parent Bank Group 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 202 119 Deferred tax 228 290 958 1,044 Payable tax 1,143 1,042 30 33 Capital tax 33 30 178 95 Accruals 455 541 373 326 Provisions 326 373 101 70 Loss provision guarantees 70 101 8 8 Pension liabilities 8 8 307 262 Lease liabilities 441 460 76 89 Creditors 134 149 251 345 Debt from securities 345 251 188 185 Other 273 281 2,673 2,577 Total other debt and recognised liabilities 3,457 3,527 Other liabilities, not recognised 6,181 6,391 Credit limits, trading 6,391 6,181 - - Other commitments 33 54 6,181 6,391 Total other commitments 6,424 6,235 8,854 8,968 Total commitments 9,881 9,762 Collateral As from 1 March 2017 the bank is required under the European market infrastructure regulation (EMIR) to have in place a CSA with daily exchange of margin collateral etc. with all financial counterparties with which the bank deals domiciled (inter alia) in an EU member state. The Emir regulation regulates OTC derivatives and entails inter alia that SpareBank 1 SMN will be entitled to clear certain derivatives transactions through a central counterparty. This mainly applies to interest rate derivatives in euro and Norwegian kroner. Derivatives are cleared through London Clearing House as central counterparty where cash is the only collateral at present. SpareBank 1 SMN is not a direct member of London Clearing House, but has entered an agreement with Commerzbank and SEB as clearing broker. The liabilities are presented gross in the table below. SpareBank 1 SMN is registered as a GCM member of NASDAQ OMX Clearing AB. The bank offers customers clearing representation related to their trade in electricity and salmon derivatives on NASDAQ OMX Oslo ASA and Fish Pool ASA. Clearing representation entails that the bank substitutes itself in the place of the client as counterparty to NASDAQ OMX Clearing AB and takes on the obligation towards NASDAQ to furnish margin collateral and to execute settlement of contracts and pay charges. For the bank’s exposure as a GCM, clients will furnish collateral in the form of a deposit of cash and/or encumbrance of other assets. Parent Bank Group Cash deposit Total Securities pledged Total Cash deposit 1,285 1,285 Securities pledged 31 December 2025 1,285 1,285 -82 -82 Relevant liabilities 31 December 2025 -82 -82 749 749 Securities pledged 31 December 2024 749 749 2,406 2,406 Relevant liabilities 31 December 2024 2,406 2,406 Ongoing lawsuits The Group is not involved in legal disputes that are considered to be of substantial significance for the Group’s financial position.
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343SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 343 Provisions The Group has made provisions for pension liabilities (see note 22) and gifts. Provision on gifts is the part of previous year’s profit to be allocated to non-profit causes. More on this topic in the section Community dividend in the Report of the Board of Directors. For specified losses on guarantees, see note 10. Parent Bank and Group NOK million Pension liabilities Gifts Provisions at 1 January 2025 8 372 Additional provisions in the period - 240 Amounts used in the period - -287 Provisions at 31 December 2025 8 325 NOK million Pension liabilities Gifts Provisions at 1 January 2024 9 456 Additional provisions in the period - 250 Amounts used in the period -0 -335 Other -1 - Provisions at 31 December 2024 8 372
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344SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 38: Subordinated debt and hybrid capital issue Accounting policy Subordinated debt are measured at amortised cost like other long-term loans. Subordinated debt ranks behind all other debt. Hybrid capital denotes bonds with a nominal interest rate, but the Bank is not obliged to pay interest in a period in which no dividend is paid, nor does the investor subsequently have a right to interest that has not been paid, i.e. the interest does not accumulate. Hybrid capital have been classified as equity since these do not satisfy the definition of a financial liabiltiy in IAS 32. The bond is perpetual and SpareBank 1 SMN has the right to not pay interest to the investors. The interest will not be presented as an interest expense in the income statement, but as a reduction to equity. See also Note 3 for a closer description. The treatment of subordinated debt and hybrid capital in the calculation of the Group’s capital adequacy is described in Note 5: Capital adequacy. Parent Bank Group 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 Dated subordinated debt - - 2026 SpareBank 1 Finans Midt-Norge 23/34 78 78 1,000 1,000 2032 floating rate NOK (Call 2027) 1,000 1,000 750 750 2033 floating rate NOK (Call 2028) 750 750 500 500 2034 floating rate NOK (Call 2029) 500 500 400 400 2035 floating rate NOK (Call 2029) 400 400 - 100 2035 floating rate NOK (Call 2030) 100 - 6 20 Accrued interest 20 7 2,656 2,770 Total dated subordinated debt 2,848 2,735 6.67% 6.40% Average rate NOK 6.40% 6.67% Additional Tier 1 Capital - - 5/99 SpareBank 1 Finans Midt-Norge floating rate NOK (Call 2028) 96 96 143 - 7/99 fixed rate 5,0 % NOK (Call 2025)1) - 143 50 - 5/99 floating rate NOK (Call 2025) - 50 500 500 5/99 floating rate NOK (Call 2027) 500 500 200 200 7/99 fixed rate 7,12 % NOK (Call 2027)1) 200 200 300 300 5/99 floating rate NOK (Call 2028) 300 300 150 150 5/99 floating rate NOK (Call 2029) 150 150 150 150 7/99 fixed rate 7,04 % NOK (Call 2029)1) 150 150 450 450 5/99 floating rate NOK (Call 2030) 450 450 - 150 5/99 floating rate NOK (Call 2030) 150 - 1,943 1,900 Total additional Tier 1 Capital 1,996 2,039 7.37% 8.15% Average rate NOK 8. 15% 7.37% 1) Fixed rate funding changed to floating rate by means of interest rate swaps
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345SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 345 Changes in subordinated debt and hybrid equity issue NOK million 31/12/2023 Issued Fallen due/ redeemed Other changes 31 Dec 2024 Ordinary subordinated debt, NOK 2,226 902 400 - 2,728 Accrued interest 21 - - -14 7 Total subordinated debt 2,247 902 400 -14 2,735 NOK million 31 Dec 2024 Issued Fallen due/re- deemed Other changes 31 Dec 2025 Ordinary subordinated debt, NOK 2,728 100 - - 2,828 Accrued interest 7 - - 13 20 Total subordinated debt 2,735 100 - 13 2,848 Changes in additional Tier 1 Capital NOK million 31/12/2023 Issued Fallen due/ redeemed Other changes 31 Dec 2024 Additional Tier 1 Capital, NOK 1,903 450 315 - 2,039 Total hybrid equity issue 1,903 450 315 - 2,039 NOK million 31 Dec 2024 Issued Fallen due/re- deemed Other changes 31 Dec 2025 Additional Tier 1 Capital, NOK 2,039 150 193 - 1,996 Total hybrid equity issue 2,039 150 193 - 1,996
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346SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 39: Investments in owner interests Accounting policy Associated companies Associates are companies in which the Bank has substantial influence. As a rule, influence is substantial where the Bank has an ownership interest of 20 per cent or more. Associates are accounted for by the equity method in the consolidated accounts. The investment is initially recognised at acquisition cost and subsequently adjusted for the change in the Bank’s share of the associated undertaking’s net assets. The Bank recognises its share of the profit of the associated undertaking in its income statement. Associates are accounted for in the parent bank accounts by the cost method. Joint arrangements Under IFRS 11 investments in Joint arrangements shall be classified as Joint operations or joint ventures depending on the right and obligations in the contractual arrangement for each investor. SpareBank 1 SMN has assessed its joint arrangements and concluded that they are joint ventures. Jointly controlled ventures are accounted for using the equity method in the group and the cost method in the parent bank. When the equity method is used joint ventures are recognised at their original acquisition cost. The carrying amount is thereafter adjusted to recognise the share of the results after the acquisition and the share of comprehensive income. When the group’s share of a loss in a joint venture exceeds the capitalized amount (including other long-term investments that are in reality part of the group’s net investment in the venture), no further loss is recognized unless liabilities have been assumed or payments have been made on behalf of the joint venture. Unrealized gains on transactions between the group and its joint ventures are eliminated according to the ownership interest in the business. Unrealized losses are also eliminated unless the transaction gives evidence of a fall in value on the transferred asset. Amounts reported from joint ventures are, if necessary, restated to ensure they correspond with the accounting policies of the group. Non-current assets held for sale and discontinued operations Assets which the board of directors of the bank has decided to sell are dealt with under IFRS 5 if it is highly likely that the asset will be sold within 12 months. This type of asset comprises for the most part assets taken over in connection with bad loans, and investments in subsidiaries held for sale. In the case of depreciable assets, depreciation ceases when a decision is taken to sell, and the asset is measured at fair value in accordance with IFRS 5. The result of such activity and appurtenant assets and liabilities are presented on a separate line as held for sale.
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347SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Subsidiaries, associates, joint ventures and companies held for sale Company Company number Registered office Stake in per cent Investment in significant subsidiaries EiendomsMegler 1 Midt-Norge 936159419 Trondheim 92.4 % SpareBank 1 Regnskapshuset SMN 936285066 T rondheim 93.3 % SpareBank 1 Invest 990961867 Tr ondheim 100.0 % SpareBank 1 Finans Midt-Norge 938521549 Tr ondheim 64.8 % SpareBank 1 SMN Kvartalet 990283443 T rondheim 100.0 % SpareBank 1 Bygget Steinkjer 934352718 Tr ondheim 100.0 % St. Olavs Plass 999263380 T rondheim 100.0 % Sparebank 1 Mobilitet Holding 2 833039342 Trondheim 56.5 % SpareBank 1 Bilplan 979945108 Trondheim 100.0 % Shares owned by subsidiaries and sub-subsidiaries GMA Invest 994469096 Trondheim 100.0 % Sentrumsgården 975856828 Leks vik 35.3 % Aqua Venture 891165102 Tr ondheim 37.6 % Omega-3 Invest 996814262 Namsos 33.6 % Tjeldbergodden Utvikling 979615361 Aure 23.0 % Grilstad Marina 991340475 Trondheim 35.0 % GMN 6 994254707 Trondheim 35.0 % GMN 51 996534316 Trondheim 30.0 % GMN 52 996534413 Trondheim 30.0 % GMN 53 996534502 Trondheim 30.0 % Grilstad N8 AS 926281070 Trondheim 35.0 % Brauten Eiendom 917066221 Trondheim 100.0 % Leksvik Regnsk apskontor 980491064 Leksvik 50.0 % SpareBank 1 Mobilitet Holding 927249960 Hamar 30.7 % Investment in joint ventures SpareBank 1 Gruppen 975966372 Tromsø 19.5 % SpareBank 1 Utvikling 986401598 Oslo 18.0 % Investment in associates SpareBank 1 Boligkreditt 988738387 Sta vanger 22.8 % BN Bank 914864445 Trondheim 35.0 % SpareBank 1 Næringskreditt 894111232 Stavanger 14.8 % Kredittbanken 975966453 Tr ondheim 15.1 % SpareBank 1 Betaling 919116749 Oslo 20.5 % SpareBank 1 Gjeldsinformasjon 924911719 Oslo 18.1 % SpareBank 1 Forvaltning 925239690 Oslo 21. 7 % SB1 Markets 992999101 Oslo 31.9 % Investment in companies held for sale Mavi XV 890899552 T rondheim 100.0 % Mavi XXIX 827074462 Trondheim 100.0 % Byscenen Kongensgt 19 992237899 Tr ondheim 94.0 % Bjerkeløkkja 998534976 Oppdal 95.0 %
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348SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 348 Shares in subsidiaries Recorded at acquisition cost in the Parent Bank. Full consolidation in the Group accounts. Total costs include tax charge. The booked value of subsidiaries in the tables below is the parent bank’s booked value. The profit or loss column shows the company’s profit of the year. 2025 (NOK million) Company’s share capital (NOK 1000’s) No. of shares Nominal value (NOK 1000’s) Assets Liabilities Equity NCI of equity1) Total income Total expenses Profit or loss NCI of profit or loss1) Book value 31.12 SpareBank 1 Finans Midt-Norge 1,400,000 90,471 15 13,655 11,613 2,042 642 470 249 220 78 1,056 Total investments in credit institutions 1,056 EiendomsMegler 1 Midt-Norge 105,960 4,788 22 533 208 325 25 569 509 60 5 201 SpareBank 1 SMN Kvartalet 30,200 30,200 1 108 16 92 - 26 16 10 - 126 SpareBank 1 Regnskapshuset SMN 20,944 222 94 795 308 487 33 732 649 83 6 368 SpareBank 1 Invest 457,280 914,560 1 898 15 882 - 50 3 47 - 540 SpareBank 1 Bygget Steinkjer 1,000 100 10 37 2 35 - 1 -1 1 - 40 St. Olavs Plass 1,000 100,000 0 55 1 54 - 5 3 2 - 50 SpareBank 1 Bilplan 5,769 41,206 0 8 0 8 - 0 0 -0 - 9 SpareBank1 Mobilitet Holding 2 700 565 0 1 - 1 0 - - - - 0 Total investments in other subsidiaries 1,335 Total investments in Group companies, Parent Bank 2,391 *) Non-controlling interests 2024 (NOK million) Company’s share capital (NOK 1000’s) No. of shares Nominal value (NOK 1000’s) Assets Liabilities Equity NCI of equity1) Total income Total expenses Profit or loss NCI of profit or loss1) Book value 31.12 SpareBank 1 Finans Midt-Norge 1,350,000 77,288 10 13,159 11,160 1,999 769 464 236 228 98 889 Total investments in credit institutions 889 EiendomsMegler 1 Midt-Norge 105,960 4,788 22 442 176 266 20 512 457 55 4 201 SpareBank 1 SMN Kvartalet 30,200 30,200 1 110 18 92 - 26 15 10 - 126 SpareBank 1 Regnskapshuset SMN 20,349 211 96 754 289 465 31 694 633 61 4 368 SpareBank 1 Invest 457,280 914,560 1 859 23 836 - 37 4 33 - 540 SpareBank 1 Bygget Steinkjer 1,000 100 10 35 1 34 - 1 1 -1 - 40 St. Olavs Plass 1,000 100,000 0 53 1 52 - 4 4 0 - 50 SpareBank 1 Bilplan 5,769 41,206 0 8 0 8 - 0 0 -0 - 9 SpareBank1 Mobilitet Holding 2 700 565 0 1 - 1 0 -0 - -0 - 0 Total investments in other subsidiaries 1,335 Total investments in Group companies, Parent Bank 2,225 1) Non-controlling interests
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349SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Dividends from subsidiaries NOK million 31 Dec 2025 31 Dec 2024 SpareBank 1 Finans Midt-Norge 135 - EiendomsMegler 1 Midt-Norge - 28 SpareBank 1 Regnskapshuset SMN 51 78 SpareBank 1 SMN Invest - - SpareBank 1 SMN Kvartalet 10 10 St. Olavs Plass 1 SMN - - SpareBank 1 Bygget Steinkjer - 1 Total dividends 196 117 Shares in associates and joint ventures Associates and joint ventures are recorded at acquisition cost in the Parent Bank. Group figures are presented by the equity method. Parent Bank Group 31 Dec 2024 31 Dec 2025 NOK million 31 Dec 2025 31 Dec 2024 6,270 6,789 As at 1 January 10,084 8,695 519 573 Acquisition/sale 582 518 - - Write-down - - - - Equity capital changes 133 -182 - - Profit share 1,017 1,254 - - Dividend paid -583 -201 6,789 7,362 Book value as at 31 December 11,234 10,084 Specification of year’s change, Group Additions / disposal Equity change SpareBank 1 Gruppen - 7 SpareBank 1 Boligkreditt 600 85 SpareBank 1 Næringskreditt 46 - Kredittbanken 22 -1 SpareBank 1 Betaling - 11 BN Bank - -2 SpareBank 1 Forvaltning 4 -2 SB1 Markets -90 42 Other companies - -7 Total 582 133 Dividends from investments in associates and joint ventures NOK million 31 Dec 2025 31 Dec 2024 SpareBank 1 Gruppen - - SpareBank 1 Boligkreditt 130 100 BN Bank 263 - SpareBank 1 Næringskreditt 14 10 Kredittbanken - - SB1 Markets 129 61 SpareBank 1 Forvaltning 46 29 Total dividend from associates and joint ventures 583 201
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350SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Company information on the Group’s stakes in associates and joint ventures The tables below contain company or Group accounting figures on a 100 per cent share basis, except for profit share which is stated as the SMN Group’s share. Badwill and amortisation effects related to acquisitions are included in the profit share. Booked value is the consolidated value in the Group. 2025 NOK million Assets Liabilities Total income Total costs Profit share Book value 31.12 No. of shares SpareBank 1 Gruppen 187,173 162,443 29,058 24,751 446 2,855 420,498 SpareBank 1 Boligkreditt 369,617 351,951 763 215 105 3,782 25,491,998 SpareBank 1 Næringskreditt 10,215 8,116 86 17 9 310 2,400,484 Kredittbanken 23,622 20,377 977 933 7 489 1,373,988 SpareBank 1 Betaling 1,296 0 - 2 -6 266 6,849,205 BN Bank 54,392 47,207 1,553 681 291 2,332 4,943,072 SpareBank 1 Forvaltning 2,129 1 1,857 1,590 58 285 1,001,208 SB1 Markets 3,903 1,863 1,228 1,025 74 650 1,915,359 Other companies 35 264 Total 1,017 11,234 2024 NOK million Assets Liabilities Total income Total costs Profit share Book value 31.12 No. of shares SpareBank 1 Gruppen 166,903 144,915 24,361 22,128 678 2,402 420,498 SpareBank 1 Boligkreditt 357,386 342,603 846 232 129 3,123 21,531,278 SpareBank 1 Næringskreditt 10,515 8,387 133 35 14 270 2,062,045 Kredittbanken 12,177 9,598 594 648 -10 461 1,310,189 SpareBank 1 Betaling 1,264 0 - 2 -19 261 6,849,205 BN Bank 52,518 45,408 1,504 601 302 2,306 4,943,072 SpareBank 1 Forvaltning 1,693 430 1,076 829 54 272 988,156 SB1 Markets 3,002 1,111 1,186 961 89 754 2,137,142 Other companies 16 236 Total 1,254 10,084
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351SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 351 Companies held for sale SpareBank 1 SMN’s strategy is that ownership duse to defaulted exposures should at the outset be of brief duration, normally not longer than one year. Investments are recorded at fair value in the Parent Bank’s accounts, and is classified as investment held for sale. 2025 2025 (NOK Million) Assets Liabilities Revenue Expenses Profit Ownership Mavi XV Group 175 1 11 -22 -11 100% Total Held for sale 175 1 11 -22 -11 2024 2024 (NOK Million) Assets Liabilities Revenue Expenses Profit Ownership Mavi XV Group 190 2 13 15 -2 100% Total Held for sale 190 2 13 15 -2
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352SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 40: Business acquisitions/business combinations Accounting policy Upon acquisition of businesses a purchase price analysis is prepared in accordance with IFRS 3 where identifiable assets and liabilities are recognised at fair value on the acquisition date. Acquisition in subsidiaries EiendomsMegler 1 Midt-Norge AS (EM1MN) acquired all shares in Norion Næringsmegling AS in 2025. As of 2025, Norion Næringsmegling AS is a wholly owned subsidiary of EM1MN, and the commercial real estate division in EM1MN has been merged into the subsidiary Purchase price allocations (PPA) have been prepared in accordance with IFRS 3, whereby identifiable assets and liabilities have been measured at fair value at the acquisition date. The difference between the Group’s acquisition cost and the carrying amount of net assets has been allocated to goodwill. SR-Rekneskap AS and Meese Regnskap AS were acquired by SpareBank 1 Regnskapshuset SMN AS in 2024 and were merged into the company in 2025.
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353SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 353 Note 41: Significant transactions with related companies In this context ‘related parties’ means subsidiaries, associated companies, joint ventures and companies held for sale over which the Bank exercises substantial influence, as well as SpareBank 1 SMN Pensjonskasse (pension fund) and companies owned by the Bank’s personal related parties. The opening balance may differ from the previous year’s closing balance as the opening balance includes companies that during the fiscal year have been classified as related partied of the Bank. Subsidiaries Other related companies Loans (NOK million) 2025 2024 2025 2024 Outstanding loans as at 1.1 10,781 10,559 17 705 Loans issued in the period -278 126 -9 -1,901 Repayments -702 -2 -2 -1,201 Outstanding loans as at 31.12 11,205 10,687 10 5 Interest rate income 614 614 8 36 Bonds and subordinated loans as at 31.12 232 230 571 928 Deposits (NOK million) Deposits as at 1.1 1,329 1,040 2,900 1,289 Contribution received during the period 31,416 31,281 1,260,236 959,260 Withdrawals 31,426 30,993 1,259,951 957,649 Deposits as at 31.12 1,318 1,328 3,185 2,900 Interest rate expenses 61 65 186 158 Securities trading - - 149 223 Commission income SpareBank 1 Boligkreditt - - -22 -23 Commission income SpareBank 1 Næringskreditt - - 14 14 Issued guarantees and amount guaranteed - - 26 26 Loans and deposits All loans and deposits for related parties are booked in the Parent Bank.
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354SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Securities trading SpareBank 1 SMN’s treasury department and SB1 Markets, through outsourced business, carry out a large number of transactions with the Bank’s related companies. Transactions are executed on a ongoing basis in the fixed income and forex area, payments transmission, bond trading etc. These transactions are part of ordinary bank operations and all agreements are contracted on market terms. Numbers above includes net investmens in derivatives, bond transactions and deposits. Other transactions SpareBank 1 SMN has signed supply agreements with several related companies in order to safeguard ordinary banking operations and further development of the SpareBank 1 Alliance. This includes development of data-technical solutions for alliance collaboration, commission from insurance and savings and investment products, administrative services, leasing of premises etc. The agreements are considered to be on market terms. In addition the Bank participates in increases of capital in related companies; see note 39 on investment in owner interests.
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355SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 355 Note 42: ECC capital and ownership structure ECC capital The Bank’s ECC capital totals NOK 2.884.311.800 distributed on 144 215 590 equity capital certificates (ECCs), each with a face value of NOK 20,00. As of 31 December 2025 there was 19.408 ECC holders (17 348 as of 31 December 2024). ECC capital has been raised by the following means: Year Change Change in ECC capital (NOK) Total ECC capital (NOK) No. of ECCs 1991 Placing 525,000,000 525,000,000 5,250,000 1992 Placing 75,000,000 600,000,000 6,000,000 2000 Employee placing 5,309,900 605,309,900 6,053,099 2001 Employee placing 4,633,300 609,943,200 6,099,432 2002 Employee placing 4,862,800 614,806,000 6,148,060 2004 Bonus Issue 153,701,500 768,507,500 7,685,075 2005 Placing 217,424,200 985,931,700 9,859,317 2005 Employee placing 23,850,000 1,009,781,700 10,097,817 2005 Split - 1,009,781,700 40,391,268 2005 Rights issue 252,445,425 1,262,227,125 50,489,085 2007 Dividend issue 81,752,950 1,343,980,075 53,752,203 2007 Employee placing 5,420,000 1,349,400,075 53,976,003 2008 Dividend issue 90,693,625 1,440,093,700 57,603,748 2008 Employee placing 6,451,450 1,446,545,150 57,861,806 2009 Bonus issue 289,309,025 1,735,854,175 69,434,167 2010 Employee placing 12,695,300 1,748,549,475 69,941,979 2010 Rights issue 624,082,675 2,372,632,150 94,905,286 2011 Rights issue 625,000 2,373,257,150 94,930,286 2012 Reduction in nominal value -474,651,430 1,898,605,720 94,930,286 2012 Rights issue 569,543,400 2,468,149,120 123,407,456 2012 Employee placing 16,220,200 2,484,369,320 124,218,466 2012 Placing 112,359,540 2,596,728,860 129,836,443 2023 Merger 287,582,940 2,884,311,800 144,215,590
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356SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS 20 largest ECC holders at 31 December 2025 ECC holder No. Of ECCs Holding Sparebankstiftinga Søre Sunnmøre 10,471,224 7.26% Sparebankstiftelsen SMN 7,420,111 5.15% KLP 5,129,741 3.56% VPF Eika Egenkapitalbevis 4,712,608 3.27% Skandinaviska Enskilda Banken AB (Nominee) 3,206,783 2.22% Pareto Aksje Norge VPF 2,884,617 2.00% VPF Alfred Berg Gamba 2,765,315 1.92% VPF Holberg Norge 2,430,000 1.68% State Street Bank and Trust Comp (Nominee) 2,359,586 1.64% J.P. Morgan SE (Nominee) 2,298,783 1.59% Spesialfondet Borea Utbytte 2,149,204 1.49% Forsvarets per sonellservice 2,018,446 1.40% The Northern Trust Comp (Nominee) 2,013,742 1.40% Citibank, N.A. (Nominee) 1,841,610 1.28% J. P. Morgan Chase Bank, N.A., London (Nominee) 1,781,575 1.24% J.P. Morgan SE (Nominee) 1,659,359 1.15% State Street Bank and Trust Comp (Nominee) 1,644,700 1.14% J. P. Morgan Chase Bank, N.A., London (Nominee) 1,483,101 1.03% J.P. Morgan SE (Nominee) 1,479,086 1.03% J.P. Morgan SE (Nominee) 1,473,165 1.02% The 20 largest ECC holders in total 61,222,756 42.45% Others 82,992,834 57.55% Total issued ECCs 144,215,590 100.00% Dividend policy SpareBank 1 SMN aims to manage the Group’s resources in such a way as to provide equity certificate holders with a good, stable and competitive return in the form of dividend and a rising value of the bank’s equity certificate. The net profit for the year will be distributed between the owner capital (the equity certificate holders) and the ownerless capital in accordance with their respective shares of the bank’s total equity capital. SpareBank 1 SMN’s intention is that around one half of the owner capital’s share of the net profit for the year should be disbursed in dividends and, similarly, that around one half of the owner capital’s share of the net profit for the year should be disbursed as gifts or transferred to a foundation. This is on the assumption that capital adequacy is at a satisfactory level. When determining dividend payout, account will be taken of the profit trend expected in a normalised market situation, external framework conditions and the need for tier 1 capital.
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357SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 43: Earnings per ECC ECC owners share of profit have been calculated based on net profit allocated in accordance to the average number of certificates outstanding in the period. There is no option agreements in relation to the Equity Capital certificates, diluted net profit is therefore equivalent to Net profit per ECC. NOK Million 2025 2024 Adjusted Net Profit to allocate between ECC owners and Savings Bank Reserve 1) 4,118 4,339 Allocated to ECC Owners 2) 2,751 2,898 Issues Equity Captial Certificates adjusted for own certificates 144,191,372 144,187,578 Earnings per Equity Captial Certificate 19.08 20.10 1) Adjusted Net Profit 2025 2024 Net Profit for the group 4,367 4,591 - adjusted for non-controlling interests share of net pr ofit -88 -106 - adjusted for Tier 1 capital holders share of net profit -161 -146 Adjusted Net Profit 4,118 4,339 2) Equity capital certificate ratio (parent bank) (NOKm) 2025 2024 ECC capital 2,884 2,884 Dividend equalisation reserve 9,168 8,721 Premium reserve 2,422 2,422 Unrealised gains reserve 134 164 Other equity capital - - A. The equity capital certificate owners’ capital 14,608 14,191 Ownerless capital 7,205 6,984 Unrealised gains reserve 67 82 B. The saving bank reserve 7,272 7,065 To be disbursed from gift fund 968 896 Dividend declared 1,947 1,803 Equity ex. profit 24,795 23,955 Equity capital certificate ratio A/(A+B) 66.8 % 66.8 % Equity capital certificate ratio for distribution 66.80% 66.80%
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358SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | NOTES TO THE ANNUAL FINANCIAL STATEMENTS Note 44: Events after the balance sheet date Accounting policy The annual accounts are regarded as approved for publication once they have been considered by the board of directors. The supervisory board and regulatory authorities can thereafter refuse to approve the accounts, but not to change them. Events up to the time at which the accounts are approved for publication, and which relate to circumstances already known on the balance sheet date, will be included in the information base for accounting estimates and thus be fully reflected in the accounts. Events concerning circumstances that were not known on the closing date will be illuminated if significant. The accounts are presented on the going-concern assumption. In the view of the Board of Directors this assumption was met at the time the accounts were approved for presentation.
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359SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | FINANCIAL SUMMARY (GROUP) 359 Financial summary (Group) Income statement (NOK million) 1) 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 Interest income 13,618 13,560 11,262 5,927 3,913 4,197 4,626 4,057 3,825 3,597 Inter est expenses 8,276 8,187 6,631 2,588 1,107 1,439 1,939 1,655 1,600 1,714 Net interest and credit comission income 5,343 5,373 4,732 3,339 2,805 2,759 2,687 2,403 2,225 1,883 Commision and fee income 2,602 2,392 2,084 2,042 2,141 2,572 2,290 2,177 2,005 1,674 Income from investment in related companies 1,017 1,254 297 442 705 681 879 423 443 423 Return on financial investements 106 103 402 −61 134 269 322 334 317 521 Total income 9,068 9,123 7,515 5,760 5,786 6,281 6,178 5,337 4,989 4,502 Salaries, fees and other personnel costs 2,089 1,981 1,691 1,406 1,378 1,883 1,699 1,584 1,426 1,159 Other operating expenses 1,390 1,319 1,326 1,038 981 1,069 1,098 1,040 943 844 Total costs 3,479 3,300 3,017 2,443 2,360 2,952 2,797 2,624 2,369 2,003 Operating profit before losses 5,589 5,823 4,498 3,317 3,426 3,329 3,380 2,713 2,621 2,499 Losses on loans and guarantees 140 176 14 −7 161 951 299 263 341 516 Operating profit 5,449 5,647 4,484 3,324 3,266 2,378 3,081 2,450 2,279 1,983 Taxes 1,072 1,054 904 718 563 400 518 509 450 341 Result investment Held for sale -11 -2 108 179 200 1 0 149 −1 4 Profit of the year 4,367 4,591 3,688 2,785 2,902 1,978 2,563 2,090 1,828 1,647 Dividend 1,947 1,803 1,730 840 970 569 840 661 571 389
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360SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | FINANCIAL SUMMARY (GROUP) 360 Balance sheet NOKm 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 Cash and loans to and claims on credit institutions 2,282 9,821 9,917 12,834 5,956 7,856 2,871 5,957 7,527 4,207 CDs, bonds and other interest-bearing securities 53,402 55,015 50,655 53,792 44,024 43,522 35,508 32, 438 31,672 29,489 Loans before loss provisions 184,387 180,102 169,862 152,629 147,301 134,648 126,277 120,473 112,071 102,325 - Loan loss provisions 891 848 907 1,081 1,410 1,517 998 744 1,113 971 Other assets 3,735 3,609 3,189 5,137 2,974 3, 403 3,004 2,581 3,096 3,030 Total assets 242,914 247,699 232,717 223,312 198,845 187,912 166,662 160,705 153,254 138,080 Debt to credit institutions 9,584 13,941 13,160 14,636 15,063 13,095 8,853 9,214 9,607 10,509 Deposits from and debt to customers 146,165 140,897 132,888 122,010 111,286 97,529 85,917 80,615 76,476 67,168 Debt created by issuance of securities 48,993 56,074 52,818 55,781 44,241 51,098 46,541 47 ,251 45,537 40,390 Other debt and accrued expences etc. 3,458 3,528 3,007 3,818 3,217 3,085 2,841 2,671 1,924 1,532 Subordinated debt 2,848 2,735 2,247 2,058 1,796 1,795 2,090 2,268 2,201 3,182 Total equity 31,865 30,523 28,597 25,009 23,241 21,310 20,420 18,686 17,510 15,299 T otal liabilities and equity 242,914 247,699 232,717 223,312 198,845 187,912 166,662 160,705 153,254 138,080 Key figures 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 Total assets 242,914 247,699 232,717 223,312 198,845 187,912 166,662 160,704 153,254 138,080 Average total assets 250,123 241,090 235,303 213,112 196,229 183,428 165, 154 156,992 145,948 137,060 Profit as a percentage of total assets 1.80% 1.85% 1.58% 1.25% 1.46% 1.05% 1.54% 1.30% 1.19% 1.19% Gross loans to customers 184,387 180,102 169,862 152,629 147,301 134,648 126,277 120,473 112,071 102,325 Gross loans to customers incl. SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt 258,923 249,350 236,329 211,244 195,353 182,801 167,777 160,317 148,784 137,535 Gross loans in retail market 175,343 167,159 159,777 141,833 132,894 124,461 115,036 108,131 98,697 89,402 Gross loans in corporate market 83,580 82,191 76,553 69,411 62,458 58,340 52, 740 52,186 50,087 48,133 Deposits from and debt to customers 146,165 140,897 132,888 122,010 111,286 97,529 85,917 80,615 76,476 67,168 Deposits from retail market 68,267 62,581 57,874 48,316 44,589 40,600 35,664 33,055 31,797 29,769 Deposits from corporate market 77,898 78,316 75,015 73,693 66,697 56,928 50,253 47,561 44,678 37,398 Ordinar y lending financed by ordinary deposits 79% 78% 78% 80% 76% 72% 68% 67% 68% 66% Ordinary lending incl. SpareBank 1 Boligkreditt and SpareBank 1 Næringskreditt financed by ordinary deposits 56% 57% 56% 58% 57% 53% 51% 50% 51% 49%
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361SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | FINANCIAL SUMMARY (GROUP) 361 Capital adequacy 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 CET 1 Capital 23,328 22,409 21,589 19,776 17,790 17 ,041 15,830 14,727 13,820 13,229 Core capital 25,731 24,769 23,793 21,835 19,322 18,636 17 ,742 16,472 15,707 15,069 Primary capital 28,958 28,004 26,399 24,147 21,333 20,759 19,854 18,743 17,629 17,185 Risk weighted volume 139,273 122,622 114,633 104,716 98,664 93,096 91,956 101, 168 94,807 88,788 CET 1 Ratio 16.8 % 18.3 % 18.8 % 18.9 % 18.0 % 18.3 % 17.2 % 14.6 % 14.6 % 14.9 % Core capital ratio 18.5 % 20.2 % 20.8 % 20.9 % 19.6 % 20.0 % 19.3 % 16.3 % 16.6 % 17.0 % Capital ratio 20.8 % 22.8 % 23.0 % 23.1 % 21.6 % 22.3 % 21.6 % 18.5 % 18.6 % 19.4 % Leverage ratio 7.0 % 7.0 % 7.2 % 7.1 % 6.9 % 7.1 % 7.5 % 7.4 % 7.2 % 7.4 % Other figures 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 Cost/income ratio 44% 42% 44% 42% 41% 47% 45% 49% 47% 44% Losses on loans 0.06% 0.05% 0.01% 0.00% 0.09% 0.54% 0.18% 0.17% 0.23% 0.39% ROE 14.8 % 16.6 % 14.4 % 12.3 % 13.5 % 10.0 % 13.7 % 12.2 % 11.5 % 11.3 % Growth in lending (gross) 3.8 % 5.5 % 11.9 % 8.1 % 6.9 % 9.0 % 4.7 % 7.8 % 8.2 % 8.0 % Growth in deposits 3.7 % 6.0 % 8.9 % 9.6 % 14.1 % 13.5 % 6.6 % 5.4 % 13.9 % 4.8 % Number of staff 1,854 1,832 1,737 1,498 1,449 1,588 1,588 1,588 1,482 1,328 Number of FTEs 1,672 1,660 1,545 1,432 1,340 1,560 1,509 1, 493 1,403 1,254 Number of branches 47 47 46 40 40 45 46 48 48 48 1) Historikk for 2021 er omarbeidet etter at SpareBank 1 Markets (nå SB1 Markets) ble reklassifisert til holdt for salg fra Q4 2022. Historikk for tidligere år er ikke omarbeidet.
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362SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | FINANCIAL SUMMARY (GROUP) Net profit and return on equity 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 5000 4500 4000 3500 3000 2500 2000 1500 1000 500 0 16.00 % 14.00 % 12.00 % 10.00 % 8.00 % 6.00 % 4.00 % 2.00 % 0.00 % 18.00 % 1681 1828 2090 2563 1978 2902 2785 3688 4591 4367 Capital ratio per year 25.0 20.0 15.0 10.0 5.0 0.0 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Loans and deposits (NOKbn) 160 140 120 100 80 60 40 20 0 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Development FTEs 1800 1600 1400 1200 1000 800 600 400 200 0 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 630 524 595 808 575 918 622 887 660 900 646 836 646 928 798 747 841 819 857 815
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363SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | FINANCIAL SUMMARY (GROUP) 363 Loan losses 1000 800 600 400 -200 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 200 0.60 % 0.50 % 0.40 % 0.30 % 0.20 % 0.10 % 0.00 % -0,.0 % - 0.39 % 0.23 % 0.17 % 0.18 % 0.54 % 0.09 % 0.00 % 0.01 % 0.07 % 0.06 % Dividend and profits per ECC (NOK) 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 25,00 20,00 15,00 10,00 1000 0,00 0 1 2 3 4 5 10 11 12 13 14 15 16 17 18 19 20 21 9 22 23 24 25 3,00 4,40 5,10 6,50 4,40 7,50 6,5 12 12,5 13,5
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364SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | EQUITY CAPITAL CERTIFICATE 364 Equity capital certificate At end-2025 the market price of SpareBank 1 SMN’s EC was NOK 206.05. At year-end 2024 it was NOK 171.3. At the end of 2025 SpareBank 1 SMN’s equity certificate (EC) capital totalled NOK 2,884,311,800 distributed on 144,215,590 ECs with a nominal value of NOK 20 each. At the turn of the year the group had a treasury holding of ECs totalling 4.672 ECs. Equity Certificates (EC) 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 Quoted price 206.05 171.32 141.80 127.40 149.00 97.60 100.20 84.20 82.25 64.75 No. of ECs issued, million 144.19 144.21 144.20 129.29 129.39 129.39 129.30 129.62 129.38 129.83 Market value (NOKm) 29,711 24,706 20,448 16,471 19,279 12,629 12,956 10,914 10,679 8,407 Dividend per EC 13.50 12.50 12.00 6.50 7.50 4.40 5.00 5.10 4.40 3.00 Book value per EC 138.30 128.09 120.48 109.86 103.48 94.71 90.75 83.87 78.81 73.26 Profit per EC 19.08 20.60 16.88 12.82 13.31 8.87 12.14 9.97 8.71 7.91 Price-Earnings Ratio 10.80 8.32 8.40 9.94 11.19 11.01 8.26 8.44 9.44 8.19 Price-Book Value Ratio 1.49 1.34 1.18 1.16 1.44 1.03 1.10 1.00 1.04 0.88 Payout ratio 69% 61% 71% 51% 56% 50% 54% 51% 50% 38% EC fraction 66.8 % 66.8 % 66.8 % 64.0 % 64.0 % 64.0 % 64.0 % 64.0 % 64.0 % 64.0 %
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365SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | EQUITY CAPITAL CERTIFICATE Stock price compared with OSEBX and OSEEX 1 January 2024 to 31 December 2025 OSEBX = Oslo Stock Exchange Benchmark Index OSEEX = Oslo Stock Exchange ECC Index Trading statistics 1 December 2024 to 31 December 2025 Total number of ECs traded (1000) 20 largest ECC holders No. Of ECCs Holding Sparebankstiftinga Søre Sunnmøre 10,471,224 7.26% Sparebankstiftelsen SMN 7,420,111 5.15% KLP 5,129,741 3.56% VPF Eika Egenkapitalbevis 4,712,608 3.27% Skandinaviska Enskilda Banken AB (Nominee) 3,206,783 2.22% Pareto Aksje Norge VPF 2,884,617 2.00% VPF Alfred Berg Gamba 2,765,315 1.92% VPF Holberg Norge 2,430,000 1.68% State Street Bank and Trust Comp (Nominee) 2,359,586 1.64% J.P. Morgan SE (Nominee) 2,298,783 1.59% Spesialfondet Borea Utbytte 2,149,204 1.49% Forsvarets per sonellservice 2,018,446 1.40% The Northern Trust Comp (Nominee) 2,013,742 1.40% Citibank, N.A. (Nominee) 1,841,610 1.28% J. P. Morgan Chase Bank, N.A., London (Nominee) 1,781,575 1.24% J.P. Morgan SE (Nominee) 1,659,359 1.15% State Street Bank and Trust Comp (Nominee) 1,644,700 1.14% J. P. Morgan Chase Bank, N.A., London (Nominee) 1,483,101 1.03% J.P. Morgan SE (Nominee) 1,479,086 1.03% J.P. Morgan SE (Nominee) 1,473,165 1.02% The 20 largest ECC holders in total 61,222,756 42.45% Others 82,992,834 57.55% Total issued ECCs 144,215,590 100% 0 500 1000 1500 2000 2500 3000 3500 4000 4500 0 500 1000 1500 2000 2500 3000 3500 4000 jan feb mar apr mai jun jul aug sep okt nov des 2025 4500 OSEEX, Total ReturnSpareBank 1 SMN, Dividend adjusted OSEBX, Total Return SpareBank 1 SMN 130 140 150 160 170 180 190 200 210 220 230 240 250 260 130 140 150 160 170 180 190 200 210 220 230 240 250 260 jan mar mai jul sep nov jan mar mai jul sep nov jan 2024 2025
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366SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | EQUITY CAPITAL CERTIFICATE Dividend policy SpareBank 1 SMN aims to manage the Group’s resources in such a way as to provide equity certificate holders with a good, stable and competitive return in the form of dividend and a rising value of the bank’s equity certificate. The net profit for the year will be distributed between the owner capital (the equity certificate holders) and the ownerless capital in accordance with their respective shares of the bank’s total equity capital. SpareBank 1 SMN’s intention is that up to one half of the owner capital’s share of the net profit for the year should be disbursed in dividends and, similarly, that up to one half of the owner capital’s share of the net profit for the year should be disbursed as gifts or transferred to a foundation. This is on the assumption that capital adequacy is at a satisfactory level. When determining dividend payout, account will be taken of the profit trend expected in a normalised market situation, external framework conditions and the need for tier 1 capital.
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367SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | STATEMENT IN COMPLIANCE WITH STA SECTION 5-5 Statement in compliance with the securities trading act, section 5-5 Statement by the Board of Directors and the Group CEO We hereby declare that to the best of our knowledge: • The financial statements have been prepared in conformity with applicable accounting standards and that the accounting information gives a true and fair view of the assets, liabilities, financial position and profit/loss of the Parent Bank and the Group taken as a whole, and • the Directors’ report gives a f air review of developments, profit/loss and position of the Parent Bank and the Group, together with a description of the principal risks and uncertainties facing the Group and • the Directors’ report, wher e required, has been prepared in accordance with standards for sustainability reporting which have been established in accordance with the Accounting Act § 2-6, and in accordance with rules established in accordance with the taxonomy regulation article 8 no. 4 Trondheim, 3 March 2026 Board of Directors in SpareBank 1 SMN Kjell Bjordal Christian Stav Mette Kamsvåg Board chair Deputy chair Freddy Aursø Nina Olufsen Ingrid Finboe Svendsen Kristian Sætre Inge Lindseth Christina Straub Employee rep. Employee rep. Jan-Frode Janson Group CEO
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368SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | AUDITOR’S REPORT PricewaterhouseCoopers AS, org.no.: 987 009 713 MVA, Statsautoriserte revisorer, medlemmer av Den norske Revisorforening og autorisert regnskapsførerselskap Advokatfirmaet PricewaterhouseCoopers AS, Org.no.: 988 371 084 MVA, Medlemmer av Advokatforeningen. advokatfirmaet@pwc.com PwC Tax Services AS, Org.no.: 962 066 321 MVA, Autorisert regnskapsførerselskap, Medlem av Regnskap Norge Brattørkaia 17B, 7010 Trondheim, T: 02316 (+47 952 60 000) www.pwc.no To the Supervisory Board of SpareBank 1 SMN Independent Auditor’s Report Report on the Audit of the Financial Statements Opinion We have audited the financial statements of SpareBank 1 SMN, which comprise: • the financial statements of the parent company SpareBank 1 SMN (the Company), which comprise the statement of financial position as at 31 December 2025, the income statement, total comprehensive income, statement of changes in equity and statement of cash flows for the year then ended, and notes to the financial statements, including material accounting policy information, and • the consolidated financial statements of SpareBank 1 SMN and its subsidiaries (the Group), which comprise the statement of financial position as at 31 December 2025, the income statement, total comprehensive income, statement of changes in equity and statement of cash flows for the year then ended, and notes to the financial statements, including material accounting policy information. In our opinion • the financial statements comply with applicable statutory requirements, • the financial statements give a true and fair view of the financial position of the Company as at 31 December 2025, and its financial performance and its cash flows for the year then ended in accordance with IFRS Accounting Standards as adopted by the EU, and • the consolidated financial statements give a true and fair view of the financial position of the Group as at 31 December 2025, and its financial performance and its cash flows for the year then ended in accordance with IFRS Accounting Standards as adopted by the EU. Our opinion is consistent with our additional report to the Audit Committee. Basis for Opinion We conducted our audit in accordance with International Standards on Auditing (ISAs). Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the Financial Statements section of our report. We are independent of the Company and the Group as required by relevant laws and regulations in Norway and the International Ethics Standards Board for Accountants’ International Code of Ethics for Professional Accountants (including International Independence Standards) (IESBA Code) as applicable to audits of financial statements of public interest entities, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. To the best of our knowledge and belief, no prohibited non-audit services referred to in the Audit Regulation (537/2014) Article 5.1 have been provided. We have been the auditor of SpareBank 1 SMN for 7 years from the election by the general meeting of the shareholders on 22 November 2018 for the accounting year 2019. Key Audit Matters Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the financial statements of the current period. These matters were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. 2 / 5 Key Audit Matters How our audit addressed the Key Audit Matter The value of loans to customers Loans to customers represent a considerable part of total assets. The assessment of loan loss provisions is a model-based framework which includes assessments with elements of management judgment. The framework, is complex, includes considerable volumes of data and judgmental parameters. We focused on this area due to the significance of the impairment considerations for the value of loans, and the fact that the use of judgement has a potential to affect the profit for the period. Furthermore, there is an inherent risk of errors because of the complexity and quantity of data involved in the modelling. The use of models to determine expected credit losses entails judgement, specifically with respect to: • Classification of the various credit portfolios by risk and asset type; • Identification of loans with a significant increase in credit risk; • The categorization of loans into stages; and • The parameters such as the probability of default, loss given default and loss scenarios. In the case of loans where there is objective evidence of impairment, an individual allowance for credit loss is recognized. The assessments require management to use judgement. Please refer to note 3, 6, 8 and 10 in the annual report for a description of the company’s impairment model and how the company estimates their expected credit losses using IFRS 9. In our audit of expected loss allowance, we evaluated and tested the design and effectiveness of controls for quality assurance relating to the applied assumptions and models used in the calculations. Furthermore, we tested the input used in the model-based calculation of allowances as well as the individually calculated allowances. For loans considered on a collective basis the calculation is based on a framework model. We tested the model and considered the relevance and the reasonableness of important assumptions used in the calculation. We obtained a detailed understanding of the process and tested relevant controls directed at ensuring: • Calculations and the applied method; • That the applied model is designed according to the framework, and working as planned; • The reliability and accuracy of the data used in the model. Our controls testing gave no indication of material misstatements in the model, or deviations from IFRS 9. We also discussed the impact of the macroeconomic situation on the size of loss provisions and the value of collateral with the management. Our work included tests of the company’s financial reporting systems relevant to financial reporting. The company uses external service providers to operate some of the important IT systems. The auditor at the relevant service organization are used to evaluate the design and efficiency of the established control systems, and tests the controls designed to ensure the integrity of the IT system that are relevant to financial reporting. The auditor have issued a report that included testing of whether central calculations performed by core systems were performed according to expectations, hereunder interest calculations and mortifications. The testing included the integrity of data, changes of and access to the systems. To assess whether we could rely on the work performed by other auditors, we satisfied ourselves regarding the auditors’ competence and objectivity and examined the reports received and assessed potential weaknesses and remediation initiatives. Our assessments showed that we could rely on the data handled and calculations performed within the IT systems that are relevant to financial reporting. For loans with objective evidence of impairment and where the impairment amounts were individually calculated, we tested a sample by assessing the estimated future cash flows used by management to substantiate the impairment calculation. We challenged management’s assumptions by interviewing key credit personnel and management both to assess the
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369SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | AUDITOR’S REPORT 3 / 5 information received from customers and to assess how the reliability of the information were evaluated. We compared the assumptions made by management to external documentation when available. The result of the testing showed that management’s assumptions in the calculation of impairment amounts were reasonable. We have read the notes and found that the information provided was sufficient. Other Information The Board of Directors and the Managing Director (management) are responsible for the information in the Board of Directors’ report and the other information accompanying the financial statements. The other information comprises information in the annual report, but does not include the financial statements and our auditor’s report thereon. Our opinion on the financial statements does not cover the information in the Board of Directors’ report nor the other information accompanying the financial statements. In connection with our audit of the financial statements, our responsibility is to read the Board of Directors’ report and the other information accompanying the financial statements. The purpose is to consider if there is material inconsistency between the Board of Directors’ report and the other information accompanying the financial statements and the financial statements or our knowledge obtained in the audit, or whether the Board of Directors’ report and the other information accompanying the financial statements otherwise appears to be materially misstated. We are required to report if there is a material misstatement in the Board of Directors’ report or the other information accompanying the financial statements. We have nothing to report in this regard. Based on our knowledge obtained in the audit, it is our opinion that the Board of Directors’ report • is consistent with the financial statements and • contains the information required by applicable statutory requirements. Our opinion on the Board of Directors' report applies correspondingly to the statement on Corporate Governance. Our opinion on whether the Board of Directors’ report contains the information required by applicable statutory requirements, does not cover the Sustainability Statement, on which a separate assurance report is issued. Responsibilities of Management for the Financial Statements Management is responsible for the preparation of financial statements that give a true and fair view in accordance with IFRS Accounting Standards as adopted by the EU, and for such internal control as management determines is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error. In preparing the financial statements, management is responsible for assessing the Company’s and the Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Group or to cease operations, or has no realistic alternative but to do so. Auditor’s Responsibilities for the Audit of the Financial Statements Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements. As part of an audit in accordance with ISAs, we exercise professional judgment and maintain professional scepticism throughout the audit. We also: • identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error. We design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. 4 / 5 • obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Company's and the Group's internal control. • evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management. • conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Company's and the Group's ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor's report. However, future events or conditions may cause the Company and the Group to cease to continue as a going concern. • evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves a true and fair view. • obtain sufficient appropriate audit evidence regarding the financial information of the entities or business activities within the Group to express an opinion on the consolidated financial statements. We are responsible for the direction, supervision and performance of the group audit. We remain solely responsible for our audit opinion. We communicate with the Board of Directors regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit. We also provide the Audit Committee with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, actions taken to eliminate threats or safeguards applied. From the matters communicated with the Board of Directors, we determine those matters that were of most significance in the audit of the financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor’s report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication. Report on Other Legal and Regulatory Requirements Report on Compliance with Requirement on European Single Electronic Format (ESEF) Opinion As part of the audit of the financial statements of SpareBank 1 SMN, we have performed an assurance engagement to obtain reasonable assurance about whether the financial statements included in the annual report, with the file name sb1smn-2025-12-31-0-no.zip, have been prepared, in all material respects, in compliance with the requirements of the Commission Delegated Regulation (EU) 2019/815 on the European Single Electronic Format (ESEF Regulation) and regulation pursuant to Section 5-5 of the Norwegian Securities Trading Act, which includes requirements related to the preparation of the annual report in XHTML format, and iXBRL tagging of the consolidated financial statements. In our opinion, the financial statements, included in the annual report, have been prepared, in all material respects, in compliance with the ESEF regulation. Management’s Responsibilities Management is responsible for the preparation of the annual report in compliance with the ESEF regulation. This responsibility comprises an adequate process and such internal control as management determines is necessary. Auditor’s Responsibilities Our responsibility, based on audit evidence obtained, is to express an opinion on whether, in all material respects, the financial statements included in the annual report have been prepared in compliance with ESEF. We conduct our work in compliance with the International Standard for Assurance Engagements (ISAE) 3000 – “Assurance engagements other than audits or reviews of historical financial information”. The standard requires us to plan and perform procedures to
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370SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ANNUAL FINANCIAL STATEMENTS | AUDITOR’S REPORT 5 / 5 obtain reasonable assurance about whether the financial statements included in the annual report have been prepared in compliance with the ESEF Regulation. As part of our work, we have performed procedures to obtain an understanding of the Company’s processes for preparing the financial statements in compliance with the ESEF Regulation. We examine whether the financial statements are presented in XHTML-format. We evaluate the completeness and accuracy of the iXBRL tagging of the consolidated financial statements and assess management’s use of judgement. Our procedures include reconciliation of the iXBRL tagged data with the audited financial statements in human-readable format. We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. Trondheim, 3 March 2026 PricewaterhouseCoopers AS Rune Kenneth S. Lædre State Authorised Public Accountant Note: This translation from Norwegian has been prepared for information purposes only.
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4 Attachments Norwegian Code of Practice for Corporate Governance (NUES) 372 Glossary 373
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372 Norwegian Code of Practice for Corporate Governance The statement describing how SpareBank 1 SMN complies with the 15 recommendations of the Norwegian Code of Practice for Corporate Governance (NUES) is published on the Group’s website (smn.no). The statement has been prepared in accordance with Section 2‑9 of the Norwegian Accounting Act and the Norwegian Code of Practice for Corporate Governance, as issued on 14 October 2021. The recommendation is available at nues.no. SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ATTACHMENTS | NUES
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373 Glossary An overview of terms and acronyms used in the Group’s annual report is listed below: AI Artificial intelligence Akademiet - The Academy The Group’s internal competence program Annex Appendix or addition to a document AML Anti Money Laundering APM Alternative Performance Measures AR Application Requirement ARP Aktivitet- og redegjørelsesplikt (Activity duty of employers) AUM Assets Under Management BETR The Group’s quality management system OHS (BHT) Occupational Health Service BP Basis for preparation CapEx Capital Expenditure CEO Chief Executive Officer CO2-equivalents (CO2eq) A common unit used to compare emissions from different GHGs based on their global warming potential Community dividend Dividend to the community, which owns 41,1 % of SpareBank 1 SMN CM Corporate market CRR3 Capital Requirements Regulation CSDDD/CS3D Corporate Sustainability Due Diligence Directive CSRD Corporate Sustainability Reporting Directive ”Current policies” A scenario describing current policies, ambitions and guidelines DEFRA Department for Environment, Food & Rural Affairs DEI Diversity, equality and inclusion Double materiality assessment (DMA) A method used to assess how a company impacts the environment/society (impact materiality) and how the environment/society affects the company (financial materiality) Downstream Activities or processes occurring at the customer and consumer level SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ATTACHMENTS | GLOSSARY
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374 DNSH Do No Significant Harm DORA Digital Operational Resilience Act DPIA Data Protection Impact Assessment Due diligence A thorough assessment or process to evaluate risks and opportunities DR Disclosure Requirement EBA European Banking Authority EEA The European Economic Area EEIOA Environmentally Extended Input‑Output Analysis EFRAG European Financial Reporting Advisory Group Equity method Consolidation method based on ownership stake ESG Environmental, Social, and Governance ESRS European Sustainability Reporting Standards One SMN 2.0 An organizational transformation project with effect from January 1, 2025. EU Taxonomy A framework for classifying sustainable economic activities within the EU Finance Norway An interest organization for the financial industry in Norway FINREP A framework to harmonize financial regulatory reporting among banks in the EU FinGuar Financial Guarantees F&C Fees and commisions GAR Green Asset Ratio GAR flow The total value of new balance sheet exposures aligned with the EU taxonomy, divided by total assets GAR stock The total value of balance sheet exposures aligned with the EU taxonomy, divided by total assets GDPR General Data Protection Regulation GHG Greenhouse Gas GHG-intensity The amount of emissions per unit of activity, production, or economic value GOV Reporting requirements covering governance and leadership (Governance) GRI Global Reporting Initiative HSE Health, safety and environment SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ATTACHMENTS | GLOSSARY
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375 ICAAP Internal Capital Adequacy Assessment Process IEA International Energy Agency IFRS International Financial Reporting Standards IG Implementation Guidance ILO International Labour Organization IMF International Monetary Fund IMO International Maritime Organization IPCC Intergovernmental Panel on Climate Change IRO Impacts, Risks and Opportunities K2 The indicator for household domestic gross debt in Norwegian kroner and foreign currencies KPI Key Performance Indicator KPI-JAE Consumer Price Index (CPI) adjusted for tax changes and energy products Kunming-Montreal Global Biodiversity Framework An international framework for biodiversity conservation, adopted in 2022 KWh Kilowatt‑hour LCR Liquidity coverage ratio LO The Norwegian Confederation of Trade Unions OECD Organization for Economic Co‑operation and Development Operational control The company has full authority to manage operations and, therefore, control over activities and facilities OpEx Operating expenses MDR-A Minimum Disclosure Requirement ‑ Actions MDR-M Minimum Disclosure Requirement ‑ Metrics MDR-P Minimum Disclosure Requirement ‑ Policies MDR-T Minimum Disclosure Requirement ‑ Targets Mennesker og organisasjon The Group’s HR department Midstream Processes or activities occuring within the company (own operations) Miljøfyrtårn A Norwegian certification system for businesses that document compliance with environmental, climate, workplace, and corporate social responsibility requirements SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ATTACHMENTS | GLOSSARY
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376 MING SpareBank 1 SMN’s ticker on Oslo Bors. MREL Minimum Requirement for Own Funds and Eligible Liabilities MSS Minimum Social Safeguards MWh Megawatt‑hours NACE Nomenclature of Economic Activities NAV The Norwegian Labour and Welfare Administration (national social welfare system) Net Zero 2050 Net Zero‑emissions by 2050 NFRD Non‑Financial Reporting Directive NGAAP Norwegian Generally Accepted Accounting Principles NGFS Network for Greening the Financial System NHO The Confederation of Norwegian Enterprise NIBOR Norwegian Interbank Offered Rate Non-employees Individuals performing tasks for an organization but who are not directly employed NOx Nitrogenoxide NTNU The Norwegian Univeristy of Science and Technology NVE The Norwegian Water Resources and Energy Directorate NZEB Nearly Zero‑Energy Building PCAF Partnership for Carbon Accounting Financials PCCLA (ASAL) The Norwegian Public Limited Liability Companies Act (Allmennaksjeloven) RM Retail market SBM Strategy and business models SBTi Science Based Targets initiative Scope GHG‑emissions categories (scope 1, 2, 3). SME Small‑ and medium‑sized entreprise SOx Sulfur oxide SpareBank 1 Alliance A collaboration between independent savings banks in Norway that share branding, technology, products, and services to strengthen the competitiveness of local banks Supervisory Board The highets governing body in a savings bank SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ATTACHMENTS | GLOSSARY
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377 Taxonomy-aligned Compliant with all EU Taxonomy criteria Taxonomy-eligible Included and described in the EU Taxonomy and related regulations TCFD Task Force on Climate‑related Financial Disclosures TEK07, 10 og 17 Norwegian Building Codes The Transperancy Act Regulating transparency in the supply chain concerning fundamental human rights and decent working conditions. TPT Transition Plan Taskforce Trading Book A portfolio of financial instruments actively traded Turnover (employees) The rate of employees leaving within a year Value chain The collection of activities that create and deliver a product or service Upstream Activities or processes occurring before the main production phase in the value chain WinningTemp A digital tool measuring and improving employee engagement and well‑being SPAREBANK 1 SMN | ANNUAL REPORT 2025 | ATTACHMENTS | GLOSSARY
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SpareBank 1 SMN Søndre gate 4 7011 Trondheim Company number: NO 937901003 Switchboard: 915 03900 E-mail: ir@smn.no https://smn.no