Integration of Sustainability Risks

(In accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 and Delegated Regulation (EU) 2022/1288, as amended)

Article 3
Transparency of policies on sustainability risks

The BCP Group is committed to promoting a culture of environmental, social, and financial responsibility, namely combating climate change and social inequalities, alongside strategic objectives of digital and technological innovation.

Sustainability and ESG (Environmental, Social, and Governance) factors are increasingly relevant topics for our clients, our business, and society. The sustainability of the planet is one of the great challenges of today, and urgent action is not only necessary but imperative to combat climate change and social inequalities.

The European and international commitments undertaken, particularly the Paris Agreement and the 2030 Agenda for Sustainable Development adopted by the United Nations (UN), imply a transition to a sustainable economic development model, where the involvement and alignment of the financial sector are decisive. This transition is also promoted by the European Commission's Action Plan for Sustainable Finance, which defines the European strategy for the financial sector.

We believe that, for the transition to a more sustainable world, we - citizens, companies, and institutions - have the responsibility to promote changes in our individual and collective behaviors, in order to implement economic and social development models that foster prosperity, job creation, the valuing of people, and respect for biodiversity.

Our ambition is to be an active protagonist of the intended change, and in this sense, we commit to integrating ESG aspects into our operations, our products and services, and our supply chain, positively influencing the long-term value of the organization, contributing to the well-being of people, communities, and the preservation of natural resources and the environment.

The BCP Group has the following main corporate policies and principles:

• Sustainability Policy;
• Responsible Financing Principles;
• Responsible Investment Principles;
• Environmental Policy;
• Anti-Corruption and Anti-Bribery Policy;
• Social Impact Policy;
• Human Rights Policy;
• Diversity and Equal Opportunities Policy;
• Tax Principles;
• Guiding Principles of Sustainability for Suppliers;
• Responsible Purchasing Policy.

Article 4
Transparency of adverse sustainability impacts at entity level

The BCP Group monitors and guides its actions by legal and regulatory initiatives related to climate change as a systemic risk to the financial system, highlighting:

• The Paris Agreement;
• The 2030 Agenda for Sustainable Development adopted by the UN;
• The UN Global Compact Principles;
• The UN Principles for Responsible Banking;
• EU Directive 2022/2464 on Corporate Sustainability Reporting (CSRD);
• Alignment with the ESRS (European Sustainability Reporting Standards);
• The Commitment Letter for Sustainable Finance promoted by the Portuguese government.

Additionally, the BCP Group monitors the evolution of the European regulatory framework on sustainability, including Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR), Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (European Taxonomy), and Directive (EU) 2022/2464 on corporate sustainability reporting (CSRD), as well as the respective European Sustainability Reporting Standards (ESRS).

The BCP Group identifies risks related to climate change to ensure business continuity in the event of natural disasters that cause business interruption. We seek to understand the positioning of our portfolio to promote and assess its resilience in the transition to carbon neutrality. Over the years, we have financed ecological and energy-efficient projects, including projects related to replacing coal-fired energy with low-emission energy sources and modern energy infrastructures, reducing pollutant emissions and energy efficiency, particularly in energy-intensive and high-emission industries, and, among others, low-emission mobility.

The BCP Group integrates environmental and social risks into its risk analysis processes, incorporating policies, standards, and procedures for their management. Environmental risk analysis is an integral part of client assessment, credit granting, project finance, and discretionary portfolio management processes.

We recognize the existence of sectors of activity or projects that do not meet the commitment undertaken by the BCP Group in preserving the environment and biodiversity, promoting sustainable development, and combating climate change; we consider sectoral financing and investment principles for industries with high exposure to environmental or reputational risks in our decisions, and we do not finance activities or projects related to:

• production or trade of products or activities considered illegal;
• coal: extraction and energy production;
• weaponry;
• prostitution, pornography, and related activities;
• unlicensed trade and sale of endangered species or wild animals.

The BCP Group is evaluated by the most relevant ESG indices and analysts, including MSCI, Sustainalytics, CDP - Carbon Disclosure Project, EthiFinance, among others.

These sustainability indices are a relevant tool for evaluating and communicating our performance in the economic, environmental, and social areas, and also a way to identify and promote improvements.

Statement on the principal adverse impacts of investment advisory services on sustainability factors

The consideration of principal adverse impacts is carried out in accordance with the legal obligations applicable to each entity of the Group and the nature of their respective products and services.

• Advisory service and non-recurrent investment advisory service (Millenniumbcp)
• No consideration of adverse impacts of investment decisions on sustainability factors (Interfundos)

Article 5
Transparency of remuneration policies with regard to the integration of sustainability risks

The remuneration policy of BCP and Subsidiaries in Portugal (1) is reviewed annually by the competent bodies and aims to inform Employees and members of the management and supervisory bodies about the rules and principles underlying the applicable remuneration management.

To this end, it integrates a set of good governance rules, in the sense that it includes provisions designed to ensure an alignment of its executives and other employees with sound and prudent management of the Institution that considers the interests of all its stakeholders, not promoting an incentive to assume risks at levels higher than those defined, avoiding the creation or contribution to the creation of conflict of interest situations, and through these rules and alignment, contributing to the sustainability of the Institution.

Among these rules, the following stand out:

• The principle that the remuneration policy is intended to promote behaviors that ensure the generation of long-term value and the sustainability of results over time. In this sense, the variable remuneration of both Employees and members of the Executive Committee takes into account not only the achievement of objectives but also how they are achieved, thus not promoting commercial practices misaligned with the interests of the respective Clients. Factors such as Client satisfaction and strict compliance with internal and external regulations are also considered.
• Employees and members of the Executive Committee with control functions are evaluated by the degree of execution of their control responsibilities, in order to ensure their independence from the Institution's business objectives, thus promoting the sustainability of results.
• The fixed components of remuneration constitute the predominant part of the general remuneration conditions, with the variable component generally being more conservative, mitigating its potential for generating risks.
• Employee remuneration is defined according to their function, professional background, and degree of achievement of established objectives. The variable remuneration or incentive system is thus based on individual performance evaluation, which includes a behavioral component and an objective achievement component, alongside each Employee's remuneration position relative to the Reference Remuneration for their function.
• The remuneration policy is thus structured taking into account the context of BCP's and the Subsidiary's situation and results and includes a fixed remuneration based on the function performed by each Employee and the inherent level of responsibility, as well as their career, constituting a significant part of their total compensation and, when so decided, a variable remuneration or incentives linked to the achievement of pre-established objectives and prudent risk management, which may not be awarded in exceptional cases, namely if its award limits the ability of BCP and the Subsidiary to strengthen their own funds base, and in any case, all types of current and future risks will always be taken into consideration in its granting.
• If variable remuneration is awarded, it is subject to limits defined as a percentage of fixed remuneration, and for Employees with Key Functions and members of the Executive Committee, it is composed of cash and BCP shares (or other financial instrument defined in the Subsidiary's Remuneration Policy, where applicable), with payment deferred for a period of 5 years. In addition to deferral, the remuneration policy provides for rules for retaining BCP shares or other instruments for a minimum period of one year after their availability.
• These mechanisms aim to ensure that the incentives for the individual performance of these Employees are aligned with the long-term and sustainability objectives of the Bank and the Subsidiary, adapted to their risk profile.
• The remuneration policy also provides for rules for the reduction and clawback of variable remuneration, to be applied in situations duly justified by their severity, as well as rules for the suspension or non-award of variable remuneration in situations of significant deterioration of BCP's and the Subsidiary's profitability conditions.
• The Remuneration Policies for Employees and members of the Executive Committee, for the purpose of awarding variable remuneration, include a KPI (Key Performance Indicator) related to the level of execution of the Bank's sustainability master plan.

(1) Banco ActivoBank, SA e Interfundos - Sociedade Gestora de Organismos de Investimento Coletivo, SA

Article 6
Transparency with regard to the integration of sustainability risks

Portfolio Management and Investment Advisory services provided by Millenniumbcp include descriptions of the following elements in their pre-contractual information:

• how sustainability risks are integrated into product selection and portfolio construction processes; and
• exclusion criteria and detailed analysis of products where identified sustainability risks may jeopardize their return.

Interfundos - Sociedade Gestora de Organismos de Investimento Coletivo, S.A. (Interfundos) manages and administers only real estate investment undertakings. Interfundos recognizes the importance of the transition to a more sustainable, efficient, and circular economy, which is why it considers, in the decision-making process, to the extent feasible and possible, sustainability risks, which are defined as an "environmental, social or governance event or condition that, if it occurs, could cause a material negative impact on the value of the investment." The decision-making process in this context is guided by the following general principles:

• Proportionality: sustainability risks are, like others, weighed according to the nature, scale, and complexity of the activity and the size of the organization; and
• Adaptability: the emerging requirements for considering environmental, social, and governance factors are adapted to the real estate investment undertakings under management.

Article 8
Transparency of the promotion of environmental or social characteristics in pre-contractual disclosures

BCP provides portfolio management services that promote environmental and social characteristics, contributing to a more sustainable investment approach and the adequate integration of ESG factors into decision-making processes. To this end, the Bank considers environmental, social, and governance factors in the selection and monitoring of investments, using exclusion criteria, sustainability risk analysis, and the assessment of the ESG characteristics of eligible investment products. The promotion of these characteristics is carried out in accordance with applicable legal and regulatory requirements, with the respective information, methodologies, and limitations described in pre-contractual documentation and periodic disclosures.

(V.4 - Information updated as of 31-08-2026)