2620291 BNG - Annual Report 2025

financing solutions are becoming increasingly important. The realisation of new wind and solar projects is also challenging due to a lack of suitable space. New large-scale rooftop solar projects are scarcer because the most suitable roofs have already been occupied.

Attention to sufficient local support is becoming more important. We are increasingly seeing local governments taking the initiative to set up energy projects and remaining involved in the operational phase. BNG aims to make a difference specifically in these projects, as our focus is on energy projects in which the public sector has a direct or indirect interest. The "Future-Proof Maintenance Fund" initiative, established in 2024 and financed by

BNG, focuses on energy savings while simultaneously offering housing associations the opportunity to invest in mixed homeowners' associations (VvEs). The fund has provided 23 loans totalling EUR 4.7 million. Thanks to these loans, 639 flat owners were able to

invest in (overdue) maintenance and sustainability improvements to their homes. The

fund thus contributes to the further sustainability and energy efficiency of real estate in the Netherlands.

sustainable. Financing the energy transition – such as investments in renewable energy,

role in society. These projects contribute to climate goals and have a demonstrable positive impact on our customers' living environment.

At the same time, we recognise that the energy transition is not without risk: technologies are developing rapidly in markets that are not always fully predictable or mature, with long depreciation and payback periods, and where the risks are sometimes heavily concentrated in the start-up phase.

Examples of (still) immature markets are the solar and (to a lesser extent) wind energy

sectors, where a lack of network and storage capacity means that generated electricity cannot always be sold, which has clearly changed the original business case.

Examples of long maturities with large(r) upfront risks include investments in geothermal energy and heat networks, where a more risky investment phase is usually followed by a

(long and) more stable payback phase. This creates a tension with our very conservative

risk profile, which is in line with the business model of a bank such as BNG. The stability and creditworthiness of our loan portfolio are paramount. This means that we must constantly weigh up how much scope there is to support impactful, but sometimes riskier projects,

without compromising our solid credit position. This balance requires ongoing dialogue, sharp risk analyses and clear choices.

Environment

In the Environment department, we provided various financing options last year that

contribute to making waste collection and processing more sustainable. For example,

we provided financing to collectors such as Reinigingsbedrijf Midden Nederland and De

Meerlanden for further electrification of small equipment and their fleet. For collector Blink, we financed the land on which their new headquarters is planned. A significant milestone

was reached last June for processor Twence, where, after a construction period of almost three years, one of the first carbon capture facility was officially opened by Her Majesty Queen Máxima. As part of the consortium, BNG financed this plant at the end of 2023.

38

Mobility

new housing developments and the redevelopment of existing (business) sites. We fulfill

contribute to making public transport and the major seaports and airports in the

scale projects possible. The challenge with area development is that major investments in

In the Mobility department, we provided various financing options last year that directly Netherlands more sustainable. With our financial support, we help these sectors achieve

ambitious climate goals, which are essential in the broader energy transition. Our financing plays a key role in enabling sustainable projects and innovations. A prime example of such financing is our sustainability-linked loan to the Port of Amsterdam (Port Authority). This

EUR 60 million loan is linked to sustainability goals, encouraging the port authority to take concrete steps to reduce CO2 emissions.

In addition, we are the main financier of regional transport in the two major metropolitan

areas of the Netherlands: the Amsterdam Transport Region (VRA) and the Rotterdam-The Hague Metropolitan Region (MRDH). Together, VRA and MRDH account for approximately

28% of bus transport in the Netherlands. Throughout the Netherlands, approximately 39% of buses are now emission-free (24% in MRDH and 74% in VRA). These customers are

therefore well on their way to emission-free public transport, and BNG is contributing

with its financing, which is used to purchase these emission-free buses. This makes us an important partner for these transport operators in transforming their bus fleets to

a trusted role as a public sector financier and provide the financial basis to make large-

infrastructure, public space, and amenities are required before homes or business locations reach their final location. Therefore, we work closely with public partners such as provinces,

municipalities, and Regional Development Agencies (ROMs). We also deploy our expertise in

Public-Private Partnerships (PPPs) where this offers added value. In 2025, we financed a wide range of projects in the field of area development. For example, in the Amersfoort region, we

refinanced the new phase of a development site for EUR 100 million through a public-private partnership (PPP). We also financed the redevelopment of a port site for EUR 14 million in

collaboration with a regional development company. Furthermore, we are actively involved in the planning phase of area developments throughout the Netherlands. Our projects

range from development sites for housing to the redevelopment of business parks. These investments not only contribute to a livable residential environment but also strengthen the economic capacity of regional governments. By future-proofing infrastructure and

facilities, we support the broader ambitions of the Netherlands regarding sustainability and resilience.

be completely emission-free, and we support the sector-wide commitment to make bus transport completely zero-emission by 2030.

Besides focusing on green investments, such as electric buses and sustainable

infrastructure, we also recognise the importance of "gray investments" to keep the mobility industry operational. While the transition to sustainable mobility is essential for reducing

the CO2 footprint, existing systems must continue to function reliably during this transition. Our role as a financier is therefore twofold: we stimulate the energy transition and ensure continuity in the mobility sector.

Spatial planning

With the ambition to build over 900,000 homes by 2030, area development is more

relevant and important than ever. This challenge requires significant investments in both

39

3..

Financial results and outlook

3 40

3.1 Solid foundation in money and capital markets Developments in 2025

(SDGs) of the United Nations. Our ambition is to ensure that a substantial part of our funding

Despite market volatility, partly due to geopolitical tensions, BNG has good access to

it was still 14% of the total bond issue, in recent years it was from 30% to over 40%. This year,

In 2025, we raised EUR 16.6 billion in long-term funding with an average maturity of 6.9 years. funding with medium and long-term maturities on the capital market throughout the year. Our triple A ratings play a crucial role in this regard. The total amount of funding raised is in line with the average for recent years, but the premiums were higher on average than

is raised through ESG bonds. This proportion has grown sharply in recent years: while in 2020

we issued a significant volume of EUR 5.5 billion in ESG bonds (33%), both through new issues and by increasing existing bonds.

the previous year. Part of the funding raised is, again, composed of several large syndicated bond issues, the so-called benchmarks. This year, we made three new benchmark issues in EUR and three new benchmark issues in USD, underscoring our ambition to maintain a robust and liquid benchmark curve for both currencies. We also issued two large bonds

denominated in CHF and were active in GBP and AUD. We also underscored our presence in Asian markets by returning to the Chinese yuan. This is in line with our aim to achieve a high level diversity in our investors, both in terms of geography and type. The principal investor interest in 2025 confirms that we are achieving this diversity successfully.

Importance of ESG bonds

Demand for ESG bonds continued to be strong in 2025. Since our first issue in 2014, we have

now issued more than EUR 38 billion in ESG bonds. We do so through sustainability issues for

municipalities and through social issues for housing associations. The issues are covered by

our Sustainable Finance Framework, according to which the bond income is used to finance municipalities and housing associations. Under this framework, municipal budgets and

expenditure by housing associations are linked to the green and social bond categories of

the International Capital Market Association (ICMA) and the Sustainable Development Goals

41

Keyfigures for funding Total outstanding ESG Bonds

Long term funding raised

€ 30.0

€ 16.6

billion

30.0

billion

26.7

18.6

16.6

21.9

15.2 7.5

6.3

5.5

2025

2024

2025

2023

2024

2023

(in EUR billions)

(in EUR billions)

Funding by currency

Funding by geographic region

USD 39%

3% CHF 5% GBP

Capital market funding Of which ESG Bonds

Middle East and Africa 8% Asia 13%

2% AUD

CNY 2%

49% EUR

North and South America 25%

Europe 55%

42

3.2 Financial results Results and return

liquidity. Managing this portfolio involves regularly selling and buying bonds to keep it liquid.

EUR 122 million less than in 2024. This result was also reflected in a lower return on equity

by new liquid bonds with high returns in the coming years. The other unrealised market

Over the 2025 reporting year, BNG recorded a net profit of EUR 172 million. This is

of 3.5%, compared with the return on equity for the previous year (6.4%). A lower interest result, a negative result on financial transactions, higher total operating expenses and impairments contributed to the decline in net profit.

BNG achieved an interest result of EUR 496 million. This result is EUR 40 million lower than the result for 2024. Due to changes in the interest rate curve, customers have borrowed

with shorter maturities. This has resulted in lower margins on new loans granted. We have also applied a deliberate pricing strategy, using part of the profit to give discounts back

to our customers. Higher margins on funding have led to an increase in interest expenses.

Furthermore, in 2025, we decided to start phasing out the non-strategic portfolio. In 2025, a number of transactions were settled, which led to a decrease in interest income.

In 2025, compared to the previous year, the commission result decreased by EUR 7 million

The negative sales results that must be recognised directly in the result under IFRS are offset value changes yield a result of EUR 19 million positive (2024: EUR 9 million positive) and are caused by market volatility that affects the valuation of financial instruments.

The consolidated operating expenses for BNG amounted to EUR 173 million on balance.

These have increased by EUR 21 million compared to 2024. This is the result of the inclusion of a restructuring provision of EUR 15 million. This reorganisation provision is necessary to

achieve the objectives of the Route to More Added Value. This will enable us to strengthen

our execution capabilities, collaborate in a chain-oriented manner, invest in leadership and professionalise. In addition, staff costs have increased as a result of the collective labour agreement and investments have also been made in the strengthening of the current IT

infrastructure. On the other hand, the resolution fund did not call for additional contributions as in 2024.

to EUR 23 million. This decrease is due to one-off fee income in 2024 that was related to

The result from the impairments on financial assets in 2025 is EUR 41 million negative (2024:

customers remained stable.

These items were provided in the years 2018 to 2020 with Sustainable Energy Transition

treasury activities. Commission income from payment transaction commissions invoiced to

The result on financial transactions amounts to EUR 31 million negative (in 2024:

EUR 15 million negative). The non- effective portion of hedge accounting yields a negative result of EUR 44 million (2024: EUR 6 million negative). The vast majority of our derivatives

and assets and liabilities are involved in hedge accounting. We use hedge accounting to eliminate an accounting mismatch. This was 99.2% effective in 2025. The realised sales

results amounted to EUR 6 million negative (2024: EUR 18 million negative) and relate to sales in the liquidity portfolio. We have a liquidity portfolio of EUR 16 billion to absorb shocks in

EUR 35 million positive). These impairments relate in particular to the solar energy sector.

Incentive (SDE) subsidies. This scheme did not provide sufficient compensation for negative energy prices, causing these projects to run into difficulties. Most of these items have been classified as non-strategic items. The bank’s total provisions for expected credit losses increased by EUR 41 million to EUR 98 million by the end of 2025.

The effective tax burden for 2025 was 28.2%, at a nominal corporate income tax rate of

25.8%. The bank levy amounted to EUR 36 million in 2025, EUR 5 million higher than in 2024.

43

This increase was caused by the fact that current and long-term debts were higher at year-end 2024 than in the year before.

The balance sheet total for BNG in 2025 was EUR 116 billion, which is EUR 12 billion lower than

in 2024. This is due, among other things, to the repayment of short-term funding. As a result,

Dividend

A dividend of EUR 79 million for 2025 will be proposed at the Annual General Meeting

(EUR 140 million in 2024). In line with our policy, this is 50% of the net profit, adjusted for the payout on the additional Tier 1 capital.

the balance sheet item Debt securities has decreased by EUR 9 billion.

The size of the long-term loan portfolio is EUR 95.7 billion, of which EUR 7.7 billion is subject to solvency requirements. The increase in the portfolio by EUR 2.7 billion compared to the

end of 2024 is almost entirely free of solvency requirements. In 2025, EUR 11.2 billion in new long-term loans and advances were granted, which is EUR 0.5 billion less than in 2024.

The increase in the portfolio is particularly due to high demand in the housing sector. The housing sector portfolio increased by EUR 3.1 billion to EUR 54.0 billion in 2025.

BNG maintains a target of at least 90% solvency-free exposures in the total loan portfolio. The target was achieved at 92.0% in 2025. In addition, we aim for a success rate of at

least 60% on solvency-free long-term lending to local authorities, housing associations and healthcare institutions. In 2025, 61% of loan applications were granted by us and the target of 60% was met.

Liquidity ratios remain strong, with a net stable funding ratio of 143% in 2025 (139% in 2024) and a liquidity coverage ratio of 159% (217% in 2024). These ratios are also well above the minimum levels and reflect our prudent risk management.

At year-end 2025, BNG’s equity stood at EUR 4.9 billion. Of this amount, EUR 0.3 billion is

additional Tier 1 capital. The bank’s solvency ratios remain strong. The Common Equity Tier 1

ratio is 42%. In 2024, this figure was 40%. At the end of 2025, the leverage ratio was 14%, which is 2% higher than the 12% at year-end 2024. The CET1 and leverage ratios are well above the minimum values imposed by the regulator.

The size of the longterm loan portfolio is increased to

EUR 95.7 billion.

44

Future-proof educational properties in Breda In Breda, BreedSaam provides future-proof school buildings in primary and special education. As a social organisation, BreedSaam is responsible for the housing of 54 schools. The organisation creates safe, sustainable and inspiring learning environments in which children feel at home and can learn to the best of their ability. BreedSaam manages more than 70 buildings and works with 11 school authorities. New construction and renovation projects are carried out with due care, with sustainability as the guiding principle. The organisation uses the Trias Energetica principle: first by limiting energy demand through proper insulation, compact construction and energy-efficient installations. Then by using renewable energy sources, such as solar energy, and finally the most efficient use of fossil energy, for example through cogeneration. This is how BreedSaam makes a concrete contribution to a sustainable urban environment. BreedSaam has been financed by BNG since 2021. A follow-up loan in 2025 will make investments possible through 2029. This is in line with the agreements made with the municipality of Breda, which sets the compensation for educational housing for a period of eight years.

This financial security allows us to continue to make structural investments in energy-efficient, well-maintained school buildings that meet the needs of both current and future users.

With our support, BreedSaam is building sustainable school buildings where children can learn to the best of their ability.

Image: KdV architectuur

3

Financial Results Lending 2025

Long-term

loans 2025

€ 11.2 billion

AAA 2024

2023

External ratings by

€ 11.7

€ 172

€ 294

Share of

of the Dutch State.

in portfolio.

are in line with the ratings

million

million

Return on equity

promotional loans

Net profit decreased in 2025

3.5%

2025

Return on equity is above return

6.4%

2024

benchmark of the Ministry of Finance of 1,7%

At least 90% of the long-term loans on the balance sheet should qualify 42%

50%

40%

50%

43%

50%

Factors that influence net profit:

2025

94%

Target 90%

Scoring percentage for lending

Lower interest results 496

536

Lower result financial transactions

volume exceeds 60% 14%

2025

2023

2024

Moody’s, S&P and Fitch

Leverage ratio

2024

Net profit 2025

billion

Common equity Tier 1 ratio 2025

2024

12%

13%

Increase in operational expenses

173

15%

15%

15%

2025

61%

-31

Target

152

Changes in net impairment losses

+39

-15

-34

≥60%

2025

2024

(in EUR million)

2025

2024

(in EUR million)

2025

2024

(in EUR million)

2025

2024

(in EUR million)

46

3.3 Financial outlook As in previous years, BNG's funding policy will continue to be focused on ensuring

permanent access to the money and capital markets at the terms and volumes required and at the lowest possible rates. BNG expects to raise approximately EUR 15 to 17 billion in funding in 2026. Over the next year, we again intend to raise a substantial part of its long-term funding from ESG bonds.

We do not expect to pay a contribution to the Single Resolution Fund in 2026. The fund has

been fully paid up since 2023 and requests for it to be supplemented are only made in the event of a bankruptcy of a European bank.

BNG is expected to remain financially strong in 2026, as well. Strong capitalisation, healthy profitability combined with a high market share and good funding conditions are also providing a solid financial foundation for the future.

The total amount of net profit is subject to uncertainty because we cannot forecast the

development of unrealised market value adjustments. We are unable to reliably estimate the net profit for 2026 for that reason.

47

4..

CO 2e emissions

4 48

Although BNG clients are mainly active in the social field, they also have a role to play in the field of the environment and energy transition. The climate crisis, stricter EU legislation on sustainability and increasing pressure on the public domain call for substantial investments and innovative solutions to climate issues. This underlines the urgent need for financial institutions to deal effectively using the resources available. Our impact-driven strategy responds to this. We aim to achieve net-zero CO2e emissions

within our value chain by 2050. In doing so, we are focusing primarily on making our lending more sustainable, with specific reduction targets for 2025 and 2030. In addition, we are also taking measures within our own business operations, such as the use of renewable energy, when renovating our office and policy regarding business travel and lease cars.

Responsible financing for a sustainable society

Climate change entails significant risks, such as physical damage from extreme weather conditions and transition risks from the transition to a sustainable economy. An example

infrastructure. Network operators play a crucial role in this, which is why we also support investments in expanding and strengthening the energy network.

Financed emissions

We are aiming for a 25% reduction in CO2e emissions from financed emissions in 2026

compared to 2018. Based on the measurement year 2024, a reduction of 25.5% has been achieved compared to 2018. This means we are well on track to achieve our reduction target for 2025. Since 2018, we have been measuring the CO2e emissions caused by

our financing. This is based on the method developed by the PCAF (the Partnership for

Carbon Accounting Financials). The outcome of this measurement and the methodology and data used are described in detail in our report ‘Greenhouse Gas Emissions of BNG’s Assets’, which can be found on our website. In this annual report, we will provide an

update on the financed emissions associated with the outstanding long term loans as at

31 December 2024. Chapter 9.1 of this annual report explains the most important elements of the methodology and data.

of this is the depreciation of buildings that do not meet the sustainability requirements.

In our ‘Going Green’ climate plan, we have set targets for our financed emissions. The

sustainable economy, while also working actively to limit risks.

in September 2025. Every year, we report on the progress made on these targets in our

Through strategic cooperation, we are supporting our clients in their transition to a more

Although we only have an indirect influence on our clients’ emissions, we encourage

sustainability by means of targeted financing, strategic discussions and conditions that

short-term objectives of BNG were validated by the Science-Based Targets Initiative (SBTi) Climate Progress Report, which we publish as a separate document at the same time as this annual report.

encourage sustainability. Examples of this are the financing of the heat supply in the

Absolute financed emissions originating from our entire loan portfolio decreased from 2,417

housing associations.

decrease in emissions in the Care sector, which is caused in particular by a change in

Westland region and the provision of green loans aimed at promoting sustainability among

We are actively contributing to the energy transition by financing renewable energy, such as wind and solar energy, energy-efficient buildings, electric mobility and CO2e storage

kt CO2e in 2023 to 2,363 kt CO2e in 2024 (-2.2%). This decrease is mainly attributable to the

methodology1. The coverage ratio of our measurement remained virtually unchanged from

99.6% in 2023 to 99.7% in 2024. The loan portfolio also grew by 4.4% from EUR 87.8 billion

1 For the Healthcare, Education and Municipalities sectors, the methodology has been adjusted or different source data has been used; see Chapter 9.1 for more details. These adjustments have been applied retroactively to the 2018 and 2023 emissions. For Healthcare, it was not possible to apply this to all items in 2018 and 2023.

49

in 2023 to EUR 91.7 billion in 2024. This resulted in 26.0 tCO2e per financed million euros, a decrease of 6.5% compared to 2023 (2023: 27.8 tCO2e/EUR million).

In our Climate Progress Report, we look more closely at the client groups that we finance within this sector. If we limit ourselves to the sectors we measure from 2018, these will

generate 18.8 tCO2e per financed million euros, a decrease of 3.6% compared to 20232. Only

the sectors that we have been measuring since 2018 have been included for the calculation of the KPI on a percentage decrease of the absolute scope 1 and 2 emissions. These relate

to housing associations, municipalities, provinces, water boards, healthcare, education and drinking water companies.The absolute emission measurement for scope 1 and 2 for these sectors is 835 ktCO2e in 2024, 840 ktCO2e in 2023 and 1,121 ktCO2e in 2018. This represents a decrease of 0.6% in 2024 compared to 2023 and 25.5% compared to 2018.

In the previous year, we mapped out the financed emissions for our bond portfolio for the

first time. These are bonds that we have purchased from governments, supranational and multilateral development banks, municipalities and companies in the Public Infrastructure and Energy sector. Emissions were able to be measured for 62% of this portfolio in 2024. These results are explained in more detail in the Climate Progress Report.

2 The base year for the Housing Associations, Municipalities, Provinces, Water Boards, Care and Education sectors is 2018. The base year for Drinking Water Companies is 2020.

50

CO2e emissions 2024 associated with loan portfolio

Avoided emissions

Social Housing

Public Sector

Healthcare Institutes

Education

Public Infrastructure

Other

Emissions

(tCO2e/€ mln)

10.4

35.5

527

981

2.1

100%

23

12.9

143.2

10.2

Renewable energy

687.2

Total 2.363 kton CO2e Emissions attributed to credit loans by BNG

PCAF data quality score (range 1 to

5, with 1 being the

695

2

366

145

13

3.9

2.6

3.4

3.4

4.4

3.0

100%

99.7%

100%

100%

100%

74%

highest score)

% portfolio included  in measurement

More details are included in the tables in section 9.1 of this Annual Report.

51

Development in CO2e emissions associated with the loan portfolio

Social Housing

Public Sector

Healthcare Institutes

Education

Public Infrastructure

-1%

-24%

-6%

-12%

% change in CO2 emissions measured in tCO2e/€ mln 2024 compared to 2023

5%

17.3

Development of CO2 emissions

10.4

9.9

2024

2023

35.5

35.8

39.6

24.4

46.3 23.0

30.2

12.9

13.7

2024

2023

143.2

162.3

of selected client sectors (in tCO2e/€ mln)

2018

2024

2023

2018

2024

2023

2018

2018

2024

2023

The Public Infrastructure sector is sinds 2023 available and Other sectors are not included in this visual.

52

Internal operations and sustainability

Scope 3

use of materials within our own operations. We report our scope 1, 2 and 3 emissions

travel will in principle be the standard from 2024 onwards. This will be reflected in the

In addition to our external impact, we aim to achieve CO2e neutrality and the responsible

annually in accordance with the Greenhouse Gas Protocol (GHG).

In 2023, we started renovating our office building on Koninginnegracht. The building will

be preserved further and will meet the highest energy efficiency standards after delivery

(energy label A++). During the renovation period, we are using temporary accommodation that runs partly on gas, which has led to a temporary increase in scope 3 emissions. Nevertheless, the electricity supply remains completely green. We will return to our renovated and more sustainable office building in the beginning of 2027.

Our policy on business travel has changed. For journeys of up to 750 kilometres, train

CO2e emissions from our air travel. This year, for the first time, we have mapped out the

emissions from our employees' commuting. In 2026, we will make our mobility policy even

more sustainable and investigate how we can further facilitate and encourage employees to make sustainable choices. Starting this year, on the advice of SBTi, we are reporting the electricity consumption of electric lease cars under scope 3, as we have no influence on the electricity mix of charging points outside BNG. This item was reported under scope 2 last year.

Scope 1 & 2

By 2025, the targets for scope 1 and 2 of our own business operations will have been

validated by SBTi. These targets concern: a 100% reduction in absolute CO2e emissions and BNG will continue to purchase only renewable electricity until 2030.

Our lease policy changed last year, which means that employees will only be able to lease electric cars in the future. As a result, we will see a decrease in our Scope 1 emissions

for this category in the coming years. Due to the expiry of lease contracts for cars with a combustion engine, our Scope 1 emissions will be zero from 2029. At year-end 2025,

there were no longer any diesel-powered lease cars and two-thirds of the lease cars were fully electric.

53

Energy and heat consumption

Emissions CO2e (in tonnes) 2025

2024

521

Total

416

Total

( 1.1 per fte)

2,745

776

1.5 107

94 67

0

0.6

0.4

Scope 1

Scope 2

Scope 3

Scope 1

(in tonnes)

Absolute

(in tonnes)

8 Scope 2

0.0

0.4

0.2

0.2

0.1

Scope 3

Scope 1

Scope 2

Scope 3

(in tonnes)

732 5.5

0

Electricity Natural gas Heat consumption consumption consumption (in MWh) (in GJ) (in GJ) Absolute

0.4

2023

(0.6 per fte)

215

194

2024

268

Total

(0.9 per fte)

297

223

2025

2023

1.5

2,151

1,275

2.7

212

0.4

Electricity Natural gas Heat consumption consumption consumption (in MWh) (in GJ) (in GJ)

1,091

1,014

2.3

2.1

4.5

Electricity Natural gas Heat consumption consumption consumption (in MWh) (in GJ) (in GJ)

Per fte

Note: Our scope 1 emissions have increased since 2023 due to the use of gas in our temporary office building for heating the building.

Per fte

54

5..

Internal business operations

55

5.1 Employees Our people: the heart of the bank

Our employees make a difference and are the beating heart of BNG. This is also reflected in our strategy, in which we state: ‘We are a bank with a heart, focused on personal growth and cooperation.’

Personnel policy and reorganisation

Our human resources policy focuses on creating an inclusive, sustainable and fair working environment. This policy is based on our human rights policy, which applies to lending,

liquidity management and procurement. It promotes equal opportunities and fair pay, regardless of gender, race, religion or employment relationship.

Strategic priorities

In 2025, we implemented important policy updates to strengthen our human resources

strengthening executive effectiveness, supply chain-oriented collaboration, and sustainable

a new job centre, consisting of seventeen job families, which promotes internal flow.

Our HR policy is focused on realising the strategic course "Road to More Added Value" by employability. By investing in leadership, expertise, and entrepreneurship, we make our

strategy concrete through the development and deployment of our people. Our HR policy seamlessly aligns with the corporate strategy, using our core values as the foundation for our daily actions and collaboration. In 2025, we therefore added the core value

strategy. In cooperation with the works council, for example, we have implemented

This gives employees more insight into the knowledge, skills and competences required for development within or outside their job family. This transparency contributes to

engagement and growth and supports management in strategic workforce planning.

"entrepreneurial," in line with the Route to More Added Value. This new value emphasises

The Road to More Added Value strategic course of action revolves around a sharper focus

"expert, connecting, optimistic, and enterprising" form a solid foundation for our policy.

to reinforce this course of action. One of these measures is the reorganisation, which is

a new way of working, with greater executive effectiveness and proactivity. Our core values

Our strategy needs to be tightened up with concrete and measurable objectives. Each

quarter, we reported on progress and impact through identified KPIs. These quarterly reports are an important way to show successes and take further steps. In the fourth quarter of

2025, we developed the ambitions for our strategic objective further in programme plans for 2026 and targets through to 2028.

and a new way of working. We are taking measures to future-proof the organisation in order taking place in two phases: first the top structure, then the broader organisation. The RfA

(request for advice) for the top structure (phase 1) was completed in the summer of 2025. The RfA for the rest of the organisation (phase 2) was submitted in December 2025 and

will be completed in the first quarter of 2026. The implementation of the new organisation will take place in the second quarter of 2026. For this reorganisation, we have taken a restructuring provision of over EUR 15 million.

Delivering added value is a lasting objective and a driving force that is visible in our culture, results and growth. The KPIs for this objective are now also anchored in the Performance

Management System, through which joint results targets for management will be integrated across the bank by 2026.

56

Personal growth

referral programme. 9 new employees have been recruited via the referral programme.

more internal mobility and saw a growing use of our learning and development platform,

decreased in the second half. We have increasingly filled vacancies through internal flow,

We invested fully in the development of our employees again in 2025. We stimulated

which is a part of the ‘Unlimited Learning’ concept. This concept reflects our ambitions

to continuously support employees in their personal and professional growth. The BNG

Academy was introduced in 2025, offering a mix of mandatory e-learning modules and tailor-made learning tracks on specific themes, such as onboarding. These provide an overview of learning activities for each position or role that will help our employees to

develop their knowledge, skills and conduct. Each employee sets themselves personal

development goals for the coming year through our Performance Management system.

The time needed to fill vacancies (time to hire) increased in the first half of 2025, but recommendations and our own recruitment efforts. As a result, the share of external

agencies in our recruitment activities continued to decrease. We have improved our

onboarding programmes in 2025 to integrate new employees more quickly, regardless of their employment relationship. These programmes help them feel connected to our organisational culture. They contribute to a smooth start and reinforce the sense of involvement in BNG as an attractive employer.

To strengthen talent development, we continued the Personal Leadership Journey in 2025.

As at 31 December 2025, our workforce consists of 503 in-house staff (measured in FTEs).

selected based on their development potential.

a decrease of 45 FTEs compared with the figure as at 31 December 2024. The externally

This process built on previous leadership initiatives, for which forty employees had been

Diversity and inclusion

Diversity and inclusion took centre stage in 2025. In line with the SER Charter Diversity

signed in 2024, the action plan has been submitted and we are monitoring this annually.

As part of this plan, we established an ambassador group that actively works to promote diversity and inclusion within the organisation. These efforts received additional support

from a range of events, including the initiatives during Diversity Day and workshops such as “Unconscious bias” and “Dilemma training”. These events contributed to raising awareness and engagement among employees. The results of our Pulse Survey in the last quarter of 2024 and 2025 provided important insights into social safety. We shared the team results

across all teams and discussed actions and improvements together. In addition, we have

identified a number of bank-wide topics in 2025 that we will work with on a structural basis in 2026.

Recruitment, selection and onboarding

We optimised our recruitment and selection activities in 2025. We are reinforcing our

The number of external staff stands at 124 FTEs as at 31 December 2025. This represents

hired staff consist of individuals on self-employed contracts and seconded staff, who are primarily working on strengthening and modernising our IT organisation. The decrease in

the number of externally hired staff in 2025 is due to the transition from external to internal staff and the completion of IT projects.

Sustainable employability and green employment conditions

Sustainability is an essential aspect of our human resources policy. We are inspired

in this instance by the UN Guiding Principles on Business and Human Rights and the

OECD Guidelines for Multinational Enterprises. This is reflected in sustainable employment relationships, ‘green employment conditions’ and sustainability of our mobility and lease policies. To promote the sustainable employability of employees, we offer facilities such as a sports budget, bicycle plan and vitality leave. These contribute to the vitality and

long-term commitment of our employees. Absenteeism was 4.35% in 2025, higher than in 2024 (4.0%). This higher rate of absenteeism is mainly due to higher absenteeism in the fourth quarter. Long-term absenteeism is largely medically related.

presence on social media and deploying our employees as ambassadors through the

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Key figures HR

Remuneration policy

BNG is a member of the Employers’ Association for Banks (WVB) and applies the Collective

503

Labour Agreement Banks. Of all BNG employees, 95% are covered by the Dutch Collective

157

346

colleagues

59

left the organization

84

is the youngest employee

is the eldest employee

number of employees

100

male female

50

further by the organisation.

BNG has a parental leave scheme where the first four weeks of the partly paid parental leave (a total of nine weeks can be taken) can be topped up to a maximum of 100% of

the salary. Thirteen employees (10 men and 3 women) made use of the scheme in 2025. All employees whose parental leave ended returned to their jobs.

changed position internally

The Collective Labour Agreement Banks also has a vitality scheme. Based on a number of criteria and with retention of part of their salary, employees can take two months’ leave. Eleven employees made use of this scheme in 2025. In addition, the vitality scheme has

work part-time < 32 hours

a so-called 80-80-100 scheme, in which the employee works 80% hours at 80% salary but retains 100% pension accrual. Within BNG, two employees participated in this scheme.

All employees participate in the ABP pension scheme. As the employer, BNG contributes 70%

work full-time > 36 hours

to pensions, while the employee contributes 30%. All figures mentioned are as of the end of 2025.

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BNG aims for a restrained remuneration policy that corresponds with our identity and

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strategy. We want the remuneration policy to discourage taking more risk than is

acceptable. The remuneration policy must also not lead to incentives for dishonest

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behaviour. Employees and members of the Executive Committee and Supervisory Board

51 25

-

on 1 January 2025 and then by 1% on 1 July 2025. In addition to many other schemes, the

male

86

75

Based on the agreements in this CLA, salaries and salary scales were increased by 4%

collective labour agreement also includes a parental leave scheme that can be detailed

49 454

is the average age

68

female

28

commenced employment

45.9 Years 21

Labour Agreement Banks (CAO Banken).

33

37

36

20.5%

24%

29.5%

26%

≤34

35-44

45-54

≥55

age

do not receive variable remuneration.

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The Supervisory Board monitors the bank’s remuneration policy. The general principles of

the remuneration policy for Executive Committee and employees have been approved by

the Supervisory Board. Each year, the implementation of the remuneration policy is reported to the Supervisory Board and the Supervisory Board assesses whether the policy meets the principles for a restrained remuneration policy. For that purpose, Risk Management carries out a risk analysis for various components of the remuneration policy.

The Annual General Meeting adopts the remuneration policy for the statutory members of the Executive Committee and the remuneration scheme for members of the Supervisory Board. In 2025, the salary of the highest-earning member of the Executive Committee

was 3.72 times the median salary of employees at BNG (3.87 in 2024). The average salary (wage bill) increased by 8.7% compared with 2024. The salary of the highest-paid ExCo

member increased by 7.8% in 2025. The remuneration policy and the remuneration report are published on the website. The remuneration of Executive Committee and Supervisory Board members in 2025 is reported in the financial statements.

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5.2 Compliance The integrity of BNG is essential to safeguarding the trust of our stakeholders and to achieving our strategic objectives. This integrity starts with compliance with laws and regulations and the enforcement of a common set of standards. To promote this integrity, we agree on rules that guide our actions.

Compliance cycle Governance & compliance universe (Charter, Regulatory Compliance 

Riskmanagement)

Governance

Risks that threaten the integrity of BNG are described as the bank's compliance risk. We

divide this risk into four sub-risks that relate to financial economic crime, behaviour, fraud

Risk identification  & assessment

Reporting

and regulatory compliance. Managing these risks is the responsibility of the entire bank. As

Driven by: Corporate values Company code

an independent second-line compliance function, the Compliance department provides

support in this regard based on a compliance cycle. This cycle is in line with the generic risk management cycle of BNG and is laid down in the Compliance Charter..

Compliance policies & procedures

Monitoring

Advise & support

Training & awareness

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Developments in 2025

In 2025, BNG focused on improving the demonstrability of the management of compliance risks. This creates a more complete and objective view of the risks. Where we identify

the starting point for managing this risk. This code gives employees direction in their actions and is an important building block in the integrity of BNG.

gaps in our risk picture, we perform further analysis, including the Systematic Integrity Risk

New employees (internal and external) go through an onboarding programme when they

management. We will discuss the main developments in 2025 for each sub-risk below.

take the banker's oath and the second-line compliance function provides an introduction

Analysis (SIRA). We also identify opportunities for improvements and tightening in our risk

Financial and economic crime

An important condition for our integrity is that BNG is not involved directly or indirectly in

start work with us. In this training, they are given an explanation of the code of conduct,

to the regulations that employees must comply with. In addition, new employees must take in-depth training courses to mitigate conduct risks in the first weeks after commencement of employment.

money laundering, terrorist financing, sanction violations, bribery or corruption. The client

Employees who are already employed can always consult the policy internally. Through

counterparts in the international money and capital markets, clients in the Dutch public

surveys, BNG monitors whether employees remain aware of the standards of conduct that

integrity policy forms the basis for mitigating this risk. Based on this policy, we assess

domain and other relationships. In addition, we use this policy as a foundation for our transaction monitoring programme, which allows us to detect unusual transactions.

The Anti-Money Laundering and Terrorist Financing Act (Wwft) and the Sanctions Act (SW) form important frameworks in this policy for client integrity. In 2025, BNG made

qualitative improvements to the implementation of this policy and the systems used in the implementation of the policy.

Bribery or corruption are fundamental offences that lead to money laundering. Managing

these risks in relationships is part of the due diligence process for these relationships. Within BNG, we screen our employees and have a code of conduct to which employees commit. We assess the inherent risks of corruption or bribery as limited both in our commercial

processes and in our internal processes. Therefore, BNG does not specifically offer of anticorruption training. We also did not register any incidents of corruption in 2025.

additional training courses, intranet reports, stand-ups, management focus and employee we agree upon with each other. Managers, HR and Compliance are ready to provide

consultancy or answer questions about this policy. In addition, employees can report

potential irregularities via an incident process, a complaints procedure or a reporting procedure. In this way, we bear responsibility for the integrity of BNG jointly.

In the case of clients, counterparties and other third parties, the code of conduct is the

starting point. BNG wants to support positive social transitions and promote ethical action among these stakeholders. The code of conduct is the starting point in a supplementary policy that is aimed at these external stakeholders. These stakeholders can also provide feedback on BNG's actions, for which there is a complaints procedure (link).

BNG did not receive reports or identify incidents in which conduct risks with a significant impact materialised in 2025.

Conduct risk

Conduct risk includes the risk of actions by BNG, its employees or its relations that are

contrary to our standards, legal requirements or social standards. Our code of conduct is

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Fraud risk

We monitor fraud risk as a separate sub-risk due to the nature of this risk and the impact

that a fraud incident can have on confidence in BNG or the financial sector as a whole. This

Data security is a component of DORA. As a result, these activities also increase the maturity of BNG in its compliance with the General Data Protection Regulation (GDPR).

risk includes both internal fraud by employees and external fraud directed against BNG or

The Capital Requirements Regulation, BCBS239 and the Wwft/SW remain important

separate fraud risk management framework. Developments in existing or new fraud risks

The Instant Payments Regulation and the Artificial Intelligence Act were added in 2025. BNG

our business relations. We ensure the detection and settlement of fraud cases through our form part of the SIRA.

BNG did not identify any cases of internal fraud or external fraud against BNG in 2025. We

detect signs of external fraud at or through our relationships using management measures,

legislative files with regard to regulatory compliance risks arising from other regulations.

remains committed to compliance with all obligations based on a risk-based approach. If structural solutions for compliance require additional time to implement, BNG uses temporary mitigating measures.

such as transaction monitoring. Here too, the number remained limited in 2025 and these

BNG remained in close contact with regulators in 2025 about regulatory compliance

focus point for financial institutions in 2025. BNG’s clients are less susceptible to fraud in

notifications and inspections. We did not receive any fines or penalties and were not

signals were reported, where necessary. Fraud in payment transactions continues to be a payment transactions due to the nature of their business and the fact that this type of fraud is often directed against consumers.

risks. These contacts include informal discussion, as well as formal information requests, involved in any legal proceedings due to non-compliance. There were also no outstanding fines or sanctions from previous years.

Regulatory compliance risk

Customer privacy

new regulatory compliance risk management policy provides a framework for identifying

subjects associated with clients.

Finally, BNG has defined the risk of breaches of laws and regulations as a separate risk. The and reporting on compliance risks. We identify material compliance risks through analyses and monitoring within the compliance cycle. Information from first-line monitoring, audit reports and discussions with the supervisory authorities provide input into this analysis

BNG attaches great value to the privacy of persons, employees, applicants and other data

We took steps to increase our level of privacy maturity in 2025: •

and monitoring.

•

A number of new or amended laws entered into force in 2025 and the volume of legal

•

obligations remains extensive. In 2025, BNG prioritised activities that manage regulatory

compliance risks more highly. Implementing the obligations under the Digital Operational Resilience Act (DORA) has been given absolute priority in this regard. These activities not

only reduce the regulatory compliance risk, but also reduce the operational risks of BNG in this area.

We have set up a Privacy Office to further strengthen the privacy framework.

The Privacy Policy has been revised and supplemented with a range of guidelines and procedures.

At the launch of our new website, we implemented a cookie consent mechanism and a cookie statement, in accordance with the instructions of the Dutch Data Protection Authority (DPA) for clear cookie banners.

Data breaches

Under the GDPR, BNG must register data leaks internally and, depending on the severity, report them to the DPA and data subjects. A data breach is a security incident, in

62

which personal data is accidentally or unlawfully destroyed, lost, modified, provided, made accessible or temporarily unavailable. We registered 29 data breaches in 2025 (2024: 23). Only two of them were reported to the AP (as many as in 2024). One report was later

withdrawn, as further investigation revealed that there was no risk to data subjects. The

data breach reported concerned access rights set incorrectly, which meant that data was

too widely accessible internally. There was no unauthorised external access. There were no data leaks requiring reporting to data subjects.

Rights of data subjects

In 2025, BNG introduced a new procedure that provides frameworks for handling requests from data subjects to exercise their privacy rights under the GDPR. BNG received one

request in 2025: a removal request from an applicant. In addition, BNG did not receive any complaints about breaches of the privacy of data subjects.

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5.3 Risk Management BNG strengthens civil society organisations with financial clout. We do this not to maximise profits, but to make a positive impact. The risk that we are prepared to take on this must fit in with the strategic principles and is based on a long-term and prudent risk profile.

protecting our reputation. Taking balanced risks that are adjusted to the risk appetite is

Identifying, analysing and managing risks is inherent in our activities. We manage and

The RMF is the set of policy documents that outline the risk management principles at

control risks through an extensive Risk Management Framework (RMF), which integrates

risk management in all our business activities, from strategic planning to daily operational activities. This is aimed at safeguarding and maintaining the bank's secure risk profile and

essential for our managed business operations.

Risk Management Framework

BNG. The framework brings together a range of elements that play a role in our risk management. Our RMF is shown in the overview below.

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Risk Management Framework Internal Governance

Charters Executive Committee and Supervisory Board

Three Lines of Responsibility

Risk Framework

Assessment

Risk policies

Other Policies

Risk Definitions

Risk Appetite Statement

Integrated Risk Management

Risk Management Charter

Financial Risk Management

Compliance Cycle

Non Financial Risk Management

(Strategic) Risk Materiality Analysis

ICAAP

ILAAP

Recovery & Resolution

Risk Control Self Assessment processes, projects, applications, outsourcing partners

Business Contingency Planning

Credit Risk Policies

Market Risk Policy

Liquidity & Funding Risk Policy

Operational Risk Management Policy

Product Approval Policy

Capital Management Policy

Stress Testing  Policy

Outsourcing  Policy

Disclosure Policy

Model Governance Policy

Model Validation Policy

ICT Risk  Management Policy

Security Policy

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Risk-related committees

Risk related governing bodies

The Executive Committee determines the risk management frameworks with the approval of the Supervisory Board. The Asset & Liability Committee (ALCO), Credit Committee (CC), Credit Policy Committee (CPC), Credit Committee Treasury (CCT), Sustainability Banking

Committee (SBC), Non-Financial Risk Committee (NFRC) and Client Acceptance and Review

Supervision

Policy Committee (CARPC) make decisions on the risk management of the bank.

Supervisory Board (all risks)

The Supervisory Board (SB) and, in particular, the Risk Committee (RC) of the SB, evaluate the risk management. This is an important part of his supervisory role.

Risk Committee (all risks)

See the overview of risk-related committees beside:

Policies and decision making Executive Committee (all risks)

Operational ALCO (market risk, liquidity risk, capital)

Credit Committee STMP (credit risk)

Credit Policy Committee STMP (credit risk)

Sustainable Banking Committee (ESG)

Non Financial Risk Committee (operational, compliance, security risks)

Client Acceptance and review policy Committee

Credit Committee Treasury (credit risk)

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The purpose and powers of the Risk Management and Compliance departments are

laid down in the Risk Management Charter and Compliance Charters respectively. Risk

Management and Compliance are is represented in the risk-oriented ExCo committees and takes part in meetings held by the SB’s Risk Committee. The Compliance and Risk

Management department heads are accountable to the CRO, the ExCo and have a reporting line to the SB.

A summary of the roles of the Exco committees per risk type is set out in the table:

Committee

Responsible for risk type limits/objectives

2nd line reporting

Executive Committee

Strategic Risk and monitoring of all risks

Integrated Risk report

ALCO

Liquidity risk and market risk

Market risk dashboard

Capital limits (covering multiple risks)

Liquidity risk dashboard Share capital dashboard

CC/CPC STMP

Credit risk for legally defined market parties

STMP Credit Risk Monitoring Report

CC Treasury

Credit risk of financial counterparties, Treasury portfolios

Treasury credit risk monitoring report

NFRC

Operational Risk, security risk and compliance risk

Operational risk report, Compliance report, Security report

SBC

Overarching ESG risk. Coordinating ESG-related activities and analysing the potential effects of strategic ESG risks.1

ESG risk dashboard

CARC

Integrity risk related to financial-economic crime

Monitoring results and consultancy

1 ESG risks that fall specifically in a traditional risk category are subject to the same risk governance. For example, ESG risks related to credit risks are handled by the sub-committee of the Executive Committee that monitors credit risks.

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Three Lines of Responsibility model Supervisory Board/Committees

• Audit Committee • Risk Committee • Remuneration Committee • HR Committee

Executive Committee

Risk Control

Risk Assurance

1st line of responsibility

2nd line of responsibility

3rd line of responsibility

Core Business

Suporting functions

Risk Management

Commercial • Relationship banking • Lending • Client Services & Payments • Business Strategy & Control • Restructuring & Recovery

Board Secretary

• • •

Treasury • Funding • Portfolio Management Back Office

Strategy & Sustainability IT • • • • •

Architecture & Data Cloud & Infrastructure Delivery Security Control & Support

Integrated Risk Management Financial Risk Management Non-Financial Risk Management

Compliance

Internal Audit

External audit

Risk Ownership

Regulators/Supervisors- ECB/DNB/AFM

• ALCO • Credit Committee Clients • Credit Policy Committee Clients • Credit Committee Treasury • Sustainable Banking Committee • Non Financial Risk Committee • Integral Portfolio committee • Client Acceptance and Review Policy Committee

Finance and control Human Resources Legal & Tax affairs Communication

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Three Lines of Responsibility (3LoR)

BNG uses the 3LoR model as its governance framework for risk management. Each line

the RAS to Key Risk Indicators (KRIs), integrated risk reporting, coordination of Pillar 3 reporting, and monitoring and advising on prudential laws and regulations.

has a specific role and defined responsibilities in managing and controlling risks. The figure below shows the allocation of departments within BNG to the three lines. Lines

Roles

Responsibilities

1st line

Risk Ownership

Business departments. Responsibility for identifying, assessing, measuring, limiting and monitoring risks and developing, implementing and carrying out effective audit measures to control these risks.

2nd line

3rd line

Risk Control

Risk Assurance

Risk Management departments and Compliance. Responsible for advising, facilitating and supporting, monitoring and challenging the first line. The first line remains responsible for the risk, together with management. These second line departments support the Executive Committee in implementing BNG’s risk management policy. Internal Audit. The IAD periodically conducts operational- and IT audits to evaluate the design and operating effectiveness of the bank’s risk management systems and to assess whether the currently applicable laws and regulations are properly complied with.

The responsibilities in the second line are fulfilled by three Risk Management departments

and Compliance, which operate independently of the first line. The purpose and powers of

the Risk Management and Compliance departments are laid down in the Risk Management

•

Financial Risk Management (FRM) subdivided into the following sub-departments:

– Asset Liability Management (ALM): The ALM department is responsible for market and

liquidity risk and carries out the coordination of the ICAAP and ILAAP and the recovery plan and coordinates the bank-wide stress testing.

– Credit Risk Management (CRM) CRM is responsible for credit risk at portfolio and client

level from the second line. The tasks include providing a second-line challenge and an opinion on credit proposals and reviews of individual clients, financial counterparties and investments.

– Model Risk Management (MRM) is responsible for model risk as a subcategory of

operational risk and carries out the model management, including model governance and validation of the bank's models.

•

Non-Financial Risk Management (NFRM): The NFRM department is responsible for

monitoring all operational risks (including IT-related risks) and provides support in

identifying, qualifying, and quantifying operational risks in regular business activities and change programs. NFRM is also responsible for bank-wide coordination of the investigation and follow-up of operational incidents.

•

Compliance: The Compliance department is responsible for monitoring compliance risks, monitors compliance with rules, laws and internal policies and promotes the integrity of the organisation, its clients, its employees and the markets in which BNG operates. See 5.2 Compliance for further details.

and Compliance Charters respectively. •

Integrated Risk Management (IRM) is responsible for oversight of bank-wide risks,

including strategic and reputational risk. The IRM department is responsible for, among

other things, the bank-wide Risk Management Framework and underlying policy, drawing up the Risk Appetite Statement (RAS) in line with the risk taxonomy and cascading

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Risk Appetite Statement and taxonomy Risk Appetite

The Risk Appetite Statement (RAS) describes the risk appetite that we accept to achieve our

strategic objectives. It defines the risk management principles within BNG and sets limits on all different types of risk.

The risk appetite is described qualitatively for BNG relevant risk types and elaborated in key risk indicators with defined limits. The risk appetite is evaluated annually and adjusted if necessary, to keep it in line with current developments and BNG’s strategic objectives. The Executive Committee, after discussion and approval by the Supervisory Board,

determines the RAS and ensures that our operational activities remain within the risk parameters identified with the support of the risk departments.

Taxonomy

The main risks that apply to BNG are recorded and described in the risk taxonomy. A

distinction is made between financial risks, non-financial risks, strategic risks, ESG risks

and reputational risks. Where applicable, main risks (level 1) and sub-risks (level 2) have

been defined within these categories. The diagram below shows the relevant risks, without

indicating the scale of the risk for each type. The overview shows that ESG risk and strategic risk are spread across financial and non-financial risks and that reputational risk is always the result of not managing other risks correctly. The BNG’s risk taxonomy is shown as follows: