CaixaBank SA

Sustainability governance in general, specifically as it relates to climate change, is one of CaixaBank's priorities. For this reason, the Board of Directors is ultimately responsible for approving the sustainability strategy and Business Principles, as well as supervising their correct implementation. [...] To this end, a sustainability governance system has been implemented by the governance bodies (Board of Directors, Appointments and Sustainability Committee, Risk Committee and Audit and Control Committee) and management (Management Committee), complemented by other internal committees and areas of the Bank (Global Risk Committee, Sustainability Committee and Sustainability Department). [...] In addition, this governance system will also enable CaixaBank to meet its goal of implementing a coherent, efficient and adaptable environmental and climate change risk management governance model that oversees the achievement of the CaixaBank Group's goals as a framework for managing climate and environmental risk, in line with the ECB's expectations[26] and with best market practices. [...] The Board of Directors has always been very involved in matters of sustainability and climate change. The most recent amendments to the By-laws and the Regulations of the Board of Directors in this area are set out below: [...] The Board of Directors led, reviewed and approved in December 2021 the Sustainable Banking Plan 2022-2024. [...] In March 2022, the Board of Directors approved the Sustainability Principles, as an update to the previous Corporate Sustainability/CSR Policy. [...] The Environmental and Climate Strategy includes a public commitment Statement on Climate Change, in which CaixaBank commits to take the necessary measures to comply with the Paris Agreement. This statement was reviewed and approved by the Board of Directors in January 2022. [...] The Board of Directors approved the Corporate Sustainability/ESG Risk Management Policy in March 2022. This Policy combines the previous Environmental Risk Management Policy and Corporate Policy on Relations with the Defence sector, establishing criteria for ESG analysis in the Bank's customer admission and credit approval processes. The Policy establishes general and sector exclusions linked to activities that may have a significant impact on human rights, the environment and the climate. CaixaBank will not assume credit risk in activity involving these exclusions. General exclusions apply to all customers, while sectoral exclusions apply to certain activities in the defence, energy, mining, infrastructure and agriculture, fishery, livestock and forestry sectors. [...] The creation of this committee was approved in April 2021 by the Management Committee, which grew out of the Environmental Risk Management Committee, created in 2019, and also took over the sustainability/CSR-related duties of the Corporate Responsibility and Reputation Committee in 2015. Its mission is to help CaixaBank to be recognised for its excellent sustainability management, taking charge of implementing the sustainability strategy and driving it forward in the organisation. [...] The Sustainability Committee is a delegated body of the Management Committee, to which it reports directly, which in turn reports, where appropriate, to the Appointments and Sustainability Committee, and the latter to the Board of Directors. In addition, for sustainability risk policies, the Sustainability Committee reports to the Global Risk Committee, which forwards these policies to the Risk Committee and the latter to the Board of Directors. [...] The Sustainability Committee meets on a monthly basis, and among its main duties in the area of sustainability and climate change, it is responsible for: Approving CaixaBank's sustainability strategy and practices and monitoring them, as well as proposing and submitting the general policies for sustainability management for approval by the corresponding governance bodies. Overseeing the Sustainability Master Plan (Sustainable Banking Plan), approved in December 2021 as a development of the Socially Responsible Banking Plan (2019-2021) and monitoring projects and initiatives for the deployment of the Master Plan. Promoting the integration of sustainability criteria in the Bank's business management. Understanding and analysing regulatory requirements, trends and best practices in the sustainability sector. Reviewing and approving the information to be issued regarding sustainability. Reporting to the Management Committee on the resolutions of the Sustainability Committee. Raising to the Global Risk Committee issues related to sustainability risk management policies, reporting and monitoring of assigned Risk Appetite Framework (RAF) metrics, and periodic reporting related to sustainability risks. Validating the reasonableness of non-financial ESG indicators.

The **Board of Directors is responsible for approving, supervising and periodically assessing the** definition, development and implementation of the sustainability strategy, which, in turn, includes the climate change strategy. It is also responsible for approving, supervising and monitoring the effectiveness of this Statement and the commitments included herein.

In addition, the **Appointments and Sustainability Committee's functions include following** supervising compliance with CaixaBank's environmental and social policies and rules, assessing and revising them periodically, as well as supervising that CaixaBank's practices in these matters are in line with its strategy and policies. The Risks Committee also proposes the Group's risks policy to the Board. Moreover, the Control and Auditing Committee supervises the process of preparing and presenting the financial and non-financial regulatory information, which includes climate information.

The **Management Committee is responsible for developing the Entity's Strategic Plan approved** by the Board of Directors and, to this end, adopts resolutions, either directly or through its delegate committees, in relation to sustainability matters.

Moreover, several internal committees are responsible for the coordination and supervision of different aspects set out in this Statement, including the Sustainability Committee, the Global **Risk Committee, and the Regulation Committee.**

Finally, the Sustainability Department coordinates defining, updating and monitoring the Group's sustainability strategy, which also includes climate change issues.

This Statement will be revised and updated at least every two years.

**Statement reviewed and approved by the Board of Directors on 15 February 2024.**

Sustainability governance in general, including climate change, is one of CaixaBank's priorities. For this reason, the Board of Directors is responsible for the approval of the strategy and the Principles of Sustainability, as well as for monitoring their correct implementation. To this end, a sustainability governance system has been structured through the Governing Bodies (mainly through the Board of Directors, Appointments and Sustainability Committee, Risk Committee and Audit and Control Committee) and corporate bodies (Management Committee), complemented by other internal committees and areas of the Entity (Sustainability Committee and Sustainability Department). [...] Within the Sustainability Department, Sustainability Risk Management is responsible for defining the principles of action in relation to managing ESG risks, as well as advising on their application criteria, validating these and transferring them to the corresponding analysis tools. To specifically enhance the oversight of climate risks, in January 2022 the Climate Risk Management was created within the Sustainability Office. [...] Furthermore, the Risk Committee is responsible, among other functions, for proposing the Group's risk policy to the Board of Directors and examining the Group's risk information and control processes. This Committee periodically reviews issues related to the management of sustainability and, in particular, climate-related risks. [...] The highest management body with responsibility for managing sustainability risk, including climate and environmental risk, is the Sustainability Committee, a representative body of the Management Committee, to which it reports directly. In addition, when applicable, it reports to the Appointments and Sustainability Committee, and in matters related to the sustainability risk policies to the Global Risk Committee, which submits them to the Risk Committee. Both the Appointments and Sustainability Committee and the Risk Committee are representative committees of the Board of Directors. [...] The Sustainability Committee reports to the Sustainability Director, who is a member of the Management Committee. Among other functions, this Committee is responsible for overseeing the Sustainability Master Plan and monitoring projects and initiatives to implement the Sustainability Master Plan, promoting the integration of sustainability criteria in business management, knowing and analysing the regulatory requirements in terms of sustainability, reviewing and approving the information to be disclosed regarding sustainability. [...] The Sustainability Department is responsible for coordinating the definition, updating and monitoring of the Group's sustainability strategy, including the implementation of these Principles. With this objective, and to coordinate and monitor the implementation of the Sustainability Master Plan, an internal weekly work group has been set up to monitor the Plan, in which the entire Sustainability Management is involved. Additionally, the Sustainability Committee reviews the degree of progress in implementing the Master Plan, including the first level KPIs, on a quarterly basis. The Appointments and Sustainability Committee is informed every six months of the progress and status of the Master Plan (in 2022, the first year of implementation of the Master Plan, the Appointments and Sustainability Committee and the Board of Directors were informed in the fourth quarter). Members of committees may request the establishment of new actions in the event that the objectives are not achieved or new areas of priority attention are identified.

Sustainability governance in general, specifically as it relates to climate change, is one of CaixaBank's priorities. The integration of ESG factors in CaixaBank's activity requires defining and/or reviewing policies, procedures and roles to ensure that these key factors are taken into account in decision-making: **–** Definition and updating of ESG policies In addition, this governance system will also enable CaixaBank to meet its goal of implementing a coherent, efficient and adaptable ESG and climate risk management governance model that oversees the achievement of the CaixaBank Group's goals, in line with the ECB's expectations[57 ]and best market practices. **–** Establishment of criteria, roles and responsibilities **–** Integration into the Bank's systems and procedures **–** Measurement of performance and accountability For this reason, the Board of Directors is ultimately responsible for approving the Sustainability Strategy and Principles, as well as supervising their correct implementation. Solid corporate governance enables companies to maintain an efficient and methodical decision-making process, because it introduces clarity in the allocation of roles and responsibilities and, at the same time, fosters proper risk management and the efficiency of internal control, which promotes transparency and limits potential conflicts of interest. To this end, a sustainability governance system has been implemented by the governance bodies (Board of Directors, Appointments and Sustainability Committee, Risk Committee and Audit and Control Committee) and management (Management Committee), complemented by other internal committees and areas of the Bank (Global Risk Committee, Sustainability Committee and Sustainability Department).

CaixaBank has a rigorous process for assessing any proposal to join an association or commercial chamber. This process includes an internal reputational risk check to ensure that the association in question is recognised and has a proven reputation and conduct. In this way, CaixaBank ensures that its membership in any association is aligned with its values and objectives, also in terms of sustainability.

CaixaBank has a robust internal governance process to ensure that the positions and communications that reach associations and authorities are consistent with the bank's strategy. Where applicable, these positions can also be found publicly posted on the European Commission's website.

Under no circumstances do we contract services directly from lobbyists to define our position with government agencies. We generally share opinions through different industry associations to try to reach a common position, and we occasionally also directly send out our own messages. [...] At CaixaBank, we assess the alignment of the position of organisations with which we collaborate, as well as that of our advocacy activities, with objectives of the Paris Agreement and other core values of CaixaBank. In the event of misalignment, mitigating measures are defined and implemented. [...] The CaixaBank Regulation Committee is a body dependent on the Management Committee and is responsible for monitoring the regulatory environment and setting positions on developments of public policies that are relevant to the entity and the financial system. In order to exercise its functions, the Regulatory Committee relies on the Public Affairs Directorate its preparation and coordination, based on technical analysis and assessment by experts within the Group. The Chief Compliance, Control and Public Affairs Officer (member of the Management Committee) and the Director of Public Affairs are the representatives before the administrative, management and control bodies for the internal supervision of CaixaBank's public policy activities.

CaixaBank's participation and interaction in meetings with the heads of authorities and supervisors are shared with the members of the Regulatory Committee on a monthly basis. CaixaBank's positions presented and/or distributed in these meetings are also reported.

In 2023, an internal audit was carried out on the Regulatory Committee, which determined that it fulfils the functions defined in the Committee Governance Standard by monitoring, coordinating and determining the CaixaBank Group strategy in the national, European and international debate.

In any case, CaixaBank's Sustainability Committee, given its corporate character, will ensure that these policies are integrated by the Group companies in a proportionate manner, that any internal policies approved by the Group companies are consistent with the corporate policy, and that all the policies are consistent throughout the CaixaBank Group. [...] The Board of Directors of CaixaBank is responsible for implementing a risk governance framework that addresses the Group's risk propensity. This includes the adoption of a solid and diligent risk culture, setting a risk appetite in accordance with the Risk Appetite Framework (RAF) and defining responsibilities for taking, managing and controlling risks. [...] The Board of Directors is ultimately responsible for establishing the Group's general strategies and policies, and is tasked with approving these Principles - after review by the Risks and Appointments and Sustainability Committees - and enforcing their provisions. [...] To implement the Policy to which these Principles refer, the Sustainability and Global Risk committees must establish an application procedure for the proper application of the criteria set out in the Policy.

The Appointments Committee and Sustainability oversees the Company's activity in relation to sustainability, as well as the compliance with the Company's rules and policies in environmental and social matters, regularly evaluating and reviewing them, with the aim of confirming that it is fulfilling its mission to promote the corporate interest and catering, where appropriate, to the legitimate interests of remaining stakeholders, as well as submitting the proposals it considers appropriate on this matter to the Board and, particularly, submitting the sustainability/corporate responsibility policy for approval. In addition, the Committee will ensure the Company's environmental and social practices are in accordance with the established strategy and policy. [...] The Risk Committee is responsible for proposing the Group's risk policy to the Board of Directors, including ESG risks and, in particular, climate risks. [...] The Audit and Control Committee oversees the process of elaborating and presenting mandatory financial and non-financial information regarding the Company and, where relevant, the Group, including information related to Sustainability, among others, climate information. [...] The Sustainability Department defines the principles of action in relation to managing ESG risks, as well as advising on their application criteria, validating these and transferring them to the corresponding analysis tools. It also assesses and analyses the Entity's participation in climate and sustainability associations.

###### Sustainability Governance\n\n Mission and values Strategic Plan 2019-2021\n\n Board of Directors: approves the Sustainability/CSR strategy and policy and oversees their implementation.\n\n GOVERNANCE AND MANAGEMENT\n\n At CaixaBank, management and control of the Company is distributed among the Annual General Meeting, the Board and its committees:\n\n**ANNUAL GENERAL MEETING** **EXTERNAL AUDIT**\n\nExecutive\nCommittee\n\nAppoints Reports to\n\nAppointments and\nSustainability Committee\n\nRisks Committee Remuneration\nCommittee\n\n**MANAGEMENT BODIES**\nChief Executive Officer and Management Committee\n\nInnovation, Technology\nand Digital Transformation\nCommittee\n\nAudit and Control\nCommittee\n\n###### STRUCTURE OF GOVERNING BODIES\n\n**Appointments and Sustainability**\n**Committee**\n\nOversees compliance with the Company's\nenvironmental and social policies and rules, so\nthat they succeed in promoting the company's\ninterests and take into account the legitimate\ninterests of other stakeholders\n\n**Sustainability Committee**\n\nImplements the sustainability\nstrategy and promotes it across the\norganisation\n\n**Risks Committee**\n\nProposes the Group's risk\npolicy to the Board, including\nESG issues\n\n**Management**\n**Committee**\n\nApproves the main courses of\naction in the realm of sustainability and CSR\n\n--NEW-PAGE--\n\n###### Responsible management\n\n MAIN COMMITTEES\n\n###### SUSTAINABILITY COMMITTEE\n\n Approves and monitors CaixaBank's sustainability strategy and practices, while also proposing and raising the general policies for sustainability management.\n\n**Frequency: monthly**\n\n###### REPUTATIONAL RISK COMMITTEE\n\n Monitors corporate responsibility strategy and practices, and proposes and escalates general policies for corporate responsibility and reputation management.\n\n**Frequency: monthly**

The governance bodies of CaixaBank perform certain functions associated to their responsibility to approve and supervise the strategic and management guidelines established around corporate sustainability/social responsibility in the interests of all the Group companies, as well as the supervision, monitoring and integrated control of the Group's risks as a whole, among these being reputational risk. The Board of Directors of CaixaBank are responsible for the strategic definition of CaixaBank and its Group, the specific organisation for its implementation and the supervision and control of compliance by the management with the management targets and guidelines established by the Board of Directors, all in accordance with the purpose and social interest of the CaixaBank Group, namely: The approval of the Corporate Sustainability/Corporate Social Responsibility Policy corresponds to the CaixaBank Board of Directors, which will adopt the necessary measures for the implementation and supervision of the development and application of the Policy. The CaixaBank Appointments Committee is responsible, amongst other duties, for supervising the performance in relation to initiatives regarding corporate sustainability/social responsibility and for submitting any proposals it deems appropriate on this matter to the Board: The Risks Committee advises CaixaBank's Board of Directors on the Group's overall risk appetite and its strategy to this end. Within the framework of the management of reputational risk, it reviews this Policy prior to its approval by the Board. The Audit and Control Committee, with regard to this Policy, reviews the fulfilment of the regulatory requirements in relation to the preparation of financial information and performs a regular follow-up of the KPI (Key Performance Indicators) associated with the non-financial information included in the annual Management Report. In relation to the corporate sustainability/social responsibility, as a key aspect of the management of reputational risk, the Global Risks Committee reviews this policy prior to its approval by the governance bodies. CaixaBank's Management Committee is responsible for developing the Strategic Plan and the consolidated budget approved by the Board of Directors. During this development it will adopt resolutions, either directly or through its delegate committees, in relation to corporate sustainability/social responsibility. To ensure good decision-making, CaixaBank has set up a Corporate Responsibility and Reputation Committee which reports to the Management Committee and is responsible for promoting and, where applicable, approving initiatives with regard to corporate sustainability/social responsibility, as well as coordinating or managing the approved initiatives. This Subsidiary Corporate Responsibility and Reputation Coordination Group has the function of coordinating, informing and promoting initiatives with regard to corporate sustainability/social responsibility in the subsidiaries of the CaixaBank Group. The Executive Division for Communication, Institutional Relations, Brand and CSR is responsible, among other duties, for implementing the corporate sustainability/social responsibility strategy and executing the Master Plan (Socially Responsible Banking Plan), preparing reputational risk management policies, managing the initiatives in this area approved by the governance bodies, monitoring the initiatives implemented in the CaixaBank Group and carrying out regular internal and external reporting. Additionally, any functional area of the CaixaBank Group can, via the Corporate Responsibility and Reputation Committee or the Subsidiary Corporate Responsibility and Reputation Coordination Group, propose initiatives relating to corporate sustainability/social responsibility.

The CaixaBank Board of Directors is responsible for approving these Principles and the commitment with the stakeholders included in this document. It is also responsible for approving, supervising and periodically assessing the definition, development and implementation of the sustainability strategy. Meanwhile, the **Appointments and Sustainability Committee oversees CaixaBank's action in the area of sustainability.** It reviews and proposes to the Board the adoption of policies, declarations and standards at CaixaBank that develop the sustainability strategy. The Risks Committee proposes the Group's risk policy to the Board, including sustainability risk. The Audit and Control Committee monitors and assesses the process of drawing up and presenting non-financial information and the effectiveness of internal control systems. It also works alongside the Risks Committee in supervising and assessing the effectiveness of risk management systems, including social and environmental risks. [...] The Sustainability Department, as the area responsible for coordinating the process of defining, updating and monitoring the Group's sustainability strategy, is also responsible for drawing up and updating the Principles (at least once every two years). [1]); for presenting them to the governance bodies for approval; for monitoring their degree of implementation within the Group; for ensuring awareness of these Principles among all covered persons and, where appropriate, seeking to extend them to the relevant Group subsidiaries. Lastly, the various areas and divisions affected by these Principles shall apply and observe them in their daily activities, make them part of the relevant internal regulations and monitor their effective application. To this end, additional internal processes and systems may be developed. In addition, the Sustainability Department will, when deemed necessary or desirable, advise the other departments on sustainability matters and on how best to implement these Principles.

The policies described in this document are kept up to date. They are regularly reviewed, monitored and adapted according to legal requirements and progress in the field of sustainability and submitted to the governing bodies for approval. In the future, the adaptation of these guidelines may also be considered depending on the development and performance of the PAI indicators. [...] As regards the allocation of responsibility for the application of policies within the framework of organisational policies and procedures, both CaixaBank and CaixaBank AM apply the three lines of defence model, in which the first line of defence is responsible for the application of policies, the second for monitoring their application and the third for auditing them. This is a cross-cutting task in each of the aforementioned lines and the policies are applied from the outset. [...] The CaixaBank Group has developed a corporate framework[9] for investment operations applicable to the provision of discretionary portfolio management or investment advisory services, based on three main pillars: [...] Long-term engagement (including dialogue with issuers and third-party managers via CaixaBank AM, as specified in the CaixaBank Discretionary Portfolio Management Engagement Policy):  The purpose of the dialogue actions carried out through CaixaBank AM (within the framework of the aforementioned delegation) is to improve and change the behaviour of companies on certain relevant matters, including, when discovered, negative incidents or ways to improve the management of their impact, both positive and negative. Potentially applies to all PAI. CaixaBank AM (as part of CaixaBank's discretionary portfolio management) systematically analyses and monitors the principal adverse impacts on sustainability factors and takes the necessary remedial action. These measures may consist of not investing, divesting, reducing exposure or placing it under observation and, if necessary, taking whatever action is deemed necessary.

The strategy and management on sustainability and climate change has been approved and supervised by the Board of Directors. [...] The Board of Directors is ultimately responsible for approving the Sustainability Strategy and Principles, as well as supervising their correct implementation. [...] To this end, a sustainability governance system has been implemented by the governance bodies (Board of Directors, Appointments and Sustainability Committee, Risk Committee and Audit and Control Committee) and management (Management Committee), complemented by other internal committees and areas of the Bank (Global Risk Committee, Sustainability Committee and Sustainability Department). [...] The Appointments and Sustainability Committee is made up of non-executive directors, in the number determined by the Board, with a minimum of 3 and a maximum of 5 members, the majority being independent directors. Members of the Appointments and Sustainability Committee are appointed by the Board on a proposal received from the Committee itself. Meanwhile, the Committee's Chairman will be appointed from among the independent directors sitting on the Committee. The Committee's competencies include examining policies on sustainability/corporate social responsibility as well as diversity and sustainability issues. The Committee also monitors climate and environmental risks. [...] The Management Committee is the highest management body responsible for approving the main lines of action in matters of sustainability. In view of the growing importance of all aspects of sustainability, a new Sustainability Department was created in 2021, the head of which is a member of the Management Committee. [...] The Sustainability Committee is the body reporting to the Management Committee responsible for approving CaixaBank's sustainability strategy and practices and monitoring them, as well as proposing and submitting for approval by the corresponding governance bodies the general policies for sustainability management. Its mission is to help CaixaBank to be recognised for its excellent sustainability management, reinforcing its positioning through its sustainable banking model. The Sustainability Committee reports directly to the Management Committee, which in turn reports, where appropriate, to the Appointments and Sustainability Committee, and the latter to the Board of Directors. In addition, for sustainability risk policies, the Sustainability Committee reports to the Global Risk Committee, which forwards these policies to the Risk Committee and the latter to the Board of Directors. Prior to submission to the Board, the Sustainability Committee has to receive a favourable report from the Management Committee and the Appointments and Sustainability Committee. [...] The Board of Directors approved the Corporate Sustainability/ESG Risk Management Policy in March 2022. This Policy combines the previous Environmental Risk Management Policy and Corporate Policy on Relations with the Defence sector, establishing criteria for ESG analysis in the Bank's customer admission and credit approval and investment processes on behalf of the Bank. [...] In 2023, CaixaBank approved a new circuit for intra-CaixaBank Group coordination in relation to serious ESG controversies linked to companies with which the Group has or seeks to have a position and which may potentially involve a violation of the Corporate Sustainability Risk Management Policy or other responsible policies. To this end, a delegated Working Group of the Sustainability Committee has been set up to analyse and give an opinion on the seriousness of the potential violation. Alerts on potential disputes may come from external or internal sources. This Working Group analyses any alert corresponding to issuers with which CaixaBank has an active position of its own (ALM, Treasury & Funding or investee); has a contractual relationship; is a customer or is in the process of being studied and/or is in the active positions of customers with advised portfolios. Following this analysis, the Working Group decides or submits for decision to the Sustainability Committee (or Management Committee) the seriousness of the controversy and proposes response strategies for each of the Units of the Group with a position in the company related to the dispute.

The Board of Directors of CaixaBank is responsible for ensuring compliance with these Principles and the commitment with the stakeholders named in this document. It is also responsible for approving, supervising and periodically assessing the definition, development and implementation of the sustainability strategy. Meanwhile, the Appointments and Sustainability Committee oversees CaixaBank's action in the area of sustainability. It reviews and proposes to the Board the adoption of policies, declarations and standards at CaixaBank that develop the sustainability strategy. The Risks Committee proposes the Group's risk policy to the Board, including sustainability risk. The Audit and Control Committee monitors and assesses the process of drawing up and presenting non-financial information and the effectiveness of internal control systems. It also works alongside the Risks Committee in supervising and assessing the effectiveness of risk management systems, including social and environmental risks. [...] Moreover, other internal committees are responsible for the coordination and supervision of various aspects set out in these Principles. These include the Sustainability Committee, which reports to the Management Committee and is responsible for promoting and, where applicable, approving sustainability-related initiatives, while also coordinating and managing those initiatives that are ultimately approved. The **Global Risks Committee is responsible for the overall management, control and monitoring of all risks,** including sustainability risk. [...] The Sustainability Department, as the area responsible for coordinating the process of defining, updating and monitoring the Group's sustainability strategy, is also responsible for drawing up and updating the Principles (at least once every two years). [1]); for presenting them to the governance bodies for approval; for monitoring their degree of implementation within the Group; for ensuring awareness of these Principles among all covered persons and, where appropriate, seeking to extend them to the relevant Group subsidiaries. [...] Lastly, the various areas and divisions affected by these Principles shall apply and observe them in their daily activities, make them part of the relevant internal regulations and monitor their effective application. In addition, the Sustainability Department may, when deemed necessary or desirable, advise the other departments on sustainability matters and on how best to implement these Principles. [...] All CaixaBank Group companies must ensure the existence of controls to ensure the proper application of the general principles enshrined in this Policy and, where applicable, their implementation within internal frameworks and procedures.

The policies described in this document are kept up to date. They are regularly reviewed, monitored and adapted according to legal requirements and progress in the field of sustainability and submitted to the governing bodies for approval. In the future, the adaptation of these guidelines may also be considered depending on the development and performance of the PAI indicators. [...] As regards the allocation of responsibility for the application of policies within the framework of organisational policies and procedures, both CaixaBank and CaixaBank AM apply the three lines of defence model, in which the first line of defence is responsible for the application of policies, the second for monitoring their application and the third for auditing them. This is a cross-cutting task in each of the aforementioned lines and the policies are applied from the outset. [...] The CaixaBank Group has developed a corporate framework for investment operations applicable to the provision of discretionary portfolio management or investment advisory services, based on three main pillars: [...] Long-term engagement (including dialogue with issuers and third-party managers via CaixaBank AM, as specified in the CaixaBank Discretionary Portfolio Management Engagement Policy): The purpose of the dialogue actions carried out through CaixaBank AM (within the framework of the aforementioned delegation) is to improve and change the behaviour of companies on certain relevant matters, including, when discovered, negative incidents or ways to improve the management of their impact, both positive and negative. Potentially applies to all PAI. CaixaBank AM (as part of CaixaBank's discretionary portfolio management) systematically analyses and monitors the principal adverse impacts on sustainability factors and takes the necessary remedial action. These measures may consist of not investing, divesting, reducing exposure or placing it under observation and, if necessary, taking whatever action is deemed necessary.

In any case, CaixaBank's Sustainability Committee, given its corporate character, will ensure that these policies are integrated by the Group companies in a proportionate manner, that any internal policies approved by the Group companies are consistent with the corporate policy, and that all the policies are consistent throughout the CaixaBank Group. [...] The Board of Directors of CaixaBank is responsible for implementing a risk governance framework that addresses the Group's risk propensity. This includes the adoption of a solid and diligent risk culture, setting a risk appetite in accordance with the Risk Appetite Framework (RAF) and defining responsibilities for taking, managing and controlling risks. [...] The Board of Directors is ultimately responsible for establishing the Group's general strategies and policies, and is tasked with approving these Principles - after review by the Risks and Appointments and Sustainability Committees - and enforcing their provisions.

###### 4.1. GOVERNANCE

The Board of Directors is the maximum authority in setting business strategies for the entity, its risk strategy and its risk management policies, including environmental matters. To attain such objective, it also has the Risks and Appointments Executive Committees.

CaixaBank has two committees which the Management Committee supervises, to which coordination of the implementation of the bank's environmental strategy has been delegated: the Environmental Risk Management Committee and the Sustainability Committee.

Its functions, among others, are to establish, approve and keep up to date a programme that ensures the consumption and processes related to CaixaBank's financial activity respect the environment and to encourage and promote the participation of all those who form part of CaixaBank.

In 2021, a new organisation chart was designed as a result of the merger with Bankia. This included the creation of a new Sustainability division, the head of which is a member of the company's Management Committee. This Committee is responsible for aspects related to internal environmental management, which is managed from the Sustainable Business Product Coordination area.

The most important decisions relating

Monitoring Group and the Sustainability Committee, with working groups being set up involving Environmental Management and other areas with environmental responsibilities, such as Purchasing, General Services and Maintenance.

These working groups evaluate and renew the objectives annually to guarantee continuous improvement in CaixaBank's environmental management and reduce its impact

In addition, the Sustainability Department coordinates the proposal, approval and submission of the environmental management content of the Sustainability Principles to the Sustainability Committee, and the environmental management projects to implement the bank's environmental strategy are defined.

This system ensures that CaixaBank's critical environmental aspects are reviewed, updated and, where

The **Board of Directors is responsible for approving, supervising and periodically assessing the** definition, development and implementation of the sustainability strategy, which, in turn, includes the climate change strategy. It is also responsible for approving, supervising and monitoring the effectiveness of this Statement and the commitments included herein.

In addition, the **Appointments and Sustainability Committee's functions include following** supervising compliance with CaixaBank's environmental and social policies and rules, assessing and revising them periodically, as well as supervising that CaixaBank's practices in these matters are in line with its strategy and policies. The Risks Committee also proposes the Group's risks policy to the Board. Moreover, the Control and Auditing Committee supervises the process of preparing and presenting the financial and non-financial regulatory information, which includes climate information.

The **Management Committee is responsible for developing the Entity's Strategic Plan approved** by the Board of Directors and, to this end, adopts resolutions, either directly or through its delegate committees, in relation to sustainability matters.

Moreover, several internal committees are responsible for the coordination and supervision of different aspects set out in this Statement, including the Sustainability Committee, the Global **Risk Committee, and the Regulation Committee.**

Finally, the Sustainability Department coordinates defining, updating and monitoring the Group's sustainability strategy, which also includes climate change issues.

This Statement will be revised and updated at least every two years.

**Statement reviewed and approved by the Board of Directors on 15 February 2024.**

CaixaBank has delegated the discretionary portfolio management service to CaixaBank AM. However, CaixaBank is ultimately responsible for the provision of this service and, as such, will monitor that the exercise of this function by the management company is in line with the provisions of this Engagement Policy. [...] The Private Banking Sustainability Division, responsible for the Policy, will review the validity of this document's content on an annual basis. [...] As a review procedure, the person responsible for the Policy will: - Share the result of the analysis with the rest of those involved and make the necessary modifications to the Policy. - Include a summary of the review in the 'Version control' section of the Policy. - Present the Policy to the Management Committee and the Board of Directors for approval. [...] The Board of Directors will approve the Engagement Policy, on the recommendation of the Private Banking Sustainability Division.

###### Environmental Risk Management Policy\n\n##### Governance\n# 03\n\n--NEW-PAGE--\n\n###### Recording transactions\n\nAdditionally, when originating new transactions for the sectors covered by this policy, CaixaBank's Business area shall check to see whether any exclusion criteria apply. In\ndoing so, it will rely on available public information and on the information provided\nby the customer and during the due diligence process (where such a process must\nbe performed due to the nature of the transaction).\n\nIf in doubt as to whether the aforementioned exclusion perimeter applies, the environmental risk experts attached to the Bank's Business units shall conduct a preliminary verification and diagnosis. If still in doubt, the query must be escalated to the\nTransaction Analysis and Appraisal Unit defined in this policy, which will issue a report\non the level of environmental risk, including a recommendation on the desirability of\nrecording the transaction. The final decision will be down to the Environmental Risk\nManagement Committee defined in this policy.\n\n###### Transaction Appraisal Unit\n\nThis unit specialises in environmental risk and supports the Bank in daily decision-making processes in connection with ordinary risk acceptance activities. It reports to the\nEnvironmental Risk Management Committee.\n\nThe unit comprises environmental risk experts acting on behalf of the Business, Risks\nand Corporate Responsibility areas.\n\nThe unit's main function is to run analyses and issue reports or explanations with\nrespect to potential levels of environmental risk whenever required of it and especially when granting new loans in relation to the activities and sectors covered by this\npolicy. Any decision by the Environmental Risk Management Committee to approve\nan exception to the general and industry-specific exclusions will require a preliminary\nreport from this unit supporting that exception.\n\n###### Environmental Risk Management Committee\n\nBroadly speaking, the Environmental Risk Management Committee (which reports\nto the Management Committee) is the most senior specialised executive body at\nCaixaBank when it comes to environmental risk management. It is therefore responsible for analysing and, where necessary, approving the proposals received from the\ndifferent functional areas concerning the Bank's strategy and approach, while also\nidentifying, managing and controlling the associated risks as a first line of defence.\n\nAll environmental risk management initiatives are supervised by this committee. It\nmay also seek, at any time, the advice of the environmental risk experts attached to\nthe Bank's various business areas involved in environmental risk acceptance, management, monitoring or control activities. The committee may also authorise exceptions to the general and industry-specific exclusions set out in this policy, although\nany such decision may need to be reported to the bodies responsible for approving\nthe new lending transaction or project.\n\nThe committee shall regularly report to the Bank's Global Risks Committee.

Sustainability governance in general, specifically as it relates to climate change, is one of CaixaBank's priorities. For this reason, the Board of Directors is ultimately responsible for approving the sustainability strategy and Business Principles, as well as supervising their correct implementation. [...] To this end, a sustainability governance system has been implemented by the governance bodies (Board of Directors, Appointments and Sustainability Committee, Risk Committee and Audit and Control Committee) and management (Management Committee), complemented by other internal committees and areas of the Bank (Global Risk Committee, Sustainability Committee and Sustainability Department). [...] In addition, this governance system will also enable CaixaBank to meet its goal of implementing a coherent, efficient and adaptable environmental and climate change risk management governance model that oversees the achievement of the CaixaBank Group's goals as a framework for managing climate and environmental risk, in line with the ECB's expectations[26] and with best market practices. [...] The Board of Directors approves and supervises the strategic and management guidelines established in the interest of all Group companies and ensures compliance with regulations and the application of good practices in the performance of their activities and the observance of additional, voluntarily accepted principles of social responsibility. Its duties include approving and overseeing the sustainability and climate change management and strategy. [...] The Board of Directors led, reviewed and approved in December 2021 the Sustainable Banking Plan 2022-2024. [...] In March 2022, the Board of Directors approved the Sustainability Principles, as an update to the previous Corporate Sustainability/CSR Policy. [...] The Environmental and Climate Strategy includes a public commitment Statement on Climate Change, in which CaixaBank commits to take the necessary measures to comply with the Paris Agreement. This statement was reviewed and approved by the Board of Directors in January 2022. [...] The Board of Directors approved the Corporate Sustainability/ESG Risk Management Policy in March 2022. This Policy combines the previous Environmental Risk Management Policy and Corporate Policy on Relations with the Defence sector, establishing criteria for ESG analysis in the Bank's customer admission and credit approval processes. The Policy establishes general and sector exclusions linked to activities that may have a significant impact on human rights, the environment and the climate. CaixaBank will not assume credit risk in activity involving these exclusions. General exclusions apply to all customers, while sectoral exclusions apply to certain activities in the defence, energy, mining, infrastructure and agriculture, fishery, livestock and forestry sectors. [...] The Appointments and Sustainability Committee regulates its own functioning and meets whenever it is advisable for the performance of its duties or whenever the Board or its Chairman requests the issuance of a report or the adoption of a proposal. The main duties of the Appointments and Sustainability Committee in the area of sustainability include: Supervising compliance with the Company's environmental and social policies and rules, evaluating and reviewing them periodically so that they fulfil their mission of promoting social interest and take into account, as appropriate, the legitimate interests of the remaining stakeholders, as well as submitting the proposals it deems appropriate in this area to the Board. Submitting the Sustainability Principles to the Board for approval. Communicating, prior to their submission to the Board of Directors, the reports that the Company makes public in the area of sustainability, including the review of the non-financial information contained in its annual management report, as well as the publication Sustainability, socio-economic impact and contribution to the UN SDGs and the Sustainable Banking Plan, ensuring the integrity of their content and compliance with applicable legislation and international benchmarks. Overseeing the Company's actions in the realm of sustainability and submitting the Sustainability/Corporate Responsibility Policy to the Board for approval. [...] The Sustainability Committee is a delegated body of the Management Committee, to which it reports directly, which in turn reports, where appropriate, to the Appointments and Sustainability Committee, and the latter to the Board of Directors. In addition, for sustainability risk policies, the Sustainability Committee reports to the Global Risk Committee, which forwards these policies to the Risk Committee and the latter to the Board of Directors. This committee is chaired by the Sustainability Director, a member of the Management Committee, and is made up of executives from different areas of the Bank: Sustainability, Chief Executive Management, Corporate and Institutional Banking (CIB) and International Banking, Compliance and Control, General Risks Division, Communication and Institutional Relations, Finance, Accounting, Management Control and Capital, General Secretary's Office, Media, Head of Human Resources, Internal Audit, CaixaBank Asset Management, VidaCaixa and BPI. The Sustainability Committee meets on a monthly basis, and among its main duties in the area of sustainability and climate change, it is responsible for: Approving CaixaBank's sustainability strategy and practices and monitoring them, as well as proposing and submitting the general policies for sustainability management for approval by the corresponding governance bodies. Overseeing the Sustainability Master Plan (Sustainable Banking Plan), approved in December 2021 as a development of the Socially Responsible Banking Plan (2019-2021) and monitoring projects and initiatives for the deployment of the Master Plan. Promoting the integration of sustainability criteria in the Bank's business management. Understanding and analysing regulatory requirements, trends and best practices in the sustainability sector. Reviewing and approving the information to be issued regarding sustainability. Reporting to the Management Committee on the resolutions of the Sustainability Committee. Raising to the Global Risk Committee issues related to sustainability risk management policies, reporting and monitoring of assigned Risk Appetite Framework (RAF) metrics, and periodic reporting related to sustainability risks. Validating the reasonableness of non-financial ESG indicators.

CaixaBank has delegated the discretionary portfolio management service to CaixaBank AM. However, CaixaBank is ultimately responsible for the provision of this service and, as such, will monitor that the exercise of this function by the management company is in line with the provisions of this Engagement Policy. [...] The Private Banking Sustainability Division, responsible for the Policy, will review the validity of this document's content on an annual basis. [...] As a review procedure, the person responsible for the Policy will: - Share the result of the analysis with the rest of those involved and make the necessary modifications to the Policy. - Include a summary of the review in the 'Version control' section of the Policy. - Present the Policy to the Management Committee and the Board of Directors for approval. [...] The Board of Directors will approve the Engagement Policy, on the recommendation of the Private Banking Sustainability Division.

The **Board of Directors is responsible for approving, supervising and periodically assessing the** definition, development and implementation of the sustainability strategy, which, in turn, includes the nature strategy. It is also responsible for approving, supervising and monitoring the effectiveness of this Statement and the commitments included herein.

In addition, the **Appointments and Sustainability Committee's functions include following** supervising compliance with CaixaBank's environmental and social policies and rules, assessing and revising them periodically, as well as supervising that CaixaBank's practices in these matters are in line with its strategy and policies. The Risks Committee also proposes the Group's risks policy to the Board.

The **Management Committee is responsible for developing the Entity's Strategic Plan approved** by the Board of Directors and, to this end, adopts resolutions, either directly or through its delegate committees, in relation to sustainability matters.

Moreover, several internal committees are responsible for the coordination and supervision of different aspects set out in this Statement, including the Sustainability Committee, the Global **Risk Committee and the Regulation Committee.**

Finally, the Sustainability Department coordinates defining, updating and monitoring the Group's sustainability strategy, which also includes nature-related issues. In this regard, it works across disciplines with other departments and companies in the group to advance in the implementation of the lines of work included in this Statement.

This Statement will be revised and updated at least every two years.

**Statement reviewed and approved by the Board of Directors on the 1[st] of February 2024.**

#### (4.11) In the reporting year, did your organization engage in activities that could directly or indirectly influence policy, law, or regulation that may (positively or negatively) impact the environment?

(4.11.1) External engagement activities that could directly or indirectly influence policy, law, or regulation that may impact the environment

_Select all that apply_
##### ☑ Yes, we engaged indirectly through, and/or provided financial or in-kind support to a trade association or other intermediary organization or individual
###### whose activities could influence policy, law, or regulation

#### (4.11.2) Indicate whether your organization has a public commitment or position statement to conduct your engagement activities in line with global environmental treaties or policy goals

_Select from:_
##### ☑ Yes, we have a public commitment or position statement in line with global environmental treaties or policy goals

--NEW-PAGE--

#### (4.11.3) Global environmental treaties or policy goals in line with public commitment or position statement

_Select all that apply_
##### ☑ Paris Agreement

#### (4.11.4) Attach commitment or position statement

_Consolidated Management Report 2023_CaixaBank.pdf_

#### (4.11.5) Indicate whether your organization is registered on a transparency register

_Select from:_
##### ☑ Yes

#### (4.11.6) Types of transparency register your organization is registered on

_Select all that apply_
##### ☑ Voluntary government register

#### (4.11.7) Disclose the transparency registers on which your organization is registered & the relevant ID numbers for your organization

_EU Transparency Register: 055017716307-39_

#### (4.11.8) Describe the process your organization has in place to ensure that your external engagement activities are consistent with your environmental commitments and/or transition plan

_All the agreements and positions agreed upon with the associations are discussed and validated internally, first with the areas in charge of the topics and later in_
_working groups and high-level committees. The Regulation Committee is responsible for monitoring the regulatory environment and setting positions on_
_developments that are relevant to the bank and the financial system. Based on an internal analysis, it identifies potential legislative proposals to ensure they are_
_consistent with the company's vision._

_[Fixed row]_

--NEW-PAGE--

#### (4.11.2) Provide details of your indirect engagement on policy, law, or regulation that may (positively or negatively) impact the environment through trade associations or other intermediary organizations or individuals in the reporting year.

Row 1

#### (4.11.2.1) Type of indirect engagement

_Select from:_
##### ☑ Indirect engagement via other intermediary organization or individual

#### (4.11.2.2) Type of organization or individual

_Select from:_
##### ☑ Other, please specify :WSBI: International banking association and ESBG: European Banking association

#### (4.11.2.3) State the organization or position of individual

_World Savings and Retail Banking Institute (WSBI) and European Savings and Retail Banking Group (ESBG)_

#### (4.11.2.5) Environmental issues relevant to the policies, laws, or regulations on which the organization or individual has taken a position

_Select all that apply_
##### ☑ Climate change

#### (4.11.2.6) Indicate whether your organization's position is consistent with the organization or individual you engage with

_Select from:_
##### ☑ Consistent

#### (4.11.2.7) Indicate whether your organization attempted to influence the organization or individual's position in the reporting year

--NEW-PAGE--

_Select from:_
##### ☑ Yes, we publicly promoted their current position

#### (4.11.2.8) Describe how your organization's position is consistent with or differs from the organization or individual's position, and any actions taken to influence their position

_Founded in 1924, WSBI focuses on issues of global importance affecting the banking industry. It supports the aims of the G20 in achieving sustainable, inclusive and_
_balanced growth and job creation around the world, whether in industrialised or less developed countries. WSBI represents the interests of its members towards_
_international policy makers and standard setters on the main regulatory and other issues that shape international retail bank ing policy. They also promote a vision for_
_a pluralistic banking model and an enabling environment for financial inclusion. WSBI has the additional role of bringing together members to exchange knowledge_
_through meetings at international level as well as technology platforms. WSBI-ESBG has been a signatory of the United Nations Global Compact since 2006, whose_
_10 Principles provide a complete description of the commitments to follow in the area of social and environmental responsibility. Based on this, WSBI-ESBG pays_
_deep consideration to the new set of 17 measurable Sustainable Development Goals (SDGs), formally accepted by the UN General Assembly in 2015, and which_
_range from ending world poverty to fighting climate change and further developments by 2030. WSBI-ESBG member banks recognise that the environmental_
_challenge and climate change are some of the main collective hazards ever experienced worldwide. As part of their strong commitment to corporate social_
_responsibility (CSR) and sustainable development, WSBI-ESBG and its members contribute to the mitigation of climate change and therefore they: -Acknowledge the_
_risks and opportunities caused by environmental issues and try to adapt their business accordingly. -Work towards mitigating the impact of their business on the_
_environment, both directly in terms of own operations and indirectly in terms of customers and suppliers. -Promote projects in energy efficiency, green transport and_
_energy, mainly via the loan business. - Promote products and services that respect social, environmental and sustainable development criteria. CaixaBank (CB)_
_aligns with WSBI-ESBG's climate change vision and participates in working groups with them. This association, in turn, participates and influence policy makers in the_
_development of policies in this sense._

#### (4.11.2.9) Funding figure your organization provided to this organization or individual in the reporting year (currency)

_125000_

#### (4.11.2.10) Describe the aim of this funding and how it could influence policy, law or regulation that may impact the environment

_Our bank is socially and environmentally committed to the surroundings in which we operate. We channel our efforts to improve financial well-being and sustainable_
_economic growth by contributing to the strengthening of society as a whole. Throughout our history, CaixaBank has made significant commitments, collaborating with_
_many associations, task forces and forums to develop and disseminate good practices, principles and values, seeking to foster progress in various fields. To advance_
_our commitment to sustainability and to be part of best practices, we take part in many initiatives related to ESG (Environmental, Social and Governance). W SBI-_
_ESBG is the European association we are involved for those purposes._

--NEW-PAGE--

#### (4.11.2.11) Indicate if you have evaluated whether your organization's engagement is aligned with global environmental treaties or policy goals

_Select from:_
##### ☑ Yes, we have evaluated, and it is aligned

#### (4.11.2.12) Global environmental treaties or policy goals aligned with your organization's engagement on policy, law or regulation

_Select all that apply_
##### ☑ Paris Agreement

#### Row 2

#### (4.11.2.1) Type of indirect engagement

_Select from:_
##### ☑ Indirect engagement via other intermediary organization or individual

#### (4.11.2.2) Type of organization or individual

_Select from:_
##### ☑ Other, please specify :confederation and banking association

#### (4.11.2.3) State the organization or position of individual

_CECA_

#### (4.11.2.5) Environmental issues relevant to the policies, laws, or regulations on which the organization or individual has taken a position

_Select all that apply_
##### ☑ Climate change

--NEW-PAGE--

#### (4.11.2.6) Indicate whether your organization's position is consistent with the organization or individual you engage with

_Select from:_
##### ☑ Consistent

#### (4.11.2.7) Indicate whether your organization attempted to influence the organization or individual's position in the reporting year

_Select from:_
##### ☑ Yes, we publicly promoted their current position

#### (4.11.2.8) Describe how your organization's position is consistent with or differs from the organization or individual's position, and any actions taken to influence their position

_CECA is a banking association committed to promoting, defending, and representing its associated companies' interests, giving them advice, and cementing their_
_social mission. Represented in CECA are savings banks, banking foundations and credit institutions that can integrate, and maintain the functions and aims that it_
_holds in accordance with the aforementioned regime, and others who are determining their statutes. The credit institutions as sociated with CECA are characterised by_
_the so-called 3Rs, which identify all members of the WSBI (The World Savings and Retail Banking Institute): Retail: Focused on the financing of families and SMEs;_
_Responsible: Identified with the Social Projects and Corporate Social Responsibility; Rooted: Rooted in the community: Bound and committed to the areas in which_
_they act. Finresp, the Financial Center for Sustainability in Spain, is an initiative of AEB, CECA, Inverco, Unacc and Unespa to meet the needs of the Spanish_
_productive fabric, particularly SMEs, in their adaptation to the principles and standards of sustainability developed by the UN. Finresp presented its commitments to_
_the environment and responsible finances within the framework of the Climate Summit COP25 In Madrid in 2019. In this sense, t he CEO of CECA stated that "the role_
_that the financial sector will play as a catalyst for a new production model based on a decarbonised economy is key. The European authorities they must facilitate this_
_work in the design of the new Green Pact ". CaixaBank aligns with CECA's climate change vision and participates in working groups with them. This association, in_
_turn, participates and influence policy makers in the development of policies in this sense. In 2019, CaixaBank joined the UN Collective Commitment to Climate_
_Action, which reflects the desire of the Bank to align its portfolio with the goals of the Paris Agreement, generate a positive impact and set targets. Additionally,_
_CaixaBank signed on to the Commitment to the Climate that CECA and the AEB have been promoting for the Spanish banking sector._

#### (4.11.2.9) Funding figure your organization provided to this organization or individual in the reporting year (currency)

_1900000_

#### (4.11.2.10) Describe the aim of this funding and how it could influence policy, law or regulation that may impact the environment

--NEW-PAGE--

_Our bank is socially and environmentally committed to the surroundings in which we operate. We channel our efforts to improve financial well-being and sustainable_
_economic growth by contributing to the strengthening of society as a whole. Throughout our history, CaixaBank has made significant commitments, collaborating with_
_many associations, task forces and forums to develop and disseminate good practices, principles and values, seeking to foster progress in various fields. To advance_
_our commitment to sustainability and to be part of best practices, we take part in many initiatives related to ESG (Environmental, Social and Governance). WSBI-_
_ESBG is the European association we are involved for those purposes._

#### (4.11.2.11) Indicate if you have evaluated whether your organization's engagement is aligned with global environmental treaties or policy goals

_Select from:_
##### ☑ Yes, we have evaluated, and it is aligned

#### (4.11.2.12) Global environmental treaties or policy goals aligned with your organization's engagement on policy, law or regulation

_Select all that apply_
##### ☑ Paris Agreement

_[Add row]_

###### Environmental Risk Management Policy\n\n##### Governance\n# 03\n\n--NEW-PAGE--\n\n###### Recording transactions\n\nAdditionally, when originating new transactions for the sectors covered by this policy, CaixaBank's Business area shall check to see whether any exclusion criteria apply. In\ndoing so, it will rely on available public information and on the information provided\nby the customer and during the due diligence process (where such a process must\nbe performed due to the nature of the transaction).\n\nIf in doubt as to whether the aforementioned exclusion perimeter applies, the environmental risk experts attached to the Bank's Business units shall conduct a preliminary verification and diagnosis. If still in doubt, the query must be escalated to the\nTransaction Analysis and Appraisal Unit defined in this policy, which will issue a report\non the level of environmental risk, including a recommendation on the desirability of\nrecording the transaction. The final decision will be down to the Environmental Risk\nManagement Committee defined in this policy.\n\n###### Transaction Appraisal Unit\n\nThis unit specialises in environmental risk and supports the Bank in daily decision-making processes in connection with ordinary risk acceptance activities. It reports to the\nEnvironmental Risk Management Committee.\n\nThe unit comprises environmental risk experts acting on behalf of the Business, Risks\nand Corporate Responsibility areas.\n\nThe unit's main function is to run analyses and issue reports or explanations with\nrespect to potential levels of environmental risk whenever required of it and especially when granting new loans in relation to the activities and sectors covered by this\npolicy. Any decision by the Environmental Risk Management Committee to approve\nan exception to the general and industry-specific exclusions will require a preliminary\nreport from this unit supporting that exception.\n\n###### Environmental Risk Management Committee\n\nBroadly speaking, the Environmental Risk Management Committee (which reports\nto the Management Committee) is the most senior specialised executive body at\nCaixaBank when it comes to environmental risk management. It is therefore responsible for analysing and, where necessary, approving the proposals received from the\ndifferent functional areas concerning the Bank's strategy and approach, while also\nidentifying, managing and controlling the associated risks as a first line of defence.\n\nAll environmental risk management initiatives are supervised by this committee. It\nmay also seek, at any time, the advice of the environmental risk experts attached to\nthe Bank's various business areas involved in environmental risk acceptance, management, monitoring or control activities. The committee may also authorise exceptions to the general and industry-specific exclusions set out in this policy, although\nany such decision may need to be reported to the bodies responsible for approving\nthe new lending transaction or project.\n\nThe committee shall regularly report to the Bank's Global Risks Committee.

CaixaBank has a rigorous process for assessing any proposal to join an association or commercial chamber. This process includes an internal reputational risk check to ensure that the association in question is recognised and has a proven reputation and conduct. In this way, CaixaBank ensures that its membership in any association is aligned with its values and objectives, also in terms of sustainability.

CaixaBank has a robust internal governance process to ensure that the positions and communications that reach associations and authorities are consistent with the bank's strategy. Where applicable, these positions can also be found publicly posted on the European Commission's website.

Under no circumstances do we contract services directly from lobbyists to define our position with government agencies. We generally share opinions through different industry associations to try to reach a common position, and we occasionally also directly send out our own messages. [...] At CaixaBank, we assess the alignment of the position of organisations with which we collaborate, as well as that of our advocacy activities, with objectives of the Paris Agreement and other core values of CaixaBank. In the event of misalignment, mitigating measures are defined and implemented. [...] The CaixaBank Regulation Committee is a body dependent on the Management Committee and is responsible for monitoring the regulatory environment and setting positions on developments of public policies that are relevant to the entity and the financial system. In order to exercise its functions, the Regulatory Committee relies on the Public Affairs Directorate its preparation and coordination, based on technical analysis and assessment by experts within the Group. The Chief Compliance, Control and Public Affairs Officer (member of the Management Committee) and the Director of Public Affairs are the representatives before the administrative, management and control bodies for the internal supervision of CaixaBank's public policy activities.

CaixaBank's participation and interaction in meetings with the heads of authorities and supervisors are shared with the members of the Regulatory Committee on a monthly basis. CaixaBank's positions presented and/or distributed in these meetings are also reported.

In 2023, an internal audit was carried out on the Regulatory Committee, which determined that it fulfils the functions defined in the Committee Governance Standard by monitoring, coordinating and determining the CaixaBank Group strategy in the national, European and international debate.

The CaixaBank Appointments and Sustainability Committee is responsible, among other duties, for supervising the performance in relation to environmental, social and governance initiatives, which include those relating to Human Rights, and for submitting any proposals it deems appropriate on this matter to the Board. [...] The Sustainability Committee, which is accountable to the Management Committee, is responsible for approving the strategies and practices in Human Rights at CaixaBank, as well as promoting and, where appropriate, approving initiatives in this area, coordinating and managing the approved initiatives and their monitoring, as well as proposing and submitting them to the governance bodies for approval. [...] The Sustainability Division is responsible for encouraging the fulfilment of the Principles and promoting initiatives in order to move forward in respecting, defending and promoting human rights and executing the Sustainability Master Plan, as well as managing the initiatives in this area approved by the governance bodies, monitoring the initiatives implemented in the CaixaBank Group and carrying out regular internal and external reporting. In particular, the review of the Sustainability Principles falls on the Sustainability Strategy and Monitoring Divisions and the process for Due Diligence and Assessment of Human Rights falls on the Sustainability Risks Division.

CaixaBank does not engage direct lobbying or interest representation services to influence public authorities. Instead, in general, it shares its views through various associations to try to come to an understanding on the industry's position, although in some specific cases it may communicate directly with regulators and public authorities. The **CaixaBank Regulation Committee is the body res-** ponsible for monitoring the regulatory environment and setting positions on developments of public policies that are relevant to the bank and the financial system. The Committee uses internal studies of proposed regulatory changes to identify potential unwanted effects or impacts that could be disproportionate in relation to the desired aim of the legislation. After analysing the proposals, the Committee decides on the regulatory strategy that will be channelled through associations or communicated directly to the authorities. Relationships with political parties and public authorities are subject to CaixaBank's Code of Ethics and Action Principles and its Anti-Corruption Policy. These documents inform all of CaixaBank's interactions in regulatory processes. CaixaBank's Code of Ethics and Anti-Corruption Policy are intended to ensure not only compliance with applicable legislation, but also to underscore its firm commitment to its ethical principles as signatories to the United Nations Global Compact. and our determination to combat corruption in all its forms. Section 6 of the CaixaBank Anti-Corruption Policy prohibits donations to political parties and their associated foundations. CaixaBank has controls in place to ensure that donations are not made to political parties."
"CaixaBank shall not contract direct lobbying or interest representation services to position itself with authorities but rather it will generally share its opinions through various associations to try to come to an understanding on the industry's position. [...] In March 2022, the Board of Directors approved the Corporate Policy on Sustainability/ESG Risk Management, which consolidates the previous Environmental Risk Management Policy and Corporate Policy on Relations with the Defence Sector and establishes the criteria for ESG analysis in the processes of customer admission and credit approval processes."
"At CaixaBank, the definition, follow-up and monitoring of compliance with the Principles for Responsible Banking corresponds to the Board of Directors and Delegated Committees appointed by the company. More specifically, the **Sustainability Committee, a top-level** committee with the participation of the key areas and subsidiaries in sustainability matters, which reports to the Management Committee, the Global Risk Committee, the Appointments **and Sustainability Committee, and the Board of Directors. This committee meets at** least monthly and is chaired by a member of the Management Committee, the Sustainability Director. The Management Committee is also informed on a monthly basis of the matters dealt with in the Sustainability Committee. [...] Furthermore, the **Risk Committee of the Board of Directors is responsible, among other** functions, for proposing the Group's risk policy to the Board and examining the Group's risk information and control processes. This Committee periodically reviews issues related to the management of sustainability and climate-related risks. [...] Members of Committees may request the establishment of new actions in the event that the objectives are not achieved or new areas of priority attention are identified.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]All the agreements and positions agreed upon with the associations are discussed and validated internally, first with the areas in charge of the topics and later in working groups and high-level committees.

The Regulation Committee is responsible for monitoring the regulatory environment and setting positions on developments that are relevant to the bank and the financial system. Based on an internal analysis, it identifies potential legislative proposals to ensure they are consistent with the company's vision.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes