Oversea-Chinese Banking Corp Ltd

Finalising our targets. This was a collective decision-making process involving all relevant internal stakeholders including our business and risk management teams. The targets were endorsed at the highest levels, by OCBC's senior management team and the Board Sustainability Committee. [...] Holding ourselves to account. To track our progress against the 2050 and the interim 2030 targets, we will measure and update our financed emissions in the six priority sectors annually, and compare them against prior years and our targets. We will disclose our progress transparently in our Sustainability Report. We will closely monitor trends and developments in the six sectors, as well as revised sectoral reference pathways that may be released from time to time. We do not intend to update our targets as and when new reference pathways are released, in order to preserve consistency in our internal goal setting and client engagements. Nevertheless, we will review, and update if necessary, our targets at least once every 5 years.

##### Our Sustainability Governance Structure

To embed responsible and sustainable practices into our business, a robust governance structure is important. The Board has ultimate responsibility for overseeing all aspects of sustainability at OCBC. It is supported by the Sustainability Council and the Sustainability Committees.

###### Board The Board has ultimate responsibility for and oversight of sustainability at OCBC.
As part of its responsibility, the Board takes our material ESG factors into account
when setting the strategic direction of the company.

###### Sustainability Council The Sustainability Council is responsible for the identification, management and
monitoring of the material ESG factors set out in our Sustainability Framework.
It is chaired by the Group Chief Executive Officer and comprises other Senior
Management Team members.

###### Sustainability Committees The Sustainability Committees comprise the Sustainability Taskforce and the
Sustainability Working Group. They are responsible for driving sustainability
strategy and transformation, as well as implementing initiatives, engaging internal
and external stakeholders on sustainability matters, and driving performance
against our material ESG factors through the setting and measurement of
KPIs and targets. Its members include representatives from across all our main
business units.

OCBC's project selection involves a two-step process, with initial screening by the relevant business units and final validation by the Sustainability Council, which consists of members of the Management Committee. OCBC has outlined a comprehensive list of exclusions which serve to mitigate environmental or social risk associated with the eligibility criteria. This is in line with market practice. [...] OCBC has committed to tracking the proceeds using its established internal information system, and to using a register to track the allocation of funds to eligible projects. Unallocated proceeds may be temporarily invested in marketable instruments. This is in line with market practice. [...] OCBC intends to report on an annual basis, providing allocation and impact information at the category level. In Sustainalytics' view, reporting on these metrics is in line with market practice.

Our Sustainability Governance Structure [...] With sustainability as a strategic priority, we established the Board Sustainability Committee to provide oversight and direction on sustainability imperatives. We also appointed our first Group Chief Sustainability Officer (GCSO) to actively lead our sustainability strategy, ensure synergy across the Group and guide our efforts in supporting our clients' transition to net zero. [...] Board Sustainability Committee [...] Chaired by an independent director, the BSC meets at least twice a year to provide strategic direction on sustainability issues, with a focus on climate and environmental matters. It approves and oversees the management and monitoring of ESG factors that are material to the business and considers the Bank's position on relevant emerging sustainability trends and issues. It also has oversight of the Bank's sustainability reporting including climate-related disclosures. [...] The BSC oversees the Bank's net-zero strategy including the relevant targets. Further, the BSC reviews the sector-specific decarbonisation strategies for six priority sectors to support our clients in the transition to a low-carbon economy. [...] Sustainability Council [...] The Sustainability Council (SC) is a management committee established to support the Board of Directors and the BSC in executing the sustainability strategy for the Bank. Chaired by the Group Chief Executive Officer, the SC comprises members of senior management, and is supported by the Sustainability Steering Committee (SSC). The SC oversees the Group's sustainability strategy and its implementation, including identifying and assessing sustainability-related risks and opportunities with a focus on climate and environmental matters. In addition, the SC ensures that the Group's material sustainability risks and opportunities are monitored through metrics on an ongoing basis and are effectively managed. The SC also provides strategic direction for the SSC. To ensure effective oversight of the Bank's sustainability progress and climate-related matters, the SC meets at least three times a year. [...] Sustainability Steering Committee [...] The SSC is a management committee newly established in 2023 to support the SC in the alignment, execution and reporting of key sustainability-related outcomes and initiatives for the Group. Chaired by the GCSO, the SSC comprises key leaders from the Group's business units and key subsidiaries in driving sustainability-related initiatives across the Group. The SSC is responsible for the recommendation and implementation of Group's sustainability strategy, informing the SC of the Group's sustainability progress and advising the SC on sustainability-related matters. As the SSC comprises representatives from various business units across the Group, they are able to identify climate-related risks and opportunities that have the potential to impact the environment, society and the economy positively and negatively. The wide representation ensures that climate change-related issues are integrated into our decision-making process, escalated and addressed at the highest levels.

### Our Sustainability Governance Structure

###### Strong corporate governance and risk management are the foundation of a sustainable business and are vital for long-term success. At OCBC, we are committed to upholding business integrity by integrating sustainability across the Board, Board Committees, Management and functional groups. This holistic approach enables us to pursue our sustainability ambitions through our Sustainability Framework.

At OCBC, we recognise that a strong governance structure is essential to achieving our sustainability goals. Our approach focuses on two key objectives: strengthening sustainability oversight at a strategic level and fostering cross-functional collaboration to achieve impactful sustainability outcomes. With sustainability firmly embedded as a strategic priority, the Board of Directors provides oversight and guidance on our sustainability imperatives. Our Group Chief Sustainability Officer (GCSO) remains pivotal in leading the execution of these imperatives, ensuring alignment across the Group and supporting our clients in their transition to net zero.

###### Board of Directors

- Provides oversight for the overall sustainability agenda and strategy at OCBC

###### Board Oversight

###### Board Sustainability Committee

- Supports the Board in its oversight of the Bank's sustainability matters in conjunction with other relevant Board Committees

- Provides strategic direction on sustainability issues, with a focus on climate and environmental matters

###### Sustainability Council

- Oversees the Group's Sustainability Strategy and provides approval for key strategic initiatives relating to sustainability, with a focus on climate and environmental matters

###### Management Oversight

###### Sustainability Steering Committee

- Supports the Sustainability Council in the alignment, execution and reporting of key sustainability-related outcomes and initiatives for the Group, across all entities

### Our Sustainability Governance Structure

###### Board

The Board takes ultimate responsibility for, and sets the strategic direction of, the organisation's sustainability efforts at OCBC. Recognising the critical importance of sustainability matters, the Board Sustainability Committee (BSC) is a dedicated committee tasked with overseeing sustainability issues alongside other Board Committees. This reflects the growing significance of sustainability considerations in shaping our strategy and operations.

The BSC, chaired by an independent director, convenes at least twice a year to provide strategic guidance on sustainability matters, placing particular emphasis on climate change-related and environmental issues. In its discussions, the BSC addresses key topics such as the Bank's progress towards net-zero targets, decarbonisation initiatives for its physical operations, sectoral sustainability trends including biodiversity, and alignment with sustainability and climate-related reporting standards and frameworks.

As part of its responsibilities, the BSC oversees the Bank's net-zero strategy and tracks progress against established targets. It also evaluates decarbonisation strategies for our six priority sectors to support clients in transitioning to a low-carbon economy. Furthermore, the committee approves and manages material ESG factors, ensuring responsiveness to emerging sustainability challenges. It also supervises the Bank's sustainability reporting, including climate-related disclosures, to uphold transparency and alignment with industry best practices.

The Board Risk Management Committee (BRMC) supports the Board in its oversight of the effective management of all risks facing the Bank, including ESG risks such as climate change. ESG risk management is detailed in our Responsible Financing Framework and Policies, which are regularly reviewed and approved by the BRMC.[(5)]

To ensure the Board stays abreast of current and emerging sustainability issues, including climate change, all members have received comprehensive sustainability training.[(6)] The Bank also continues to offer capacity-building and training on sustainability topics across all levels of the organisation, ensuring that sustainability-related competencies are embedded throughout our operations.

###### Management

Sustainability Council
The Sustainability Council (SC), a management committee formed to support both the Board of Directors and the BSC, plays a pivotal role in executing the Bank's Sustainability Strategy. Chaired by the Group Chief Executive Officer, the SC consists of senior management and is supported by the Sustainability Steering Committee (SSC). The SC is responsible for overseeing the Group's Sustainability Strategy and its implementation, which includes identifying and assessing sustainability-related risks and opportunities, with a focus on climate and environmental considerations. The SC also ensures that material sustainability risks and opportunities are monitored through appropriate metrics and effectively managed. Additionally, the SC meets at least three times a year to monitor and manage the Bank's sustainability performance and provide strategic direction for the SSC.

###### Sustainability Steering Committee
One year in from its formation, the SSC plays a crucial role in supporting the SC to align, execute and report on key sustainability outcomes and initiatives across the Group. Chaired by the GCSO, the SSC comprises key leaders from the Bank's business units and key subsidiaries, who help to drive sustainability initiatives across the Group.

The SSC is responsible for recommending and implementing the Group's Sustainability Strategy, updating the SC on the progress made and providing advice on sustainability-related matters. With representatives from various business units, the SSC identifies climate-related risks and opportunities, ensuring they are integrated into our decision-making processes and addressed at the highest levels of the organisation.

In 2024, our major overseas subsidiaries in Malaysia, Indonesia and Greater China established local sustainability steering committees to lead and execute sustainability efforts in their respective countries. Members of these local sustainability steering committees are represented in the SSC at the Group level, so that initiatives at the local country level are aligned with the imperatives at the Group level.

###### Management of Sustainability Key Performance Indicators

The performance scorecards of the Group CEO and key senior executives are tied to specific, time-bound sustainability targets including climate-related ones. These performance scorecards are key elements of performance management tied to the determination of incentive compensation for executives. From climate action, sustainable financing, talent management and wellbeing, workplace diversity to fair dealing, these targets cover material ESG themes across the Group, and are in turn cascaded down to the relevant business units and employee performance scorecards. We believe that the accountability and ownership that this approach fosters are critical to ensuring the success of our Sustainability Strategy and its implementation.

Our Sustainability Governance Structure\n\nGood corporate governance and risk management form the bedrock of a sustainable business and underpin long-term success. At OCBC, we are dedicated to upholding business integrity and we have embedded sustainability focus across the Board, Board Committees, Management and functional groups, enabling us to realise our sustainability ambitions through our Sustainability Framework.\n\nWe made significant progress in 2023 to enhance our sustainability governance structure. The objectives were two-fold: to strengthen oversight of sustainability matters at a strategic level; and to cultivate greater synergy and collaborations across functions to achieve targeted and impactful sustainability outcomes. With sustainability as a strategic priority, we established the Board Sustainability Committee to provide oversight and direction on sustainability imperatives. We also appointed our first Group Chief Sustainability Officer (GCSO) to actively lead our sustainability strategy, ensure synergy across the Group and guide our efforts in supporting our clients' transition to net zero.\n\nBoard Oversight\n\nBoard of Directors\n- Provides oversight for the overall sustainability agenda and strategy at OCBC\n\nBoard Sustainability Committee\n- Supports the Board in its oversight of the Bank's sustainability matters in conjunction with other relevant Board Committees\n- Provides strategic direction on sustainability issues, with a focus on climate and environmental matters\n\nManagement Oversight\n\nSustainability Council\n- Oversees the Group's Sustainability Strategy and provides approval for key strategic initiatives relating to sustainability, with a focus on climate and environmental matters\n\nSustainability Steering Committee\n- Supports the Sustainability Council in the alignment, execution and reporting of key sustainability-related outcomes and initiatives for the Group\n\nOur Sustainability Governance Structure\n\nBoard\n\nThe Board takes ultimate responsibility for and sets the organisation's strategic direction and execution for all aspects of sustainability at OCBC. In 2023, the Board Sustainability Committee (BSC) was established to support the Board in its oversight of the Bank's sustainability matters in conjunction with other relevant Board Committees. Chaired by an independent director, the BSC meets at least twice a year to provide strategic direction on sustainability issues, with a focus on climate and environmental matters. It approves and oversees the management and monitoring of ESG factors that are material to the business and considers the Bank's position on relevant emerging sustainability trends and issues. It also has oversight of the Bank's sustainability reporting including climate-related disclosures.\n\nThe BSC oversees the Bank's net-zero strategy including the relevant targets. Further, the BSC reviews the sector-specific decarbonisation strategies for six priority sectors to support our clients in the transition to a low-carbon economy.\n\nThe Board Risk Management Committee (BRMC) supports the Board in its oversight of the effective management of all the risks faced by the Bank, including ESG risks such as climate change. The management of ESG risks is described in our Responsible Financing Framework and Policies, which are reviewed and approved regularly by the BRMC.[(1)] The Board also oversees, through the Remuneration Committee, the human resource management policies and the policies governing the compensation of executive officers of the Bank and its subsidiaries, as well as the remuneration of senior executives and Directors. In its review, the Remuneration Committee may consider incorporating sustainability performance in the assessment of performance and compensation of senior executives.\n\nAll members of the Board have attended sustainability training[(2)] to ensure they have the relevant expertise to carry out their responsibilities and are keeping abreast of current and emerging sustainability issues such as climate and the environment. Beyond that, the Bank provides capacity building and training in sustainability-related topics across all levels of the organisation.\n\nManagement\n\nSustainability Council\nThe Sustainability Council (SC) is a management committee established to support the Board of Directors and the BSC in executing the sustainability strategy for the Bank. Chaired by the Group Chief Executive Officer, the SC comprises members of senior management, and is supported by the Sustainability Steering Committee (SSC). The SC oversees the Group's sustainability strategy and its implementation, including identifying and assessing sustainability-related risks and opportunities with a focus on climate and environmental matters. In addition, the SC ensures that the Group's material sustainability risks and opportunities are monitored through metrics on an ongoing basis and are effectively managed. The SC also provides strategic direction for the SSC. To ensure effective oversight of the Bank's sustainability progress and climate-related matters, the SC meets at least three times a year.\n\nSustainability Steering Committee\nThe SSC is a management committee newly established in 2023 to support the SC in the alignment, execution and reporting of key sustainability-related outcomes and initiatives for the Group. Chaired by the GCSO, the SSC comprises key leaders from the Group's business units and key subsidiaries in driving sustainability-related initiatives across the Group.\n\nThe SSC is responsible for the recommendation and implementation of Group's sustainability strategy, informing the SC of the Group's sustainability progress and advising the SC on sustainability-related matters. As the SSC comprises representatives from various business units across the Group, they are able to identify climate-related risks and opportunities that have the potential to impact the environment, society and the economy positively and negatively. The wide representation ensures that climate change-related issues are integrated into our decision-making process, escalated and addressed at the highest levels.\n\n(1) Please refer to our Annual Report for more details on the Board Risk Management Committee. For additional information on our ESG Risk Assessment Process, please refer to our Responsible Financing chapter.

The Board, through the Board Risk Management Committee, regularly reviews and approves the sustainability-related policies. Reinforcing the Board's commitment, a sustainability training programme was conducted in 2021 for members to keep abreast of the changing global landscape and sustainability trends. [...] The Board provides oversight for the overall sustainability agenda and strategy at OCBC and is supported by the Sustainability Council. The Board determines the material Environmental, Social and Governance (ESG) factors and considers sustainability issues as part of its strategy formulation. This includes providing oversight over the effective management of opportunities and risks associated with significant ESG issues such as climate change. The Board has ultimate responsibility for the Bank's Sustainability Report. [...] The Sustainability Council is chaired by the Group Chief Executive Officer and comprises members of senior management. Supported by the Sustainability Working Group and Climate Strategy Committee, the Council sets and drives the Group's sustainability strategy, assessing ESG and/or climate-related risks and opportunities to ensure its alignment, relevance and effectiveness in supporting the Bank's Corporate Strategy. It also ensures that the ESG factors are monitored on an ongoing basis and properly managed, and approves the Bank's Sustainability Report. [...] The Climate Strategy Committee drives our 5-year Climate Strategy which encompasses five workstreams, namely, business, people, policies and systems, operations, and innovation and technology. They implement initiatives guided by three priorities of moving towards net zero emissions in alignment with the Paris Agreement goals, expanding sustainable financing and product portfolios, and growing a bank-wide ecosystem of sustainable solutions and partnerships.

The Board provides strategic direction and specifically considers sustainability issues, with a focus on climate and environmental matters, in formulating strategy. Through the Board Risk Management Committee, the Board regularly reviews and approves the sustainability-related policies to ensure they are aligned with our ESG strategy and stakeholders' expectations. To step up our efforts in the oversight of the Bank's ESG issues, we established the Board Sustainability Committee on 7 February 2023. [...] The Board is also supported by the Board Risk Management Committee which has oversight of the effective management of all risks which face the business, including ESG risks such as climate change. The management of ESG risks is described in our Responsible Financing frameworks, which are reviewed and approved regularly by our Board Risk Management Committee. [...] To ensure the robustness and credibility of our ESG data, an internal review by Group Audit was performed and OCBC also sought external assurance on selected indicators that are material to our operations this year. [...] Our Responsible Financing Framework defines our approach and commitment to managing ESG risks in our lending activities. It sets out our ESG-related approach to lending, debt issuance and debt underwriting activities for new and existing corporate, commercial and institutional clients. [...] We have integrated climate risk management into our Responsible Financing Framework and Policies, recognising that environmental issues such as climate change could adversely affect our clients through climate-related transition and physical risks. [...] Our ESG risk assessment evaluates our clients' track record as well as their capability and commitments to manage ESG factors. It forms part of the credit and risk evaluation process conducted by relationship managers on applicable new loans and is reviewed annually. Transactions that carry high ESG risks are subjected to enhanced evaluation and approval requirements. In 2022, we conducted a pilot to review our ESG risk assessment process to incorporate climate-related considerations. [...] Transactions posing potentially significant reputational risk are required to be escalated to the Reputational Risk Review Group (RRRG) for additional review. [...] The Product Suitability Committee, Policy and Framework govern the approval of new investment products, ensuring that customers are only recommended products which are appropriate for them. Using OCBC's Product Suitability Risk Rating Methodology, the Product Suitability Committee is responsible for evaluating the soundness of investment products. [...] The Board Ethics and Conduct Committee is responsible for cultivating and maintaining these core values across the organisation, anchoring the way employees conduct themselves.

The Board of Directors directs the sustainability agenda at OCBC, including for climate-related issues, and ensures that OCBC's material Environment, Social and Governance (ESG) factors are considered when setting the strategic direction of the Bank. Within the Board, the Board Risk Management Committee has oversight of effective management of all risks, which includes ESG risks such as climate change. ESG risks are described in our Responsible Financing frameworks, which are reviewed and approved regularly by our Board Risk Management Committee. [...] At the executive level, the Sustainability Council, chaired by the Group Chief Executive Officer, drives OCBC's Sustainability Strategy, which encompasses various initiatives on the SDGs including SDG 13 on Climate Action. The Sustainability Council is supported by the Sustainability Taskforce and Working Group in operationalising sustainability strategies and efforts across the Group. [...] On the risk management front, Group Risk Management is responsible for establishing frameworks and policies for managing ESG risks. A Sustainability Stewardship Group, comprising a dedicated team of ESG specialists, independently reviews clients/transactions against the underlying ESG risks. [...] OCBC regularly reviews our governance structure with regard to ESG and climate-related risks to achieve long-term, sustainable growth.

The Board provides strategic direction and specifically considers sustainability issues, with a focus on climate and environmental matters, in formulating strategy. Through the Board Risk Management Committee, the Board regularly reviews and approves the sustainability-related policies to ensure they are aligned with our ESG strategy and stakeholders' expectations. To step up our efforts in the oversight of the Bank's ESG issues, we established the Board Sustainability Committee on 7 February 2023. [...] The Board is also supported by the Board Risk Management Committee which has oversight of the effective management of all risks which face the business, including ESG risks such as climate change. The management of ESG risks is described in our Responsible Financing frameworks, which are reviewed and approved regularly by our Board Risk Management Committee. [...] To ensure the robustness and credibility of our ESG data, an internal review by Group Audit was performed and OCBC also sought external assurance on selected indicators that are material to our operations this year. [...] Our Responsible Financing Framework defines our approach and commitment to managing ESG risks in our lending activities. It sets out our ESG-related approach to lending, debt issuance and debt underwriting activities for new and existing corporate, commercial and institutional clients. [...] We have integrated climate risk management into our Responsible Financing Framework and Policies, recognising that environmental issues such as climate change could adversely affect our clients through climate-related transition and physical risks. [...] Our ESG risk assessment evaluates our clients' track record as well as their capability and commitments to manage ESG factors. It forms part of the credit and risk evaluation process conducted by relationship managers on applicable new loans and is reviewed annually. Transactions that carry high ESG risks are subjected to enhanced evaluation and approval requirements. In 2022, we conducted a pilot to review our ESG risk assessment process to incorporate climate-related considerations. [...] Transactions posing potentially significant reputational risk are required to be escalated to the Reputational Risk Review Group (RRRG) for additional review. [...] The Product Suitability Committee, Policy and Framework govern the approval of new investment products, ensuring that customers are only recommended products which are appropriate for them. Using OCBC's Product Suitability Risk Rating Methodology, the Product Suitability Committee is responsible for evaluating the soundness of investment products. [...] The Board Ethics and Conduct Committee is responsible for cultivating and maintaining these core values across the organisation, anchoring the way employees conduct themselves. [...] The OCBC Group Policy on Anti-Bribery and Corruption (ABC) sets out the following commitment and responsibilities via the ABC compliance programme: Written policies and procedures; Risk identification and assessment; Training and communication; and Prior to any external engagement, we conduct thorough due diligence on our service providers and suppliers, and communicate our strong anti-bribery and corruption stance through OCBC's ABC Notification Guidance or Supplier Code of Conduct. [...] We conduct periodic reviews on our ABC compliance programme to ensure consistency with global best practices and standards. Any political contributions and offerings of any value, including gifts, entertainment, charitable contributions and sponsorships, are prohibited.

The Board of Directors directs the sustainability agenda at OCBC, including for climate-related issues, and ensures that OCBC's material Environment, Social and Governance (ESG) factors are considered when setting the strategic direction of the Bank. Within the Board, the Board Risk Management Committee has oversight of effective management of all risks, which includes ESG risks such as climate change. ESG risks are described in our Responsible Financing frameworks, which are reviewed and approved regularly by our Board Risk Management Committee. [...] At the executive level, the Sustainability Council, chaired by the Group Chief Executive Officer, drives OCBC's Sustainability Strategy, which encompasses various initiatives on the SDGs including SDG 13 on Climate Action. The Sustainability Council is supported by the Sustainability Taskforce and Working Group in operationalising sustainability strategies and efforts across the Group. [...] On the risk management front, Group Risk Management is responsible for establishing frameworks and policies for managing ESG risks. A Sustainability Stewardship Group, comprising a dedicated team of ESG specialists, independently reviews clients/transactions against the underlying ESG risks. [...] OCBC regularly reviews our governance structure with regard to ESG and climate-related risks to achieve long-term, sustainable growth.