About this report

Contents

About Rabobank

Who We Are

Rabobank is more than just a bank. We are a cooperative – that is what sets us apart from other banks. We are a bank without shareholders, but with members and client councils. More than 2.3 million of our customers are already members. Our local presence enables us to collaborate closely with our members and customers. They tell us what is going on and what people’s concerns are, helping us to understand what matters. By listening closely, we can identify the best ways to leverage our knowledge, global network and financial solutions to support their goals. Partly thanks to our members, we aim to contribute to a more sustainable food and energy system and financially healthy communities, to gradually build a better world.

As a meaningful cooperation, we invest part of our profit back into society through cooperative initiatives and our cooperative dividend.

What We Do

We now operate in 34 countries, with over 48,000 employees. In the Netherlands, we serve retail and corporate customers with a wide range of financial products and services. Globally, we focus on entrepreneurs and companies in the food and agriculture sectors. The Rabobank Group also includes BPD, Obvion and DLL, providing our customers with housing and leasing solutions.

Our Governance

Rabobank is a cooperative bank. It has a strong connection with society and organizes customer services as closely to its customers as possible. Customers of Rabobank in the Netherlands can become a member of Rabobank. Many of our customers become members because they feel involved in their local community. Alongside other Rabobank members and employees, they share their ideas and insights on the optimal ways to leverage Rabobank's expertise, networks, and financial solutions. By now, more than two million customers have become a member of Rabobank.

Member Involvement

Since Rabobank was founded in the Netherlands at the end of the 19th century, members form the foundation of Rabobank. Members play an important role in the bank’s governance and their input gives guidance to Rabobank’s development and social contribution. The members have a say in the governance of Rabobank and are represented in a staggered manner.

Foreword

At Termeulen Roses, I once again saw something I have often noticed among entrepreneurs: down-to-earth determination. Investing step by step, using energy efficiently, caring for people and product alike. These entrepreneurs made use of our SME sustainability contribution to make their operations more energy-efficient – precisely the kind of practical progress whose impact you can feel on the grounds, in the greenhouse, and in the surrounding community. As a cooperative bank, we can make this possible because part of our profit flows back into society – more than one billion euros since 2023 – and because our solid financial foundation enables us to genuinely strengthen customers and communities.

At the same time, our cooperative identity involves more than simply returning financial resources to society. What makes us unique is that our members are also our customers and therefore our primary stakeholders. This means that in everything we do, we strive to act in their long-term interest.

Through our products and services, we aim to empower our customers, help them look ahead, and contribute to solutions for the social challenges of today and tomorrow. It is precisely this long-term perspective and intrinsic drive to create value for people, businesses, and communities that has formed the core of Rabobank for more than a century.

Resilience and progress

We are proud to present our Annual Report for 2025, a year in which Rabobank once again achieved strong results. On February 10 of this year, we announced our figures: a net profit of nearly five billion euros. In a world that is becoming increasingly volatile – marked by geopolitical tensions, economic uncertainty, and rapid transitions – we continued to perform solidly. If I had to choose two words to characterize Rabobank over the past year, they would be resilience and progress.

Thanks to our strong financial position and cooperative foundation, we were able to continue supporting customers while again allocating a substantial portion of our profit to social initiatives. In 2025 alone, we invested EUR 292 million in society through our cooperative programs. A highlight was the launch of the independent Rabo Impact Foundation, with which we are creating long-term impact in areas where traditional financing falls short, supported by an initial contribution of EUR 102 million.

In addition, we began a three-year partnership with the Princess Máxima Center for Pediatric Oncology, valued at EUR 60 million, to support research and the construction of a new innovation wing. These investments make the essence of our cooperative model tangible: the better Rabobank performs, the greater the difference we can make together in and for society.

Even more customer-focused in the Netherlands

In our home market of the Netherlands, we further strengthened our position over the past year. Once again, Rabobank was the country’s largest mortgage lender. In 2025, we helped nearly 58,000 households purchase or improve their homes. We also secured the number one position in the intermediary channel, and our business lending activities saw strong growth. These results are partly due to the even more customer-focused structure of Retail NL, in which all Dutch activities for private individuals and businesses have been consolidated.

This allows us to respond more quickly to what customers need – from the housing market to business growth ambitions.

Wholesale & Rural: steady course in a turbulent world

Rabobank also delivered a strong international performance. Our ambition to be the Food & Agri Bank of choice worldwide was further realized, although 2025 was a challenging year for many of our customers. Volatility, complex markets, and limited predictability called for a bank that stays close to its customers and performs consistently.

Our Wholesale & Rural division rose to that challenge. The portfolio grew by EUR 4 billion to EUR 132 billion in loans worldwide. Of this, 59% supports the Food & Agri value chain – precisely where the food transition is most urgent.
The energy transition also accelerated: outstanding sustainable project financing increased to over EUR 8 billion, including dozens of solar and wind projects and nearly twenty large-scale battery storage projects.

Remaining close to customers made a tangible difference. We helped companies continue their operations, secure financing for growth, and navigate necessary transitions. Our sector expertise and long-term commitment proved essential in an uncertain world.

DLL: partner and accelerator

Our subsidiary DLL also operated in a turbulent environment. While Europe and Asia-Pacific delivered solid results, geopolitical unrest and tensions in the agricultural sector in Brazil and the United States led to higher risk costs. Nevertheless, DLL remained true to its core: being a partner to vendors and dealers to support their customers.

This was confirmed in the annual Partner Loyalty Survey, where the Net Promoter Score rose from 65 to 68. At constant FX rates, the lease portfolio grew by 2%, and DLL expanded its activities in both existing and new segments.
For example, a five-year contract was concluded with Bombardier Recreational Products for pan-European inventory financing. With more than 30 new partners and nearly one million customers, DLL continues to build a stronger and future-proof organization.

Cooperative initiatives: listening, connecting, acting

Our mission, Growing a better world together, remains the guiding principle in everything we do. As a cooperative bank without shareholders but with members, we can truly contribute to a better society. In the Netherlands, we strengthen the financial health of households through initiatives such as the National Coalition for Financial Health and social collections practices. And through the Rabo Impact Foundation, mentioned earlier, we are taking steps in areas of high social urgency: energy and food systems, water safety, circularity, and – specifically in the Netherlands – healthcare and affordable housing.

We remain in continuous dialogue with our customers and members, including during the National Dialogue. These conversations provide valuable insights into what is happening in society and the economy, and where Rabobank can make a difference.

AI as a driver of our cooperative strength

Within the bank, 2025 also saw a subtle yet profound shift: the way we work was redefined by the rapid rise of artificial intelligence (AI). Repetitive processes were further automated, and colleagues increasingly received support from AI applications that accelerate analysis and improve decision-making. At the same time, it became clear that human skills—creativity, critical thinking, collaboration, and empathy—are more important than ever. This combination of technological progress and strengthened human capabilities made us more agile and efficient, and helped us serve customers better and in a more personal way. AI has become not just a tool, but a driver of our cooperative strength.

Urgency and responsibility in an unstable world

The world has become more unstable. This requires us to be, to use a fine Flemish word, performant: strong, efficient, productive, and at the same time close to customers and society. Our results in recent years give us the strength to carry that responsibility with conviction: a reliable partner for more than nine million Dutch customers and a cooperative that continues to return its dividend to society – financially as well as through knowledge and networks.

Looking ahead: simplicity, scale, and proximity

We will continue on the path we have set: simplifying where possible,
scaling where it adds value, and working even more closely with customers
– in Retail NL, in Wholesale & Rural, and at DLL. We will continue to invest in digitalization, data-driven operations, and operational excellence to make the customer journey simpler, faster, and more reliable. And we will continue, as in Almere, to visit customers on site. Listening, providing advice, and building solutions together – for today and for the long term.

As I stood among those bouquets of roses at Termeulen Roses, I was struck by how resilient such an apparently fragile product can be. Behind every flower lies craftsmanship, adaptability, and daily care. It is an apt metaphor for the year behind us – and for the course we will continue to pursue.

With the same dedication and calm with which a grower nurtures roses, we will continue building a bank that truly matters: firmly rooted in society, moving with the world around us, and always focused on sustainable growth.

Stefaan Decraene
Chair of the Rabobank Group Managing Board

Strategy

Geopolitical & economic uncertainties

Geopolitical tensions continue to disrupt markets and reshape trade and supply chains, contributing to a more fragmented global economy. Inflation has largely normalized from its peak in 2022, and monetary policy eased further in 2025. Although baseline forecasts suggest moderate growth and further monetary easing in the year ahead, these projections are subject to a backdrop of heightened geopolitical uncertainty. The U.S.-China rivalry is set to intensify this year, driving trade realignment, supply chain diversification, and tighter investment controls. U.S. allied countries are strengthening their trade and investment ties with the U.S., signaling a shift in the global economy. At the same time, regulatory fragmentation and monetary policy divergence add complexity for global businesses. Persistent conflicts, from Russia-Ukraine to the Middle East, continue to weigh on international security.

Governments face mounting fiscal pressure: the imperative to invest in defence, climate measures, and digital infrastructure coincides with rising costs of ageing societies and higher debt-service burdens. Central banks are reassessing their roles as balance sheet normalization and expanded mandates blur lines with fiscal policy. Global forums (such as G20 and G7) are showing signs of strain as sovereignty and strategic autonomy gain prominence, particularly in Europe, where defense spending is on the rise. Businesses should prepare for continued geopolitical realignment, governance challenges, and market volatility, requiring resilience and strategic flexibility.

Changing competitive landscape

Over the past years, banks have benefited from favorable market conditions such as peaks in global wealth and strong revenue margins driven by higher interest rates. As these advantages fade, banks are facing slower growth and growing pressure on profitability. As a result of the less favorable conditions, we expect that the competitive landscape within the financial sector will not only be shaped by macroeconomic developments, but also by the accurate deployment of value-driven strategies, suitable for more challenging conditions. Examples of these strategies may include a move from customer segmentation to (hyper)individualization, capital efficiency, technological advancements, and M&A. We expect that banks will continue looking for further economies of scale, cut costs, and access advanced technology. Furthermore, the rise of Banking-as-a-Service (BaaS) will continue to fuel the growth of innovative platforms, including FinTechs and Neobanks, often in partnership with traditional players. The expansion of non-bank competitors like Tech giants intensifies the already fierce competition. Given the changing dynamics within the financial landscape, traditional banks should be agile and proactive, adapting their strategies to withstand mounting pressure from embedded finance and technology-driven challengers.

Societal shifts

Generational shifts are reshaping society and business. By 2030, Millennials and Gen Z will make up more than 70% of the global workforce. Combined with aging and the lower birth rates, this trend will continue to increase pressure on labor markets, welfare systems, and financial services. For the banking industry, this means adapting to serve diverse segments simultaneously: elderly customers, younger generations, and immigrants. Banks must rethink retirement planning and post-retirement support for a population living longer, while also meeting the expectations of younger customers who prioritize digital-first experiences, sustainability, and social values. At the same time, the future of work is being changed by rapid technological advancements. Building AI literacy will become essential - not only for technical roles, but across all functions. Customers expect full control over their personal data and demand that banks handle this information with transparency, trust, and care. Building frameworks for privacy and identity management will be important to maintain confidence and meet regulatory and societal expectations. Lastly, organizations face a stronger demand for wellbeing, flexibility, and a life-centric approach.
To retain employees, customers, and partners, banks must foster innovation, embrace inclusivity, and build resilience.

Sustainability

Natural disasters are increasingly impacting the world. Extreme weather events and biodiversity loss are tangible, impacting communities and economies globally. Climate resilience, water scarcity and quality, and land degradation are significant environmental issues. Urban areas are increasingly confronted with heat challenges, food insecurity and inequality. Energy challenges relate to grid reliability and battery availability. On the one hand technological innovation can unlock solutions and accelerate progress ranging from clean-energy adoption and enhanced risk detection to carbon capture and emissions-reduction technologies. On the other hand, developments in the EU regarding regulations and commitments, the transition of the Net-Zero Banking Alliance (NZBA) from a membership “commitment” to a non-membership “framework”, delays in the Omnibus Directive and a pushback in the US on ESG regulations imply a less regulatory driven incentive for sustainability. Businesses confirm that the business case for sustainability has strengthened, due to supply chain impacts and risk management. The majority of CEOs plans to maintain or expand their sustainability commitment. This business perspective requires tangible strategies and business solutions, beyond compliance, to remain competitive. Yet public messaging remains cautious, due to greenwashing risks and increase in climate litigation.

Technology & Digitalization

The financial sector is experiencing rapid digital transformation driven by advancements in artificial intelligence, cloud computing, and blockchain. AI is increasingly applied to improve risk management, fraud detection, and customer personalization, while generative AI is streamlining operations and software development. In addition, discussions around protectionism, security, EU sovereignty, and technological independence are becoming increasingly important as institutions seek to balance innovation with strategic autonomy. Cloud adoption continues to accelerate, enabling scalability and cost efficiency. However, the heavy dependence on US vendors warrants a resilience-focused approach. Blockchain, decentralized finance, and tokenization are transforming payment systems. Open banking and API-driven ecosystems are increasing collaboration between traditional institutions and FinTech, creating new revenue streams and competitive dynamics. At the same time, cybersecurity and digital trust remain critical priorities as regulatory pressures and geopolitical risks intensify. The growing use of AI and generative AI is heightening focus on ethical use, bias mitigation, and transparency, as stakeholders expect banks to manage algorithms responsibly. Institutions that embed data analytics, AI, and cloud into their strategies will gain agility and resilience, while those that lag risk losing relevance in an increasingly digital-first market. Meanwhile, agentic AI is emerging as a proactive technology, enabling autonomous decision-making and risk anticipation, and is poised to play a major role in the years ahead. Quantum computing is also on the horizon, with the potential to disrupt current encryption standards and require new cryptographic approaches to secure financial data. Competition and emerging technologies will continue to test operational resilience and change financial service delivery, increasing customer experiences and workforce expectations. Maximizing revenues and optimizing cost efficiency will be prioritized. Maintaining customer trust through secure digital services, digital inclusion and intelligent AI solutions will be crucial.

Regulation & Legislation

In 2025, the regulatory landscape evolved significantly. The EU advanced Basel III reforms through the Capital Requirements Regulation (CRR III) and Credit Requirements Directive (CRD VI), introducing new credit and operational risk standards. Supervisory bodies strengthened risk-based, data-driven oversight, issuing crypto asset market abuse guidelines and tightening expectations on sustainable finance disclosures, while simultaneously pursuing simplification through the European Omnibus agenda. Looking ahead, global financial regulation is expected to fragment as national authorities prioritize domestic competitiveness over global harmonization, creating complexity for cross-border firms. Industry outlooks highlight stablecoins and tokenized deposits as near-term disruptors, prompting banks to make strategic decisions on issuance, custody, and processing. The European regulatory agenda will be shaped by technological innovation, with supervisory priorities shifting toward digital assets and AI governance. New frameworks are likely to emerge to address risks from tokenized deposits, stablecoins, and algorithmic decision-making. Operational resilience and cybersecurity will remain top priorities under Digital Operational Resilience Act (DORA), requiring solid IT risk management and third-party oversight. As regulatory demands intensify, supervisors are increasing monitoring and enforcement to close compliance gaps. Institutions must adapt processes to maintain service quality, meet new standards, and track evolving requirements. Political uncertainty and geopolitical tensions add further complexity, while rising compliance pressure risks slowing operations. Proactive engagement with supervisors, and attention to rating agencies, prosecutors, and investor expectations, remain critical for navigating this environment.

Group Strategy

Rabobank is a unique bank, with strong cooperative roots. We activate local networks, contribute to communities, and support social transitions. Our mission, 'Growing a better world together', drives our ambition to strengthen our leading position in the Netherlands, be the Food & Agri bank of choice globally, and be the global market leader in vendor finance. Our strategy is built on a cooperative foundation with four strategic drivers: Excellent Customer Focus, Meaningful Cooperative, a Rock-Solid Bank, and Empowered Employees. Our mission, vision, values, behaviors, and distinctive cooperative stakeholder engagement are fundamental to how we operate and create value for our members and customers.

Our Mission

For over 125 years, collaboration has been at the heart of what we do. Our guiding principle is that together, we accomplish far more than we ever could individually. And we will continue to do so because we believe that the future is also cooperative. Every generation faces its own challenges, both big and small. Seeking solutions that inspire people to join forces.

We are a bank without shareholders, but with members. Over 2.3 million customers in the Netherlands are members, representing a broad cross-section of society. On a global level, we cooperate with our customers in advisory boards and local client councils. They mean a lot to us, because they tell us what is going on and help us to understand what truly matters. As a meaningful cooperative and a rock-solid bank, we continuously invest a substantial amount back into society through our cooperative dividend and various cooperative initiatives. With the support of our members, we are able to contribute to sustainable food and energy systems and foster financially healthy communities.

Making the way we live and do business more sustainable is the challenge of our time. We know change is needed and we want to contribute. To us that means we act on climate, value nature, and enable people. We leverage our knowledge, global network, and financial solutions to help customers achieve their goals, grow sustainably and provide solutions for challenges they cannot solve individually. In this way, we support our customers to transition to a more sustainable future and improve the society we live in on different levels. This is what makes Rabobank unique and how we are growing a better world together.

Our Vision

We envision a future where our role as a cooperative bank is pivotal in driving positive change. We work closely together with our members and customers and actively invest in both our global and local networks to ensure that our efforts lead to enduring, positive impacts on communities and the environment. Our commitment to innovation, growth and sustainability is at the core of our efforts. With our vision being:

“As a meaningful cooperative, we empower our employees to deliver excellent customer focus and a rock-solid bank to realize balanced and sustainable growth”.

To realize our vision, driving positive change and building a resilient, sustainable future, we have set clear ambitions that align with our drivers and strategic goals. These ambitions are steps in our journey to stimulate balanced, sustainable growth, ensuring that our efforts benefit our members and customers and contribute to growing a better world together.

Our Ambitions

Strengthen our leading position in the Netherlands

We are the leading Dutch domestic retail bank in the Netherlands. We aim to maintain and strengthen our leading position in the Netherlands by being a lifelong partner, deepening our relationships, offering relevant digital products and services, and continuing to distinguish ourselves through our cooperative approach.

We focus on clear priorities that drive balanced growth and operational excellence, creating long-term value for our customers and society. This includes creating additional value for young customers (ages 0-30) and (starting) entrepreneurs, while expanding our market share in Private Banking, Insurance & Pensions. We are committed to simplifying our operations by ensuring IT standardization and continuity, digitizing customer journeys, reducing service costs through operational excellence and balancing the risk, return and sustainability triangle. Our regained market leadership in mortgages and starting entrepreneurs (SMEs and ZZP) demonstrates that we have the right capabilities, people and ambition to deliver on our goals.

Be the Food & Agri bank of choice globally

With our strategy, we aim to strengthen and expand our position as the preferred bank in the Food & Agri sector globally, and continue to grow in line with our sustainability agenda. We actively facilitate and finance the food system transition and support the sector in reducing its carbon footprint. By leveraging our Food & Agri expertise, global food supply chain presence, extensive network, and high-quality products, we ensure long-term relationships with our customers and society.

One of our key priorities is to continue to grow our primary customer base globally in Food & Agri. We will leverage the strong global platform we have built in Food & Agri to accelerate our growth in the future clean energy system, support our mission and net-zero ambitions and expand from our Dutch base into selected European sectors that are fundamental to society, such as built environment and technology. At the same time, we are harmonizing and simplifying our operating model, optimizing customer journeys and further embedding sustainability practices throughout our business.

Be the market leader in vendor finance globally

Our purpose is clear: partnering for a better world. We want to maintain our leading position as the global vendor finance partner by enabling sustainable business growth through point-of-sale financial solutions. With our industry specialization and asset and risk expertise we strive to add value to vendors, dealers and users of equipment and technology. DLL is well-positioned to grow by expanding existing partner and customer relationships and building new ones. We continue to enhance our product portfolio with lifecycle asset management, usage-based and servitization offerings, while actively supporting the circular, energy and food system transitions to help customers seize market opportunities in new asset classes.

Our priorities are to grow our business smartly and sustainably in our vendor, dealer and direct channels, simplify to optimize our cost-to-serve, accelerate our digital transformation, and enhance our product and service offerings in partnership with the ecosystems we operate in. With this we continue to deliver sustainable growth and long-term value for our partners and customers worldwide.

Four Drivers

Excellent Customers Focus – ‘We are client driven and prioritize our customers.’

Our strategy begins with a clear focus on understanding and prioritizing our customers. We are committed to delivering outstanding customer experiences. Leveraging our strong local presence enables us to understand the demands and needs of our members and customers. We want to be a trusted banking partner for life, attract new customers and stay relevant by offering innovative financial services that improve the customer experience and expand our value-added propositions. We aim to provide high quality customer advice, seamless digital services, optimal customer and product journeys, while pursuing balanced growth. To generate additional non-interest related business, we will focus on deepening our customer relationships, strengthening our market share through competitive propositions, and promoting our enhanced digital services.

Meaningful Cooperative – ‘We are a cooperative and connect society.’

As a cooperative bank, we want to make a meaningful difference for society and contribute to a more sustainable world. We are ambitious to further strengthen our cooperative way of working and strive to be a positive force for our members, our customers, and the communities we serve. We continuously invest a substantial amount back into society through various cooperative initiatives and our cooperative dividend. Thanks to our local connection, at the heart of society, we are ideally placed to contribute to sustainable food and energy systems, and financially healthy communities. That’s why we act on climate, value nature and enable people to make the way we live and do business more sustainable.

Rock-Solid Bank – ‘We are professional and simplify.’

We aim to provide stability in an unstable world and safeguard operational resilience. We grow in a balanced, profitable and sustainable way, ensuring we create value for present and future generations. We deliver operational excellence, uphold compliance, and balance risk, return, and sustainability impact while simplifying our operating model and reducing our cost-to-serve. At the same time, we ensure we remain in control through group-wide portfolio management, a comprehensive customer view and robust technology and infrastructure. We are committed to become a better bank, build a stronger foundation for growth and shape a future-ready organization, to stay successful and be able to invest in our customers, people, and society in the future.

Empowered Employees – ‘We take responsibility and ownership.’

We want all our colleagues to be proud to call Rabobank a great place to be. We foster a culture where our people enjoy their work, feel valued and safe. We encourage our employees to take responsibility, unleash their potential and develop skills for the future by harnessing technology. This helps us build a future-ready organization and workforce, deliver the best for our members and customers, and society. Our cooperative mindset is deeply rooted in our traditions and conveyed by our colleagues every day.

Sustainability embedded in our strategy

We want to, need to, and are committed to 'Growing a Better World Together'. That is why we help our customers, with our industry knowledge, networks, and financial solutions, to be resilient and transition to a more sustainable future. We also help to move ‘the system’ in a more sustainable direction. This is about increasing positive impact and reducing negative impact. Which to us is part of growing a better world together.

From a sustainability perspective, reducing our climate impact, balancing food and energy within planetary boundaries, and enabling people, are our main priorities. In our own organization, with our customers and in our communities, we aim to drive developments that can contribute to make a more sustainable life and business affordable, available, and accessible. We aim to act in line with our beliefs, commitments and regulations and do this in a science-based way. In addition to having our foundation in order, from human rights to good governance, our focus from an environmental perspective will be on the following topics.

Facilitating key transitions

We focus on two transitions: the energy transition and the food system transition. Everyone needs food and energy. Since both the food and energy systems are currently not yet future proof, we want to contribute to accelerate the needed transitions, making sustainably produced food and energy become the norm.

Food system transition - “Facilitate the food system transition towards a future-proof system based on responsible production and consumption of food”.

We are committed to contribute to a future-proof food system. That is a system that revolves around making the food supply chain more secure and resilient: in nature, in farming and in business models. A system that can lead to making sustainably produced nutritious food affordable, available and accessible. We work with the entire value chain: from farm to fork and fork to farm. 

Energy transition - “Facilitate the energy transition towards a future-proof system based on responsible energy production, distribution and consumption”.

We are committed to contribute to a future-proof energy system. That is a system that will strongly revolve around energy saving and using low or no carbon instead of fossil sources: from energy company to small enterprise, from multinational to farm or family home. Green energy should also become affordable, available, and accessible. We work with the entire energy system: from producer to consumer.

Performance

Rock-Solid Bank

Within Domestic Retail Banking (DRB), deposit margins decreased. However, the impact of this decrease on net interest income was mitigated by ongoing strong growth in deposit volumes of EUR 25.4 billion, and continued growth of DRB's loan portfolio by EUR 10.6 billion. Wholesale & Rural (W&R) expanded its loan portfolio by EUR 9.3 billion, while our leasing portfolio ended EUR 1.1 billion higher than last year (both at constant exhange rates).

Excluding the impact of our cooperative initiatives, our operating expenses remained largely unchanged over 2025, as the reduction in average FTEs (2% lower in comparison to 2024) offset the wage increases stemming from the Collective Labor Agreement.

Loan impairment charges amounted to EUR 764 (2024: 468) million, reflecting a return to more normalized levels following several favorable years. Main drivers for impairment charges in 2025 were macroeconomic volatility and adverse circumstances in Brazil for our leasing business.

Rabobank’s cost/income ratio remained stable at 54.5% (2024: 54.4%) reflecting expenses keeping pace with our moderate income growth. Return on Equity stood at 9.1% (2024: 10.0%).

Our CET1 ratio jumped to 20.3% from 16.9%. This improvement was principally driven by an expected drop in risk-weighted assets due to the implementation of the Capital Requirements Regulation 3 as of January 2025 and the addition of profit to our retained earnings. This robust capital position enables us to support our growth strategy and our positive impact on society.

Balance sheet

Equity Increased

Our equity increased to EUR 55.9 (2024: 53.4) billion. This reflects the addition of the lion’s share of net profit to retained earnings, a redemption of capital securities, and negative FX effects in other comprehensive income. Our equity on December 31, 2025, consisted of 79% (2024: 77%) reserves and retained earnings, 12% (2024: 13%) Rabobank Certificates, 7% (2024: 9%) Capital Securities, and 1% (2024:1%) other non-controlling interests. A simplification of the legal structure of the Rabobank Certificates was implemented.

Capital Ratios

Maintaining a Strong Capital Position

On December 31, 2025, our Common Equity Tier 1 (CET1) ratio amounted to 20.3% (2024: 16.9%). This is well above our >14% ambition. The main driver of our CET1 ratio development was a decrease of RWA, additionally an increase in CET1 capital due to the addition of net profit to retained earnings also had a positive impact. Risk-weighted assets (RWA) decreased by EUR 22.2 billion (from EUR 261.5 billion to EUR 239.2 billion) mainly due to the implementation of CRR 3 (also known as Basel IV). Our leverage ratio on December 31, 2025, was 7.7% (2024: 7.3%), which is well above the minimum leverage ratio of 3% required by the Basel guidelines and CRR. Our total capital ratio increased to 23.6% (2024: 20.9%) as a result of decreased RWA and the increase in CET1 capital, partly compensated by a reduction of the eligible amount of outstanding AT1 and
Tier 2 instruments. Rabobank deems a 20% total capital ratio appropriate.

Risk-weighted assets

In 2025, total RWA decreased to EUR 239.2 (2024: 261.5) billion mainly due to the introduction of CRR3. The main driver is lower LGD input parameters for Foundation – IRB models (minus EUR 14.5 billion). Additionally, the EAD declined due to lower credit conversion factors (CCF) for Foundation – IRB models (minus EUR 8.6 billion). Some other impacts had a combined impact of minus EUR 1.7 billion. On the other hand, RWA increased due to business development (EUR 8.2 billion). FX effects had a downward impact of around EUR 5.5 billion. Rabobank conducts a comprehensive assessment of its capital adequacy from both regulatory and internal economic standpoints. This dual approach ensures that the organization holds sufficient capital to mitigate potential adverse effects stemming from its risk profile. The results of these assessments confirm that Rabobank maintains a sound capital position.

Regulatory Capital

The regulatory (Pillar 1) capital requirement is 8% of our RWA. This requirement represents the minimum amount of capital which we are required to hold. Our regulatory (required) capital landed at EUR 19.1 (2024: 20.9) billion on December 31, 2025, of which 86% is related to credit and transfer risk, 12% to operational risk, and 2% to market risk.

Regulatory Capital by Business Segment

MREL Eligible Capital Buffer

We aim to protect senior creditors and depositors against the unlikely event of a bail-in. We therefore hold a large buffer of equity, subordinated debt, and non-preferred senior debt that will absorb initial losses in the event of a bail-in. On top of that, a buffer consisting of MREL eligible preferred senior debt is available.

The MREL requirement was established to ensure that banks in the EU have sufficient own funds and eligible liabilities to absorb losses in the event of a potential bank failure. The MREL requirement for Rabobank is set at a consolidated level, as determined by the SRB. Our binding MREL requirement as of December 31, 2025 is 27.9% of RWA (including the stacked Combined Buffer Requirement (CBR)) and 7.5% of Leverage Ratio Exposure.

As of January 1, 2026 the MREL requirement is 27.7% of RWA (including the stacked CBR) and 7.4% of Leverage Ratio Exposure.

The subordinated MREL buffer is defined as qualifying capital plus the (amortized part of) Tier 2 capital instruments with a remaining maturity of at least one year and non-preferred senior bonds with a remaining maturity of at least one year. The buffer increased from EUR 78.6 billion to EUR 79.1 billion, which corresponds to 33.1% (2024: 30.1%) of RWA. A buffer of 1.9%- points of MREL eligible preferred senior bonds was available on top of that.

MREL Eligible Capital Buffer

Risk Management

Introduction

The subsequent chapters dive into the specific categories of risk. The Financial Risk chapter covers business risk, credit risk, funding and liquidity risk, and market risks in both the banking and trading books. It highlights portfolio performance, capital adequacy, liquidity metrics, and the impact of macroeconomic, geopolitical, and environmental developments. The Non‑financial Risk chapter describes how Rabobank manages operational risks, including cyber threats, transformation challenges, data management, and resilience, as well as compliance risks such as AML, sanctions, fraud, and data privacy. Additional sections cover model risk, including the progress on regulatory models, IFRS9 developments, and the growing importance of AI risk management.

Together, these chapters provide a transparent view of Rabobank’s risk profile, the measures taken to remain within the defined risk appetite, and the bank’s ongoing efforts to balance risk, return, and sustainability in support of long‑term value creation.

Our risk management and control model is underpinned by common principles, a solid risk culture, clear Group governance structure, and advanced risk management processes across the identified risk types. This section sets out how Rabobank Group manages its risks on a day-to-day basis, explains how the risk management function is embedded within the organization based on the “three lines of responsibility” risk governance model. The section also provides qualitative and quantitative risk disclosures for business risk, credit risk, funding & liquidity risk, market risk in the banking book, market risk in the trading book, operational risk, compliance risk, and model risk. 

Every day, we make informed risk decisions as we engage with new and existing customers, extend credit, enter into interest rate and leasing contracts, make equity investments, form partnerships, and provide various customer services. We monitor risk metrics effectively, and with proactive risk management, we manage to serve our customers across different segments and sectors while satisfying our stakeholders. 

This controlled approach supports our continued prosperity as a bank. Our business model and solvency levels demonstrate resilience in a challenging macroeconomic and geopolitical environment. The transition to a low-carbon economy not only represents a great opportunity and is fully aligned with our business strategy, but also a risk which is why we embedded ESG factors in our risk management framework and models (as a risk driver).

We implement risk activities and establish controls to manage material risks within a robust risk management framework, aligned with our conscious risk-taking approach. We continuously assess the effectiveness of this framework and adapt to the latest developments and requirements. Ultimately, our risk management activities are designed to help achieve the ambitions of the bank, our customers, and stakeholders, all within the boundaries of our risk appetite.

Managing Risks

Our risk management activities are seamlessly integrated in our strategy design and execution. While new strategic initiatives can create opportunities, it is essential to balance the anticipated return against the associated risk and take into account the sustainability impact.

• We monitor external developments to identify emerging risks and key threats to our strategic plans.

• We conduct regular, comprehensive top-down and bottom-up risk assessments to identify various types of risks and perform specific stress tests to evaluate the potential impact of adverse scenarios.

An integrated overview of these risks and the measures taken to address them is periodically reviewed by the Managing Board and Supervisory Board.

Risk Governance

Our internal governance ensures transparent and consistent three lines of responsibility across Rabobank. Our risk governance framework supports the achievement of our strategic priorities and is based on regulatory guidelines and market practices. Global policies facilitate the execution of the business strategy, adherence to the risk appetite, and oversight of risks, ensuring a consistent approach across the Group.

• The business, including its support functions, owns, takes, and manages risk, return, and sustainability.

• Risk and Compliance (second line within CRO function), challenges and advises on risk-taking activities and monitors the risk profile.

• Audit (third line) provides independent assurance and insights on the quality and effectiveness of internal controls, risk management, compliance, and governance within the bank.

The risk management framework covers both existing and emerging risks including ESG risks via the main risk types:

• Financial risks: business risk, credit risk, liquidity risk, market risk in the banking book and market risk in the trading book.

• Non-financial risks: operational risk, compliance risk, and model risk.

Risk identification, materiality assessment and classification allow for a clear understanding of risks and promote a common understanding of risk management. The risk appetite is determined for all material risks, which are managed in alignment with the risk profile and our strategic priorities.

Three Lines of Responsibility

The Three Lines of Responsibility framework defines clear roles for managing risks and compliance across the organization.

• The first line consists of business and support units responsible for day-to-day risk management.

• The second line, the Compliance and Risk (CRO) department, operates according to internal governance and charters to oversee and guide risk processes. This approach ensures clarity, collaboration, and efficiency in handling risks per type, fostering proactive and responsible behavior. By understanding and respecting each role, the model supports doing the right thing for customers and achieving effective risk management aligned with Rabobank’s mission of Growing a better world together.

• The third line, internal Audit, provides independent assurance and insights on the quality and effectiveness of internal controls, risk management, compliance, and governance within the bank.

Risk Culture

Rabobank’s Risk Culture approach is aimed at ensuring a sound Risk Culture and Risk Maturity. Various instruments have been introduced and set in motion to steer the aspired Risk Culture, to assess, challenge and report the actual status and to reflect and act if interventions are required or desired. With the Risk Culture approach, a consistent way-of-working across the globe has been introduced, leading to insights to determine actions, better reporting and sharing of best practices. Leadership commitment, strong behavioral risk management and an enabling work environment are key drivers to set and steer a sound Risk Culture.

Risk Strategy

Our mission 'Growing a better world together', underlines our cooperative roots and emphasizes our dedication to enabling our customers to achieve their ambitions.

Rabobank’s risk strategy articulates the risk priorities the bank needs to manage as a precondition for achieving its strategic plan. The risk strategy is based on (a) protecting profit and profit growth; (b) maintaining a solid balance sheet and (c) protecting the bank's identity and reputation. It is used as the starting point to further define the risk appetite on individual risk type level. Rabobank reviews its risk strategy annually when updating its Risk Appetite Statement but has kept its high-level risk strategy stable for several years now.

Risk Assessment

To effectively deliver on our risk strategy, it is crucial to understand the risks Rabobank faces. Our structured approach to risk identification and assessment ensures that both current and potential future risks to Rabobank’s mission, vision, and strategic priorities are identified.

Our Risk Taxonomy is divided into three dimensions. More specifically:

• Strategic drivers: major developments that threaten to disrupt the assumptions and outcomes at the core of Rabobank's strategy, but could also provide opportunities for future growth. These are factors that may lead to financial and non-financial risks.

• Financial risks: risks that we consciously accept in order to benefit from the premium that the market offers for taking on risks (risks for which we have a risk appetite).

• Non-financial risks: risks for which we have no appetite, but which are tolerated within limits because they are inherent to the operation of the bank.

ESG Risk as a strategic driver

ESG is one of the identified strategic drivers. The consequences (physical risk) of climate and nature change (such as rising average temperatures, extreme weather events and biodiversity loss) and the risks related to a shift towards a climate-neutral economy (transition risk) are central in our mission and strategy. We are committed to the Paris Climate Agreement goals. We are a signatory to the Net-Zero Banking Alliance, the Dutch Financial Sector Climate Commitment, the Finance for Biodiversity Pledge, and the Taskforce on Nature-related Financial Disclosures. Rabobank is committed to the United Nations Guiding Principles (UNGP) on Business and Human Rights and OECD guidelines on Responsible Business Conduct and we consider it a shared responsibility to act on climate, to value nature, and to enable people in the transition.

At Rabobank, we optimize our business between risk, return, and sustainability impact. We create value together with our customers: each opportunity must contribute to a sustainable future and fit our strategy. Our risk management framework covers both existing and emerging risks via the main risk types. We have adopted a full end-to-end approach to ESG risks embedded across every aspect of the bank. We continued to mature our approach on integrating the risk of climate change by developing climate risk management tools, processes, and capabilities and implementing them in our policy framework, risk assessment, and business processes.

Please refer to the Sustainability Statements for an in-depth view on how our risk management framework manages risks and opportunities between our ambition, commitments, strategy, and business model.

The impact of ESG risk drivers is assessed for each of the risk types in the risk taxonomy as illustrated below:

In addition to the traditional outside-in perspective on risks Rabobank faces, the inside-out perspective is assessed via the double materiality assessment of impacts which the bank and its customers or suppliers might have on a wide array of ESG topics.

Capital Risk Profile

ICAAP

Rabobank has fully integrated ESG risks in its Internal Capital Adequacy Assessment Process (ICAAP). Material ESG risks are taken into account in all steps of this process, including in risk identification, risk appetite and risk management. As part of the Risk Identification and Assessment (RIA) process, Rabobank has identified the main ESG risk drivers via a double materiality assessment and these ESG drivers are assessed to have a material impact on Credit Risk, Business Risk, Operational and Compliance Risk. In the ICAAP, the impact of ESG on the actual/current, forecasted and stressed positions of these risk types are considered.

ILAAP

ESG risks can affect funding and liquidity, for example through cyber-attacks, reputational or strategic developments, potentially contributing to (deposit) outflows or credit rating downgrades. From a liquidity perspective, ESG is currently not assessed as a standalone material risk type; however, ESG-related developments are considered as potential drivers alongside other liquidity risk drivers and are embedded in the liquidity risk framework. Funding and Liquidity Risk covers ESG impacts in economic and normative key risk indicators (KRIs). Short-term liquidity risk indicators (e.g., LCR, LST) take ESG into account by considering that shifts from non-sustainable to sustainable assets could potentially affect the credit quality and market liquidity of certain non-sustainable assets. Where relevant, less liquid or lower-rated assets may be treated more conservatively in the liquidity buffer (e.g., through eligibility considerations or higher haircuts). Long-term liquidity risk indicators (e.g., NSFR) account for ESG impacts through potential effects on loan performance, which may require more stable funding for underperforming or non-performing exposures. Similarly, bonds that are not eligible for short-term liquidity metrics may require more stable funding in longer-term measures.

Our Risk Strategy produces a set of Risk Appetite Statements that are directly linked to the medium-term planning 2026-2028 (MTP) and our strategic pillars: Excellent Customer Focus, Meaningful Cooperative, Rock-Solid Bank, and Empowered Employees. These pillars establish the high-level boundaries within which our risk appetite operates. We define our risk appetite by risk type, specifying the level of risk we are willing to accept to achieve our business objectives. This overall maximum level of risk exposure is used in business activities to evaluate the desired risk profile against the risk-return sustainability profile of a given activity.

At an aggregated level, the risk appetite is articulated for capital and liquidity, aligning with the risk management priorities set by the Risk Strategy. The Managing Board is responsible for approving the Risk Appetite Statement (RAS) for the entire Group annually. This process cascades down, with each subsidiary's board having its own risk appetite. Our risk appetite is embedded across Rabobank through principles, policies, standards, risk indicators, limits, and controls including employment of early warning limits enabling monitoring and proactive risk management of potential risks before they escalate. 

A combination of breach management processes and risk governance ensures an adequate and timely response to risks that are pressuring or have exceeded our risk appetite. The risk appetite is reviewed and updated at least annually to incorporate internal or external events with a material impact. Entity-specific Risk Appetite Statements further detail the group risk appetite. In 2025, our Group Risk Appetite Statement was categorized per identified main risk type and further specified with qualitative Risk Appetite Statements and quantitative risk appetite indicators.

Group Risk Appetite Statement

Business Risk

Rabobank operates in a global environment and thus, external developments and risks, as described in the chapter Trends, Developments and Outlook are relevant for the management of financial and non-financial risks. In the global environment, our business is optimized between risk-return and sustainability impact.

Decreasing volumes, (commercial) margins, fees, commission, other income, or increasing (operating) costs caused by unexpected or temporary developments may lead to losses. Business risk is largely managed and measured through analyses of the most relevant risks for Rabobank’s business model. These analyses support management in the assessment, impact evaluation, and management of risks. The MTP process is key for managing business risk. In the MTP process, management sets the course of business for the coming year(s) based on different scenarios. Rabobank updated its scenario approach to determine the amount of business risk capital. These scenarios provide both a basis for the calculation and quantification of the required capital, and qualitative insights into the impact on Rabobank’s volumes, margins, cost, fees, and commissions under a broad range of possible developments. The implementation of Basel IV improved our business risk position with a significant improvement of the capital position.

Risk Profile Performance

Credit Risk

Portfolio credit risk refers to the risk of losses due to a customer or counterparty or group of customers or counterparties defaulting on its payment obligations towards Rabobank, considering diversification, concentration, and correlation effects across the portfolio and macroeconomic environment.

In 2025, the quality of our credit portfolio remained strong. The Non-Performing Loans (NPL) ratio declined to 1.4%, the loan impairment charges amounted to EUR 764 million, amply within the bank's risk appetite. Robust asset quality is mainly a result of Rabobank’s prudent underwriting policies and strategic focus on the Dutch market, vendor finance, the international F&A sectors and banking for the energy transition.

The credit quality of our loan portfolio remained robust in DRB and W&R, with heightened Credit Risk within DLL, driven mostly by continued adverse developments in the Brazil portfolio. Stage 2 exposure declined, but remained at elevated levels due to previous regulatory treatment of interest-only mortgage customers and model updates. Persistent geopolitical tensions, coupled with ongoing economic uncertainty and the growing impact of climate-related events, highlight the importance of sustained vigilance and adaptive risk management.

Credit Portfolio

The private sector loan portfolio is related to Dutch mortgages to Private Individuals (45%), Business Lending in the Netherlands (17%), Wholesale & Rural (29%), DLL (9%). 

Loan impairment charges of EUR 764 million (17 basis points at an annualized rate) are higher compared to 2024 (EUR 468 million) and below the through-the-cycle range of around 20 basis points. The impairment charges mainly originate from stage 3 impairments within DLL and Rural. Availability of more recent loss data warranted a re-assessment, increasing the stage 3 provisions. Management adjustments cover (interest-only) mortgages (EUR 86 million), geopolitical risks (EUR 128 million), climate & environmental risks (EUR 88 million), and an addition to the Corporate Acquisition Finance (CAF) portfolio (EUR 38 million).

Stage 2 ratio decreased to 12.5% (2024: 14.1%), amounting to an exposure of EUR 64.9 billion (2024: 69.6 billion). The decline is mostly driven by model implementations, and higher house prices for the Dutch mortgage portfolio.

Rabobank closely monitors the developments of the NPL total coverage ratio – which encompasses the NPL coverage ratio, NPL collateral ratio, and the prudential backstop – to ensure adequacy of the provisioning levels and sufficiency of the capital buffers. The NPL total coverage ratio of 93.3% (2024: 94.9%) remains high compared to other banks.

The NPL coverage ratio increased to 20.2% (2024: 16.1%), driven by the re-assessment of stage 3 provisions. The increase was partially offset by write-offs of fully provisioned customers. These write-offs improve asset quality and reduce the NPL coverage ratio. Differences in NPL coverage ratios between banks reflect differences in portfolio composition, collateralization (including valuation rules and enforceability), accounting standards, write-off policies and loan impairment policies.

Private Sector Loan Portfolio - Credit Risk

1. Total exposure denotes outstanding loan amount net of expected credit losses for the respective sub portfolio.

Residential Real Estate

The Dutch mortgage portfolio is characterized as low risk, as reflected by a low NPL coverage ratio of 2.2% (2024: 4.3%) and loan impairment charges of 1 basis point (2024: minus 3 basis points). This favorable risk profile is supported by prudent underwriting criteria, robust housing prices, and structural housing shortages. Average house prices increased by 8.6% in 2025 (2024: 8.7%), and Rabo Research expects prices to increase further in 2026 and 2027.

The Dutch mortgage portfolio with a total exposure of EUR 204 billion continues to perform well. The portfolio shows a decreased loan-to-value (LTV) ratio of 48.1% (2024: 48.3%) and an increased share of National Mortgage Guarantees (NHG) of 17.2% (2024: 16.3%). The share of Interest-Only Mortgages (IOM) decreased to 46.8% (2024: 49.2%), in line with our portfolio de-risking strategy. On January 22nd 2026, Rabobank announced stricter norms on IOM lending, effective May 11th 2026.

Commercial Real Estate

One of Rabobank's financing strategies is focused on the Dutch Market for Commercial Real Estate (CRE), with a particular emphasis on lower-risk subsectors that contribute to addressing key societal challenges, such as the housing shortage and energy transition. Our CRE portfolio remains stable at approximately EUR 23 (2024: 22.7) billion , accounting for 5% (2024: 5%) of the private sector loan portfolio. In 2025, a significant risk transfer transaction of around EUR 1 billion was closed to support our ambition to grow our CRE lending in the Netherlands in a risk-controlled way. The asset quality of the CRE portfolio is strong with a stage 2 ratio below 2% and NPL ratio below 1%.

Asset quality of Rabobank's CRE portfolio remains robust. The average LTV of the portfolio is 49%, with less than 2% of the exposure having an LTV above 80%.

Funding and Liquidity Risk

Funding and liquidity risk arises when Rabobank Group is unable to obtain sufficient liquidity to meet contractual or contingent obligations on time or cannot sustainably maintain a well‑diversified funding base to support its assets and off‑balance‑sheet activities without incurring unacceptable losses.

Rabobank's funding and liquidity management framework is equipped with adequate liquidity positions to meet expected and unexpected cash flows and collateral needs without affecting either daily operations or the financial stability of the bank. This is supported by a stably funded balance sheet, sufficient and high-quality liquidity buffers, a diversified funding profile, a limited structural currency mismatch, and liquidity measures managed to target and well within risk limits. The objective is to maintain Rabobank Group’s ability to fund assets and meet any contractual financial obligations as and when they fall due without unacceptable losses under any circumstances.

The importance of a healthy balance sheet and prudent funding and liquidity risk management is fully embedded in Rabobank’s strategy, budgeting, procedures, and measurements. The liquidity and funding risks are managed centrally by Group Treasury, under the responsibility of the Asset-Liability Committee (ALCO) during business-as-usual and/or the Liquidity Crisis Team (LCT) during stress periods.

Rabobank has an extensive set of normative and economic risk indicators and market indicators which prudently cover Rabobank's funding and liquidity risk. The metrics, which are considered crucial for risk management and balance sheet utilization, are included in the bank’s Risk Appetite Statement (RAS).

Funding Profile

The funding and liquidity risk framework focuses on stable funding consisting of funds entrusted by customers and long-term wholesale funding. Rabobank takes various measures to avoid becoming overly dependent on a single source of wholesale funding. These include the balanced diversification of financing sources regarding maturity, currencies, investors, geography and markets, a high degree of unsecured funding (and therefore limited asset encumbrance), and an active and consistent investor relations policy.

Our funding mix consists of three building blocks: customer deposits, issued debt, and equity. Our sizeable and stable retail deposit base can be seen as the anchor of the funding mix, and the amount of stable retail customer funding increased further in 2025. The deposit base is complemented by centrally sourced Treasury deposits from large corporate and financial institutions.

In addition to deposits, Rabobank attracts funding through the issuance of debt instruments. This includes the issuance of preferred senior (PS) and non-preferred senior (NPS) instruments, driven by capital requirements (Tier 2/MREL). Rabobank maintains a prudent maturity profile of its debt instruments to maintain a reliable funding base while adding to the flexibility of the bank’s balance sheet in terms of volume, tenor, and currency when compared to customer-related deposits. The following table shows a breakdown of our issued debt.

In 2025, the amount of issued debt decreased by EUR 8.2 billion to EUR 118.2 billion. Long-term debt securities decreased by EUR 9.4 billion. The changes in issued debt reflect funding management in view of the uncertain macroeconomic outlook, market conditions in Q4 2025, the maintenance of an adequately diversified funding profile, and MREL requirements. Funding and Liquidity is managed centrally, which means that individual locations adhere to the strategic principles of maintaining a stable, diversified, and optimized funding mix at the Group level while seeking their own funding and minimizing local liquidity gaps. The strategic principle of stable funding also applies to the currency-specific level. Rabobank’s funding and liquidity risk indicator levels (see Table below) are well within our risk appetite and comply with regulatory requirements. The Loan-to-Deposits (LtD) ratio measures the reliance on wholesale funding. It is defined as Total Loans over Total Deposits, based on a specific definition of loans and deposits. During 2025, the LtD remained stable around 107%. Asset Encumbrance (AE) is the result of providing assets as collateral for certain liabilities. It poses risks to unsecured creditors who are unable to benefit from the liquidation of encumbered assets in the event of insolvency. The ratio is stable around 9% and well within the target.

Balance Sheet Risk

Short-term Liquidity Resilience

Another key component of funding and liquidity management is to maintain substantial high-quality liquid assets (HQLA)/Liquidity Buffer. These assets can be used as collateral for central banks in repo transactions or can be sold directly in the market to generate liquidity immediately.

In addition, Rabobank has securitized a portion of the mortgage and SME loan portfolio internally, which means it can be used as collateral for the central bank. The outstanding amount of retained collateral has increased by EUR 6.9 billion (market value) in 2025 to improve Rabobank’s capacity to absorb liquidity outflows. Since this concerns retained securitizations, it is not reflected in the consolidated balance sheet.

Our liquidity buffer consists of cash at central bank and qualifying securities in the different Treasury books with High Quality Liquid Assets (HQLA).

Liquidity Buffer Composition

The liquidity buffer has sufficient capacity to cover the net outflows in a stress scenario, as reflected by the LCR and internal stress test results. Throughout 2025, Rabobank’s liquidity buffer remained at a prudent level and the LCR was managed above regulatory limits and internal targets.

Liquidity Coverage Ratio

Detailed plans have been drawn up for contingency funding to ensure the bank is prepared for potential crisis situations. Periodic operational tests are performed on these contingency funding plans. The liquidity stress test assesses whether Rabobank maintains sufficient liquidity buffers to mitigate funding and liquidity pressures, ensuring the bank can meet severe outflows and continue supporting its customers under defined stress scenarios. Unweighted counterbalancing capacity equals EUR 235.4 billion, with EUR 197.2 billion in weighted counterbalancing capacity.

Risk Profile Performance

In 2025, Rabobank remained rock-solid from a funding and liquidity perspective. The liquidity buffer remained high close to 62% of the buffer is held in cash at central banks. Rabobank managed Rabobank Group LCR and NSFR comfortably above the internally defined risk limits and therefore well above the regulatory minimum requirements throughout 2025. The USD balance sheet is of strategic importance for Rabobank. Specific monitoring and reporting of the USD funding and liquidity position is in place, including a USD-specific LCR and NSFR.

Rabobank integrates sustainability risk into its liquidity and funding management framework. Sustainability risks, like cyber threats or strategic challenges may lead to deposit outflows and/or credit rating downgrades. These impacts are reflected in both economic and normative key risk indicators (KRIs). Short-term liquidity indicators (e.g., LCR, LST) help monitor investor behavior, signaling shifts towards sustainable assets, and higher default rates for non-sustainable exposures. Non-liquid or lower-rated assets are excluded from the liquidity buffer or subject to higher haircuts. Long-term indicators (e.g., NSFR) incorporate sustainability considerations through loan performance, requiring more stable funding for underperforming or non-performing loans. Non-LCR eligible bonds also carry higher stable funding requirements under NSFR.

Sustainable Finance

The sustainable finance context is characterized by fast market developments from both a regulatory and a geopolitical perspective. Rabobank leverages the EU Taxonomy and other sources such as subsidy schemes and market principles to help us define and steer on sustainable finance. Sustainable finance has been included in the medium-term planning process, balance sheet management and strategic choices on risk/return/sustainability trade-offs. Steering on risk/return/sustainability trade-off will further mature over time.

Since 2016, Rabobank has its Sustainable Funding Framework (SFF) in place to support the bank’s sustainability efforts. Green instruments in various formats can be issued from the SFF, including secured and unsecured bonds, commercial paper, certificates of deposit and wholesale deposits. The SFF eligible green asset criteria are based on the technical screening criteria for substantial contribution of the EU Taxonomy. Since 2016, Obvion issues green RMBS on stand-alone green bond frameworks.

Our sustainable funding ambitions are on a best-effort basis and are dependent on data availability, sustainable asset availability, financial market circumstances, investor demand and market- and regulatory developments.

Market Risk in the Banking Book

Market Risk in the Banking Book is the risk of changes in value or earnings of non-trading banking books resulting from interest rate risk, credit spread risk or FX/commodity price risk.

Rabobank manages its balance sheet in order to protect the asset and liability positions against interest rate risk in the banking book (IRRBB), credit spread risk in the banking book (CSRBB) and FX & Commodity (Price) Risk in the banking book.

IRRBB

In the context of easing inflation and increased geopolitical tensions during 2025, the yield curve steepened. Changes in interest rates impact the bank’s economic value and earnings. To respond to changing interest rates, an IRRBB strategy with potential changes of duration is in place. Prepayment risk assumptions and hedging are monitored continuously and reviewed to reflect, among other things, interest rate movements and current housing market activity. Declining interest rates can lead to margin compression for non-maturing deposits.

To monitor balance sheet exposure, a set of validated risk metrics is in place that measure interest rate risk from the perspectives of earnings and economic value, including Earnings-at-Risk, Modified Duration, Supervisory Outlier Test on Economic Value of Equity (EVE SOT) and Supervisory Outlier Test on Net Interest Income (NII SOT). Exposure was managed within defined internal risk appetite limits and regulatory requirements in 2025.

Interest Rate Risk in the Banking Book

Risk Profile Performance

In 2025, IRRBB positioning remained fairly stable. Movements are related to regular strategic Treasury positioning and responding to higher savings volumes within risk appetite limits.

Credit Spread Risk in the Banking Book (CSRBB)

Credit spread risk in the banking book (CSRBB) refers to the risk that is driven by changes in the market perception of the price of credit risk, liquidity premium and potentially other components of credit-risky instruments introducing fluctuations in the price which are not explained by IRRBB or by expected credit/(jump-to-) default risk.

In line with its CSRBB strategy—focused on maintaining a robust balance sheet, sustainable funding sources, and an adequate liquidity buffer—Rabobank accepts only a limited level of credit spread risk in the banking book. The exposure aligns with the strategy defined by the ALCO committee and managed within defined risk levels, where the main driver stems from securities held within the HQLA portfolio. The bank employs a centralized approach to manage its exposure to CSRBB, supported by a set of risk indicators that monitor developments at an aggregated level. These indicators primarily focus on the impact on Economic Value and Earnings and is reported monthly to ALCO and Risk Committee.

FX & Commodity Price Risk (Banking Book)

Rabobank’s international operations and cross-border activities expose it to foreign exchange rate risk. A portion of the bank’s capital and funding flows occur across borders and involve multiple currencies. In the banking book, commodity price risk arises from Structured Inventory Products business, though the resulting exposure is economically minimal.

FX Translation Risk (FXTR) is the risk that FX fluctuations will adversely affect the translation of assets and liabilities of operations --denominated in foreign currency-- into the functional currency of the parent company. The functional currency for CRUA is the euro. Translation Risk impacts Rabobank’s equity position, risk-weighted assets, and capital ratios. Rabobank manages its FXTR with regard to its Common Equity Tier 1 (CET1) ratio by deliberately taking positions and/or hedges to reduce this risk on a foreign currency basis.

FX & Commodity (Price) risk (Banking Book)

Rabobank aims not to be exposed to non-structural FX exposures; Currency Risk in the Banking Book is immaterial and Rabobank complies with the 2% Open Currency Position (OCP) de-minimis threshold. Rabobank also aims not to be exposed to Commodity (Price) Risk in its Banking Books.

Risk Profile Performance

In 2025, IRRBB positioning remained fairly stable. Movements are related to regular strategic Treasury positioning within risk appetite limits . Rabobank’s CSRBB profile has been growing due to an increase in high-quality debt securities holdings (overwhelmingly EUR AAA rated securities) to optimize the asset allocation within Rabobank’s liquidity buffer; the position has been managed within risk appetite. We expect this trend to continue in 2026. 

The impact of exchange rate fluctuations on Rabobank's consolidated CET1 ratio remained within the established risk appetite parameters throughout 2025 and will be maintained within the bank's risk appetite.

Market Risk in the Trading Book

Market Risk in the Trading Book is the risk of changes in the value of the trading portfolio when market risks occur, resulting from price changes in the market.

The main risks that Rabobank is exposed to within the trading environment are interest rate risk (including basis risk), credit spread risk, commodity risk, and currency risk.

We aim for a modest exposure to market movements in our trading environment, with customer risk redistribution and dynamic management by hedging as part of our strategy. Market risk in the trading environment is monitored at least daily. The main risk indicators used to measure overall market risk in the trading book are:

• Event Risk: based on loss estimates generated from extreme but plausible moves in risk factors by using sensitivity, hypothetical, and historical stress scenarios. For Rabobank, event risk in the trading environment is mostly driven by interest rates, cross currency and credit-related scenarios.

• Value at Risk (VaR): based on a historical simulation that uses one year of historical data. Interest rate risk and credit spread risk are the main contributors to VaR.

Market Risk in the Trading Book

Rabobank works with an extensive set of complementary parameters and controls to monitor market risk in the trading book.

The main risk indicator for the loan underwriting business is the stress limit, for which shocks are applied, that depends on credit risk scores, and the market categorization of the debt, to generate potential loss in case of very severe market price movements. The bank has a stringent loan underwriting and approval process for every deal, to account for potential market stress factors, current market conditions, and absolute exposure levels.

In 2025, Financial Markets were dominated by the US economic policy on trade tariffs targeting trade partners across the globe, raising concerns about the global economic outlook. The uncertainty contributed to increased market volatility in mainly global stock and bond markets and to a shift in investment flows from U.S. dollar-denominated assets towards European markets. This also affected U.S. Treasury bonds and led to a depreciation of the U.S. dollar against major currencies, including the euro. Further, yields on European sovereign bonds increased over concerns on fiscal policy changes and increased defense spending. Central banks continued to lower interest rates in 2025 in line with market expectations.

Rabobank's trading desk adapted well to market uncertainties. In general, the trading desks managed risks diligently given the increased volatility.

Loan underwriting market activity remained low due to the uncertainty surrounding trade tariffs with primary markets ceasing activity in April. Both primary and secondary markets gained momentum after the partial policy reversal and further tariff agreements and recovered to pre-disruption levels with robust issuance across both Investment Grade and Leveraged segments.

Looking ahead, we expect geopolitical tensions and uncertainty around trade restrictions to remain the main themes for the next year. These factors could further negatively impact domestic growth and increase inflation, leaving central banks with a limited scope for monetary policy adjustments. The current low-risk exposure strategically positions the bank to handle future uncertainties related to interest and credit risk factors. The risk profile is expected to remain well within the set risk appetite.

Operational Risk

Operational risk involves failures in how an organization operates. It is tied to internal breakdowns or external shocks that interrupt normal operations.
Operational risk is defined as the risk resulting from inadequate or failed internal processes, people and systems or external events, including, but not limited to, legal risk or information and communication technology (ICT) risk, but excluding strategic and reputational risk as they are an inevitable part of Rabobank's business activities. Rabobank manages these operational risks within the boundaries set by our risk appetite as appropriate to the complexity and size of our organization and proactively monitors the risks and takes action where needed. Managing operational risks is an integral part of the way we do business supported by risk and control activities.

Transformation Risk in the organization

The organization continued to pursue significant transformation initiatives in 2025 aimed at enhancing operational efficiency and customer experience. This transformation risk continues to pose challenges to people, processes, and IT, which was actively managed through robust project governance, frequent risk assessments, and close monitoring of change impacts.

Product Governance

Product governance remained a priority to safeguard customers and the organization from emerging risks. Our products must fit our customers' needs and align with Rabobank's sustainability vision. Regular product lifecycle reviews are performed to ensure adherence with regulatory requirements and internal standards, supporting responsible innovation and minimizing risk exposure.

Operational Resilience

Global cyber threats remained elevated in 2025, driven by persistent geopolitical tensions and vulnerabilities within supply chains. Emerging technologies, including the misuse of generative AI, introduced additional complexity to the risk landscape. Rabobank remains committed to safeguarding customer data, ensuring uninterrupted service availability, and maintaining trust. To achieve these objectives, Rabobank continues to leverage innovation to strengthen threat defences and enhance resilience in an increasingly complex digital environment.

Rabobank strengthened its operational resilience across four critical areas in 2025. Business Continuity Management (BCM) was reinforced through quality enhancement of Group wide Business Continuity Plans and integrated scenario analyses to address geopolitical and environmental challenges. Information Security was boosted by enhanced controls, proactive intelligence monitoring, and advanced technologies to counter increasingly sophisticated cyber threats and generative AI misuse. Information Technology improvements included institutionalizing a method for measurement and steering of the IT portfolio rationalization and standardizing processes, while maintaining agility to manage emerging risks from GenAI and quantum computing. Finally, Third-Party Risk Management increased focus on external supplier dependencies, concentration risks and the impact of geopolitical tensions on vendor availability.

Enhancements in our Data Management framework further strengthened our delivery of safe and available banking products to our customers, while safeguarding customer data.

Risk Profile Performance

Additional progress was made in managing operational risks during 2025. The overall profile remains elevated but stable for newly reported incidents. Remediation programs are in place to continue to lower the operational risk profile. The majority of Rabobank's operational risk losses in 2025 were related to Execution, Delivery and Process Management.

Compliance Risk

Compliance oversees the risk of impairment of Rabobank’s integrity. Safeguarding Rabobank’s integrity is essential to protect the rights and interests of our customers as well as the reputation and trustworthiness of Rabobank.

Rabobank is committed to comply with all applicable laws and regulations, and to uphold the spirit of the law. This principle is foundational to our operations and informs every aspect of our decision-making. Our robust Compliance Framework provides the structures and processes that enable effective management of compliance risks.

Financial Economic Crime

As a financial gatekeeper, Rabobank holds a pivotal responsibility in preventing, detecting, and reporting financial crime. We have strong controls against money laundering, terrorist financing, sanctions violations, and bribery. Through active participation in various industry forums, we engage with regulators to promote a risk-based, proportionate, and customer-focused implementation of all AML Regulations.

DNB Instruction and Remediation

Following the completion of the remediation of compliance deficiencies related to the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (‘Wet ter voorkoming van witwassen en financieren van terrorisme’), Rabobank has continued to embed and maintain robust, operationally effective controls within its day-to-day business processes. In consultation with public stakeholders such as DNB and the Ministry of Finance, we apply these measures proportionately to ease administrative burdens for our customers.

Sanctions

Rabobank adheres to all applicable sanctions regimes established by governmental authorities and international bodies, ensuring compliance across its services and operations. Stringent monitoring, risk assessments and robust internal controls are in place for ensuring compliance with sanction regulations and to ensure proper reporting to DNB and/or the Financial Intelligence Unit (FIU) and other local competent authorities. Rabobank monitors developments in conflict areas and implements new, applicable sanction packages, including additions to existing restrictive measures, as they are released. The sanctions landscape is expected to remain highly volatile and complex. Rabobank is in close contact with DNB and the Dutch Ministry of Finance regarding sanctions developments.

Fraud

Rabobank remains vigilant in addressing evolving fraud risks driven by technological innovation, geopolitical developments, and market uncertainty. Emerging technologies such as AI and deepfakes introduce new complexities, while upcoming regulations shape our approach. We strengthen fraud detection, enhance our risk and control framework, and promote awareness among employees and customers. Our team of experts ensure timely compliance and effective preventive measures. Collaboration is key to our strategy. We work together with other financial institutions and through Public-Private Partnerships to manage fraud risk and make a positive contribution to society.

Anti-Corruption and Anti-Bribery

Rabobank is committed to contributing to a sustainable society by operating with integrity and aligning with economic, social, and ecological responsibilities. Rabobank complies with all relevant anti-bribery and corruption laws and regulations and strives to enhance our anti-bribery and corruption framework.  Rabobank prohibits any form of bribery or corruption where it has actual knowledge or reasonable grounds. Rabobank employees are encouraged to report suspicions of misconduct or irregularities, including criminal offences such as bribery and corruption, via the (whistleblowing) reporting channels in accordance with the Rabobank’s Global Policy on Whistleblowing.

Transaction Reporting

We are improving our transaction reporting framework to meet evolving global requirements. In 2025, we implemented changes related to Hong Kong Monetary Authority and Canadian derivatives reporting. We are supporting ESMA’s simplification efforts under the Markets in Financial Instruments Regulation (MiFIR), European Market Infrastructure Regulation (EMIR) and Securities Financing Transactions Regulation (SFTR) to reduce the reporting burden for both supervisors and market participants, as well as similar Financial Conduct Authority initiatives in the UK.

Data Privacy

Rabobank aims to protect personal data and safeguard privacy. In 2025, we updated our Global Privacy Policy Framework and Global Policy on Record Keeping, strengthening compliance and aligning with upcoming regulatory changes. This policy framework governs the responsible use of personal data in digitalization, including artificial intelligence, supporting our position as a data-driven bank. The Anti-Money Laundering Regulation (AMLR) will bring new mandatory requirements for processing personal data, and we are embedding Privacy by Design principles throughout the AMLR implementation. Rabobank continues to strengthen its data protection and privacy practices. In 2025, Rabobank implemented a new privacy management platform which serves as a foundation for more robust privacy implementation and oversight. Continuous monitoring of external developments, regular employee training, and maintaining technical and organizational measures ensure that we adapt to new risks and safeguard the trust placed in us by our customers and stakeholders.

Treating Clients Fairly

Treating Clients Fairly (TCF) is a priority for Rabobank. We focus on providing adequate advice, execution-only services, responsible lending, clear product information, preventing discrimination, ensuring accessibility, and learning from customer feedback. Sustainable products for our customers and ESG requirements form an integral part of our products and services to customers. The European Accessibility Act (EAA) was implemented on 28 June 2025. Additionally, to maintain access to responsible consumer credit for Dutch consumers, Rabobank partnered with ABN AMRO to integrate Alfam’s activities into Rabobank.

Furthermore,  Rabobank is proactively compensating certain customers after not consistently adjusting interest rates on certain consumer credit products in line with the reference rate indicated by the Dutch Financial Services Complaints Tribunal (Kifid). The bank has issued letters to the remaining customers currently entitled to compensation. For customers who may become entitled in the future, activities will be integrated in standard business operations. A residual provision of EUR 3.5 million remains.

Greenwashing

In 2025, Rabobank focused on embedding the Global Greenwashing Standard into day-to-day practices and strengthening oversight to meet evolving regulatory expectations. Rabobank continued to embed strong governance and rigorous controls over external communications, reflecting its proactive commitment to transparency and stakeholder trust. Growing scrutiny from regulators and NGOs further validated the importance of these measures, reinforcing our determination to maintain adequate standards.

Rabobank remains focused on addressing regulatory divergence and evolving sustainability requirements across the diverse jurisdictions in which it operates, including various EU initiatives aimed at simplifying sustainability-related regulations.

Risk Profile Performance

Further progress was made in managing compliance-related risks during 2025. The overall compliance risk profile has improved with a positive outlook for 2026. Notable progress has been made in the remediation of highest risks. Risk step-downs for Sanctions Violation, Data Privacy, and External Fraud were achieved in 2025, additional remediation milestones are planned in 2026 to further reduce risk.

Model Risk

Model Risk is the risk of incorrect model design, improper implementation of a correct model, or inappropriate application of a correct model.

Models are now embedded in Rabobank’s DNA, powering processes, products, and services to deliver customer-centric solutions and enable data-driven decisions. In an ever-changing environment, models are not just tools, they are strategic assets that help us stay relevant and ahead of the game.

With opportunity comes responsibility. Managing model risk is critical for sound decision-making, financial stability, and regulatory compliance. Our comprehensive Model Risk Management framework spans the full lifecycle, from initiation and development to independent validation and governance, ensuring models are reliable androbust, and are used responsibly.

We continue to invest significantly in:

• Strengthening controls and mitigating risks while simplifying

• Advancing regulatory compliance

• Steering model strategy to enable sustainable innovation

2025 Highlights 

On the credit models, significant progress was made on the Return to Compliance (RtC) program, along with the overall regulatory obligations. Key milestones included the go-live of IPRE and the completion of onsite IMIs for the Residential Mortgages, Retail SME and Rural rating systems. Following receipt of the final decision letter, the go-live of the Residential Mortgages rating system is planned for Q1 2026. Pending receipt of final decision letters, go-live for the Retail SME and Rural rating systems is planned for 2026. The IFRS9 Corporate model went live, while the implementation of other IFRS9 models is ongoing. The Residential Mortgages Early Warning Signal (EWS) model went live in Q1 2025. New EWS models have been developed for Rural and for the smaller segment within the Corporate portfolio, and the Residential Mortgages EWS model has been enhanced to broaden its scope of application. All three of these models are planned to go live in 2026.

On compliance models, the models within the remediation RNL scope along with most other compliance models were validated enabling the closure of the FEC Remediation program.

AI Risk

In 2025, the CRO domain laid the foundation for robust AI risk management by updating policies, in alignment with EU AI Act requirements, establishing solid AI risk governance. Over the next three years, the focus will be on embedding integrated AI risk management into the bank’s DNA. Key milestones include integrating AI as a cross-enterprise risk driver and implementing shared tooling for risk oversight. The roadmap also emphasizes strong cross-domain collaboration, consistent practices across business lines, and strategic funding to support the full AI lifecycle. Integral and integrated AI risk management will ensure responsible AI innovation and sustained regulatory compliance across the organization.

Sustainability

Interview with our Chief Sustainability Officer

“As a cooperative bank, we believe sustainable living and working should be affordable, available and accessible. We aim to play our part in achieving this. For us, this means we pursue our three sustainability aspirations: act on climate, value nature, and enable people to future proof their activities, homes, and businesses. From an organizational perspective, our focus is on ensuring that these aspirations are taken into account in our business decisions. That’s why I am proud that over the past year, we’ve matured in how we balance risk, return, and sustainability. It will keep evolving and it’s never truly ‘finished’, but sustainability is now part of our strategic and commercial considerations and decisions – especially on climate. Leveraging financed emissions as a progress indicator has been instrumental in the progress we made.”

“We made progress across all three aspirations. On Nature, we have a sharper view of material topics – land-use, water, and pollution – across the regions and sectors where we cooperate across bank functions such as risk, data analytics, and relationship managers. We also advanced our nature‑metric development. Metrics are vital to assess nature‑related impacts and risks – ours and our customers’ – and build resilience from there. Our progress on the Brazil land‑use strategy deserves highlighting. It is a regional strategy to complement our global deforestation and land-use policy. The strategy focuses on land-use change risks, strengthens monitoring, and accelerates product development.

It’s a good example of linking ambition to real-economy action and portfolio management. And I want to mention our new five-year partnership with WWF, which is shaped around redirecting financial flows to protect nature from further deforestation and negative land conversion.”

“On People, we launched a bank-wide vision that clarifies how we consider human rights in each of our roles: as employer, as procurer, and as financial services provider. And we performed a group-wide saliency assessment, to identify where human rights could potentially be most at risk in our role as a financial services provider. In this stage our focus will be on addressing human rights risks in the context of labor exploitation, livelihood and lands and social inclusion.”

“There is much more, and I can’t mention everything, but I am really proud of our sustainability community. It’s an employee community that organizes sustainability focused webinars, workshops, film screenings to inspire and activate. With over 7,500 members, it’s the largest community in the bank.
To me that indicates the high level of interest in the topic of sustainability
and the motivation to keep driving it.”

What shifts did you observe in the external landscape over the past year?

“In 2025, we have seen both the frequency and severity of extreme weather events increase. Skepticism around the feasibility of limiting global warming to 1.5°C is growing. Geopolitical instability is increasingly putting human rights at risk. In addition, it’s quite obvious that the international landscape has reached new levels of complexity. In the US, we are witnessing significant changes in the context in which we operate, including regulatory changes. In the EU, sustainability-related regulations have been revised, with reduced ambition levels. And especially in the climate area, we see international commitments wavering. The Net-Zero Banking Alliance (NZBA) ceasing its operations in October of last year, is the most prominent example. It is important in this situation that we keep navigating with the right compass toward the future and continue delivering on our sustainability aspirations.”

“On the other hand, disclosure requirements such as the CSRD remain in place. Nature related disclosure requirements are developing, and commitments to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and UN Principles for Responsible Banking have not changed. Supervisory expectations and requirements, for example on addressing the risks associated with climate change, are evolving. Additionally, it is my experience and expectation that when governments and international commitments step back, other stakeholders step up. NGOs obviously will not walk away from their societal role. And innovation, science and finance, will redirect their efforts towards areas that offer potential and opportunity. Areas like the energy transition and adaptation to climate change impact. We believe that sustainability is a driver of competitiveness: customers that adapt will be stronger, and we must be ready to help them. We feel supported in our thinking by the fact that sustainable finance as well financing of renewable energy is increasing."

How does this context influence Rabobank’s strategy – what stays the same, and what evolves?

“What stays the same is who we are. We are a bank that is expected to be a stable factor in the Dutch economy and international food and agricultural sectors. What is more, we are a cooperative. We don’t have shareholders; we have members and client councils – more than 2.3 million customers are member. By listening closely, we try and use our knowledge, network, and financial solutions to support their goals and advance our sustainability ambitions. So, we allocate funds through cooperative initiatives and our cooperative dividend that help address societal changes."

"From a sustainability perspective, our north star is unchanged: we act on climate, value nature, and enable people. We have voiced this on numerous occasions over the course of 2025. We will continue to be clear about what we will – and won’t – finance. And we’ll keep aiming for real‑economy impact through our products and services: better terms for front‑runners, sustainable investments, and blended‑finance solutions that help make financed activities future‑ready and more competitive.”

“We can’t deny though, that in a world of shifting politics and rising skepticism, we need to reposition sustainability. Sustainability is not just about compliance, it is about competitiveness. Acting on sustainability builds our customers and our bank’s resilience and determines our ability for future growth. Regarding the unfolding, 1.5-degree global warming debate; as a sailor, I see our ambitions as a lodestar, a constant beacon that gives you direction. We aren't thinking of changing or lowering our ambitions – after all, an overshoot was always projected – but the winds are shifting and we are preparing for higher levels of global warming. We’ll need to redistribute our actions and efforts among mitigation and adaptation. Done right, that’s a win-win – customers improve long‑term resilience and we improve risk profiles and, over time, portfolio composition. That way, our sustainability ambitions serve as that star on the horizon guiding us closer to where we need to be."

What’s in store for 2026? What steps do we still have to take?

“What hasn’t changed is the science: climate change and nature loss are still happening and impacts are being felt more clearly all the time: droughts, floods and supply‑chain disruptions will keep affecting activities and businesses – from coffee producers in Brazil to farmers in Australia – and that reality ultimately flows through to banks' results as well. As a result, I expect that financing adaptation and resilience will move from niche to core banking, and we will lean into that shift with solutions that strengthen customers’ business models.”

“Within this context, I think the sustainability space benefits from to motivational targets that guide transformation and support growth. Adapting to climate- and nature-related risks can lead to opportunities. Nature based solutions alongside new technologies, smarter infrastructure, value-chain innovations, and increased attention for human rights, can lift productivity and reduce risks and losses. Our role is to support this.”

“We will need to continue explaining our role. To be clearer about what we can and cannot do. Policy-based acceptance and risk criteria sit within our sphere of influence. At the same time, financing a customer does not mean that a customer is already 100% future proof; most will still need to transition to some extent. We can support with the right products and propositions, but we cannot force adoption – customers decide, and our job is to support them to navigate their challenges and opportunities and make informed decisions.“

“Acknowledging that our influence is, in a way limited, is sometimes at odds with our sustainability ambitions. So monitoring is essential. We will need to continue, improve and expand how we monitor impacts, through financed emissions and – the still evolving – nature metrics and people indicators. Internally, we will continue to equip colleagues to move from compliance to competitiveness – in day-to-day operations and in customer engagement – so that sustainability informs decisions on capital allocation, portfolio composition and risk appetite, and is part of our ongoing dialogue with our customers.”

“In sum, I am proud of what we’ve achieved, but humble about what remains. The road ahead demands realism and momentum, and above all cooperation. We won’t please everyone on pace, but – as a cooperative bank – we want to do this together – with customers, peers, civil society and policymakers – and we will play our role in accelerating the transition.”

Sustainability Statements

General Information

Disclosure Requirement (DR)

This section highlights how Rabobank’s Sustainability Statements have been prepared in line with the principles of the ESRS.

Rabobank's Consolidated Sustainability Statements (hereafter Sustainability Statements) have been prepared in accordance with European Sustainability Reporting Standards (ESRS) as adopted by the European Union (EU). The Sustainability Statements have been prepared on the basis of the policies set out in this section.

Rabobank's Sustainability Statements include the sustainability information of Coöperatieve Rabobank U.A. and its consolidated subsidiaries. The scope of consolidation of the Sustainability Statements is the same as for the Consolidated Financial Statements as included in Note 2.2 to Rabobank's Consolidated Financial Statements, unless otherwise indicated.

The information provided in Rabobank’s Sustainability Statements includes information on the material impacts, risks and opportunities in connection with Rabobank’s own operations, and direct and indirect business relationships in the upstream and/or downstream value chain. Rabobank’s material impacts, risks and opportunities are assessed following the double materiality principle. For more information on the double materiality assessment, see the Description of Our Processes to Identify and Assess Material Impacts, Risks and Opportunities. In preparing these Sustainability Statements, management has exercised its judgement in making estimates and assumptions concerning the future. Actual results may differ from those estimates and assumptions.

Disclosures regarding policies, actions, targets, and metrics concerning our own operations, and our upstream and downstream value chain are presented in the appropriate sections of the Sustainability Statements.

Sustainability is an on-going practice that responds to and may trigger changes in the company’s strategy, business model, due diligence, activities, business relationships, operating, sourcing, and selling practices that could be relevant for stakeholders. The Sustainability Statements may therefore not include every impact, risk and opportunity or additional entity-specific disclosure that individual stakeholders may consider important in their own assessments.

Estimation and outcome uncertainty

In the metrics disclosed in Rabobank's Sustainability Statements, we use estimates, and assumptions. The metrics disclosed as part of ESRS E1-6 climate change contains downstream value chain data. The information on the value chain estimation applied, and sources of estimation and outcome uncertainty, are presented in Appendix 6: Methodology Financed Emissions. The main estimation and outcome uncertainty can be summarized as follow:

• The majority of our customers emissions are related to Food & Agri sectors, where emissions data and science-based decarbonization pathways are scarce. More than half of these emissions are non-CO₂ emissions, which are impossible to fully abate; there will always be residual emissions from for example livestock activities. The implication is that non-CO₂ emissions will not be net-zero in 2050.

• Our absolute emissions target is sensitive to balance sheet fluctuations and therefore does not provide a completely accurate picture of our customers’ GHG reduction performance. The emissions intensity targets we have set for sector x region combinations on the other hand, do not say anything about the total amount of GHG gasses being emitted. The implication is that despite progress on the intensity-based targets our absolute emissions could still increase. 

• Among the main challenges Rabobank and other banks face is the lack of customer-reported GHG emissions data. Therefore, we have to use proxy indicators (see bullet below) to estimate the majority of client emissions. Over time methodologies will improve, more data will become available and bottom-up (company specific) numbers will replace top-down (sector) estimates. This means that data may need to be restated in future and comparisons over time will be difficult until methodologies and regulations are more settled.

• In Rabobank we use the PCAF standard for accounting and disclosing financed emissions. The availability, specificity and accuracy of the data we use to make these calculations varies widely per sector. Therefore, the financed emissions overview presented in this report should be interpreted as our "estimates on a best effort basis", in accordance with PCAF methodology, using the current information and data we have at hand. Where possible, we have used client-reported GHG emissions. The average data quality score of our in scope portfolio for scope 1 and 2 is 3.6. The average data quality score of our in scope portfolio for scope 3 is 3.8.

For the gender pay gap calculation as part of ESRS S1-16, we use an estimated variable pay. Further information is presented in the own workforce section of the Appendix 1: Methodology & Definitions Sustainability Statements.

Changes in preparation or presentation of sustainability information

Rabobank’s Sustainability Statements present comparative information, when available or when already disclosed in the prior year. In the reporting period FY2025, Rabobank updated the methodology used to calculate the gender pay gap by refining the estimate of variable pay. The gender pay gap is calculated as the difference between the average gross hourly pay of male and female employees, expressed as a percentage of the average gross hourly pay of male employees, in line with ESRS S1-16.

The change was implemented to improve the accuracy of the disclosure with new information. This change is in line with with ESRS 1 requirements and enhances the comparability and transparency of the disclosed metric. As a result of this change, the gender pay gap reported for FY2024 and FY2023, is not fully comparable with figures reported for prior periods. Prior-period figures have been restated using the updated methodology to ensure comparability. The restated prior-period figures are presented in the ESRS S1 Own workforce metrics section of the Sustainability Statements. Rabobank applies the updated methodology consistently across reporting periods going forward.

No other substantial changes nor material errors occurred compared to the previous reporting period.

Incorporation by reference

Rabobank incorporates information by reference to the Sustainability Statements for the following other sections (for ESRS relevant disclosures requirements) of Rabobank's Annual Report:

Time horizons, transitional provisions, and data collection

In general, we assess material impacts, risks and opportunities over the short, medium and long term. Since sustainability-related matters often materialize over time, the nature of these topics warrants more forward-looking reporting. For forward-looking information on Rabobank’s material impacts, risks and opportunities in the Sustainability Statements, we consistently apply the definitions provided by ESRS:

• 1 year as short term;

• Between 1 year and 5 years as medium term; and

• More than 5 years as long term

Where our time horizons deviate from these general guiding principles, this is disclosed when reporting on the specific topic or risk tool used.

Disclosures in relation to incorporation by reference, transitional provisions and use of phase-in provisions in accordance with Appendix C of ESRS 1, and data collection of sustainability information are presented in Appendix 1: Methodology & Definitions Sustainability Statements.

The following section explains in more detail how Rabobank has set out its governance processes to overlook and manage its sustainability activities.

Rabobank's sustainability governance consists of the Supervisory Board, Managing Board, Sustainability Implementation Management Team and Risk Management Committee Group. Internal rules are available for each body and committee which provide the mandate, responsibilities, scope, hierarchical relationships, membership, authority levels, and modalities of these bodies and committees. The management and supervisory bodies, as referred to under the ESRS, are Rabobank's Managing Board and Supervisory Board.

For the general Corporate Governance, composition and diversity of the Managing Board and Supervisory Board, please refer to the members of the Managing and Supervisory Board section of the Corporate Governance of Rabobank's Annual Report and our section metrics and targets of our own workforce in these Sustainability Statements.

Supervisory Board

The Supervisory Board (SB) is responsible for supervising and advising the Managing Board (MB) on all relevant business matters, including sustainability. This encompasses the responsibility of supervising and advising the MB on (the implementation of) the sustainability strategy, ensuring new developments align with Rabobank's strategy and purpose. Additionally, the SB oversees the MB's stakeholder engagement. Sustainability topics are also discussed and prepared in SB committees (e.g., the Cooperative and Sustainability Committee).

Managing Board

The MB is responsible for setting and implementing the bank’s corporate strategy, including business, risk and sustainability strategies. The MB is responsible for adequately embedding sustainability impacts, risks, opportunities and dependencies within the corporate strategy, setting the risk management framework and overseeing its implementation. The MB is responsible for the implementation of the laws, regulations and commitments necessary to comply with sustainability regulations, expectations and aspirations.

The MB meets in principle on a weekly basis. The MB is assisted by the Company Secretary, who ensures that proper procedures are followed and that the obligations under relevant legislation and the Articles of Association are complied with. Together with the Company Secretary, and based on input from the Chief Sustainability Officer (CSO), the Chair sets a rolling agenda on matters (including sustainability) to discuss during the MB meetings. This rolling agenda is group-wide, with allocated MB and topic owners and includes sustainability reporting, the double materiality assessment (DMA) and other material sustainability topics as recurring agenda items.

Sustainability Implementation Management Team

The Sustainability Implementation Management Team (IMT) consists of the Sustainability leads from key domains and departments and is chaired by the CSO. The CSO reports to the Chair of the MB. The IMT reports and is accountable to the MB and ensures the implementation of Rabobank's sustainability vision, ambitions, strategy, roadmap, regulations and commitments across Rabobank Group. It also provides advice to the MB on decision-making regarding sustainability strategy and ambitions. Responsibilities of the IMT include guidance of and alignment of the sustainability activities within Rabobank. The approval of policies is not within the scope of the IMT. Sustainability policies are discussed and aligned in the IMT but follow the regular approval processes via RMC Group and MB. The IMT provides advice to the RMC Group on the approval of these policies.

Risk Management Committee Group

The Risk Management Committee Group (RMC Group) is mandated by the MB to establish and maintain the risk management framework, including risk management policies and risk limits, oversee the implementation of the risk management framework, assess the management of risks and act as the guardian of the risks taken by Rabobank Group. The RMC Group is chaired by the Chief Risk Officer (CRO) and includes MB members and members of senior management of relevant domains. The RMC Group is entrusted with the oversight of the bank’s Risk Appetite Statement (RAS). As part of its oversight, the RMC Group receives updates on Rabobank's risk management approach to ESG, including the bank's approach to stress testing and its integration into existing risk management processes.

Business Units

Business unit management teams, under the oversight of the MB, are primarily responsible for implementing and further detailing the strategy within their business unit, including relevant sustainability and risk aspects, and provide advice and proposals on the strategic considerations involved. Their sector & region plans incorporate these elements in alignment with group policies and guidance.

The business domain members of the MB are primarily responsible for managing sustainability impact, risk, opportunities and dependencies in their respective domains as part of their role in managing overall customer and business performance.

Supervisory Board members gain knowledge and expertise with regard to sustainability topics via several permanent education sessions. During 2025, 3 out of 7 permanent education sessions were focused on sustainability. Managing Board members regularly attend these permanent education sessions. The topics discussed align largely with the impacts, risks and opportunities that result from the double materiality assessment and topics deemed important by internal and external stakeholders. Furthermore, the MB members have direct access to relevant sustainability expertise within their domains, and they are informed and consulted on the most relevant sustainability topics through the IMT and RMC.

The remuneration of the Managing Board and Supervisory Board is limited to fixed pay; members are not eligible for variable compensation as part of their regular remuneration package. More information is available in the Remuneration section in the Annual Report.

Rabobank's Statement on Due Diligence is presented in Appendix 1: Methodology & Definitions Sustainability Statements.

When preparing information for the Sustainability Statements, data quality reviews are performed, plausibility checks are executed and where possible alignment with external data is ensured. The Sustainability Statements are submitted to internal experts for review and are approved by senior management (including the Managing Board, the Audit Committee of the Supervisory Board and the full Supervisory Board) prior to publication. This to mitigate the risks of material misstatement. In addition, information is provided to our external auditor enabling them to perform their limited assurance engagement. Since sustainability reporting is still developing, we are also still developing and improving our risk management and internal control procedures with regard to the Sustainability Statements.

The following section explains in more detail how Rabobank’s approach to sustainability aligns with its mission to ‘Grow a better world together’ and how sustainability is embedded in Rabobank’s overall group strategy.

As described in our overall group strategy, it is Rabobank’s mission to Grow a better world together. Our group strategy cascades from our mission to our ambition to our four drivers (Excellent Customer Focus, Meaningful Cooperative, Rock-Solid Bank, Empowered Employees), values and strategic priorities. In the Strategy section, we explain our group strategy in more detail.

Essentially, our sustainability aspirations (elaborated on in the Sustainability section) define our long‑term sustainability ambitions, while the material topics resulting from the double materiality assessment (elaborated on in the Outcome Double Materiality Assessment) anchor these ambitions in the most relevant impacts, risks and opportunities across our value chain. To help realize our aspirations and concurrently address material topics, we apply a generic approach to all three of our sustainability aspirations (act on climate, value nature, enable people).

Policy development to provide our strategy with guardrails

Acceptance requirements are requirements an in scope customer or business partner must meet to be able to (continue to) receive financing from or do business with Rabobank. The acceptance requirements are set at customer and business partner-level or at ‘activity’ level. Acceptance criteria are described in each of the individual topics and are summarized in Rabobank’s lists of non-accepted customers and non-accepted activities, which can be found at the end of our sustainability policies briefing document.

Identifying climate and nature sectors to prioritize strategy execution

Based on the identify and assess-step of our approach and the outcomes of the double materiality assessment, we prioritize sector x region combinations (19 for climate, 12 for nature) and develop plans for each. These are specific plans with which we aim to achieve climate and other targets and manage the relevant sustainability impacts, risks and opportunities. The levers (help customers transition, help move the system, optimize our portfolio for sustainability) are used to classify the types of actions in the plans.

Sustainability is embedded in Rabobank’s strategic steering cycle

Sustainability (including each of the above elements, our sustainable finance ambition, acceptance requirements and transition plans) is integrated into how we steer the bank. We balance risk, return and sustainability impact and use a six‑step strategic steering cycle to connect our ambitions and material topics to planning and portfolio steering across Rabobank.

1. Overarching: strategy, policy & governance

Our mission and sustainability ambitions are embedded in our decision‑making. Theme and sector policies set requirements for in scope customer and business partners on climate, nature and people topics. Our governance model assigns clear roles and responsibilities to ensure consistent execution and oversight.

2. Outlook and materiality

Each year we assess key external developments and perform a double materiality assessment to determine which impacts, risks and opportunities are most relevant to our business model and value chain. These insights inform prioritization and are disclosed in the ESRS topical standards of these Sustainability Statements.

3. Sustainability impact and risk assessment

We assess climate, nature and people‑related impacts, risks and opportunities across customers and portfolios and use these insights to inform customer engagement, underwriting and risk management. Customer‑level sustainability acceptance, performance and ESG‑risk insights are applied consistently in the customer journey and aggregated to support underwriting decisions, pricing and risk appetite limits, and portfolio steering.

Our heatmaps and scenario analyses program helps us understand how climate‑ and nature‑related developments may affect customers and portfolios over time. These insights inform actions across the bank and are also reflected in IFRS 9 through climate‑environmental adjustments (via a Risk Adjustment Factor and management adjustments). This approach ensures that our expected credit loss estimates incorporate the forward‑looking effects we observe. ESG risk scores and climate‑nature data support day‑to‑day credit decisions and customer dialogue.

4. Transition plans

Our sector x region plans outline how sectors can transition in line with sustainability ambitions and changing external conditions. These plans help determine portfolio priorities, shape customer dialogues and identify transition levers at the sector and regional level. Transition plans are updated as new insights emerge and support a consistent forward‑looking view across the bank.

5. Medium‑Term Plan (MTP) & Risk Appetite Statement (RAS)

We integrate sustainability into strategic steering through KPIs, portfolio targets and risk‑appetite limits. In the MTP, sustainability KPIs, sustainable‑asset targets and portfolio‑wide metrics (e.g., financed emissions) steer portfolio composition and the balance between risk, return and sustainability impact. In the RAS, sustainability‑related risk indicators and limits link strategic objectives to clear guardrails for acceptable risk and desired portfolio direction.

6. Monitoring and reporting

We monitor sustainability performance at the customer, portfolio and bank level to stay in control of developments and to support informed decision‑making. At the customer level, we use structured sustainability assessments to identify changes in sustainability performance and to determine where additional engagement may be needed. At the portfolio level, we track indicators such as sustainable finance volumes, financed emissions, the distribution of energy‑label data and developments in climate‑ and nature‑related risk exposures. This monitoring helps us understand how our portfolio is progressing, where risks may emerge and where targeted actions can support our sustainability ambitions. We report on our sustainability progress through this Annual Report, and other external disclosures.

Sustainable Finance as a Means to Deliver on our Strategy

With the scale of capital required for the energy and food systems transitions, Rabobank sees a strategic opportunity and a need to mobilize larger volumes of sustainable finance. Our sustainable finance product offerings help us manage our portfolio and intend to support our customers in their transition. In recognition of its strategic importance, sustainable finance is being integrated in our medium‑term planning process, balance sheet management, and our broader risk, return and sustainability decision framework.

An ambition level¹ has been set at EUR 83 billion in 2030 for sustainable assets (2025: EUR 63,9 billion; 2024: EUR 48,5 billion)². In addition, Rabobank raises sustainable funding - such as Green Bonds and Green Residential Mortgage Backed Securities (RMBS) - to further support the bank's sustainability aspirations. We report yearly on the exposures we classify as sustainable assets, and sustainable funding, along with the rationale behind the exposure reported. Rabobank reports the outstanding sustainable finance exposure (i.e. drawn amounts).

Sustainable Finance

Sustainable Funding

As can be noted in the overview above, Rabobank's sustainable finance includes project finance for renewable energy, green loans that align with the LMA Green Loan Principles or the RVO Green Projects Scheme (Groenregeling), mortgages aligned with the EU Taxonomy substantial contribution criteria and Sustainability‑Linked Loans aligned with the LMA Sustainability-linked Loan Principles. Sustainable funding covers Rabobank green bonds and green money market instruments, Obvion green Residential Mortgage-Backed Securities and Rabo Groen Bank B.V. Green Savings. The detailed methodology of what we consider sustainable finance can be found in the Methodology & Definitions Sustainability Statements-section.

1. Our sustainable finance ambition is best effort and dependent on among others data availability, sustainable asset availability and market- and regulatory developments.
2. The ambition level has been adjusted upward from EUR 75 billion to EUR 83 billion to reflect the fact that DLL Sustainable Finance is now included in the scope of the reported sustainable finance figures.

The interaction with our stakeholders serves as both input and output for our business model. We distinguish direct stakeholders (customers, members, investors and employees) and indirect stakeholders (NGOs, public service bodies, communities, governing and supervisory bodies, other banks, the media and regulators).

Stakeholder Engagement

We aim to engage in strategic, constructive, and proactive dialogues with our stakeholders. As a bank of systemic importance, we engage with many stakeholders, who are important to us. For example, based on our communication with members, we develop and enhance our products and services, while ensuring compliance with laws and regulations.

Among the ways we engage with stakeholders is the method of appreciative inquiry dialogue. This method is applied to highlight and inquire economic, ecological, and societal issues from different perspectives. We leverage structured dialogues for multiple purposes: to achieve a common local, regional, and/or national approach; to explore themes that are important to our members, customers and other stakeholders/society as a whole; and to translate the outcomes - where possible - into input for our strategy, further exploring insights per theme, creating connections within chains and/or regions and engaging in dialogues with employees.

In addition, we engage with environmental and/or social welfare organizations on numerous topics, with a variety of stakeholders through several member/client councils, customer feedback platforms, customer and employee surveys, and through participation in initiatives that are being launched in the sectors in which we are involved. Our Managing Board members meet with customers, members, employees, politicians, NGOs and other stakeholders to discuss our strategic progress, receive their feedback on our contribution to society and discuss developments in the financial sector, both generally and specifically in relation to Rabobank.

Creating value for stakeholders

As a result of our activities, we have direct and indirect impact with possible favorable and/or unfavorable outcomes for one or more of our stakeholders.

Customers

We engage actively with our customers and create positive satisfaction through services such as financing and everyday banking and by sharing our knowledge through our research publications, our networks, our innovations and (digital) products. Our customers and other parties in the Food & Agri (F&A) value chain have a positive impact on the availability of food. However, F&A activities can also have a negative impact on the environment (by way of nitrogen and carbon emissions). We encourage our customers to reduce this negative impact as much as possible and to contribute to creating a regenerative ecosystem. We support them in these efforts e.g., by providing access to funding, sustainability-linked and green loans.

Members

Member involvement is crucial for us as a cooperative bank. By providing feedback, our members motivate us to execute our strategy and support us in the challenges we encounter along the way. We offer our members forums through which they can advise us on multiple topics, as well as vote on the designation of our cooperative dividend. Our members also influence our strategy through the General Members' Council. We monitor value creation for our members through the member engagement score.

Employees

We want to provide our employees with a great working environment and give them the opportunity to excel. With this in mind, our employees receive a wide range of training and development opportunities, with which we aim to create higher job satisfaction and employee engagement in the long term. The reason we attach so much importance to employee engagement is that we are convinced that there is a strong link between employee well-being and customer satisfaction: happy people create happy customers. Increasing diversity, equity and inclusion in our workforce helps improve our decision-making and ethical perspective. Furthermore, we believe it improves our services to customers. Ensuring that Rabobank remains a future-fit and agile organization also means that we need to keep attracting and retaining talent. At the same time, we will not be able to provide employment for all our current employees in the future. We try to minimize redundancies as much as possible by, for example, repositioning employees through internal secondments, re-skilling, and upskilling. It is important to us that employees who leave Rabobank, quickly succeed in finding employment elsewhere or are able to start a business. This is something we aim to facilitate through support.

Society

Our institutional role as a bank means that, on the one hand, we have an impact on economic and financial stability, and, on the other hand, we are subject to geopolitical developments and systemic risks. This, in turn, affects society. We drive economic growth in the long term through our banking activities in the transitions and topics that are important to us and our stakeholders. These investments can have a positive effect on well-being in the long term. Our local regions also have a business agenda that is based on all relevant dimensions of "sustainable well-being". Through banking activities and - for example - through our cooperative dividend, we have an impact on (social) safety, engagement, social contacts, financial resilience, and diversity and inclusion. Possible negative effects of our business are cases of fraud, low pay, and labor rights issues within our value chain. In the interaction with our customers and business partners, we monitor possible negative effects. If we encounter possible negative effects, we engage (e.g., through dialogues and engagement strategies) and monitor changes. If we continue to encounter possible negative effects, we can take measures (including ending the relationship).

Strategy and risk management framework

Our sustainability aspirations (act on climate, value nature, enable people) and the sustainability risks have been incorporated in the Group Strategy and risk management framework.  Various climate targets have been set, see the Metrics and Target section of the Climate Change Mitigation and Adaptation chapter. Nature-related effort targets are included in the Nature chapter. The sustainability policies have been established to outline the business principles Rabobank wishes to adhere to regarding sustainability in accordance with our mission and vision (please refer to the Strategy section). 

Rabobank assesses its risk drivers annually. Strategic drivers are a possible source of risk impact but could also result in opportunities. Sustainability is identified as a strategic risk driver and therefore forms an important part of the assessment. It is subsequently analyzed through a Double Materiality Assessment (DMA) which evaluates financial and impact materiality. This approach ensures that sustainability related risks and opportunities are systematically identified and incorporated in our risk management framework.

This is outlined in the Integrating our sustainability approach within Rabobank's overall group strategy section.

Integration of sustainability matters into the overall (risk) management process

The risks at portfolio level are managed through intensity-based emission targets, risk appetite setting, pricing, and acceptance & underwriting criteria.

• Climate Targets: Physical emission intensity targets have been set for sector x region combinations. In the Dutch F&A portfolio, we use absolute financed emission targets which is in alignment with the Dutch Financial Sector Climate Commitment. Please refer to the Environmental chapter for more details.

• Risk Appetite Setting: Various sustainability related metrics have been included in the Risk Appetite Statement.  This includes sector limits, exposures to sensitive sectors, sustainable assets, energy labels and compliance with sustainability policies.

• Pricing: The translation of ESG risk pricing into loans, products and services is part of the ESG risk model vision roadmap and will develop over time. Pricing is already integrated via RAROC (Risk Adjusted Return on Capital) targets derived from the medium-term planning process and vulnerable sectors where necessary and applicable. To encourage our customers to make the transition, we have put pricing incentives in place in the form of lower interest rates for customers with certain eco-labels (Impact Loans), sustainability KPIs (sustainability linked loans) or with concrete sustainability investments (Green Loans).

• Acceptance Criteria and Underwriting Criteria: Underwriting criteria can incorporate specific sustainability metrics.  Examples are compliance with sustainability policies, energy labels for commercial real estate, and criteria related to international energy transition customers.

Our portfolio and sustainability

Determining where we have the most impact and dependency on our environment starts with analyzing our portfolio. In the Dutch market, we have a large market share in the residential mortgage market and we are a big lender to Food & Agri (F&A) customers. Internationally, the bulk of our activities is focused on F&A. Regionally, our activities are mainly concentrated in North and South America, Europe, Australia, and New Zealand. Within the F&A sector, Commodities, Animal Protein, Dairy and Fresh Produce are most prominently represented in our portfolio. Details on our products, markets, revenues and more can be found in the Financial Statements. We report a breakdown on the segments we service in the note Segment Reporting as included in our Financial Statements.

Connectivity between the Sustainability Statements and the Financial Statements

The connectivity between the sustainability statements and the financial statements is explicitly reflected in the area of credit risk and non-financial risk. ESG risks are translated into IFRS impairment allowances through multiple channels. The impairment allowances are captured in the IFRS 9 ECL models. For further information on this, please refer to Rabobank's Consolidated Financial Statements Note 4.3.9.

In line with the ESRS standards, this section outlines the sustainability‑related impacts, risks, and opportunities. It provides an overview of how we identify, assess, and manage material topics, ensuring transparency in our Sustainability Statements.

As part of our double materiality assessment (DMA), we assessed our impact on people, society and environmental-related matters (impact materiality), and the impact on Rabobank arising from environmental, social and governance risks and opportunities (financial materiality). With this assessment, we determined which impacts, risks and opportunities are material to us and which sustainability topics are material for reporting purposes.

Our DMA considered our value chain (upstream and downstream) in addition to our own operations, and consisted of the following three main steps:

1. Understanding our value chain and identifying our environmental, social and governance topics (sustainability topics).

2. Assessment and determination of the material impacts, risks and opportunities related to sustainability.

3. Management response, including validation, approval and reporting.

Understanding our value chain and identifying our environmental, social and governance topics

Rabobank considers funding and savings, and procurement and vendor management as its upstream value chain. Its own operations relate to its own business activities as a bank and its downstream value chain comprises financial services provided to its direct customers and indirect relations. When defining Rabobank’s material impacts, risks and opportunities (IRO), we plotted the material topic within our value chain. The views of Rabobank's likely affected stakeholders are considered during this assessment. We consider our customers, members, investors and employees as our direct stakeholders, and society (NGOs, public service bodies, communities, and governing and supervisory bodies) as our indirect stakeholders.

Assessment and determination of the material impacts, risks and opportunities
related to sustainability topics

Impact materiality

When assessing and determining sustainability topics from an impact perspective, we consider actual or potential, positive or negative impacts on people or the environment over the short, medium or long term. We consider impacts connected to our own operations and upstream and downstream value chain, including through our products and services, as well as through our business relationships. Within our impact assessment, we focus on assessing the drivers of the sustainability related impacts.

For the assessment criteria and thresholds, and data sources and estimates related to impact materiality, refer to Appendix 1: Methodology & Definitions.

Financial materiality

The financial materiality of risks and opportunities is assessed based on a combination of the likelihood of occurrence and the potential magnitude of the financial effects over the short, medium or long term. We consider the average of three types of risk: financial, reputational and regulatory risks. The risk rating scales used are aligned with our Risk Control Framework and Global Standard on Risk Identification and Assessment.

For the assessment criteria and thresholds, and data sources and estimates related to financial materiality, refer to Appendix 1: Methodology & Definitions.

Management response, including validation, approval and reporting

Decision-making process and internal control procedures

The DMA is executed within CRO Enterprise Risk, and with the collaboration of Group Sustainability, Finance, and various other departments. The Sustainability Implementation Management Team (IMT) and Group Risk Management Committee (Group RMC) endorsed the outcome of the DMA. The outcome of the DMA has been discussed within the Managing Board and Supervisory Board and the Managing Board approved the material topics resulting from the DMA.

The DMA process is embedded in Rabobank's Risk Control Framework and Rabobank's Global Procedure on Double Materiality Assessment, as part of Rabobank's Global Policy on Risk Management. For the integration of sustainability topics in the (risk) management process, refer to Risk Management.

Process updates compared to prior year

For our Sustainability Statements, we executed the double materiality assessment in accordance with ESRS. This year, we identified 11 material sustainability topics (2024: 12 material sustainability topics).

We aligned our DMA process with Rabobank’s risk management framework, including risk identification and assessment processes. Which resulted in an increased materiality threshold to EUR 250 million (2024: EUR 240 million). In addition, we refined our material impacts, risks and opportunities which resulted in updated IRO descriptions for the topics of Water, Land degradation / Land-use change and Information- and safety-related impacts for consumers and/or end-users, and the removal of Affordable housing as entity-specific topics.

• Water (ESRS E3): Based on our analysis, this topic is no longer deemed material from a risk perspective. Water-usage risk is captured under climate change adaptation. Water remains material from a negative impact perspective.

• Land use (ESRS E4): This topic is no longer deemed material from a positive impact nor an opportunity perspective. Although our initiatives have or aim to have positive impact, their scope and impact are concentrated and insufficient to mitigate negative effects. This topic remains material from a negative impact and risk perspective.

• Information- and safety-related impacts for consumers and/or end-users (ESRS S4): In addition to the financial risk, our material negative impact has also been considered to be material.

• Affordable housing (entity-specific): Although this topic is considered of high importance for Rabobank, on a consolidated level the severity level is below threshold. Nevertheless, our high ambitions are important and reported as part of our impact on consumers and end-users.

For every material sustainability topic, we disclose the material information in relation to the material impacts, risks and/or opportunities assessed to be material. Therefore, our Sustainability Statements comply with the material and relevant disclosure requirements of the ESRS topical standards. For the disclosure requirements complied with in preparing the Sustainability Statements, refer to the general, environmental, social and governance information sections, where the reference to paragraphs is made in a content index. Within Rabobank's Sustainability Statements, we disclose the material information prescribed within a material disclosure requirement, if that information is relevant due to its significance in relation to the material topic, or when the disclosure of such information meets the users' decision-making needs.

For Rabobank's definitions of its material sustainability topics, refer to Appendix 1: Methodology & Definitions. For the datapoints that derive from other EU legislation as listed in appendix B of ESRS 2, please refer to Appendix 5: Datapoints that derive from other EU legislation.

At Rabobank, we aim to embed sustainability in our policies in line with regulations and commitments, and Rabobank’s own ambitions. Rabobank has a Policy Document Management (PDM) framework in place that defines requirements relating to the development and structure of policies. This section elaborates upon the setup of the sustainability policies and the integration in the customer credit journey. In the following sections, in which we describe the 11 material sustainability topics resulting from the DMA, we explain in more detail which aspects of the Theme and Sector policies are most relevant for each material topic.

Sustainability policies (Theme and Sector policies)

Rabobank’s sustainability policies distinguish between impacts within our direct control and those that are indirectly created through our relationships with customers (excluding private individuals) and business partners (business partners include suppliers and ‘non-supplying business partners’ such as intermediaries and donation receiving parties). We therefore set requirements for our own activities (Rabobank’s own activities) and for our in scope customers and business partners (acceptance requirements and performance monitoring), to the extent applicable. They are developed to support our business decision-making and are reviewed and updated as necessary. Acceptance requirements and performance monitoring are established per ‘theme’ and ‘sector’. In total, we have established sustainability policies on 4 Themes and 6 Sectors. These documents are all included in the Global Standard on Sustainability Acceptance and Performance. The sustainability policies apply to the Consolidated Coöperatieve Rabobank U.A. (together referred to as ‘Rabobank or ‘the bank’), unless explicitly stated otherwise. If an entity, business line or department can temporarily not comply with the sustainability policies, the management of each entity, business line or department must apply for a waiver. Waivers are required when all or parts of sustainability policies cannot be implemented by the deadline set and/or when elements of the (relevant) sustainability policies conflict with applicable laws or regulations, in which case local laws or regulations shall prevail.

Sustainability in the Customer Credit Journey

The sustainability policies are implemented as part of our customer credit journey (customer acceptance and performance). Within the credit journey we assess (a) the sustainability performance of our customers which includes compliance with the Rabobank sustainability policies, (b) whether specific financing facilities can be classified as sustainable finance, and (c) the impact of ESG factors on customer creditworthiness, having regard to applicable local legislation.

This involves the following steps:

• The analysis contains a risk assessment, determines the material topics, actions taken and mitigants.  For potentially high-risk wholesale customers, an in-depth sustainability assessment is required.  For customers in climate sensitive sectors, a specific environmental risk analysis will be performed.

• The outcome determines the engagement agenda with the company and a reputational/litigation risk assessment. The sustainability risk assessment should be explicitly included in the credit risk analysis. This concerns impact on the business model (market environment, competitive position), financial analysis (revenues, required investments and impact on cost levels) and the asset valuation.

• Through the credit risk analysis, the ESG impact on the credit risk parameters is established indirectly (credit risk classification, Probability of Default (PD) and Loss Given Default (LGD)).

The Global Standard on Product Governance details how the needs and objectives of customers are taken into account in the development of new products and changes to existing products, as well as a thorough assessment of the risks the new/changed product could pose to customers. The Standard also provides requirements for event-triggered and periodic product reviews. Within product governance, specific sustainable products are approved and assessed. This includes (a) a target market assessment including sustainability factors and objectives; and (b) a separate assessment of sustainable products and inclusion in the product books.

Reputational risk assessments can be conducted and can originate from non-compliance with sustainability policies and from incorrectly classifying loans as “sustainable” (greenwashing risk). The sustainability policies are published on the corporate website and as such publicly available. Please refer to the section Interests and Views of Stakeholders, included in these Sustainability Statements, for an explanation on how interests of key stakeholders are taken into account in setting the sustainability policies.

Environmental Information

Disclosure Requirement (DR)

Our climate goal

Rabobank¹ remains committed to aligning its activities with 1.5ºC pathways by 2050 and to helping customers successfully navigate their transition to a sustainable pathway. We measure and disclose our progress annually with the publication of the Gross GHG emissions in our Sustainability Statements. Ultimately, our ability to fulfil our 2050 climate ambitions depends on how successful our customers are in reducing their GHG emissions. We will try to use our financing, networks and knowledge to help them make climate-smart choices for their homes and businesses. But we are conscious of the fact that government policies, technological developments, market conditions, consumer sentiment and many other factors also influence the overall progress.

Reducing our own emissions

Our starting point is to take mitigating actions to reduce CO₂e emissions from our own operations. Note that the emissions resulting from our own operations (Scope 1 and Scope 2) are low compared to the emissions that result from our customers' activities (Scope 3, financed emissions). We disclose the emissions resulting from our own operations voluntarily, as this topic is not deemed material from a double materiality perspective. Please refer to the EU Taxonomy section in the Annual Report for information on aligning economic activities with criteria established in the Commission Delegated Regulation 2021/2139. We aim to mitigate the CO₂e emissions from our own operations, such as the emissions resulting from energy purchased to heat or cool our offices, or from our lease fleet and business travel. Our approach involves mindful travel decisions, electrifying our lease fleet, and enhancing the energy efficiency of our office buildings.

Reducing our financed emissions

The vast majority of our emissions results from our customers' activities (Scope 3, category 13 and 15) i.e., our financed emissions. To address those, we leverage our generic four-step approach (outlined in the Sustainability Embedded in our Strategy-section):

1. We build our understanding (through data collection and analysis) how much our customers are emitting and how much of it we are facilitating. At Rabobank, we use the Partnership for Carbon Accounting Financials (PCAF) standard for accounting and disclosing financed emissions.

2. We identify science-based sectoral decarbonization pathways that provide guidance on the rate at which customers in a given sector need to reduce their GHG emissions, and set emission-reduction targets for the most material sector x region combinations in our portfolio.

3. We develop sector x region level implementation plans to achieve the targets set. The sector x region level implementation plans also address climate-related physical risks, and as such address the topic of climate change adaptation.

4. We assess the effectiveness of our actions to also ensure accountability, transparency and consistent reporting.

Within Rabobank, the Finance domain is the owner of financed emissions calculations and reporting. Benchmarking and target setting are included in our policy framework. The sector x region based approach is integrated into our business strategy and financial planning (please refer to the Material Impacts, Risks and Opportunities and Their Interaction with Strategy and Business Model for more detail).

Focus and targets for 19 prioritized sector x regions

To achieve our 2050 goal, we set GHG emissions reduction targets for 19 prioritized sector x region combinations in our portfolio. During 2025, we worked together with the NVB to improve the comparability in the GHG emissions reduction targets between financial institutions. Please refer to the Targets Related to Climate Change Mitigation section. These targets cover a significant majority of the financed emissions of our portfolio (61%). We published GHG emission-reduction targets for the prioritized sector x region combinations in our portfolio for the first time in our 2022 Road to Paris report and expanded on them in our 2024 Road to Paris addendum. Both have been approved by the Managing Board. We consider these aspects of the combined 2022 Road to Paris report and the 2024 Road to Paris Addendum to be the backbone of our climate approach.

The absolute financed emissions metric (Mt CO₂e) is sensitive to balance sheet fluctuations and therefore does not provide a completely accurate picture of our customers’ GHG reduction performance. Therefore, in most cases we use a physical emissions intensity metric (kg CO₂e/kg product), except for our Dutch F&A portfolio, where we use absolute financed emissions targets which is in alignment with the Dutch Climate Agreement. In our view, the physical emissions intensity metric is the better metric in terms of providing an indicator of the real-economy changes to the emissions profile of a given sector. In addition, the physical emissions intensity metric provides a clearer picture in line with our focus on helping our customers to transition to more carbon-efficient practices.

2030 progress indicator

We have introduced a 2030 financed emissions progress indicator to regularly check our progress towards our overarching climate goal. This figure, based on our 2024 portfolio as a reference, represents on a like-for-like basis (i.e., no portfolio growth) our current “best estimate” of where we will be on our journey to Paris in 2030. It incorporates many assumptions, including estimated current GHG emissions for segments of our portfolio without reported customer data (which constitutes the majority of our loan portfolio), estimated GHG-reduction pathways for our 19 prioritized sector x regions and estimated attribution factors. The financed emissions progress indicator provides insight into whether our strategic interventions, including customer support, stakeholder engagement, and portfolio alignment, are contributing to measurable decarbonization, as we believe there is a correlation. It serves as a directional tool to assess the effectiveness of our sustainability approach, as further elaborated in the next section.

Based on the data available to us, our most recent models estimate that the progress indicator of our 2030 financed emissions for our total like-for-like on-balance sheet lending portfolio (CO₂ and non-CO₂ emissions combined) will be approximately 29 MtCO2e for customer Scope 1 & 2 emissions. This breaks down into approximately 16 MtCO₂ emissions and 13 Mt non-CO₂ emissions. This is lower than our 2024 estimate of 32 MtCO₂e. The change is due to a combination of data improvements and the continuing decarbonization of our lending portfolio. These outcomes do not account for future portfolio growth. Given the bank’s role in supporting our customers in the energy and food systems transitions, we anticipate growth in our on-balance sheet lending portfolio, which will inherently have an upward effect on financed emissions.

1. Note that Rabobank is not excluded from the EU Paris-aligned benchmarks.

Type of climate-related risk

Rabobank assesses climate-related ESG drivers as part of its Risk Identification and Assessment process (RIA). We assess the impact of these ESG drivers on each risk type within our Risk Taxonomy. These climate- and nature-related ESG drivers are assessed to have a material impact on credit risk, business risk, operational- and compliance risk.

Scenario Analysis and Resilience

Rabobank conducts climate- and nature-related scenario analyses to understand how different futures could affect our business model and strategy. These analyses are essential for steering towards our sustainability commitments, meeting regulatory expectations and ensuring that our strategy remains resilient to climate change and varying policy developments.

In 2025, Rabobank performed a comprehensive program of scenario analyses across short-, medium-, and long-term horizons. These analyses covered both physical risks, such as extreme weather events, and transition risks, such as policy changes and carbon pricing. In addition, Rabobank executed over many scenario analyses in 2024 and 2025, alongside group-wide resilience and stress testing, underscoring our commitment to managing climate- and nature-related risks across the balance sheet. They provide insights that guide strategic decisions, inform capital allocation, and guide management actions, including targeted adaptation measures for sectors most exposed to climate risks.

Resilience analysis

Our resilience analysis focused on long-term climate pathways developed by the Network for Greening the Financial System (NGFS). In 2025, Rabobank assessed our business model against three NGFS scenarios: Net-Zero 2050, Fragmented World, and Nationally Determined Contributions (NDC). Two quantitative analyses supported this assessment:

1. Credit Loss Scenario Analysis - This analysis provides insight into how physical and transition risks could affect the financial performance of climate-sensitive portfolios. It projects expected credit losses under each scenario using the same methodology applied in provision calculations.

2. Financed Emissions Scenario Analysis - This analysis projects Rabobank’s financed emissions for 2030, 2040, and 2050 under all three scenarios, accounting for uncertainty in global climate developments. The scope and methodology align with financed emissions projections in our MTP and cover climate-relevant exposures in the balance sheet.

The purpose of this analysis is to determine whether Rabobank’s business model and strategy remain resilient under different climate futures. The results confirmed that our business model is resilient, while highlighting pockets of risk in certain sectors that require targeted actions and adaptation measures. The results are included in sector x region plans and ICAAP, to support our transition commitments for 2030 and 2050.

Climate Stress Test

In addition to long-term resilience analysis, Rabobank performs climate stress tests to evaluate short- and medium-term impacts under adverse conditions. Our 2025 stress test applied the adverse NGFS scenario “Disaster and Policy Stagnation” alongside a baseline scenario. The stress test methodology relied on NGFS assumptions and short- to medium term projections up to 5 years. The stress test covered the entire Rabobank Group and included detailed assessments for rural sectors in Australia/New Zealand and the United States, incorporating material ESG risks such as credit, operational, and business risk. The outcomes provided valuable insights into transmission channels at both macro and micro levels. Such as GDP shifts, carbon pricing, and commodity price changes at the macro level, and borrower credit quality, collateral values, and sector-specific stress factors at the micro level. It quantified the potential impact on profit and capital and identified specific vulnerabilities and pockets of risks in our portfolio.

The stress test is used to identify short-term management actions where needed, supporting near-term resilience.The outcomes are integrated in key internal processes such as ICAAP and transition planning.

Portfolio Climate and Nature scenario analyses

Beyond group-wide scenario analyses, Rabobank performs scenario analyses across individual risk type e.g., credit risk, business risk, and operational risk. This approach ensures that climate- and nature-related risks are assessed where they matter most in our portfolio and operations.

For credit risk, we analyze how physical risks such as flooding, drought, and foundation damage, as well as transition risks like carbon pricing and nitrogen policies, affect borrower repayment capacity and collateral values. For business risk, we assess how sustainability regulations, financed emissions limits, and deforestation policies could impact Rabobank’s business model and growth opportunities. For operational risk, we include ESG-related scenarios such as supply chain disruptions due to extreme weather and compliance risks linked to sustainability obligations.

Beyond these risk-type programs, Rabobank executed an extensive range of targeted analyses across multiple portfolios and regions. These included assessments of extreme heat, riverside and coastal flooding, heavy precipitation, droughts, water scarcity, wildfires, and cyclones, as well as transition risks linked to greenhouse gas and nitrogen policies. We also analyzed financed emissions trajectories, second-round transition impacts under Fit-for-55, and nature-related risks. Examples from recent years include combined flooding and foundation damage risks in Dutch mortgage and Commercial Real Estate portfolios, drought and transition risk in beef portfolios in the United States and Australia, and nature-related risk scenarios at group level.

This structured approach demonstrates the breadth and depth of Rabobank’s scenario analysis program.

These climate-and nature-related risk scenario analyses are integrated into our strategic steering via our transition plans and ICAAP process.

Climate Change Mitigation

Impact

As part of our double materiality assessment, we assessed our negative impact on climate change mitigation due to the financial services provided to our customers in the Food & Agri, industrial and real estate sectors, to be material. Specifically, through our Wholesale & Rural, Dutch business customers, leasing and loans to consumers portfolios, we are facilitating the GHG emissions of our customers. To address climate change mitigation, we identified 19 sector x region combinations in our portfolio that are most material from a financed emissions perspective. These sector x region combinations are embedded in our transition plan for climate change mitigation and we have set GHG emissions reduction targets for each. Within our Sustainability Statements, we also report upon our financed emissions per asset class and business unit, including these 19 sector x region combinations, as required by Disclosure Requirement ESRS E1-6.

We have also identified our positive impact on climate change mitigation to be material due to the financial services provided to our customers to transition to a low-carbon business model and economy.

Risk

From a climate-related transition risk perspective, we have identified the risk of insufficient decarbonization efforts taken by our customers as a result of regulation, technology and market shifts, influencing our customers financial position. We have identified a financial (credit) risk that the transition to a low-carbon economy, driven by regulation, technology and market shifts, can render carbon-intensive business models obsolete, affecting borrowers’ revenues and asset values. This can result in stranded assets in carbon-intensive sectors, regulatory tightening (e.g., carbon pricing, emission caps) increasing operational costs and market shifts reducing demands for high-emission products. From a financial (business) perspective, we have identified the risk of losses due to customers’ insufficient decarbonization efforts which makes them prone to reputational damage, regulatory penalties and decreased market value affecting the competitive environment, e.g., decreasing volumes, (commercial) margins, fees, commission, other income, or increasing (operational) costs.

Opportunity

Specially within Wholesale & Rural, Dutch business customers and our leasing portfolio, we identified opportunities to support our customers in their transition to a low-carbon business model and economy, as it affects our customers’ needs for financial services that we can provide to support decarbonization measures.

Climate Change Adaptation

The impact of climate change is already substantial and we will face more extreme weather and climate change events (such as hurricanes, droughts, flooding, forest fires, reduced crop yields, and increased scarcity of drinking water). Efforts to reduce vulnerability to climate change impacts are referred to as adaptation actions.

While we continue to contribute to mitigating climate change, we also want to help our customers adapt to climate impacts. We see adaptation as a pathway to resilience. Without sufficient adaptation, risk to both our customers and ourselves will rise. Adaptation can reduce the impact of physical risks, and is as such an essential part of the risk management strategy. The mirror image is opportunity. Scaling up adaptation finance can help prevent, prepare for, and respond to climate caused events and make communities, economies and natural systems more resilient.

Following our contribution to UNEP FI’s target-setting guidance for climate adaptation finance (launched in November 2023), we continued cooperating with UNEP FI (in 2024 focusing especially on sectoral deep-dives), and in 2025 on their Practical guidance on implementing adaptation and resilience (finalized and launched in August 2025).

Using our generic four-step approach (outlined in the Sustainability Embedded in our Strategy section) we structured key elements from available guidance (including from UNEP FI (NGFS). We subsequently aim to:

1. Create insight into the resilience of our portfolio to climate-related and other environmental risks.

2. Identify prioritized sector x region combinations (climate related physical risks are already included in the sector x region plans).

3. Increase internal knowledge and awareness around the topic of adaptation, and, based on sector x region prioritization, engage with relevant stakeholders, to assess actions already in place. Relevant to underline is that adaptation requires sector-, region-, and customer-specific knowledge, as exposure and vulnerability to physical climate risks differ. That is why we started involving and engaging areas of expertise on a central level and from there, we will start involving departments and colleagues on the decentralized level. We also dedicate time and effort to actions related to the ‘system change’ lever (e.g. participating in the Platform for Sustainable Finance and continuation of our collaboration with UNEP FI).

4. Keep track of the resilience of our portfolio, and disclose accordingly. 

Rabobank adopts an iterative approach. Choices need to be revisited as data guidance and methodologies advance. This is in line with available guidance that advocates a ‘progressive pathway to impact’. Consequently, to date we have not set adaptation-related (group level) targets.

Risk

From a financial (credit) perspective, we have identified increasing physical climate risks. Climate risk events (e.g., floods, droughts, and storms) can damage assets, disrupt supply chains and reduce productivity across sectors. This weakens the financial position of our customers, especially those in sensitive sectors.This could result in higher probability of default due to physical damages or operational disruption, asset or collateral devaluation, sector vulnerability, and underinsurance or lack of resilience planning among borrower We have also identified financial (business) risks. The risk of losses due to climate change related events such as extreme heat, river line flooding, coastal flooding, heavy precipitation, drought, wildfires, cyclones, windstorms and water scarcity (the only chronic event) affecting the competitive environment (e.g., decreasing volumes, (commercial) margins, fees, commission, other income, or increasing (operating) costs).

Climate-related physical risks and climate-related transition risks are identified as strategic drivers in our Risk Taxonomy. As part of our Risk Framework, we perform stress testing scenario analysis and risk resilience analysis (outlined in the section Scenario Analysis and Resilience).

The described climate resilience analysis is a forward-looking assessment of the potential impacts of a set of distinct long-term climate scenarios, encompassing both transition and physical risks, on the viability and resilience of our business model. Within this assessment, we assume:

• Our business model is reflected by our balance sheet portfolio mix and (ESG) Medium-Term Planning (MTP) projections.

• Long term means the horizon is until 2050, given our net-zero ambition.

• Climate scenarios are represented by three Network for Greening the Financial System (NGFS) scenarios (Net-Zero 2050, Fragmented World and Nationally Determined Contributions).

• Potential impacts of the climate scenarios are represented by Financed Emissions and Expected Credit Loss (ECL) impacts.

• Forward-looking assessment to determine whether the development of Financed Emissions and ECL has impact on our business model in each scenario.

We conducted in-depth analyses on ‘water availability’ in our exposures in Beef and Grains & Oilseeds in the U.S., Australian, as well as Dutch mortgage and commercial real estate portfolio. Dryer summers and wetter winters due to climate change are expected to exacerbate the risk of floods and foundation problems in buildings across the Netherlands. We established the relevance of this risk in the short to medium term and the potential increase in the longer term. These risks can potentially diminish collateral values, reduce their marketability, and affect the customers’ cash flows by decreasing rental income or increasing repair costs.

For the real estate portfolios, we assessed water-related risks and established an ESG risk score based on these factors at the facility or customer level. This score will be continuously enhanced with new events (e.g., natural occurrences) and more granular data. The score will be used to capture ESG risks in our risk models and to manage ESG risk at the facility or customer level.

In the section Sustainability policies, an explanation is included on the sustainability policies. The Global Standard on Sustainability Acceptance and Performance covers three policies relevant to managing our material impacts, risks and opportunities related to climate change and biodiversity loss mitigation:

• Climate Policy: sets acceptance requirements for in scope customers and business partners of Rabobank and as such aims to decrease our customers' negative impact on the climate and mitigating our climate-related financial risks. The performance monitoring criteria help identify and assess downstream customer-linked risks. The climate policy stipulates that Rabobank will accept customers or business partners that:

  • Submit their climate-related performance to Rabobank if they are required to report according to the Corporate Sustainability Reporting Directive (CSRD), from the first year CSRD applies to them onward.

  • Are willing to enter into a dialogue with Rabobank regarding staying, or becoming aligned with a 1.5°C pathway.

  • Are willing to enter into a dialogue with Rabobank regarding their possibilities of measuring actual greenhouse gas emissions data or alternative information about their progress to become 1.5°C aligned.

• Energy Policy: sets our acceptance requirements at the customer and business partner level and at activity level and defines performance monitoring activities on a customer level (these are elaborated upon in the 'Our Stance on Energy section'.

• The Deforestation and Land Conversion Policy which is elaborated on in the "Policies related to land use"-section in the Land Use-chapter.

Overall, our policies support our business decision-making at all levels and provide a frame of reference for how we want to deal with business opportunities and risks in the context of direct and indirect sustainability impacts. These group-wide policies apply to in scope customers and business partners whose activities have potential and actual material impacts on sustainability related matters. Potential and actual material impacts include responsibility and control over their value chains. Our policies contain acceptance requirements (mandatory) and performance monitoring criteria following a risk-based approach.

The following sector initiatives, commitments and frameworks relate to these policies:

• Partnership for Carbon Accounting for Financials

• Net-Zero Banking Alliance (in 2025, NZBA transitioned away from a member-based alliance and established its guidance as a framework)

• Taskforce on Climate-related Financial Disclosures

• Financial Institutions Commitment to the Dutch Climate Agreement

The Global Standard on Sustainability Performance Management (applicable to all core activities) is used to guide climate targets. It also includes the criteria those targets need to fulfil:

• alignment with Rabobank's strategy;

• consistent target setting with clear responsibilities.

Our Stance on Energy

In our view, our role is not to finance the entire energy system, but to make clear choices about what we support and what we avoid. We prioritize financing e.g. renewable energy, electrification, efficiency, flexibility and emerging low-carbon technologies—and we limit or exclude financing activities that risk locking the energy system into a high-emissions pathway. Through these choices, Rabobank supports a transition that aligns with 1.5°C target (using the IEA NZE scenario and SBTi guidance).

Our energy portfolio

Our energy portfolio, primarily focused on clean energy, makes up 3% of the private loan portfolio. Approximately 80% of project finance supports renewable projects like wind, solar, storage, and related infrastructure, with clean energy financing doubling in the past three years. Most oil and gas exposure is in short-term Trade & Commodity Finance (TCF), shaped by global demand and energy security, which cannot shift overnight.

Rabobank aims to reduce traded oil and gas financing by 20% by 2030 (vs. 2022), with gas forming a larger share and oil financing declining more steeply. This approach balances the need to cut fossil fuel use for the 1.5°C target while maintaining stable supply chains during the transition. 

Our energy policy-based requirements

Alongside our oil and gas target, Rabobank enforces strict fossil fuel boundaries to prevent locking energy systems into high-emissions pathways. These are elaborated on in the adjacent visual. In sum, we apply limitations to fossil infrastructure to avoid creating new assets that would be inconsistent with a net-zero future. Credible net-zero scenarios highlight the role of carbon capture and storage, hydrogen, ammonia and energy system conversion technologies. In these well-defined areas, Rabobank sees a constructive role for banks: financing solutions that are necessary for a net-zero system, provided they are implemented responsibly and do not prolong the life of high-carbon assets or creates unacceptable impact on people or nature.

Climate change mitigation and climate change adaptation (as climate related phyical risks are part of our Risk Taxonomy, climate and nature scenario analyses, and included in our sector x region plans) are being integrated in the strategic steering cycle of the bank. Within Rabobank Group’s Sustainability department, a dedicated climate team has been in place since 2022. This team works closely with Finance, Risk, our dedicated climate risk teams and RaboResearch’s Sustainability & Data Analytics team in areas such as footprint measurement, target setting and monitoring as well as on onboarding sustainability in business-as-usual processes. In addition, the team works closely with commercial business lines.

As the context and characteristics of sector x region combinations differ, our actions differ per sector x sector region as well. In the Sector x Region Analyses section, we offer a more elaborate overview of our prioritized sector x region combinations, that addresses the rate of GHG emission decrease, compared to the relevant decarbonization pathway, factors that influence that rate, and the actions Rabobank is undertaking to support the transition. Exceptions are Traded Oil & Gas (as the pathway is clear cut; reducing traded oil and gas financing by 20% by 2030 (vs. 2022)), Project Finance (as approximately 90% of project finance already supports renewable projects), Commercial Real Estate Wholesale and Transport  Wholesale (as the Retail NL parts of these portfolios are most material). In this section, we suffice with listing a number of common denominators in the actions throughout all sector x region combinations and of actions that transcend the sector x region level.

• In the “help customers transition” lever, emphasis is placed on actions that relate to:

  • Customer engagement.

  • Knowledge sharing; carbon workshops, exploring sustainable energy investments, etcetera.

  • Developing and offering pricing incentives for an improved energy label in our real estate portfolio.

• In the “system change” lever, emphasis is placed on:

  • Working with sector specific partners to improve data availability and quality.

  • Advocating for governmental, long-term climate policies

• In the “portfolio optimization” lever, emphasis is placed on:

  • Risk Appetite Statement, e.g., changing our risk appetite for customers who are not compliant with our sustainability policy, sector-specific limits, etcetera.

  • Leveraging our capital allocation processes, e.g., increased appetite for financing the energy transition.

  • Performance monitoring of customers and business partners regarding having (or working towards) a plan that captures actions to become1.5°C aligned.

Please note that our actions, including certain product offerings, have the potential to help customers transition to improved carbon efficiency, but are dependent on customer interest and on factors outside our influence. The actions, as referred to within this section, through which we manage climate change mitigation, are on-boarded in our business as usual processes and activities. The expected outcomes (achieved or expected GHG emission reductions) and time horizons of our actions cannot always be disclosed at this point in time.

Our starting point is to identify how much of our emissions result from our own operations, and how much result from our customers' activities (financed emissions). This is our GHG inventory, and is disclosed in the accompanying infographic and financed emissions table. In the next step we identify science-based sectoral decarbonization pathways that provide guidance on the rate at which customers in a given sector need to reduce their GHG emissions as well as setting emission reduction targets for the most material sector x region combinations in our sector x regions targets table.

Rabobank's material impact is on the GHG emissions from our customers (Scope 3 emissions, category 13 and 15). Operational GHG emissions (Scope 1 and 2 emissions, and Scope 3 upstream emissions) are also relevant.

Operational GHG Emissions

While our operational GHG emissions account for only a small portion of our total carbon footprint, we are committed to minimizing these emissions wherever possible. With over 48,000 employees, offices in 35 countries, and two datacenters in the Netherlands, our operational GHG emissions mainly consist of energy consumption in our offices, fuel use / electricity consumption in our company vehicles and fuel use / electricity consumption associated with employee travel (business travel/commuting).

• Emission reduction compared to base year (2018) = -54%

• Tonnes of CO₂ per FTE = 1.5 (FY2024: 1.4)

Scope

When we refer to our operational GHG emissions, we mean Scope 1 (emissions in company facilities and company vehicles), Scope 2 (emissions from purchased electricity, steam, heat and cooling), and Scope 3 Upstream activities (emissions from purchased goods and services, capital goods, fuel- and energy-related activities, transportation and distribution, waste generated in operations, business travel, employee commuting and leased assets). Currently, we report on our emissions in Scope 1, Scope 2, and some emissions in Scope 3 (i.e., paper consumption, fuel- and energy-related activities, business travel and employee commuting). The emissions of leased assets (leased facilities and leased cars) are reported in scope 1 and scope 2. A dedicated working group has been established to gain greater insight into the remaining upstream operational GHG emissions within Scope 3.

Benchmarking & target setting

For the largest categories within our operational GHG emissions, we have benchmarked our emissions against recognized decarbonization pathways and set 2030 targets that are in line with those pathways.

Operational GHG Emission Reduction Targets

For the category “Other”, the target-setting process is still under development. It mainly consists of business travel by car, paper consumption, employee commuting and fuel- and energy-related activities. Employee commuting and fuel-and energy-related activities are new categories in our 2025 reporting, these categories were not yet included in the 2024 and 2018 figures.

Rabobank Key Actions

• Company vehicles: We aim for a 100% electric vehicle fleet; our leasing policy allows only electric cars.

• Business air travel: Our business travel policy follows a digital‑first approach and requires train travel on all Western European high‑speed rail routes (under 600 km).

Considering the magnitude of the CO₂e emissions from our operations, we do not consider this to be material for Rabobank.

Emissions from our customers

This year we are able to report financed emissions for 98% (FY 2023: 99%) of the relevant (73% of our total assets (FY 2023: 73%)) on-balance sheet assets. We increased the bottom-up coverage (combined client reported-emissions and client assessed-emissions) of our financed emissions calculations to 21% in 2024 from15% in 2023 (from a financed emissions perspective). In addition, Rabobank works to expand the scope of sectors where customers are enabled to calculate their emissions and provide reported emissions by making carbon calculators available.

A decrease in financed emissions and an increase in avoided emissions

We will focus our reduction efforts on our customers’ scope 1 & 2 emissions, as this is where we have more influence. In our most recent GHG inventory, we observed a 10% decrease in our financed emissions (Scopes 1 and 2) on a comparable basis, from 46.9 Mt CO₂e to 42.0 Mt CO₂e. This decrease is driven by a combination of factors: 1. improved data quality, including both bottom-up data from clients’ own reports and carbon calculators, as well as top-down estimate data, which improved accuracy and reduced emissions by 3.2 Mt CO₂e; 2. a shift in portfolio mix towards lower GHG-intensive sectors, reducing emissions by 1.9 Mt CO₂e; and 3.  sector- and system-level decarbonisation efforts, resulting in a reduction of
0.9 Mt CO₂e. These reductions offset an increase in financed emissions driven mainly by growth in lending portfolio, amounting to 1.1 Mt CO₂e.

In the Rural portfolio, we have noted a reduction in emissions intensity across a range of sectors compared to previous years, resulting in a cumulative decrease of 2.0 Mt CO₂e. The most substantial reductions were observed in the Animal Protein, Fresh Produce, and Farm Inputs sectors. Additionally, changes in portfolio composition contributed to a further decline in financed emissions, with a decrease of 1.5 Mt CO₂e, primarily driven by reduced exposure in the Commodities and Dairy sectors. Among our Dutch business customers, the Non-Food & Agri (Non F&A) sector remained stable, with only a marginal decrease in financed emissions attributable to slightly lower outstanding balances. Within the Food & Agri (F&A) sectors, modest increases in emissions intensities were identified in the Animal Protein and Dairy sectors; however, these were offset by a reduction in portfolio size for both sectors. The Fresh Produce sector demonstrated improved emissions intensities, accounting for the majority of the drop in financed emissions. The Commercial Real Estate (CRE) portfolio experienced growth, and its lower emissions intensities contributed positively to the overall reduction in financed emissions. The scope 1 & 2 financed emissions for our Wholesale portfolio decreased by 1.5 Mt CO₂e to 9.4 Mt CO₂e. This is mainly due to the aforementioned improved data for top-down estimates and growth in sectors with lower intensities.

The methodology used to calculate our financed emissions is disclosed in Methodology Financed Emissions. The overview of Rabobank's financed emissions per asset class and business unit provides insight into our Scope 3 categories. Category 13 downstream leased assets is presented as part of the leasing international business unit. The remainder of the table presents a breakdown of category 15 investments. Rabobank does not base the GHG emissions on net revenue but on outstanding assets.

Avoided emissions refer to the greenhouse gas emissions that would have occurred without renewable energy projects. These emissions are primarily avoided through wind, solar, and geothermal projects that replace fossil‑fuel‑based electricity generation. These large‑scale, complex projects fall within our Project Finance renewables portfolio, which forms the scope for our avoided‑emissions calculations. In 2024, our total avoided emissions increased by 17% to 7.0 Mt CO₂e (+1 Mt CO₂e) compared to 2023, driven by projects moving from construction to operational status and growth of the portfolio. Wind and solar projects now contribute equally to total avoided emissions. Our total renewables portfolio stands at EUR 8.3 billion, of which EUR 6 billion are projects in scope with eligible sectors (wind, solar and geothermal) with positive outstanding on balance. This is a 42% growth and includes projects in construction phase. Out of these only operational projects are included for avoided emissions scope representing EUR 4.0 billion. The projects in cosntruction show strong pipeline for future growth. As grids in most countries get greener over time, avoided emissions are expected to be lower but as we see growth in the portfolio and more projects become operational, we expect avoided emissions to continue rising.

During 2025, the NVB has published templates for the disclosure of Financed emissions and GHG targets. The use of these templates by banks in the Netherlands will improve comparability between financial institutions. We have based our disclosures on these templates. The versions of the tables displayed below show a breakdown of Rabobank's total balance sheet, the scoping of the financed emissions exercise and the translation to the sector x region combinations for which the bank has set targets within the private sector loan portfolio.

Methodology Financed Emissions Interpretation Pointers

On the commitments we made 

• Rabobank supports the Paris Climate Agreement’s goals and formalized that support by signing the Dutch Financial Sector Climate Commitment and our membership of the Net-Zero Banking Alliance (2021 - 2025).

• Both Commitments share the core belief that the role of banks is not to scrub emissions from their own balance sheets,
  but to enable customers to make transitions that will have impact in the real economy.

• Rabobank shares this belief; we can contribute best to a future- proof food system by actively participating in it,
  with customers and other stakeholders, rather than turning away from regions, sectors, that are not yet future-proof.
  This applies especially to the Food & Agri sector which we believe has both emissions reduction- and
  CO₂ removal-potential.

On the targets we have set 

• Following the most recent IPCC report (also referred to by NZBA), we commit to a net-zero CO₂ emissions portfolio and “substantially” reduced non-C02 GHG emissions by 2050.

• We have  set (a) an overarching bank-level target of having our portfolio 1.5-aligned by 2050, expressed in absolute emissions metrics (MTCO₂e) and (b) preliminary targets for 19 sector x region combinations, expressed in emissions intensity metrics (kg CO₂e/kg product).

• We have pledged to have “all our operational and attributable GHG emissions from our lending and investment portfolios align with pathways to net-zero by mid-century, or sooner, including CO₂ emissions reaching net-zero at the latest by 2050, consistent with a maximum temperature rise of 1.5°C above pre-industrial levels by 2100”.

On the challenges we face 

• The majority of our customers emissions are related to Food & Agri sectors, where emissions data and science-based decarbonization pathways are scarce. More than half of these emissions are non-CO₂ emissions, which are impossible to fully abate; there will always be residual emissions from for example livestock activities. The implication is that non-CO₂ emissions will not be net-zero in 2050.

• Our absolute emissions target is sensitive to balance sheet fluctuations and therefore does not provide a completely accurate picture of our customers’ GHG reduction performance. The emissions intensity targets we have set for sector x region combinations on the other hand, do not say anything about the total amount of GHG gasses being emitted. The implication is that despite progress on the intensity-based targets our absolute emissions could still increase. 

• Among the main challenges Rabobank and other banks face is the lack of customer-reported GHG emissions data. Therefore, we have to use proxy indicators (see bullet below) to estimate the majority of client emissions. Over time methodologies will improve, more data will become available and bottom-up (company specific) numbers will replace top-down (sector) estimates. This means that data may need to be restated in future and comparisons over time will be difficult until methodologies and regulations are more settled.

• In Rabobank we use the PCAF standard for accounting and disclosing financed emissions. The availability, specificity and accuracy of the data we use to make these calculations varies widely per sector. Therefore, the financed emissions overview presented in this report should be interpreted as our "estimates on a best effort basis", in accordance with PCAF methodology, using the current information and data we have at hand. Where possible, we have used client-reported GHG emissions. PCAF's data quality scores (score 1-5) are used to qualify the level of precision of the estimates we disclose per PCAF asset class. Data with PCAF scores 1/2, (verified and unverified respectively) company-level reported emissions data, represent the highest data quality and results in the most accurate emissions estimates. This is followed by physical activity-based emissions (PCAF score 3), and PCAF scores 4/5, given for an economic activity-based emissions approach. The average data quality score of our in scope portfolio for scope 1 and 2 is 3.6. The average data quality score of our in scope portfolio for scope 3 is 3.8.

• According to the NZBA framework, banks’ GHG reduction targets should include customers’ scope 1, 2 & 3 emissions “where relevant and data is available”. There is considerable discussion surrounding the viability of banks disclosing and setting targets for customer scope 3 emissions, due to the enormous variety and complexity of supply chains involved. For Rabobank, customer scope 3 emissions are predominantly an issue in the F&A sector, where we have considerable overlap between scope 3 emissions of Wholesale customers and scope 1 & 2 emissions of our farming customers. We will disclose Wholesale customer scope 3 emissions as they become available, but we will focus our reduction efforts on our farming customers’ scope 1 & 2 emissions, as this is where we have more influence.

• Although we are fully committed to fulfil our 2050 climate ambitions, we are dependent on other stakeholders in achieving their goals. This is also acknowledged by the Commitments that state: “We will only succeed if our customers and other stakeholders also play their part.” And, “We make this Commitment with the expectation that governments will follow through on their own commitments to ensure the objectives of the Paris Agreement are met.” 

Financed Emissions metrics FY2024

Financed Emissions metrics FY2023

Wherever possible, we use science-based decarbonization pathways aligned with the 1.5°C warming scenario (such as the pathways provided by IEA, SBTi or CRREM) to help set targets for our sector x region combinations. These decarbonization pathways are based on carbon or GHG emissions budgets: the amount of GHG emissions allocated to a given economic sector in a given region help determine the future rate of decarbonization needed to reach net-zero by 2050. In DLL's own methodology, DLL derived the reduction target based on IEA projections (IEA provides decarbonization pathways aligned with the 1.5°C warming scenario), market developments, and asset-uptake for the portfolio.

In most cases, we use a physical emissions intensity metric as this is, in our view, the better metric to provide an indicator of the real-economy changes to the emissions profile of a given sector. ESRS E1-4 requests the disclosure of absolute targets. However, intensity metrics and targets fit the profile of a bank better, hence we do not have, nor disclose, absolute targets (except for our Dutch F&A portfolio). This approach is in line with ESRS 1 Paragraph 33.

Achieving the sector x region targets mentioned in this report depends on many factors within and outside our direct control. As a bank, we focus on supporting our customers in prioritized sectors to transition to more emission-efficient practices. This transition depends on many factors, including but not limited to governmental policy and technology improvements. Achieving the targets will also require joint efforts together with customers and other stakeholders to support the transition of our customers, as well as governments following through on their own commitments to ensure that the objectives of the Paris Agreement are met.

Our progress on our climate targets in 2025

The table on the next page provides an overview of the near- (2030) and long-term (2050) greenhouse gas reduction targets that we have set for the 19 sector x regions in our portfolio that we have identified as most material from a financed emission perspective.

Table explanation

Rabobank’s sector x region targets are designed to align our lending portfolios with the Paris Agreement, while supporting customers in their transition to a low-carbon economy. The table indicates the relative size (Coverage) of the sector x region, its contribution to our 2024 financed emissions inventory (Absolute financed emissions), the target metric (Metric), the 2020 – unless otherwise indicated - baseline value for that metric (Base year), the science-based decarbonization reference pathway (Scenario/pathway), the near-term goal (Target 2030), the long-term goal (Target 2050) and the most recent performance indicator (Year of reference value). In the table, “0” values indicate that the number is lower than the 0.1. A “n.a.” indicates that we are not currently able to measure a value, or disclose a target (although we continue to measure performance in the relevant US sector x regions, we no longer set GHG emissions reductions targets for those, due to regulatory changes).

2024 Results

In 2024, we were able to calculate target performance measures for 14 of 19 sector x regions (compared to 15 of 19 sector x regions in 2023). For the remaining sectors, we will continue to work on obtaining the required customer and asset data to be able to measure performance. Of the 14 sector x regions, we can currently measure (subject to data and methodological limitations), we consider 11 to be on-track towards their 2030 targets (Horticulture, Pig Farming, Dairy NL, Dairy NZ, Dairy Australia, Beef Australia, Soy Brazil, Energy/ Power Retail NL, Energy/Power Wholesale, Energy/Power Project Finance, DLL Leasing Tractors). For a full overview of sector-related progress, please refer to the sector x region analyses in the appendix.

Cross-Sector Challenges and Forward Priorities

Rabobank recognizes that several challenges are interconnected across regions and sectors:

• Data and Technology: Data availability and quality remain critical, particularly for complex supply chains. Expanding granular emissions data and scaling proven technologies are top priorities.

• Regulatory and Infrastructure: Regulatory uncertainty—especially around nitrogen and biodiversity, along with grid capacity and infrastructure constraints, pose risks for real estate, transport, and agricultural portfolios.

• Systemic Coordination: Achieving sector targets, especially in real estate, depends on stronger collaboration among municipalities, energy providers, construction firms, and policymakers.

Rabobank’s sector x region targets

1. DCA: Dutch Climate Agreement / CEG: Convenant Energytransitie-Glastuin
2. Due to data issues, preventing us from using bottom-up client specific data for reporting purposes, we cannot present the 2024 performance.
3. Note that the pathway and portfolio intensity numbers are aligned in emissions boundaries, but the values in the SBTi FLAG pathways are derived in a methodologically different way (the FLAG sector-region default value comes from a top-down model, our portfolio intensity value comes from a bottom-up calculator, with carbon footprints calculated based on primary data collected from a subset of our clients). This makes direct comparison difficult.
4. The own methodology of DLL has been verified by an external party.

EU Taxonomy Disclosure under Article 8 and Disclosures Delegated Act

The EU Taxonomy is a common classification system for sustainable economic activities allowing financial and non-financial companies to report, based on a common definition, economic activities that can be considered environmentally sustainable.

The EU Taxonomy Regulation sets out the overarching conditions that an economic activity must meet to qualify as environmentally sustainable.

Generally, an economic activity can be qualified as sustainable if it makes a substantial contribution to one of the six environmental goals of the EU Taxonomy, does not do significant harm to the other five and holds to a minimum level of social safeguards to indicate compliance with human and labor rights standards, preventing activities that breach key social principles. The EU Taxonomy has created criteria specific to the economic activities in its scope to evaluate compliance with these overarching conditions. EU Taxonomy alignment can be determined if an activity meets all applicable criteria. 

Rabobank annually discloses its green asset ratio (GAR), based on eligible and aligned assets on the balance sheet. Eligibility indicates that an activity is in scope of the EU Taxonomy. Consequently, eligible activities are tested against the economic activity-specific technical screening criteria (TSC) on substantial contribution (SC) and do no significant harm Criteria (DNSH). In addition, the undertaking carrying out the economic activity should comply with the minimum social safeguards (MS). If these criteria are met, the activity can be classified as aligned.

In 2025, in the context of the first Omnibus package, the European Commission presented Commission Delegated Regulation (EU) 2026/73, amending the existing requirements of the EU Taxonomy. For Rabobank’s reporting on 2025, this new delegated act provided three scenarios:

• Rabobank may continue to report without applying the amended Article 8 requirements;

• Rabobank may apply the amended requirements;

• Rabobank may choose not to disclose the detailed reporting templates if it does not claim any activities as being associated with economic activities that qualify as environmentally sustainable under articles 3 and 9 of the Taxonomy Regulation.

Rabobank has opted to disclose information on the EU Taxonomy according to the amended requirements of the new delegated act. In doing so, Rabobank chooses to align with the amended regulation, and take advantage of the option to present more focused disclosures. These amendments affect the detailed templates that Rabobank discloses and changes the calculation of the KPIs related to the Taxonomy Regulation.

Key changes in layout

In this section, we provide information on the key changes applied in this revised layout and the merits of these revisions.

Redesign of key metrics

In a major change from prior year disclosures, the concept of the Green Asset Ratio is revised through the redefinition of the denominator which going forward includes only those items that fall into scope of the evaluation against EU Taxonomy criteria.

Removal of certain templates

From FY2023 Rabobank started reporting on exposures to nuclear and fossil gas sectors in accordance with the complementary climate delegated act (EU 2022/1214), amending Delegated Act EU 2021/2178. Rabobank no longer reports these templates on the basis of the requirements of the new delegated act. Exposures to these activities in preceding reports were immaterial and mainly indirect. Rabobank now only reports in the summarizing fields on these activities in template 2.

In addition, as indicated in the new delegated act, the reporting on Fees and Commission income and Trading Book flow related to the EU Taxonomy has been deferred to 2028 (reporting over FY 2027). At that time, Rabobank will (re-) introduce these if material, as allowed for in the new Delegated Act.

Materiality

The consideration on materiality as presented in the new delegated act may already be applied to certain templates within the reporting framework. A credit institution may omit assessing KPIs when the cumulative value of the net turnover generated by the activities covered by those KPIs is below 10% of total net turnover of the credit institution. The turnover generated by these activities for Rabobank is below this threshold. On this basis, we have opted to exclude specific detailed reporting on Assets under Management and financial guarantees. Rabobank will report these KPIs as non-assessed KPIs.

Rabobank notes that the nature of the assets under management is such that they represent a globally diversified portfolio of underlying investments, covering both corporate holdings and sovereigns and supra-nationals. As a result of this, the relevance of EU Taxonomy criteria on Assets under Management is limited.

Simplification of overall layout

Prior year reporting was split across several columns for each of the 6 objectives defined in the Taxonomy. As of now, a more condensed format has been adopted in accordance with the new delegated act that aggregates the data to fewer columns. This provides a more legible overview of taxonomy eligibility and alignment. Similarly, the number of rows of the template has been condensed to provide a more focused overview of the exposures assessed under the regulation.

Summary of KPIs

In this chapter, Rabobank discloses tables summarizing its GAR and related figures. Additionally, Rabobank provides explanations on the effect of the regulatory changes on the reported figures. The full detailed EU Taxonomy templates can be found in Appendix 5 of this report. In addition to the comparative KPIs as disclosed in 2024, Rabobank has provided a recalculation of the 2024 KPIs according to the requirements of the amended delegated act. Both tables can be found below.

The tables show a summary of Rabobank's EU Taxonomy KPIs. As a credit institution, Rabobank reports several KPIs under the EU Taxonomy, unless deemed non-material:

• The Green Asset Ratio (GAR) stock. This KPI shows the alignment of Rabobank’s stock of assets on the balance sheet date.

• The GAR flow. This KPI shows the alignment of Rabobank assets that have originated within the reporting year.

• The Financial guarantees KPI. This KPI shows the alignment of the stock of off balance financial guarantees held by Rabobank on the balance sheet date.

• The assets under management KPI. This KPI shows the alignment of the stock of assets under management of Rabobank on the balance sheet date.

Rabobank reports these KPIs from two perspectives, based on i) the turnover of our counterparties, and ii) the capital expenditures (CapEx) of our counterparties, except for our residential mortgage portfolio, where this distinction does not apply.

Summary of KPIs as disclosed by credit institutions under Taxonomy Regulation (2025)

Summary of KPIs as disclosed by credit institutions under Taxonomy Regulation (2024 as disclosed )

Summary of KPIs as disclosed by credit institutions under Taxonomy Regulation (2024 according to new delegated act)

The amendments to the EU Taxonomy requirements have further effects on the disclosed KPIs. Most notably, while the amount of aligned assets remains constant, the KPIs themselves have increased in the like-for-like comparison between the KPIs disclosed in the 2024 annual report and the amended table. This is caused by adjustments to the denominator of the GAR. Specifically, assets that cannot become Taxonomy aligned have been excluded from the denominator. In the prior year table these assets were listed as assets excluded from the numerator of the GAR (article 7 (2) and (3) and section 1.1.2. of Annex V). Specifically this concerns:

• Financial assets held for trading

• On-demand interbank loans

• Exposures to undertakings that are not obliged to publish non-financial information pursuant to Article 19a or 29a of Directive 2013/34/EU (exposures to non-CSRD counterparties)

• Derivatives

• Cash and cash-related assets

• Other categories of assets (such as goodwill)

This change has a significant impact on Rabobank's GAR, as Rabobank has large exposures to non-CSRD counterparties, both SMEs and non-EU counterparties. (EUR 217 billion in 2024 reporting) Rabobank's reported GAR stock for FY2024 was around 4.6% from both the turnover and capex perspectives. As a result of the amended requirements, the GAR for 2024 is 10.9% for turnover and 11.0% for CapEx.

The impact on the GAR flow of this amendment is slightly smaller, with the flow KPI moving from 3,1% to 8,8% for turnover and from 3,0% to 9,3% on CapEx. This difference is caused by the impact of reverse repurchase loans. During the 2024 reporting cycle it was not possible for Rabobank to make a granular determination of the impact of these positions at counterparty level. The full position was included in the financial counterparties field of template 1. For 2025 this position is divided between CSRD counterparties (included in the denominator) and non-CSRD counterparties (non-covered assets). As these positions usually mature very quickly, the balance at year-end will be almost fully included in the flow template as well. This dampens the effect of the reduction in the denominator.

For FY2025 Rabobank's GAR stock is 15.0% for turnover and 15.1% for CapEx. Rabobank’s GAR stock and the increase compared to 2024, taking into account the new delegated act, are mainly driven by the residential mortgage portfolio. Key drivers of this increase in aligned assets are a high rate of inflow of new mortgages and a significant uptake on efforts to improve energy efficiency and label availability for customers with an existing mortgage. In this chapter Rabobank further explains how the eligible and aligned assets of the bank are determined and have developed in 2025.

Rabobank performs the EU Taxonomy assessment with the scope of the full consolidated statement of financial position for Rabobank. The composition of Rabobank’s portfolio has remained stable in 2024, with no significant changes to the relevant ratios for the EU Taxonomy. Results are disclosed using gross carrying amounts based on regulatory reporting data. The use of gross carrying amounts is required under the EU Taxonomy. In the financial statements, net amounts are presented which reconcile on an underlying basis with the tables above and those in the Annex.

Developments in EU Taxonomy Eligibility

The eligibility of Rabobank’s portfolio in 2025 follows a similar pattern to the eligibility reported in the 2024 annual report. The residential mortgage portfolio is the largest source of eligible assets. Business lending only accounts for a small fraction.

The residential mortgage portfolio is eligible by definition under the EU Taxonomy as it reflects real estate activities, for which TSC are available. For the business lending portfolio eligibility is dependent on the underlying customer's economic activities. For these customers, Rabobank based its assessment on the eligibility disclosures in their respective annual reports. This covers the regulatory requirement for financial undertakings to report on their customers EU Taxonomy eligibility based on actual information.

The eligibility of Rabobank’s business lending portfolio is limited in 2025. Out of EUR 313 billion of business lending assets, EUR 22 billion falls under covered assets and qualifies for further assessment on eligibility and alignment. This amount was reduced due to the new delegated act, as financial corporation counterparties are now split between covered and non-covered assets, in line with non-financial corporates. Currently, EUR 5.6 billion of this portfolio is eligible. This EUR 5.6 billion is contained within the Wholesale portfolio of the bank. A number of reasons for the limited portion of assets that are eligible can be identified:

• A significant portion of the exposures are to corporate customers that do not reside in the EU.  These customers are not subject to EU Taxonomy reporting requirements.

• A further portion of the exposures within the EU are not to entities that are required to report under the CSRD. The EU Taxonomy implies direct reporting obligations only for the large public interest EU companies with over 1000 employees, which is a relatively small portion of Rabobank’s business lending portfolio. While this further decreases the scope of the Taxonomy, it does not impact reporting on Rabobank’s portfolio for the current year. It may further limit available reports in the following years.

• As a final point, it is noted that currently, a large portion of the exposures is to counterparties whose economic activities are not yet described in the EU Taxonomy. For example, Rabobank has a significant portfolio in the agricultural sector, for which no screening criteria are described. Due to this, these sectors are also not eligible under the EU Taxonomy.

EU Taxonomy Alignment of Our Portfolio

Methodology on Alignment of Our Residential Mortgage Portfolio

The largest eligible portfolio on Rabobank’s balance sheet is the residential mortgage portfolio. As Rabobank’s counterparties (i.e. private individuals) have no obligation to report on their EU Taxonomy alignment, Rabobank is required to perform its own assessment of this portfolio. This section elaborates on Rabobank’s methodology to determine EU Taxonomy alignment of the residential mortgage portfolio under economic activity 7.7, acquisition and ownership of real estate, for the environmental objective of climate change mitigation. Rabobank has reviewed the draft Commission Notice on interpretation and implementation of provision of the Disclosures Delegated Act issued by the European Commission (17 December 2025) and incorporated conclusions drawn therein. This does not lead to material change in approach and does not have a significant impact on the KPIs reported by Rabobank.

Substantial contribution

The substantial contribution for the mortgage portfolio is determined based on the energy efficiency of the building. The threshold level of energy efficiency is further dependent on the year in which a permit for the building was applied for, as this threshold changed as of December 31, 2020.

Rabobank currently does not possess data on building permits and thus uses the building year for this indicator. Rabobank is comfortable with this choice as the actual building year falls after the permit is granted. With this approach, a potential overstatement of the GAR is prevented.

• For buildings built before December 31, 2020, Rabobank includes all buildings with a definitive EPC Label of A as prescribed in the requirements for substantial contribution to the climate change mitigation objective.

• For buildings built after December 31, 2020, the EU Taxonomy imposes a stricter energy performance threshold. The building should have a primary energy demand (PED) of at least 10% lower than the norm for near-zero energy buildings (NZEB).

Do no significant Harm (DNSH)

To determine adherence to the DNSH criteria, it is required to perform a physical climate risk assessment. Rabobank has screened the residential mortgage portfolio in the Netherlands to identify which physical climate risks may affect the portfolio during its lifetime. For purposes of the physical climate risk assessment, the expected lifetime is capped at 30 years, since no accurate climate projections for the relevant physical climate risks beyond 30 years are currently available.

Where a risk applies to the Dutch residential real estate sector based on the screening exercise, a further climate risk and vulnerability assessment is performed to assess the materiality of the physical climate risks on the economic activity.

Rabobank has performed climate risk screening and has evaluated hazards based on spatial occurrence and their potential impact on mortgage assets. Based on this screening, Rabobank has concluded that the risks in scope for materiality analysis are as included in the table below. In this table an explanation is also included pertaining to the further analysis of the portfolio based on these risks. The materiality threshold is derived from a scientific literature review, data availability, and internal expert judgment. It represents a combination of a severity from an event with potential to damage a building and a relevant probability of that event occurring within the next 30 years.

Within the datasets used, government-level adaptation solutions have been applied to reduce the risk of the underlying event. For example, the dataset on flooding includes the Dutch dike infrastructure as a mitigating factor. Rabobank does not consider government-level adaptation solutions if they are part of a plan or policy that has not yet been materialized. Due to data limitations, Rabobank currently has not included the effect of potential building-level adaptation solutions that can reduce the identified physical climate risk.

Minimum Social Safeguards

In November 2024, the European Commission finalized its commission notice on the interpretation and implementation of the disclosures delegated act. In this notice, draft guidance from December 2023 was made final. This notice provides a set of questions and answers on topics related to the EU Taxonomy interpretation, among which is the application of the minimum social safeguards (MS) to retail customers.

Rabobank has taken note of this guidance and updated its interpretation and implementation of the EU Taxonomy accordingly. The commission states that while the MS need not be verified for private individuals, it is required to assess the MS for providers of services and goods related to the financing provided. Rabobank interprets this guidance to not apply to economic activity 7.7, the acquisition and ownership of real estate, as this concerns existing real estate, where private individuals perform the economic activity and no providers of goods or services are involved, as these are existing buildings.

The results of our evaluation of the alignment of our mortgage portfolio is as follows:

Outlook and Challenges

There are a number of challenges and limitations to determining the alignment of Rabobank’s mortgage portfolio:

For a substantial number of properties in Rabobank’s portfolio there is no sufficient basis to evaluate the substantial contribution criteria for the objective of climate change mitigation. The EU Taxonomy substantial contribution criteria for activity 7.7 pertain to the energy performance of buildings. Evidencing of these criteria relies on definitive EPCs. This poses limitations to determine EU Taxonomy alignment of those buildings, considering a large part of the Dutch residential real estate stock does not have a valid EPC. As a consequence of higher energy prices and a general market sentiment towards a more sustainable future, there is a considerable trend to improve the energy efficiency in the Dutch housing market. However, these energy-efficiency improvements will only be visible to Rabobank when the home owners apply for an updated EPC.

Rabobank is offering incentives for customers to improve the energy efficiency of their homes and allows them to obtain a new EPC label for free. Furthermore, there are several sustainability initiatives that Rabobank may undertake in its residential mortgage portfolio that are not likely to become aligned for EU Taxonomy purposes. These initiatives can, however, make a contribution to improving the sustainability performance of the Dutch housing stock.

For example, the Cooperative Insulation Budget. Under this initiative Rabobank mortgage customers who met the eligibility criteria received an advice on their options for increasing the energy-efficiency of their homes, a maximum of EUR 500 contribution to insulate their home and an updated energy label, increasing the availability of definitive labels for the portfolio. In 2025, Obvion launched a similar insulation initiative under the name 'Energiebespaarpakket', which focuses on helping customers with label F and G transition to a more sustainable home, further expanding this initiative in 2026.

In addition to the impact of our efforts to facilitate customers improving the energy performance of their housing and choices in origination, Rabobank continued to incrementally improve its data sourcing strategy and interpretations to enhance insights on Taxonomy aligned assets. Such efforts do not translate into step changes but incrementally contribute to a longer-term perspective.

Rabobank is dependent on the availability of data on climate events to perform risk analysis. The availability of this data has limitations. For instance, projection data for 2050 for heavy precipitation and foundation risk are not available currently. There is also no data on building-level adaptation measures. Rabobank expects data improvements that will enhance the accuracy of its climate-risk capabilities over the coming years.

Rabobank will strive to further improve its climate-risk assessment, incorporating new iterations of data sources as they become available.

Methodology and description on alignment in business lending

The alignment of Rabobank’s portfolio outside of residential mortgages is limited. To assess alignment of its corporate customers Rabobank has to rely on direct disclosures by its customers. Our non-financial counterparties have disclosed their alignment in terms of capital expenditures (CapEX), operational expenditures and turnover. As a financial institution Rabobank is to report its Taxonomy KPIs based on the turnover and capital expenditures KPIs of its customers. The turnover KPI shows the alignment level of the economic activities that a customers generates revenue with, while the CapEx KPI shows the alignment level of the investments made by customers.

Nuclear and Gas

As a result of the Delegated Act amending the EU Taxonomy and the subsequent Commission Notice as regards economic activities in certain energy sectors, additional disclosure requirements were introduced with respect to nuclear energy and fossil gas. This requires financial institutions to include indicators of involvement with the relevant sectors and eligible exposures in a set of mandatory templates. Under the amended delegated act, a summarized disclosure on these activities can now be found summarized in template 2.

For the customers in scope of the mandatory disclosure, we have evaluated exposures to the nuclear energy and fossil gas sectors on the basis of their EU Taxonomy disclosures. Rabobank notes that the main driver for the GCA balance in template 2 results from financial institution counterparties. The disclosures by these customers reflect their portfolio and thus often include exposures to either fossil gas or nuclear energy related activities.

Trading Portfolio

Under the current status of the EU Taxonomy Regulation, Rabobank is not required to disclose quantitative information on the trading portfolio. Based on regulatory reporting, the main components of the Rabobank trading portfolio are derivatives and debt securities held with central government counterparties. As such, the trading portfolio is not materially in scope for alignment assessment under the EU Taxonomy.

Outlook

Over the coming year, Rabobank will continue to work towards improving the disclosure of EU Taxonomy alignment of its portfolio. This will entail improving data quality and availability to overcome the limitations noted above and to acquire further data required to determine the alignment of eligible customers.

Stimulating sustainable living remains a key part of Rabobank’s strategy concerning the energy transition.  Rabobank does so by offering knowledge and financing opportunities that will help its customers in the transition to more sustainable homes. This strategy correlates directly with increasing the EU Taxonomy alignment of the mortgage portfolio.

The resilience of food systems, clean water and sustainable livelihoods depends on healthy ecosystems, making nature integral to the long‑term resilience of our customers and our portfolio. Accordingly, we support the Kunming‑Montreal Global Biodiversity Framework (GBF) vision for 2050. For Rabobank, this means balancing food and energy within planetary boundaries. By 2030, we aim to embed nature into core banking and governance and align our portfolio and policies with GBF 2030 targets. By addressing nature-related impacts, risks and opportunities we aim to increase the resilience of our customers. Our full nature vision and approach is available here.

At Rabobank, we follow IPBES drivers as an approach to overall materiality of nature related themes. As such, we focus on drivers of ecosystem degradation and biodiversity loss. Based on our double materiality assessment, we currently focus on three interdependent and connected topics: pollution, water, and land use (including soil/land degradation, deforestation and land use change/conversion which are elaborated on in the sections below). Our bank-wide approach addressing the aforementioned topics, consists of four interdepended steps that we have elaborated upon in the Sustainability Embedded in our Strategy-section.

When working on our objectives, we include nature in our steering and decision making and use the Mitigation Hierarchy (a commonly used framework to reduce and manage negative impacts on nature) as our guide.

Nature efforts

Our initial set of Nature efforts, disclosed for the first time in our 2023 Annual Report (page 81), focused on building awareness, strengthening governance, and integrating nature considerations into risk management and customer engagement. By the end of 2025, the majority of these efforts have been achieved. Progress includes strengthened governance and accountability, and enhanced internal knowledge on the topic of nature through bank-wide training programs and recurring senior management sessions. In addition, we advanced key enablers for nature risk and impact management, including expanded portfolio insights (e.g., dependency assessments and heatmaps) and improved availability of geospatial/collateral data for rural customers. One aim was partially achieved: the sustainability scoring of Dutch dairy customers is predominantly based on Biodiversity Monitor data, while data from the Open Soil Index (OBI) has not yet been fully connected.

Looking ahead, we have updated our nature efforts for the period 2026–2027. These new efforts are structured under our three levers: Customer, System, and Portfolio. While the focus of our efforts remains consistent, embedding nature into our core business and processes, the updated efforts place greater emphasis on practical support for customers, measurable outcomes, and collaboration. For example, through our efforts to finance sustainable transitions in the food and agriculture sector, supporting Dutch farmers in adopting agroforestry practices, and further developing tools and frameworks that help us and our customers understand and manage nature-related risks and opportunities. The updated efforts can be found in the table below.

Impact & dependency analysis

We performed a top-down, modelled nature footprint analysis for the majority of Rabobank’s private sector loan portfolio of December 2022, which represents 63% of Rabobank’s total assets. We applied the BioScope biodiversity impact tool, which uses Exiobase, a multi-regional input-output model, combined with ReCiPe, which converts various drivers such as resource exploitation and emissions into biodiversity footprints. BioScope is an internally recognized and widely used tool to identify the most important impacts on biodiversity associated with businesses and financial products. Outcomes show that most of the impact of our private loan portfolio on nature is due to the effect of land use. The analysis also indicated that most of Rabobank’s customers’ impact on nature occurs at farm level in the Animal Protein, Grains & Oilseeds and Dairy sectors. Additionally, we performed a dependency analysis (based on 2022 figures, using ENCORE), which also covers 63% of our total assets. From this update, we have learned that approximately 85% of the covered assets is ‘highly’ to ‘very highly’ dependent on one or more ecosystem services. Water availability, soil quality and climate regulation are among the ecosystem services we are most dependent on.

Based on our impact and dependency analysis, we have on-boarded the topic of nature in 12 sector x region plans in 2025. These are specific implementation plans developed to achieve relevant sustainability targets and manage sustainability impacts, risks and opportunities for the particular sector x region combinations. This sector x region level based approach is integrated in our business strategy and financial planning (please refer to the Material Impacts, Risks and Opportunities and Their Interaction With Strategy and Business Model for more detail).

Pollution is a key driver of biodiversity loss and ecosystem degradation, affecting soil health, water quality and the functioning of ecosystems. For Rabobank, this topic is material due to our exposure to Food & Agriculture sectors, particularly in the Netherlands, where nutrient surpluses — notably nitrogen — exert pressure on ecosystems and protected areas. In addition, we also keep working on Impact, Risk and Opportunity management for other pollution related topics, including crop protection. Our ambition aligns with the Kunming‑Montreal Global Biodiversity Framework (GBF), particularly Target 7.

Description of the processes to identify and assess material pollution-related impacts, risks and opportunities

Pollution negatively impacts biodiversity by contaminating ecosystems, and disrupting ecological processes. Addressing pollution is crucial to maintain healthy ecosystems and preserve biodiversity. As part of our double materiality assessment, we identified the following material pollution-related impacts and risks within our downstream value chain.

Impact

We considered the pressures on nature, response on nature and state of nature, to assess our impact. For pressures on nature, we considered human activities that directly or indirectly change the state of nature, through land use (change), water use and pollution. Actions taken by stakeholders to reduce pressures and to improve the state of nature are considered to identify the response on nature. The state of nature refers to the ecosystem’s health in a specific location resulting from reduced or increased pressures and responses on nature. We performed a top-down, modelled nature footprint analysis, that we elaborated on in the first part of the Nature-section.

We assessed our negative impact on pollution to be material. We have a negative impact on pollution due to the financing of the production of fertilizers and facilitating the availability and use of them, affecting an adverse impact on nature in the Netherlands, and due to the financing of the Food & Agri sectors in the Netherlands, and thereby indirectly contributing to excess nutrients, in particular nitrogen. This can have an adverse impact on nature in the Netherlands.

We have also identified the potential positive impact on pollution to be material, due to our Vision for agrifood 2040, affecting the better protection of nature as our Dutch customers in agriculture and horticulture are supported in strategic choices toward future-proof business models.

Risk

Exposures in the Dutch livestock Dairy and Animal Protein (Pork, Poultry, and Beef) sectors, are considered vulnerable due to nitrogen uncertainty. Using heatmap analysis, a bottom-up scenario analysis was employed, focusing on financial strength and sustainability. This analysis provides insights into the necessary transitions, the potential increased risks from nitrogen-related requests, and the financial capacity of customers to make these transitions. These insights lead to sector and portfolio specific additional provisioning through a management adjustment.

From a financial (credit) risk perspective, we have identified the risk of loan impairment charges due to pollution-related environmental degradation, such as air and water contamination, soil degradation, and bioaccumulation of toxins, caused by customers driving biodiversity loss and ecosystem health decline affecting their ability to repay their loans. Stricter regulations and uncertainty can also result in additional costs and impact the current business model. Most notable example is nitrogen for dairy, veal and pig farming. From a financial (business) risk perspective, we have identified the risk of losses due to pollution caused by customers driving biodiversity loss and ecosystem health decline affecting the competitive environment, e.g., decreasing volumes, (commercial) margins, fees, commission, other income, or increasing (operating) costs.

Policies related to pollution

Specifically for pollution’s sub-topic, nitrogen in the Dutch Food & Agri (F&A) sector, the policy "Beleid en Instructie Stikstof Veehouderij" (Policy and Instruction Nitrogen Livestock Farming) effective until November 10, 2025 applied. This policy outlines Rabobank’s approach to financing applications in the livestock sector, particularly concerning nitrogen emissions. The policy applies to various livestock sectors in the Netherlands, including cattle, calves, and goats. Specific criteria (e.g. proximity to Natura 2000 areas) and exemptions (e.g., existing nitrogen permits) are detailed. The policy's key components include:

• Assessment of applications to ensure they contribute to the sustainability and profitability of the livestock sector. The necessity and urgency of the financing, including nitrogen-reduction strategies, are part of this assessment.

• Review of certain financing requests (especially those involving significant expansion) by the Engagement Committee for Nitrogen (ECV). This committee ensures uniform decision-making and monitors the impact of the financing on nitrogen emissions.

• Decision-making based on an analysis of the environmental impact and the financial stability of the applicant. The ECV meets weekly to review applications and make strategic decisions.

The policy “Nieuw Beleid en Instructie Natuurvergunningen” (New Policy and Instruction Nature permits) applies as per November 10, 2025. This applies to livestock sectors specifically and all sectors if the investment goal is new construction or renovation. The policy relates to customers who have to deal with Natura 2000 area permits.

The Global Standard on Sustainability Acceptance and Performance addresses our material impacts related to pollution, mainly via the Nature Policy. This policy section describes how we monitor the performance of our customers and business partners. More specifically, we do not accept customers or business partners that: “cause or intentionally contribute to a reduction in the population of endangered species (on the IUCN Red List of threatened species)”; which could be a result of polluting activities.

At activity level, we do not accept pollution-related activities:

• Production of, or trade in, products containing Polychlorinated Biphenyls (PCBs) or other Persistent Organic Pollutants (POPs) that are subject to international bans or phase outs as listed by the Stockholm Convention;

• Production of, or trade in, Ozone Depleting Substances (ODS) that are subject to international bans or phase outs as listed with reduction targets and phase out dates by the Montreal Protocol.

With regard to Performance monitoring, we can request supporting information on our accepted customers’ and business partners’ controls and progress that demonstrate they are aware of the key environmental impacts at their production/operational sites, by having an environmental plan addressing these impacts, e.g., land use change, water, soil, agrochemicals, pollution.

Furthermore, we also have a sector policy addressed at Agrochemical producers, specifically directed at ‘synthetic crop protection’. In this policy, we do not accept customers that do not have transition plans to phase out Highly Hazardous Chemicals.

Actions and resources in relation to pollution

Nature, including the topic of pollution, is being integrated into the strategic steering cycle of the bank step by step. Please refer to the Material Impacts, Risks and Opportunities and their Interaction with Strategy and Business Model for more detail.

Specifically for the sub-topic of nitrogen in the Netherlands, Rabobank established financing propositions with a budget of EUR 3 billion (available until 2030) to support farmers in their strategic choices towards a more future-proof business model (or a combination thereof): extensive farming, innovation, relocation, conversion, or cessation. In our Vision for agri-food 2040 , we envision a Dutch agricultural sector that has progressed its transition to producing food more sustainably by 2040. This overall vision is being translated into sector-specific visions, which in turn are translated into the relevant policies. Ecologic, economic, and environmental (including Natura 2000 area proximity) elements are included in our underwriting criteria.

Our actions and resources to manage our material impacts and risks related to the sub-topic of nitrogen in the Netherlands are visible in the following areas:

• Financing: by year-end 2024, we provided EUR 452 million financing supporting transition pathways. By year-end 2025, this amount increased to EUR 1,206 million. Most of our financing flowed towards the extensification of farming pathway (84%). Pathways related to broadening the business model, innovation and relocation represent 6%, 9% and 1% of financing respectively.

• We use various indicators linked to nitrogen (soil nitrogen surplus and ammonia (NH3) emissions) to benchmark customers in the Dutch dairy sector. We do this for the majority of Dutch dairy customers (>EUR 1 million).

The broader topic of pollution is included in our group-wide nature approach. To this end, Rabobank’s dedicated nature team works closely with Finance, Risk, and RaboResearch’s Sustainability & Data Analytics team in areas such as impact and dependency analyses, metric development, and onboarding sustainability in business-as-usual processes, while also collaborating with commercial business lines.

The actions, as referred to within this section, through which we manage pollution, are on-boarded in our business-as-usual processes and activities. The expected outcomes and time horizons of our actions cannot always be disclosed at this point in time.

Targets related to pollution

At present, Rabobank has no time-bound and outcome-oriented targets and results in place for pollution. We are in the process of identifying suitable metrics. For more information on the nature approach's effort targets and the progress we made to track the effectiveness of our policies and actions, please refer to the table in the introduction of this nature section.

Water is essential for ecosystem health, food production, and plays a critical role in sustaining biodiversity. For Rabobank, water is a material topic due to our significant financing activities in Food & Agriculture and other water‑dependent sectors, particularly in regions facing increasing water stress. Water use and availability can affect both freshwater ecosystems and the resilience of food systems and livelihoods. Our ambition aligns with the Kunming‑Montreal Global Biodiversity Framework (GBF), notably Targets 2 and 11, which focus on restoring freshwater ecosystems and maintaining ecosystem services.

Description of the processes to identify and assess material water-related impacts, risks and opportunities

Water is essential for all life on earth. It sustains ecosystems, supports human health, and influences biodiversity. Simultaneously, human actions and climate change are disrupting natural water cycles, putting freshwater ecosystems under increasing pressure. As part of our double materiality assessment, we identified the following material water-related impact within our downstream value chain.

Impact

We considered the pressures on nature, response on nature and state of nature, to assess our impact. For pressures on nature we considered human activities that directly or indirectly change the state of nature, through land use (change), water use and pollution. Actions taken by stakeholders to reduce pressures and to improve the state of nature are considered to identify the response on nature. The state of nature refers to the ecosystem’s health in a specific location resulting from reduced or increased pressures and responses on nature. We performed a top-down, modelled nature footprint analysis, that we elaborated on in the start of the Nature-section.

The negative impact on water availability, due to financing of and financial service provisioning to Rabobank's customers in the Food & Agri and industrial sector which facilitates the withdrawal and consumption of water (water use), leading to an adverse impact on nature through worsening water scarcity in countries like the Netherlands, USA and Australia.

Based on our double materiality assessment, this topic is no longer deemed material from a risk perspective. Water-usage risk is captured under climate change adaptation.

Policies related to water

In our Global Standard on Sustainability Acceptance and Performance our Nature Policy is the main policy on the material impacts, risk and opportunities related to water. In this policy, we mention that we can collect supporting information of customers and business partners demonstrating that they:  “are aware of the key environmental impacts at their production/operational sites, by having an environmental plan addressing these impacts, e.g., land use change, water, soil, agrochemicals, and pollution.” However, no specific water-related acceptance requirements are included in the Nature Policy.

Actions and resources related to water

Nature, including the topic of water, is being integrated into the strategic steering cycle of the bank step by step. Please refer to the Material Impacts, Risks and Opportunities and their Interaction with Strategy and Business Model for more detail.

Rabobank’s Sustainability department includes a dedicated Nature team that collaborates closely with Finance, Risk, and RaboResearch’s Sustainability & Data Analytics teams. Key areas of focus include impact and dependency analyses on the topic of water, development of sustainability metrics, and integrating sustainability into core business processes. The team also works in partnership with commercial business lines and the Rabobank Water Team, which was established during 2025.

In 2025, Rabobank launched its Water Vision 2030, recognizing water as a vital resource. Our Water Vision 2030 supports the EU Water Framework Directive, which provides the legal foundation for protecting and restoring Europe’s waters, and the European Water Resilience Strategy, which calls for a systemic shift towards water-smart economies and resilient ecosystems. The Water Vision is led by a dedicated Rabobank Water Team and supported by a broader ‘Water Squad’ to ensure effective implementation.

Actions include:

• Through cooperative initiatives, Rabobank currently allocates EUR 15 million directly and indirectly in water-related solutions, aiming to increase this in the future of which EUR 10 million via our subsidiary BPD to invest in grey water systems and EUR 5 million through the Rabobank Water team.

• Investing in knowledge, through a partnership with Wetsus, a European Water Technology Institute, where we continue to build on our water knowledge.

• We support the WaterBank, a Dutch Cooperative initiative, which gives residual water a second life.

With these initiatives, we are helping customers reduce their water footprint and build resilience. In addition we:

• Assess the freshwater use of our larger (exposure > EUR 1 million) business customers in its sustainability assessment tools. The Relationship Manager (the assessor) engages with the customer and for such customers that are active in water stressed regions, this engagement is part of the risk assessment. This is part of the performance criteria of our Nature policy.

• Will launch a bank-wide training on the topic of fresh water. The training provides participants with a basic understanding of the Impacts, Risks and Opportunities around fresh water. This module will be fully available in Q1 2026.

The actions, as referred to within this section, through which we manage water, are on-boarded in our business-as-usual processes and activities. The expected outcomes and time horizons of our actions cannot always be disclosed at this point in time.

Targets related to water

At present, Rabobank has no time-bound and outcome-oriented targets and results in place for water. For more information on the nature approach's effort targets and the progress we made to track the effectiveness of our policies and actions, please refer to the table in the introduction of this nature section.

Land use is a broad topic covering land use change (e.g. deforestation and land conversion of natural ecosystems), land and soil degradation, land management practices, with potential impacts on biodiversity and climate regulation and sensitive locations, such as Protected Areas. It is considered a key driver of biodiversity loss and climate change. For Rabobank, this topic is material due to our significant exposure to Food & Agriculture (F&A) sectors, which depend on healthy ecosystems and are linked to land conversion risks.

Our ambition aligns with the Kunming-Montreal Global Biodiversity Framework (GBF), particularly Target 1 (Halting deforestation and land conversion), Target 2 (Restoring degraded ecosystems) and Target 3 (Avoiding impacts in protected and key biodiversity areas). We aim to progressively adapt our portfolio and policies to prevent land conversion and promote more sustainable practices.

Transition plan and consideration of land use in strategy and business model

Land use is part of our overall nature approach which entails embedding nature into all our core banking processes and governance and progressively adapting our portfolio and policies toward alignment with the Global Biodiversity Framework 2030 targets, in line with the best practices and based on the best available science. Please refer to the introduction section in this chapter for more details on our nature approach. Moreover, the Global Standard on Sustainability Acceptance and Performance applies, which is complemented with region-specific business (impact) strategies. The first region-specific business (impact) strategy that we have developed, and are implementing, is focused on Brazil. This is elaborated on in the Actions and resources in relation to land use-section.

Description of the processes to identify and assess material land use-related impacts, risks and opportunities

Land use is considered by science to be the biggest driver of biodiversity loss; this includes deforestation and land conversion. Soils support life on land and water, nutrient cycling, food production, pollution remediation, and climate regulation. As part of our double materiality assessment, we identified the following material land use-related impact within our downstream value chain.

Impact

To assess our impact on nature, we consider the pressures on nature, the state of nature and responses. The pressures are human activities that directly or indirectly impact the state of nature. For Rabobank, the most material pressure categories are land use (change), water use and pollution. The state of nature refers to the ecosystem’s health in a specific location, for example the vegetation type and whether this resembles native vegetation. The responses are actions taken by our customers to reduce pressure and improve the state of nature. 

The Nature prioritization assessment, using BioScope (elaborated on in the first part of the Nature-section) indicates land use as the largest pressure on biodiversity loss, mostly driven by the sector's primary agricultural activities in our portfolio. The impact of land use is large because agriculturally used land for cropping or grazing typically provides less habitat to species than native vegetation. Note that land use as a pressure on nature is different from land use change, with the latter referring to the conversion of land from native vegetation to non-native land use types.

While land use change – which also entails deforestation - is not part of the assessment based on BioScope, it has been assessed with other data sources and customer-level data and is classified as material in the double materiality assessment.  Water use is material in water-stressed areas where water use for irrigation competes with the availability of the water for freshwater ecosystems. The physical risks related to drought and water scarcity are often also material in these areas.

Risk

Progress is made in strengthening Rabobank’s understanding and management of nature-related risks. Based on our heatmap analyses, we conducted various environmental risk scenario analyses including high-level macro impact of land use policy change. From a physical risk perspective, the effects of land-use change are covered in drought scenario analyses. The first land use metrics have been defined for risk management, building on this work, further land use metrics will be included over time.

From a financial (credit) risk perspective, we identified the risk of loan impairment charges due to land degradation/land-use change caused by customers driving biodiversity loss and ecosystem health decline affecting their ability to repay their loans.

Policies related to land use

Our Global Standard on Sustainability Acceptance and Performance includes Nature Policy and Deforestation and Land Conversion Policy requirements addressing land use topics.

For selected midstream customers and business partners in sector x regions that are prioritized from a deforestation and land conversion perspective (excluding palm oil):

• We do business with large midstream customers sourcing unprocessed raw materials from priority sector x regions, if they have a strategy in place towards no deforestation, even if legally authorized. This strategy must extend to both direct and indirect suppliers.

For upstream customers:

• In sector x regions that are prioritized from a deforestation and land conversion perspective, we do not provide loans or finance for deforestation and land conversion purposes, even if legally authorized.

• We do not do business with upstream customers (not just those who are active in prioritized sector x regions) or business partners whose lands have been illegally deforested or converted after January 1, 2018¹.

Specifically for upstream customers in Brazil:

• We do not accept lands in the Amazon biome as new collateral, which have been deforested after January 1, 2018, even if done legally.

In addition, our sector-specific Arable Agriculture and Forestry policy (the sectors in scope are cocoa, coffee, cotton, palm oil, soy, sugarcane, tea and forestry (including pulp and paper) states that:

• Being a Roundtable on Sustainable Palm Oil (RSPO) member for upstream customers is mandatory, this is a acceptance requirement. RSPO sets globally recognized standards that include No Deforestation, No Peat, No Exploitation (NDPE). We use this – among other sources – to monitor that our customers’ production does not cause or contribute to deforestation, new plantings on peatland and exploitation, and that they have mechanisms in place to identify, avoid and resolve land tenure conflicts with local communities or Indigenous peoples, all as detailed in the RSPO. Membership in RSPO entails a commitment to continuous progress toward full certification.

• Being a Round Table on Responsible Soy Association (RTRS) member is a performance requirement. RTRS sets a standard for responsible soy production.

• We can request supporting information on our accepted customers’ and business partners’ controls and progress in the upstream value chain that demonstrate that they are making progress in certifying the company and/or its products according to the relevant sector initiatives.

Actions and resources in relation to land use

Nature, including the topic of land use is being integrated into the strategic steering cycle of the bank step by step. Please refer to the Material Impacts, Risks and Opportunities and their Interaction with Strategy and Business Model for more detail.

We have outlined our acceptance criteria in the “Policies related to land use”. Please note that our Global Standard on Sustainability Acceptance and Performance is a global standard. And although it does include region-specific elements,

A global standard cannot effectively take into account the different local realities in regulatory contexts and market maturity. As a consequence, a global standard that overarchingly outlines what we require from our customers and what we do not allow, can be complemented with region-specific business (impact) strategies. The first region-specific business (impact) strategy we developed, and are implementing, is focused on Brazil.

Brazil

The Brazil land use strategy focuses on accelerating the transition of the food and agricultural system towards a deforestation‑free and land‑use‑change‑free future. The strategy follows the mitigation strategy and is based on four pillars: 1. improving data accuracy, 2. incentivizing our customers, 3. supporting high‑impact projects, and 4. contributing to broader system transformation.

1. Increasing data accuracy. This entails enhancing data collection, monitoring, analysis and response system. Examples of actions related to this element include comprehensive staff training, leveraging satellite imagery to monitor customer-owned land, and dashboard development.

1. Efforts to help our customers, which entail developing propositions and financial structures to:

   • Incentivize our customers not to use legal deforestation rights. An example is the Responsible Commodities Facility (RCF) which was developed and negotiated with other counterparties (MFF, IDB, Agri3, UK Retailers (Tesco, Sainsburys and Waitrose)) and aimed at promoting the responsible production and trade of deforestation- and conversion-free soy in Cerrado biome in Brazil by providing financial incentives to farmers committed to environmental preservation. For the 2025/26 season, the RCF will finance around 280 farms, producing 240,000 tons of soy and conserving around 90,000 hectares of native vegetation (of which 28,915 hectares is excess native vegetation).

   • Support forest acquisition and/or reforestation efforts. An example is the Forest Code Acceleration Loan, a long-term financing solution, offering loans up to 20 years, designed to support forest acquisition and/or reforestation efforts. This structure enables customers to meet Forest Code requirements early, without straining their cash flow. By extending the payment horizon, we align environmental compliance with financial sustainability. This product is conditioned to the additionality of acquiring and protecting more forest than the legislation requires, closing the existing gap and going beyond legislative requirements.

   • Support projects to convert or recover degraded land into sustainable agricultural and forestry systems. Examples are Ecoinvest, a BRL 350 million innovative blended finance structure backed by Brazil’s National Fund on Climate Change. The program supports projects that restore degraded land and convert it into sustainable agricultural and forestry systems, reducing pressure for new land clearing. Rabobank was selected by the National Treasury as one of the few banks to operate credit line (BRL 200 million from the government and BRL 150 million from Rabobank). Disbursements are expected to begin in Q1 2026. And AGRI3 Fund (created by the United Nations Environment Program (UNEP) and Rabobank, with support from IDH – The Sustainable Trade Initiative and the Dutch development bank FMO), which combines long-term financing with technical assistance. It is a blended finance solution that allows us to extend the term from 7 to 10 years and it is aimed at financing the restoration of degraded pastures, reforestation, forest protection, and sustainable farming projects.

2. Supporting impact projects. In addition to making impact in cooperation with our customers, we invest in projects to enable restoration and conservation. Examples are our share in Biomas, announced during COP27, in Egypt (together with other Brazilian companies such as Suzano, Marfrig, Santander, Itaú Unibanco and Vale) and focused entirely on the restoration, conservation and preservation of forests in Brazil. In April 2025, Biomas’ first reforestation project took place, with an investment of R$55 million in 1,200 ha of a property of Veracel Celulose in the South of Bahia. And our philanthropic partnership with the Black Jaguar Foundation, a non-profit organization working to restore the Araguaia Corridor, connecting the Amazon rainforest and the Cerrado savanna across central Brazil. Their objective is to realize the longest biodiversity corridor on Earth by planting over 1.7 billion native trees, in collaboration with local communities (for seed collection) and farmers. The Black Jaguar Foundation is a boots-on-the-ground organization in Brazil aiming to restore 1 million hectares of nature, bringing back rich biodiversity, creating wildlife habitat, combating climate change, and strengthening local communities. Rabobank supports the Black Jaguar Foundation in reaching its goals.

3. Contributing to system change. This entails engaging with different stakeholders, including NGOs, public and private sectors, having speaker roles in various forums, and establishing strategical partnerships to accelerate the transition of the food and agricultural system toward a deforestation‑free and land‑use‑change‑free future. Examples include:

   • Our participation in the 30th UN Climate Change Conference (COP30), in Belém, Brazil was shaped by three priority topics: reduce deforestation and land conversion, accelerate regenerative agriculture and taking efforts to act on our sustainability aspiration 'value nature'. We actively participated in panels, dialogues and coalitions and engaged with key players, like NGOs, governments and customers. In addition we advocated for system change, including long-term policy coherence and implementation.

   • WBCSD engagement : Rabobank is officially joining the LAB (Landscape Accelerator Brazil) partnership and participant of the Action Agenda Regenerative Landscapes.

   • Brazil Coalition of Climate, Forest and Agriculture: Rabobank is a formal partner in this coalition. The coalition proposal for climate transition has been officially launched on NYCW backed on three main pillars: Food Systems, Sustainable Commodities and Nature-Based Solutions.

   • IPAM - An internationally recognized Amazonian institution expert in sustainability studies in tropical agriculture.
     A partnership has been established with Rabo Brazil, focused on developing financial solutions linked to payments for environmental services, valuation of natural capital, and training of the commercial team.

   • Fundação Dom Cabral – Rabo Brazil is sponsoring this multi-stakeholder initiative led by a renowned business school to introduce an innovative business model aimed at advancing sustainability in agriculture through three key components: 1) development of a Regenerative Agriculture Sustainability Index to assess and promote sustainable practices, 2) mobilization of financial instruments tied to environmental performance, 3) creation of a digital platform to integrate data and services, enhancing transparency, accessibility and stakeholder engagement.

   • Fundação Getúlio Vargas – Rabo Brazil is sponsoring a leading Agriculture Institute for an applied research initiative aimed at developing, refining, and updating methodologies for measuring greenhouse gas (GHG) emissions in Brazilian tropical agriculture, with a particular focus on integrating technical measurement with economic analysis.

Actions and resources in other regions

In the Netherlands, the Vision for agri-food 2040 applies (although not a region-specific business (impact) strategy exclusively focused on land use). In it, we envision a Dutch agricultural sector that has progressed its transition to producing food sustainably by 2040. This overall vision is being translated into sector-specific visions, which in turn are translated into, e.g., underwriting policy. Ecologic, economic, and environmental (including Natura 2000 area proximity) elements are included in our underwriting criteria. The environmental element revolves around the location of the agricultural business, and the adequacy of the location for the intended agricultural use. In addition in the Netherlands we continue leveraging:

• The Open Soil Index (Open Bodem Index). This is a tool we co-developed with insurance company a.s.r. and water supply company Vitens to provide farmers with a better picture of the development of the soil and soil quality in the Netherlands. Ultimately, the goal is to make the soil more fertile, with the result that agricultural entrepreneurs and the drinking water supply benefit from this.

• The Biodiversity Monitor for Dairy Farming and for Arable Farming. The monitors provide insight into the actions that farmers can take to improve biodiversity on their farms and beyond. Additionally, these monitors can provide insights into new farm revenue models. Diversified revenue models could help convince and motivate farmers to manage their farms by protecting and enhancing natural capital, including biodiversity. The Biodiversity Monitor for Dairy Farming informs a pricing incentive scheme applicable to relevant financing products for (sustainable) frontrunners in the Dutch Dairy sector (for customers with more than EUR 1 million in financing and an A-score)

In Australia, in 2025 we engaged in the first land use pilot using collateral land polygons. In New Zealand, Rabobank, through Rabo Investments, has partnered with Nateva—New Zealand’s largest provider of permanent indigenous forest restoration—to offer farmers a new income opportunity via nature-based solutions. The initiative focuses on afforestation projects that generate voluntary carbon credits, which farmers can sell to local and international buyers, creating a long-term revenue stream while supporting climate mitigation and biodiversity restoration. Under a lease arrangement, eligible farmers receive 50% of the carbon credit value after costs, as Nateva manages the transition from exotic nurse crops to indigenous forests through active forest management.

The actions, as referred to in this section, through which we manage land use, are being on-boarded in our business-as-usual processes and activities. The expected outcomes and time horizons of our actions cannot always be disclosed at this point in time. In addition, we do not apply biodiversity offsets. Except for the actions disclosed in this section, we have not incorporated local and indigenous knowledge into biodiversity and ecosystems-related actions.

1. As described in our deforestation and land conversion policy and taking into account local legislation and our contractual and fiduciary duties towards our customers.

Targets and impact metrics related to land use

In addition to, having completed a first iteration of the assessment of our impact and dependency on nature, including land use, we are progressing towards land use related metrics. Leveraging satellite imagery and polygon information from the lands of our rural customers, we are in the process of defining and testing metrics. In addition, as we are advancing in implementing the Brazil land use strategy, specific land use related metrics start surfacing. Specific project related metrics are also being monitored, for example, in our philanthropic partnership with the Black Jaguar Foundation, we are considering the number of seedlings produced and, indirectly, their potential impact on restoration measured in hectares. For more information on the nature approach’s effort targets and the progress we made to track the effectiveness of our policies and actions, please refer to the table in the introduction of this nature section. At present, Rabobank has no time-bound and outcome-oriented targets and results in place for land use.

Social Information

Disclosure Requirement (DR)

As a bank, we influence people’s lives in many ways – both positively and negatively, directly and indirectly. In our role as an employer, with a presence in 34 countries and over 49,000 employees worldwide, we have a direct responsibility for the rights and well-being of our workforce. This includes fostering a safe and inclusive working environment, protecting employee privacy, and addressing factors that may affect health and well-being. We also act as a corporate lender to business customers. In this role, we may be indirectly connected to human rights impacts arising from our business customers’ operations or their value chains. And as a financial services provider, we serve more than 8 million private customers in the Netherlands. Through the products and services that we offer – such as mortgages – we recognize our role with regard to the lives and well-being of our customers.

In each of our roles, that we elaborate on in this section, people are center stage. In our sustainability aspiration ‘Enable People’, Rabobank works towards:

• Respecting human rights within our own operations, business activities, and business relationships.

• Embedding salient human rights in our business processes.

• Supporting our business customers in how to address possible causes of labor exploitation in high-risk sectors.

• Fostering social (and financial) inclusion within the retail customer market in the Netherlands.

Rabobank affirms its responsibility to respect international human rights as set out in the United Nations' Guiding Principles on Business and Human Rights (the UNGPs) and the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises on Responsible Business Conduct.

Our grievance mechanism landscape and remedy approach

Our responsibility to provide for or enable access to effective remedy for adverse human rights impacts is a common thread throughout the Social Information statements. As a bank operating in different roles, our responsibilities regarding grievance mechanisms and approaches to remedy vary accordingly, as described in the UNGPs. In 2025, as part of our People approach, we launched a bank-wide initiative to review our global grievance mechanism landscape and remedy approach. We assessed the effectiveness of our internal and external grievance mechanisms and remedy processes across our different roles. This enabled us to evaluate our effectiveness in meeting our human rights commitments and regulatory obligations, to identify potential areas for improvement and to create a shared vision for an effective, accessible, and people-centered remedy approach. Improvements from this initiative will be implemented over 2026 with the aim of aligning our grievance and remedy approach further with international standards and our commitments in our various roles.

Empowered Employees

The driver 'Empowered Employees' contains two ambitions: 'A Great Place to Be', and 'Future-Ready Organization’'. These ambitions are elaborated in the People@Work strategy. A Great Place to Be is explained as: ‘We want our employees to realize results, add value for our customers, and contribute to our goals. That is only possible if we offer them the best environment to work, develop, and grow. For us, this means a safe and supportive workplace, where people feel valued and can reach their full potential. Creating such a place requires not only an effortless employee journey and clear roles and responsibilities, but also diverse and inclusive teams that work together. We want Rabobank to be a great place to be and where people want to stay.’ The ambition 'Future-Ready Organization’ is explained as: ‘Rabobank needs a future-ready organization in order to be able to adapt and compete in an ever-changing business environment to deliver on customer expectations. Our future-ready organization is one that is equipped with the skills, knowledge, and adaptability to facilitate the key transitions: food system and energy. We support the organization in the qualitative, quantitative and structural shifts needed to build a future ready cooperative bank. We enable our people to grow, and through them, we enable the Rabobank to thrive.’

To support the ambitions of the People@Work strategy, there are three pillars: inclusive environment, work-life balance and developing people. Rabobank believes that these pillars are essential in creating and maintaining the 'Great Place to Be' and the ‘Future Ready Workforce’ it aims to realize.

By creating an inclusive environment, Rabobank promotes a culture where ideas, backgrounds, experiences and perspectives are respected and valued and professionals are selected according to their abilities and talents and no one is discriminated against. A diverse workforce – on an individual and team basis - allows Rabobank to foster the diversity of thought contributing to innovativeness, and creativity.

Work-life balance refers to the impact Rabobank has on its employees by helping them put hybrid working into practice and finding a joint optimal working balance, viable for the employee, the team and the organization. Rabobank wants to be an attractive employer for everyone as well as a high-performing organization.

To remain future fit as an employer and as an employee, Rabobank values the development of its employees, recognizing the benefits it brings to individuals, teams, the organization, and society as a whole. The objective of developing people is to build a future-ready organization and great place to be, through ongoing people development. Continuous development benefits employees, the Rabobank, and society.

Rabobank has assessed both the positive and negative impacts on its own workforce. Among the three pillars underpinning the People@Work strategy, the pillar 'Inclusive Environment' has been identified as material. The pillar positively impacts the Human Resources strategy in Rabobank's own workforce via procedures, policies and processes on the one hand, and behavior of employees and leadership on the other hand. While the other two pillars have not been classified as material to the overarching strategy, either from a positive or negative perspective, Rabobank continues to address them. In certain instances, fostering an inclusive environment may contribute to effectively managing these other pillars.

With approximately 75% of Rabobank’s employees based in the Netherlands, the impact of the bank’s workforce-related initiatives will be most strongly felt within the Dutch context. Therefore, the initiatives in the Netherlands have been deemed material for reporting purposes. However, Rabobank does not limit its efforts to the Netherlands, therefore, when available and relevant, numbers and explanations will be given for Rabobank in total, which includes employees working outside of the Netherlands.

Rabobank publishes all HR policy documents in the Rabobank Policy House Portal, which is an online library that is available to all employees and includes all its global, regional and local policy documents. Relevant policies for inclusive environment are:

• Global Policy on Diversity, Equity and Inclusion (DE&I)

• Global Policy against Harassment and

• Global Policy on Remuneration.

As Rabobank aims for a safe environment free of harassment, it has a Global Policy against Harassment to ensure that employees feel safe to speak up freely about concerns, work-related problems, undesired behavior, misconduct, and other irregularities. Rabobank strives to prevent and address harassment in all its forms. The Global Policy against Harassment contains information on why Rabobank has this policy, the scope of the harassment framework and the overarching principles to deal with harassment. Rabobank encourage resolving complaints through dialogue bilaterally between the employees involved and/or their line managers. The complainant procedure should be easily accessible. The policy is elaborated and refined in local policies and requirements. The procedure on how harassment complaints should be handled is defined in the Global Procedure against Harassment.

Rabobank has a Global Policy on Diversity, Equity and Inclusion (DE&I) that serves as a general umbrella for all global diversity, equity and inclusion initiatives. Furthermore, it serves as a guidance under which all regions, local banks and/or departments can create their own local DE&I procedures which comply with the DE&I Strategy and respect the Global Policy as well as local laws and regulations. As Rabobank believes that every employee should feel safe, valued and respected, the policy does not distinguish targets or actions for specific groups or on specific grounds. An exception is made for gender diversity as the Dutch law 'Wet Diversiteit in de Top' requires Rabobank to disclose and report on the goals set on gender diversity in senior management and the current state. However, this does not imply that Rabobank only focusses on this aspect of diversity.

The principles of the Group Remuneration Policy guarantee a conscientious, sound, and sustainable remuneration system. This remuneration policy contributes to sound and effective risk management that does not incentivize any risk-taking that is unacceptable to the bank. In addition, it is aligned with the bank’s business strategy, objectives, values and behaviors, and long-term interests. Rabobank Group promotes equal treatment of all employees and considers that all staff should be equally remunerated for equal work or work of equal value. More information and metrics on compensation can be found in the Remuneration chapter in the Corporate Governance section.

Furthermore, Rabobank commits to comply with Dutch and international legislation and regulations for the countries in which it is active.

The interests, views, and rights of people in our own workforce inform the Human Resource strategy and its pillars as well as its business model in several ways, such as through analyses on the engagement scan, conversations and input from the Works Council, the Employee Resource Groups (ERGs), Unions and Inclusion Agents. It is partly due to this interaction that impacts, risks and opportunities are derived, which co-determines the actions and allocated resources.

Employee Engagement Scan

Rabobank's employees are closely involved in our mission and committed to the strategic priorities of our bank. In order to constantly improve, Rabobank actively engages with its employees globally and seeks their valuable input on a range of topics. In addition, insights on employee engagement are discussed at all hierarchical levels within Rabobank. All managers are required to discuss the insights into employee engagement with their respective teams. Rabobank measures employee engagement globally each quarter using an engagement score survey, processed by an external company. The Engagement Score is based on the extent to which employees feel that they enjoy their work, their work gives them energy, they are proud to work for Rabobank, and they feel that they fit in at Rabobank. In total, 31,615 employees provided feedback in the Engagement Score in Q4 2025 (31,585 employees in Q4 2024). Besides the engagement score, other scores are used to measure inclusive culture, work-life balance and developing people.

Every quarter, the effectiveness of the engagement scan is assessed, for example by asking all employees the question 'My team has taken action based on the results of the previous Engagement Scan'. Overall, this process contributes to managing our (material) impact on inclusive culture, work-life balance and developing people and in relation to our own workforce by giving employees the opportunity to (anonymously) share their input.

Employee Voice

As part of the safe working environment, Rabobank offers its employees several ways to speak up freely about concerns, work-related issues, undesirable behavior (harassment) or whistleblowing cases. Rabobank aims to solve difficult situations at the workplace by starting conversations with colleagues or the managers. There are dedicated channels, including the assigned internal and external trusted persons, to offer a listening ear, guidance and advice in handling these situations. In addition, there are dedicated channels for example for employees to report or raise a complaint under the Global Policy against Harassment, the Collective Labor Agreement procedures or the Global Policy on Whistleblowing. Rabobank only reports on the figures that are related to the Rabobank employees working in the Netherlands in line with its material impact of DE&I.

The internal reporting channels on difficult HR-related situations in the Netherlands handled 734 new cases in 2025 (2024: 671), of which 589 concerned labor related issues (2024: 507),107 concerned harassment (2024: 68). Of the harassment cases, 23 (2024: 11) were related to discrimination. Cases are linked to themes based on the employee's report. If a complaint is submitted to a committee, the committee will assess it on its merits.

The Industrial Relations Disputes Committee (Geschillencommissie Arbeidsverhoudingen) dealt with 13 formal appeals in 2025 (2024: 6). The Social Plan Central Appeals Committee handled 14 formal appeals (2024: 3), and the Objections Committee Executives handled 1 formal appeal (2024: 0). The Local Harassment Committee Netherlands handled 14 reports (2024: 8). Under the Global Policy on Whistleblowing 13 new cases were reported regarding the Netherlands in 2025 (2024: 41).

As there is currently no registration of the financial settlement of the cases, Rabobank cannot report on the fines, penalties, and compensation for severe human rights issues and incidents connected to our own workforce. We currently have no internal registration of severe human rights issues and incidents in connection with our own workforce in the Netherlands, given that such complaints are not received. Based on our current procedures and operating practices, we are not aware of any such incidents.

Employee Resource Groups (ERGs)

Rabobank has seven globally operating ERGs that work to advance DE&I within our organization, providing support and advocacy for diverse groups. These ERGs aim to foster an inclusive and supportive environment and are designed to address the unique needs and challenges of diverse employee populations within the organization. The ERGs represent the following groups: women, LGBTQ+, and neurodiverse employees, employees with a bi- or multicultural background, young employees (=< 36 years old), senior employees (> 36 years old) and international workers, e.g., expats.

Inclusion Agents

An inclusion agent is an employee who voluntarily takes on an additional role alongside their primary function. They contribute to creating more awareness on DE&I in the organization and help improve inclusive collaboration. By 2025, the network of inclusion agents has grown to over 100 members worldwide. These agents facilitate a range of team sessions to raise awareness and promote equity and inclusion, driving meaningful conversations and change across the organization.

Trade unions and Works council

In the Netherlands, the Works Council plays a vital role in ensuring employee participation and protecting their interests within Rabobank. The Workers Council is mandated by the European and Dutch Works Councils Act. Rabobank carries out negotiations with trade unions on the collective labor agreement for the employees in the Netherlands.

To enlarge our positive impact on our workforce, actions and initiatives are in place. Below, we list some of the key initiatives and actions we have undertaken to create an inclusive environment for our people. These initiatives are just a few examples of Rabobank's ongoing commitment.

Updated Diversity, Equity & Inclusion strategy

Rabobank has updated its Diversity, Equity & Inclusion (DE&I) strategy to align with Rabobank’s Group and People strategy, as well as broader global developments in this area. The approach focuses on three key areas: inclusive collaboration, equitable employee journeys and a targeted approach on diversity taking into account local and regional legislation.

With inclusive collaboration, Rabobank promotes inclusive ways of working whether with colleagues or customers and supports leaders in creating fair and unbiased processes. This helps the bank manage increasing complexity and make better use of new technologies. With equitable employee journeys, Rabobank aims to provide fair opportunities and resources for all employees by reviewing the HR products, processes, and policies. Besides, we focus on increasing diversity during key moments in the employee journey, such as hiring and promotions. This helps the bank build teams that reflect the markets we serve and respond to the challenges of a shrinking workforce.

International Diversity Day

On May 21st, Rabobank celebrated International Diversity Day globally to promote and keep DE&I top of mind broadly in the organization. Rabobank chooses to align this celebration with the annual Unesco World Day to support and emphasize the importance and relevance of DE&I in society. Multiple lunches were organized internationally, and four in the Netherlands. The Managing Board participated in one of the lunches that was organized for over hundred employees. During this lunch, a business game was played to increase awareness by experiencing privileges that people have or biases that people are faced with. Globally, ten short lectures were broadcasted live, which touched upon several topics, like DE&I and GenAI and how to create inclusion in your team. Over 1,000 employees watched the lectures live.

E-learning Break the Bias

The Break the Bias e-learning module is offered to employees globally and aims to strengthen an inclusive environment for employees and customers. In this e-learning, employees will learn about the importance of recognizing and mitigating biases to create more inclusion.

Cultural Diversity Barometer

To broaden the scope of diversity, equity and inclusion within Rabobank from monitoring and steering on gender diversity to other aspects of diversity, Rabobank collaborated with Statistics Netherlands (CBS) in the Netherlands to gain insight into cultural diversity. CBS offers individual organizations with more than 250 employees the opportunity to use the Cultural Diversity Barometer to gain insight into the cultural diversity within their own organization. CBS analyzed Rabobank's organizational data to provide insights into cultural diversity within the boundaries of laws and regulations of the Netherlands to help organizations, like Rabobank, to monitor and steer on cultural diversity. The measurement is performed by CBS once a year. The scope is employees working for Rabobank, located in the Netherlands. Using this approach for monitoring cultural diversity contributes positively to the material impact on DE&I related to our own workforce as it creates awareness on the current state on cultural diversity on the organization and domain level and opens up the conversation on cultural diversity within management teams. However, as insight is generated on an annual basis, the barometer is currently insufficient for the quarterly steering cycle within Rabobank. Nonetheless, the insights provided by CBS drive action within management teams.

Fair and Equitable Compensation

Rabobank is committed to ensuring fair and equitable compensation for all employees and considers this principle fundamental in guiding pay-related decisions. To support this commitment, equal pay analytics have been developed that will help to identify and address potential systemic and individual pay equity issues. These actionable insights will contribute to achieving and sustaining pay equity across the organization. In line with our dedication to pay transparency, Rabobank also voluntarily discloses the adjusted gender pay gap.

The internal monitoring metrics capture the employee perspective, as reflected in the engagement surveys, alongside company data related to the pillars of an inclusive environment.

A target has been set for two subjects with respect to an inclusive environment. These targets concern gender diversity in top management and the engagement scan score. For these targets and Rabobank's performance on them, refer to Metrics of Our Own Workforce.

To address our impact on inclusive culture, we disclose metrics on own workforce, diversity and compensation. For information on incidents and complaints, refer to Employee Voice. For the definitions and methodology of the metrics of our own workforce, please refer to Appendix 1: Methodology & Definitions Sustainability Statements. Rabobank updated the methodology used to calculate the gender pay gap by refining the estimate of variable pay, and include all active Rabobank employees within the consolidated group. For further details on the changes in preparation or presentation of sustainability information, please refer to our Basis for Preparation.

As a financial institution, we can be linked to a wide range of adverse impacts for value chain workers and affected communities through our business customers' operations and value chains. This has been confirmed through our human rights saliency assessment as well as the double materiality assessment. The outcomes of the double materiality assessment concluded that labor rights of workers in the value chain and communities' rights are the bank's material topics for this Annual Report. We address these human rights risks through actions and approaches as set out in our People Approach.

Being a large financier in the food and agriculture sector, the rights of value chain workers and communities can potentially be adversely impacted by our activities.

In assessing the potential severity of our human rights impacts, we look at specific drivers of human rights risks that may contribute to a greater adverse impact on value chain workers and communities. In the food and agriculture sector, where many of our customers are active, these risk drivers include high labor intensity, highly seasonal driven, low-skill-low-pay activities, strong/pronounced gender segregation. Such factors heighten the risk of adverse impacts on working conditions including adequate pay, the occurrence of discrimination, and the prevalence of labor exploitation, including forced labor and child labor. For example, these risks are particularly relevant for vulnerable groups, such as migrant workers.

Within the food and agriculture sector, risk drivers for heightened risk of adverse impacts on communities are linked to specific activities and production methods, such as whether they have a significant footprint on land and resources. For instance, livelihoods can be threatened by environmental impacts including deforestation or pollution or by intensive water use. In certain regions, specific regional risk drivers come into play, such as varying levels of recognition and protection of the rights of local communities or human rights and environmental defenders. Large-scale commercial land use may exacerbate shortages of farmland accessible to local communities.

These risk drivers and potential and actual adverse impacts to rightsholders, being value chain workers and communities, could in turn also impact our business customers' operations. It could lead to reputational risks, operational risks - impacting their supply chain resilience in case of adverse human rights impacts deeper in their value chains - and/or legal risks, in case of non-compliance with local laws and regulations.

We are aware of these impacts and our people vision and approach, including our human rights due diligence process, are intended to address these impacts. This approach is guided by a set of design principles:

• We prioritize areas where people face the greatest risks, and tailor our actions proportionately to the level of impact.

• We are committed to addressing human rights within our own operations while also dedicating efforts to support our customers in doing the same.

• We view this approach as an ongoing process – one that involves monitoring the perspectives of affected people and regularly updating our human rights assessments and approach in response to their evolving needs.

In 2024, we performed a human rights saliency assessment focusing on our role as financial services provider (addressing our activities in relation to business customers and retail customers).  When referring to financial services provider, we refer to the provision of products and services to over 8 million private customers in the Netherlands and to our role as corporate lender including leasing to business customers. Through this assessment, that focused on ‘risk to people’, not ‘risk to the bank’, we identified 1) where rightsholders are most at risk to be negatively impacted by Rabobank’s activities and 2) the salient human rights risks we are connected to through our business relationships, including our business customers’ value chains.
Thereby identifying the material impacts and risks connected to our business model (including our products and services) and our business customers. The outcomes of the saliency assessment were used as input for the double materiality assessment, whereas upstream activities are out of scope of this section of the Sustainability Statements. The saliency assessment on our role as financial services provider acts as a starting point for our activities under our People Approach, we explain our approach for the saliency assessment below.

Scope

As for the scope of the saliency assessment, workers in the value chain are defined as individuals performing work in entities that are in Rabobank's downstream value chain, regardless of whether the value chain entities have any direct contractual relationship with Rabobank. These include all workers that perform work within the operations of a respective value chain entity, regardless of the nature of the work they perform or their specific contractual relationship with the value chain entity (i.e., whether they are employed directly, contracted or sub-contracted through third parties on temporary or permanent basis by the respective value chain entity). Affected communities are defined as people or group(s) who are actually or potentially impacted (negatively or positively) in Rabobank's downstream value chains. Affected communities include all types of communities independent of their economic, social, cultural, ethnic, civil and political status. Affected communities include communities within the immediate sphere of Rabobank's activities and the wider sphere of its downstream value chain, such as indigenous peoples or human and environmental rights defenders. The different rightsholder groups of the saliency assessment are aligned with the global social sustainability topics as defined as part of the double materiality assessment approach. In addition, impacts on value chain workers or affected communities arising from the transition to a greener economy (the energy and mining sector) are also considered.

Process

To verify intermediate outcomes, we involved both colleagues and external stakeholders. For the selection of external stakeholders, we looked at their regional perspective, their area of expertise as well as those that could reflect on or act as credible proxies for potentially affected people in relation to our customers and their value chains.

Results

Following these four steps of the saliency assessment, we identified the global salient human rights issues, which are categorized per rightsholder group. The saliency assessment also provided insights into the high-risk sectors where these salient issues occur. The list with high-risk sectors and the definitions for each salient issue are included in the Annex of the Global People Vision and Approach.

For workers in the value chain, the salient issues are related to (1) working conditions, (2) labor exploitation and (3) discrimination. For communities, (1) livelihood and land rights, (2) indigenous peoples' rights and (3) community conflict and human rights defenders are identified as the three salient issues. In the saliency assessment, we also identified salient issues in relation to our retail customers, the salient issues being (1) privacy and (2) social inclusion. For more information on privacy and social inclusion, please see the Sustainability Section 'Consumers and end-users'. The process and the results of the saliency assessment were endorsed by the IMT Sustainability in July 2024.

Rabobank has the responsibility to respect and uphold all international human rights (including labor and land rights) in line with international rules and regulations and our commitment to the UNGPs and the OECD Guidelines.

In the section Sustainability Policies, an explanation is included on the sustainability policies and our Global Standard on Sustainability Acceptance and Performance. In 2025, there were three policies relevant to manage our material impacts on workers in the value chain and communities; the Human Rights Policy, the Labor Rights Policy and the Land Governance Policy. The three policies do not reference specific groups of value chain workers or affected communities explicitly, except for indigenous peoples as a specific vulnerable group in certain communities.

These three policies have the aim to address the identification, assessment and management of potential and actual human rights risks at our business customers' level. Furthermore, they also address the responsibility for our business customers to cooperate in effective remediation of adverse impacts through legitimate processes, when relevant. In practice, we may engage with customers that do not yet fully meet all our requirements if they have an acceptable time-bound plan to do so.

Cases of non-compliance with these three policies, which may mean non-respect of the international human rights frameworks referenced such as the UNGPs, can come to our attention through different internal and external sources and channels. In 2025, two customers were determined to be non-compliant with Rabobank’s human rights and labor rights policy due to severe labor violations. We have engaged with both customers on the issues. The relationship with one customers is still under review due to ongoing court proceedings. The relationship with the second customer was been terminated in 2025.

Throughout the year, we have been supporting and equipping our business colleagues by offering them the tools and knowledge for customer engagement on human rights. For example, targeted ongoing presentations on our People approach, objectives, design principles and policies.

Policy Development and Implementation

As part of the Sustainability Policy Framework, we recently updated our Human Rights policy. This was approved in 2025, implementation was finalized in January 2026. The Human Rights policy replaces the abovementioned three policies. The new policy is:

• Aligned with the format of all sustainability policies explained in the section Sustainability Policies: differentiation between acceptance and performance criteria.

• Informed by our saliency assessment: We apply additional human rights requirements to customers operating in sectors with a high risk of adverse human rights impacts, particularly those engaged in high-risk activities within those sectors. This approach enables us to apply our policy proportionally; customers’ approach to how they comply with the requirements may vary in proportion to their size, specific activities, sector characteristics and geographic context. It also considers the customer’s level of responsibility and control over their value chains.

• Strengthened with more stringent criteria for customers: As an example, we strengthened the criteria for remediation through legitimate judicial or non-judicial processes for actual adverse impacts customers have caused or contributed to. Another example is that we have included specific commitments covering the prohibition of modern slavery and the elimination of child labor, in line with relevant ILO conventions, for relevant customers active in high-risk sectors (using the saliency outcomes).

The Human Rights policy relies on the norms and principles of international recognized instruments, such as our UNGP commitment and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, and highlights that certain rights and freedoms may be specific to certain individuals, groups or communities to which particular attention must be paid due to their higher risk of marginalization and vulnerability such as indigenous peoples, human and environmental rights defenders, workers (including own workforce, workers in the value chain, migrant workers and contract and subcontracted workers), women and children.

The human rights requirements in this policy are complemented by other policies and standards within the bank, which may entail additional or more stringent human rights requirements for customers and business partners, such as sector specific policies or policies on sanctions and privacy. The implementation of our policy and the assessment of our business customers against our policy criteria are key in our human rights due diligence.

As part of our due diligence process, the voices of value chain workers and affected communities help us to understand how our activities and that of our business customers could impact their human rights. Through our business customers, to whom we provide loans or other financial products, we are connected with potentially affected stakeholders (value chain workers or affected communities).

Our general process for engaging with these rightsholder groups is that we engage with credible proxies (organizations that can bring forward the voices of potentially affected value chain workers or affected communities). For instance, when executing human rights impact assessments, in the development of our approach for the strategic focus areas or in relation to urgent emerging topics such as conflict affected areas. A dedicated ‘People team’ within the Group Sustainability department engages throughout the year with credible proxies, where the frequency and formality of the approach differ per situation and motivation. Every year at the Annual UN Forum on Business and Human Rights in Geneva, we actively engage with credible proxies, for example, workers' organizations or representatives of human rights defenders, with a primary focus to gain a better understanding of the human rights risks to rightsholders in certain regions or countries, and risk drivers in the high-risk sectors in which our business customers are active. In addressing labor exploitation, one of our strategic focus areas, engagement with credible proxies and other experts, is relevant for the determination of our approach. We describe our approach for engagement in this context, in the next section.

Furthermore, we engage with our business customers, as we encourage them to enter into meaningful engagement with their stakeholders, including potentially affected people, to gain a better understanding of the human rights risks involved in their operations, value chain or sector. We encourage our customers, for instance, through our policies and in direct conversations and dialogues with them, to conduct effective stakeholder engagement in relation to the human rights most at risk in their sector or value chain. For example, we have been addressing labor exploitation risks in the Dutch horticulture sector by means of several sector dialogues, see the next paragraph.

In 2024, we strengthened our focus on human rights by establishing a formal program of work with a dedicated team. The People Approach outlines our actions and deliverables for the coming years, which you can read more about in the Global People Vision and Approach. For 2025, our action plans and resources to manage our material impacts related to value chain workers and affected communities included the following specific areas:

• Policy development and implementation (see the section 'Policies related to value chain workers and affected communities')

• Addressing our strategic focus areas

• Reviewing our grievance mechanism landscape and remedy approach

Addressing our strategic focus areas

From the eight global salient issues identified in our saliency assessment, three strategic focus areas have been prioritized. These are areas where we believe there is an opportunity to address human rights risks both at the customer and system level, and they are:

• Labor exploitation

• Livelihood and lands

• Social inclusion

Addressing labor exploitation

Based on our saliency assessment, we know that labor exploitation is a risk both in the Netherlands, where our customers are active in sectors such as horticulture and animal protein (particularly in the processing phase such as in slaughterhouses) and internationally, in the food and agriculture sector.

In the Dutch horticulture sector, risk drivers such as high labor intensity and highly seasonal-driven work could heighten the risk of adverse impacts on working conditions, especially for the migrant workers the sector relies heavily on. That is why we conducted a series of interviews with internal (colleagues in various departments within Rabobank) and external stakeholders (e.g., human rights practitioners in other companies, peers, customers, representatives of sector associations) to broaden our knowledge and further understand what is in place within Rabobank and in the sector. We focused on the Dutch horticulture sector in 2025. Through several pilot projects, we gained experience with addressing the risks of labor exploitation and raising awareness for the issue. One example is our active participation in dialogues with relevant stakeholders from the Dutch horticulture sector, as explained in the interview with Arne Bac (see next page). We also organized knowledge sessions with our commercial colleagues to exchange ideas, best practices and challenges, especially in their interaction with our business customers.

Using these experiences, we are working towards the creation of a Decent Work strategy addressing the risks of labor exploitation in the Dutch horticulture sector, in particular in relation to migrant workers. This strategy outlines our current initiatives - for instance actions related to the importance of certification for labor agencies or housing - and our actions for the near future. We aim to support the Dutch horticulture sector in addressing these systemic risks and promoting collaboration within the sector and between relevant business partners, including labor agencies. We will follow this approach in other high-risk sectors such as the animal protein sector and international food and agriculture value chains.

In 2026, we aim to explore how to address the strategic focus area 'livelihood and lands'. For livelihood and lands, we focus primarily on local communities as potentially affected people through the activities of our business customers in our role as financial services provider. For social inclusion, we leverage the experience Rabobank has in the area of Financial Healthy Living as a starting point.

Reviewing our grievance mechanism landscape and remedy approach

The UNGPs, which Rabobank is committed to, include the responsibility for companies to enable access to effective remedy for adverse human rights impacts. The nature of this responsibility under the UNGPs depends on the company’s involvement, whether a company has (1) caused or (2) contributed to the adverse impact or (3) whether they are directly linked to the adverse impact. As a corporate lender, via our financing, we are often directly linked to the adverse impacts on value chain workers or affected communities, and our responsibility with regard to remediation differs from that of our business customers who might be causing or contributing to the impact. Therefore, in our new Human Rights Policy, we have stated a clear requirement on remedy, which was implemented in January 2026. Business customers must provide for or cooperate in remediation through legitimate judicial or non-judicial processes for actual adverse impacts on human rights, labor rights and/or land rights they have caused or contributed to.

In our efforts to assess Rabobank’s existing grievance mechanism landscape and remedy approach, as stated in the introduction of this chapter, we reviewed our approach in our role as financial services provider (addressing our activities in relation to business customers). The purpose of this review was to identify and address any gaps in our current grievance mechanisms and remedy approach, and align the current approach more closely with international standards, such as the UNGPs. Our grievance mechanisms include a general contact form on our website, a sustainability mailbox, and multi-stakeholder initiatives-driven mechanisms. Following this review, we are developing an 'enabling remedy strategy' for human rights grievances raised by rightsholders impacted by activities of our business customers.

At present, Rabobank has no time-bound and outcome-oriented targets and results in place for adverse human rights impacts in relation to value chain workers or affected communities. Part of the development of our People Approach is to assess whether we can develop meaningful indicators to measure whether our efforts also have a positive effect on the people most at risk from our activities and that of our customers and business partners. We will explore effort-based targets related to our strategic focus areas in 2026.

ESRS S4 relates to social impacts on consumers and end-users. For Rabobank, as a financial service provider, the scope is individuals using our products and services for personal use. Rabobank services a diverse range of individuals in the following business lines and entities:

• Retail customers in the Netherlands form a large proportion of our individual customer base (approximately 8.2 million private customers). This includes provision of loans in the residential mortgage market and products and services in savings, payments, investment and insurance products.

• Outside the Netherlands, (individual) savings accounts are also available in Australia and New Zealand.²

• In addition, Rabobank services individuals via its wholly owned subsidiaries, including DLL, Obvion, BPD and Vista, that have activities in the Netherlands and abroad.

This chapter focuses on our efforts related to:

1. Financial Healthy Living, Accessibility, and Non-Discrimination in line with the material ESRS sub-topic of Social Inclusion. This topic is deemed material for Rabobank from a positive impact perspective for the downstream value chain (customers) access to products and services and responsible marketing practices. To be an inclusive bank, rooted in our slogan “Growing a better world together”, requires Rabobank taking shared responsibility in society and means ensuring that no one is directly or indirectly excluded.

2. Privacy, in line with the ESRS sub-topic of Information and Personal Safety Related Impacts. Privacy is deemed material for Rabobank from both a potential negative impact on society and external risks to the organization.  For example, a data breach or cyber-attack could severely impact a large number of our individual customers by violating their privacy through a leak of their financial information, compromising their rights as well as causing emotional distress. These consequences could also lead to regulatory investigations and expose the bank to significant reputational damage.

Social Inclusion and Privacy are considered salient human rights for consumers at Rabobank. Refer to section Material impacts, risks and opportunities and their interaction with our strategy and business model for further details on the saliency assessment.

1. Per the CSRD, the following definitions apply: Consumers are “individuals who acquire, consume or use goods and services for personal use, either for themselves or for others, and not for resale, commercial or trade, business, craft or profession purposes. ”. End users are “individuals who ultimately use or are intended to ultimately use a particular product or service”.
2. The programs highlighted in this section focus on customers in the Netherlands, as this is where most of our retail customers are concentrated. Policies and Standards are globally applicable, including in Australia and New Zealand.

In section Interests and Views of Stakeholders, we explain how we take the interests and views of stakeholders, including consumers and end-users, into account in relation to our strategic direction and business model. The interests and views of consumers and end-users are embedded in our internal processes, as described in the section Processes for engaging with consumers and end-users about impacts below.

Social Inclusion

The cooperative values and behaviors expected from every employee and anyone representing Rabobank are described in our Code of Conduct (RaboCompass). One of our core values is being customer-driven: the interests of our customers come first. Another key value reflects our co-operative nature: what matters to the world around us matters to us. Today, financial well-being is under pressure due to inflation, energy poverty and income inequality. Rabobank has an institutional responsibility to address these challenges, particularly in the Netherlands, where we serve as both a provider of funds and a guardian of current accounts. With 9.1 million customers (8.2 million private customers and 0.9 million business customers) entrusting us with EUR 193.8 billion in retail savings, this role is fundamental to our purpose. (2024: 9.2 million customers with EUR 177.1 billion in retail savings).

Rabobank strives to be socially conscious in all of its business operations, with inclusion high on our agenda. Consumers and end-users rely on accurate and accessible information about our products and services. We pay particular attention to customers in vulnerable situations – those who, due to personal circumstances, may experience financial worries earlier, face challenges in understanding and processing information and/or be especially susceptible to harm. This vulnerability can include exposure to fraud, financial abuse and financial difficulties. Rabobank develops solutions to support these customers to manage their bank affairs, and to safeguard their personal data.

Social Inclusion aims to promote non-discrimination and support accurate and accessible products and services through responsible marketing practices that prioritize transparency, fairness and well-being of consumers. In the Netherlands, we advance this through three priority programs: Preventing Discrimination, Financial Healthy Living, and Accessibility. These priorities are embedded in our business propositions and daily customer interactions. By promoting inclusive practices, we contribute to a sustainable society where everyone has equal opportunities.

These programs are further explained in section Taking action on material impacts on consumers and end-users, and approaches to managing material risks related to consumers and end-users, and effectiveness of those actions

Privacy

Rabobank has a fundamental responsibility to protect all personal data entrusted to us. This data often provides insight into customer’s financial well-being, personal habits, preferences, and (financial) integrity. Rabobank processes personal data for a variety of purposes, including serving customers and safeguarding the integrity of the financial system. Misuse of this personal data can pose potential significant risks to the rights and freedoms of individuals. Given the nature of the services provided, inadequate processes could negatively impact individuals’ rights to privacy, the protection of their personal data, and non-discrimination. Potential non-compliance with consumer data privacy legislation resulting in remedial actions and financial fines is recognized by Rabobank as material.

Over the past years, Rabobank has established a robust privacy framework and organization. Accountability and responsibility are embedded within business functions, and compliance with privacy policies, standards and procedures is overseen by a dedicated Data Protection Officer (DPO), who reports directly to the Chief Compliance Officer of the Rabobank Group, supported by a team of Privacy Officers and Compliance Officers within the Compliance function.

Treating Clients Fairly and Supporting Standards

The topics related to the material ESRS sub-topic of Social Inclusion are described in relevant Rabobank Global Standards. The overall objective of these global standards is to ensure that our principles, as described in our Code of Conduct (the Rabobank Compass), drive consistent and balanced outcomes for our customers. Global Standards are revised on a biennial basis¹ or sooner if material developments occur, such as a change in regulations.

• Treating Clients Fairly means putting the interest of our customers at the center of our decision-making, culture and behavior. The Global Standard on Treating Clients Fairly sets out the requirements in relation to procedures, processes and controls related to the development of products and services, information for customers and service provision (including responsible lending). The Standard addresses Social Inclusion elements such as accessibility and anti-discrimination considerations, financial education and strengthening the ‘financial difficulties’ guidance. A separate Standard is also in place for the protection of customers in relation to investment products and services.

• The Global Standard on Complaints Handling sets out the minimum requirements regarding the way Rabobank registers, handles and responds to complaints. It also provides guidance on learning from complaints and using complaints to identify systemic problems, and adopting better practices. Rabobank aims to handle complaints in a timely, competent and fair manner, making corrections or providing remedy on a best-effort basis. We aim to ensure that the outcome of the complaint is in line with internationally recognized human rights. This is reflected in the way Rabobank makes the complaints handling process accessible to customers in vulnerable positions.

• In alignment with the Treating Clients Fairly and Complaints Handling standards, employees are committed to upholding non-discriminatory conduct in all customer interactions.

• Further, specific attention is required for customers in a vulnerable position in line with Treating Clients Fairly. To the best of its ability, Rabobank will look for solutions to help these customers to manage their bank affairs and safeguard their personal data.

• The Global Standard and Global Procedure on Product Governance outline how customer needs and objectives are considered during product development alongside a thorough assessment of potential risks the product may pose to customers.

Rabobank’s Treating Clients Fairly requirements of the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct into account, which include obligations related to fair business practices, responsible marketing and advertising, and the provision of quality, reliable goods and services. Rabobank’s Global Standards also address consumer protection and human rights for consumers and end users more broadly. Rabobank’s commitment to inclusiveness and equal treatment is pivotal in fostering a supportive environment.

Privacy Policy Framework

Rabobank is required to comply with GDPR and local privacy and data protection laws and regulations in all jurisdictions where we operate. Rabobank is also committed to meeting data privacy best practices in relation to the UN Guiding Principles on Business and Human Rights. This involves adhering to the foundational principles of respecting human rights of consumers and end users, which includes ensuring transparency, accountability, and safeguarding personal data.

To meet these obligations and commitments, Rabobank has established global Policies and Standards to manage risks related to privacy and data protection, including principles such as storage limitation (retaining personal data no longer than necessary). Our commitment to safeguarding personal data processed by us is described in our Code of Conduct (Rabo Compass). This value is translated into the Global Privacy Policy framework and related Global Standards, which underwent a regular update in 2025. The updates were aligned with our Binding Corporate Rules, reaffirming the technology neutrality of our policies (while also considering processing of personal data with Artificial Intelligence) and explicitly noting the risk of discrimination. The Global Policy on Privacy and Personal Data Protection serves as the cornerstone of the Global Privacy Policy Framework, detailing principles for lawful, fair and transparent personal data processing and emphasizing accountability, data minimization, accuracy and data protection to uphold individual privacy rights. Rabobank’s privacy statements are publicly available online and updated periodically.

All policy documents referenced in this section apply across Rabobank Group. Business line and entity management are responsible for developing supporting systems, processes, procedures, and controls and delivering appropriate training to implement and adhere to internal policies and standards, as delegated by the Managing Board. Compliance with these obligations is monitored through our risk and control framework.

For human rights policies refer to section Policies related to value chain workers and affected communities.

1. The Global Standards on Treating Clients Fairly and Complaints Handling will be revised in 2026 in the biennial revision cycle.

The respective business unit Management Teams are responsible for managing the strategic and tactical issues regarding the retail banking business.

Rabobank engages with and collects feedback from stakeholders through a variety of ways and frequencies, including proactive and regular outreach as well as ad-hoc engagements.

Direct Engagement

We actively engage with our consumers and end-users through various channels, including surveys, focus groups, and direct feedback mechanisms to understand their concerns and improve our practices. This engagement helps us understand their needs, preferences, and concerns, which are critical inputs for our product development and service delivery strategies.

Member Engagement

Rabobank Members’ Council members are an antenna in the local community. They form the link between the bank and its members and act as our sounding board and our sparring partners. We engage with these members to get their input on certain topics, for example non-discrimination, and housing and care.

Other Representative Bodies

In addition, Rabobank regularly engages in various dialogues with local Supervisory Bodies and Client Council members, about topics impacting their communities such as financial education, sustainability and local social issues.

Public and private parties

• Rabobank collaborates with external parties to address societal challenges on financial health. We actively bring our knowledge and experience into collaborations with public and private parties, such as the Stichting Financieel Gezond Nederland (SFGN)¹, Geldfit and Nibud².

• Rabobank works with peer banks and the Dutch Banking Association to enhance accessibility and to prevent (perceived) discrimination. An information website with explanatory videos (www.toegankelijkbankieren.nl) is available for our customers (especially older customers) and we have established national bank information points at various local municipalities. Rabobank also works together to formulate an industry baseline for the bank’s gatekeeper function, aimed at establishing principles that ensure attention to non-discrimination.

• In case of legislative proposals related to privacy, Rabobank provides feedback to legislators via the Dutch Banking Association.

External Reports

• At the end of September 2025, DNB and Ipsos I&O (commissioned by the Dutch Ministry of Finance) reported the results of follow-up studies on discrimination by banks³. DNB notes that banks have taken important steps toward a better approach to tackling discrimination but sees room for improvement.
  Rabobank continues to work through its multi-disciplinary program on actions the bank can take to prevent our (future) customers, stakeholders, and employees from experiencing discrimination.

Complaints Handling Process

• Rabobank manages all complaints and feedback in line with the Global Standard on Complaints Handling. There are procedures in place to handle complaints and requests in a timely, effective, fair and independent manner. Fairly also means that the bank will not treat a customer adversely for making a complaint.

• Rabobank wants to learn from complaints and feedback received. Consumers can express a complaint via many channels including, in person at a Rabobank branch, by telephone, via an online form through our website, or by letter. In the Netherlands, consumers can file complaints and share general feedback via the webpage Help onze dienstverlening te verbeteren. Where possible, complaints are resolved by the first point of contact or a dedicated complaints handler. Where the complainant is not satisfied with the progress of the complaints procedure or the solution proposed, escalation to an independent unit is possible. If the complaint is not resolved to the satisfaction of the complainant or within 8 weeks after submitting their complaint, the complainant can seek an external review via a competent authority or Alternative Dispute Resolution e.g. Kifid, the Dutch Institute for Complaints related to financial services.

• For customers who experience discrimination by Rabobank, the website also provides the option to share their experience with the national Discriminatie.nl portal or the Netherlands Institute for Human Rights.

• In case of a privacy-related complaint, the complainant always has the right to register a complaint directly with the Data Protection Officer, or externally with the Data Protection Authority or the competent court.

• Rabobank identifies root causes of complaints, as well as possible improvements, via periodic analysis of complaints received. Complaints are also considered an important source of information in the product approval and review process.

• As part of our continuous learning approach, we monitor customer satisfaction with how complaints are handled.  

• To emphasize the importance of learning from complaints, reports on complaints management, including  trends, lessons learned and potential improvements, are provided to senior management, the Compliance department and the Managing Board.  The Compliance department also issues independent reports on the effectiveness of the complaints handling process.

• The effectiveness of complaints handling controls - including both complaint registration and learning from complaints - is monitored by the first and second line at least annually.

• In 2025, the Grievance Mechanism and Remedy Approach initiative⁴ assessed the complaints process for the Role of Retail Financial Service Provider, which is related to Consumers and End-Users, against the United Nations’ Guiding Principles on Business and Human Rights and OECD Guidelines. The assessment concluded that the overall process is mature, supported by well-designed procedures, effective governance and robust staff awareness of the topic. The mechanism is actively used by private customers and has delivered satisfactory remedy outcomes for complainants.

1. Foundation for Financial Healthy Netherlands.
2. Dutch National Institute for Family Finance Information.
3. Report into Experienced Discrimination In Services Provided by Banks and Payment Institutions, dated July 2025
4. See Our grievance mechanism landscape and remedy approach in Social Information Introduction.

Social Inclusion

Rabobank is committed to the United Nations’ Guiding Principles on Business and Human Rights. In the Netherlands, where most of our customers reside, we see how our transitions interlock and financial health becomes a larger issue. As a cooperative bank, whose mission is ‘Growing a better world together’, we work together with public and private organizations to help face these challenges. Our ultimate goal is to contribute to a more inclusive and financially healthy society for our customers and the wider communities.

In the Netherlands, Rabobank focusses on three key topics: Financial Healthy Living, Accessibility, and Non-Discrimination.

Financial Healthy Living

We have been promoting ­financial healthy living since 2018 through various campaigns. Key actions include:

• Proactive Customer Service: Rabobank focuses on preventing financial distress and promoting financial awareness. Dedicated teams, such as Hulp bij Geldzorgen¹, support customers facing financial difficulties and provide preventative assistance, including advice and resources from Rabobank as well as help of public and social partners. This team proactively contacts customers when usage patterns suggest potential financial stress, such as cash withdrawal on credit followed by deposits into daily banking accounts. These customers are then offered support through the Hulp bij Geldzorgen program. The next step in this program is to enhance early warning signals, enabling us to identify and assist more customers earlier in the process and prevent serious financial problems.

• Geldfit Support: Geldfit, founded by the Dutch Debt Relief Route Foundation, helps individuals regain control over their finances. Rabobank actively collaborates with Geldfit and participates in its national youth campaign. Through this partnership, we aim to support customers by connecting them with specialists, including our Help with Money Worries team.

• Rabobank App Features: The Rabo app includes an online financial health check and a ‘Rabobank Retrospective’ feature to help customers track their spending and savings. The check was developed in cooperation with Nibud.

• Employee training: Rabobank provides training for customer-facing employees to better engage with customers on financial well-being. This includes e-learning programs and regular knowledge updates.

• Local initiatives: Each region of Rabobank has a local director who stimulates local initiatives. As a figurehead in their Rabobank region, they act as the driving force and connectors of local initiatives. 14 Cooperative Directors at 'Kring' level are responsible for pioneering projects that have a positive impact on themes such as Financial Health, accessibility of services, energy equality and access to the housing market. Examples of projects that were successfully implemented this year include education programs such as bank for the classroom (education for young people about finances) and various local initiatives such as meetings for the elderly (safe financial aging), digital safety session, Fixbrigades (social employment linked to energy savings) and Smartbuilds (building/developing homes at temporary locations).

• Rabobank is the project leader of social collection within the Stichting Financieel Gezond Nederland (former Nationale Coalitie Financiele Gezondheid). The project aims to recover outstanding payments through an approach that prioritizes the debtor’s individual circumstances and well-being, rather than relying on tactics focused solely on immediate debt recovery. It is based on the understanding that people often want to pay their bills but may be unable to do so due to various reasons such as financial worries or mental health issues. As part of this project, Rabobank offers tailored solutions and connects customers with voluntary or professional support to help address financial worries and arrears.

• In 2025, special support on fraud prevention was developed as part of Geldfit for customers who have been victim of dating/ relationship fraud through messaging applications such as WhatsApp. This program educates customers about dating/ relationship fraud to help prevent repeat victimization and reduce the financial impact of these scams.

• Rabobank considers it essential to foster broad access to affordable and sustainable housing. This commitment is reflected in the activities of our subsidiary BPD, which develops residential housing in the Netherlands and Germany. It is further supported by our investment in BPD Woningfonds and by initiatives such as Rabo SmartBuilds, both of which contribute to improving housing affordability, market accessibility and the availability of sustainable homes. Rabobank has invested EUR 2.0 billion in 2024 in BPD Woningfonds. In June 2025, Rabo SmartBuilds was transferred to BPD and Rabobank provided an additional EUR 400 million, bringing the total investment in Rabo SmartBuilds to EUR 500 million (2024: EUR 100 million).

Accessibility

Rabobank aims to be accessible to all customers, including those with disabilities, supporting a more inclusive society . This includes ensuring clear customer communications for example terms and conditions, accessible website information, and usable online banking and mobile apps for everyone.

In addition to the initiatives mentioned in Processes for engaging with consumers and end-users about impact, key actions include:

• Education and resources geared towards customers in a vulnerable position. For example, Rabobank, in partnership with SeniorWeb, offers workshops and presentations on secure internet banking for those who struggle with digital banking. In addition, Rabobank also supports customers via Rabo Samen Bankieren.

• Compliance with European Accessibility Act: Rabobank has completed the core implementation program for the European Accessibility Act, ensuring that the majority of digital and physical customer touchpoints meet the required accessibility standards of this Act.

• Accessibility Improvements: The accessibility program is designed to address both digital and non-digital accessibility. It also includes a practice environment where customers can safely learn and practice online banking (eenvoudigbankieren.nl).

In 2025, Rabobank focused on further improvements within the Rabo Samen Bankieren program, aimed at strengthening support for customers in vulnerable positions and enhancing accessibility across service channels. The first phase of this approach includes:

• Exploration of future service models: Rabobank is currently developing additional support formats, such as in-home assistance and group workshops, to further empower customers who face challenges with digital banking or financial self-reliance. These initiatives are part of the program’s long-term roadmap through to 2027.

• Employee Training: Rabobank continues to invest in building accessibility awareness and competence across the organization. All customer-facing employees and product development teams receive mandatory core training on accessibility. In 2025, the training program was expanded with the rollout of role-based modules, tailored to specific functions. This supports deeper integration of accessibility into daily work and decision-making across the bank.

• Accessible Communication: A writing style guide helps ensure communication is accessible and inclusive. In 2025, a learning bite was developed to support employees in applying these principles in daily communication, making accessibility more actionable and practical across teams.

The effectiveness and impact of these programs are tracked and monitored via our Net Promoter Scores which have shown improvement over the years, specifically related to customers in a vulnerable position. In addition, we have developed impact targets which are monitored by a management tool.

Non-discrimination

Our program focused on addressing (perceived) discrimination, with the aim of strengthening inclusion and ensuring equal treatment in our services

Rabobank has gathered experiences and insights in dialogue sessions with members, customers and employees. We use these insights, together with the complaint analysis and the analysis of policy and processes, to implement structural improvements in our services. Furthermore, we develop specific training courses for our employees to further increase awareness of non-discrimination. The external findings and internal analyses of 2024 form the basis for the ongoing roadmap to improve banking services and prevent (perceived) discrimination. This topic affects all parts of our organization - from the process of becoming a customer to mortgage applications, payment transactions, and loans and customer outreach for AML/CTF purposes.

The following actions are underway or have been completed:

• Defining discrimination: The definition of discrimination used by the Netherlands Institute for Human Rights now serves as the basis to define discrimination in our relevant policies, including the Global Standard on TCF and Global Privacy Policy Framework.

• Reviewing policies: Governance documents impacting our banking services, such as the Global Standard on Complaints Handling, have been assessed, and specific references to non-discrimination will be reviewed where applicable.

• Improving customer communication: Various forms of communication, such as letters to customers and Rabobank webpages, have been reviewed to make them more inclusive and easier to understand.

• Training colleagues: Through various training methods, such as Riskwise online learning, bias awareness in online learning, and team dialogues, we have begun sharing substantive knowledge and raising awareness of non-discrimination, including case studies discussed during team dialogues.

• Enhancing monitoring: The complaints process has been adjusted to specifically monitor for complaints about all forms of discrimination including perceived discrimination. Additional monitoring activities through a structured risk monitoring framework are under development.

Grievance mechanism and remedy approach for our role as financial services provider to consumers

Rabobank is committed to the UNGPs, which emphasize the responsibility of companies to provide access to effective remedies for adverse human rights impacts. In line with this commitment, and as introduced earlier in this chapter, we have reviewed our existing grievance mechanisms and approach to remedy against the expectations applicable to our role as a financial services provider to consumers. As part of the Grievance Mechanism and Remedy Approach initiative, we conducted a review of the existing grievance mechanism and related procedures for this role and determined that they are effective and well-established. Enhancements are planned for 2026 to further align the procedure with the UNGP’s Effectiveness Criteria. Work will include improvements on language accessibility of the feedback channel used by our private customers, as well as translating the existing remedy practices we offer to customers into our procedure.

Information and Personal Safety Related Impacts

Information and Personal Safety related activities are embedded in our everyday work and regularly checked to ensure they continue to address the key impacts and risks.

• Monitoring External Developments: Data privacy is an ongoing and evolving process, and therefore we constantly monitor and improve our data privacy practices. We closely follow external developments (such as Artificial Intelligence) and their impacts on our data processing activities and take the necessary actions where required. Ongoing compliance with changing data protection laws and regulations is ensured via regulatory adherence processes and monitoring of privacy risks and controls.

• Privacy Impact Assessments are conducted to identify and manage potential risks to the rights and freedoms of individuals arising out of the processing of their personal data, as part of our privacy by design process. This is monitored regularly through specific privacy by design controls embedded in our risk and control framework. 

• Personal Data Breaches: Rabobank has policies, standards, and procedures in place to manage personal data breaches. In the event of a personal data breach, Rabobank will take measures to prevent recurrence and, if necessary, notify the Data Protection Authority. Rabobank has a policy to notify individuals in case of a breach of their personal data. To the best of its ability, Rabobank will manage potential impacts to the rights and freedoms of individuals in case of a personal data breach. Personal data breach management is regularly monitored through specific controls embedded in our risk and control framework. In 2025, we enhanced our personal data breach management process and transitioned to a new privacy management platform. This supports more effective personal data breach handling across the organization and improves reporting.

• Fraud Monitoring: Rabobank closely monitors credit and payment products for potential losses due to fraudulent activities and informs customers proactively about fraud risks. By addressing these issues, the bank strives to minimize fraud and ensure a secure banking environment for all stakeholders.

• Confidentiality, Availability and Integrity of personal data:  Rabobank has policies, standards, and procedures in place to safeguard the confidentiality, integrity and availability of personal data via design and implementation of technical and organizational measures. Regarding its digital operational resilience, data management and continuity management, Rabobank follows the applicable laws, regulations and guidelines that apply to it as a financial institution. Rabobank continuously adapts to its changing environment (such as geopolitical tensions) and recalibrates measures where necessary.

• Employee Training: We provide regular training to our employees to ensure they are equipped to uphold our standards.

• Regular audits: We conduct regular audits and assessments to ensure compliance with our policies and standards.

1. Help with Financial Worries

Social Inclusion

Rabobank plays a leading role in the Stichting Financieel Gezond Nederland (SFGN), a collaborative initiative bringing together employers, financial institutions, and other public and private organizations to improve financial health across the country. A key focus of this partnership is customer engagement - educating and supporting individuals to better manage their finances and contribute to a financially healthy society. In addition, all partners take responsibility for promoting the financial well-being of their own employees.

Financial Healthy Living

• Within SFGN, Rabobank is leading the social debt collection initiative, the initiative includes approximately 40 participating organizations.

• Rabobank continues to support customers through Geldfit, providing financial advice and guidance. As part of the Geldfit youth campaign, Rabobank referred more than 2,083 young people to Geldfit in 2025 (2,200 in 2024).

• The Nibud Financial Health Check offers users a financial health score and practical improvement tips. In 2025, 218,503 people used the check (326,364 in 2024).

Accessibility

• Rabobank achieved its target Net Promoter Score of 17 (14 in 2024). Our objective was set out for two focus groups: customers with a physical disability and older customers. This score shows that our efforts are valued by our customers.

• We organized a workshop attended by 65 customers, focused on secure online banking and helping seniors bank safely.

• A webinar on practical tips for safe online payments via the RaboApp attracted 5,400 viewers, providing clear guidance to enhance digital security.

• Rabobank ranked 8th in Sia Partners’ Global Mobile Banking Benchmark 2025, with accessibility as a key driver of this score making us the only Dutch bank in the global top 10 and reaffirming our strong digital strategy.

• Six learning bytes were developed for our employees to deepen understanding of accessibility and inclusive digital services.

• Three instructional videos, covering Online Banking with SeniorWeb, video calling via the Rabo App, and safety hub tips, were developed to support secure and confident digital banking.

Discrimination

• In 2025, the (Perceived) Discrimination Program worked with business lines to implement advice where possible. From this analysis, the program revised customer letters and website texts. It also raised awareness within the organization through training on biases and RiskWise sessions.

These targets are closely connected to the objective of the Treating Clients Fairly Standard which aims for accessibility and adequate care for all customer groups.

As noted earlier in this section, Rabobank also uses complaints and other feedback received as an indicator of performance against its initiatives and service offering as well as to identify any lessons or improvements to be made.   

Privacy

Rabobank continues to strengthen its data protection and privacy practices. During this reporting period, our focus was on transitioning to a new privacy management platform which serves as a foundation for more robust privacy implementation and oversight.

We track the effectiveness of our policies and activities through our risk control framework, which is fully embedded in our internal processes as disclosed in Information and Personal Safety Related Impacts. Employees play a key role in protecting personal data. To support them in this responsibility, we further enhanced our training programs, tailoring them to the needs of different target audiences across the bank.

Governance Information

Disclosure Requirement (DR)

Effective corporate governance ensures that we achieve our mission of ‘Growing a better world together’. In line with this mission, we take responsibility in protecting our customers, members, and society from Financial Economic Crime (FEC) with a robust governance framework. FEC risk management is embedded in our governance through policies, standards, and risk management. Acting as a gatekeeper to the financial system remains a top priority for Rabobank, and we strive to maintain full compliance with all applicable laws and regulations designed to combat FEC across the jurisdictions in which we operate.

The Managing Board and the Supervisory Board are committed to safeguarding the bank’s gatekeeper role in combatting FEC as well as ensuring compliance with the relevant rules and obligations.

Within the Managing Board, business directors (Retail NL, Wholesale & Rural, and DLL) of the Managing Board hold primary responsibility for managing FEC risk within their respective customer portfolios in their domains.

The Chief Financial Economic Crime Officer (CFECO) has specific FEC expertise and is responsible for managing FEC risk, including the implementation of an internal control framework, the execution of FEC risk assessments (including FEC SIRA) and managing and monitoring risks, controls, findings, incidents, actions and remediation.

The Chief Risk Officer (CRO) is primarily responsible for providing a risk and control governance framework, including the Global Policy on Financial Crime Compliance and related Standards, challenging and advising on risk taking, monitoring the risk profile, and the set-up of the Risk Management Committee structure which includes FEC risks.

The Supervisory Board has also established an ad-hoc Financial Economic Crime Committee who monitored progress, supported by reporting from Financial Crime Compliance and Audit Rabobank. More information about this committee can be found in the Report of the Supervisory Board. Fighting financial economic crime is and will remain a top priority for the plenary Supervisory Board.

FEC encompasses illegal activities carried out by individuals or groups to gain financial advantage through the misuse of financial services or markets. This includes money laundering, terrorist financing, sanctions breaches, and bribery and corruption.

Our materiality assessment of business conduct topics identifies bribery and corruption, within the broader context of FEC, as a material issue. FEC represents a significant risk, particularly from a financial and regulatory perspective, due to potential remedial actions and fines for non-compliance with FEC legislation. This risk underscores our ongoing commitment to strengthening a robust and future-proof execution of our gatekeeper role. Preventing financial economic crime is essential to safeguarding the integrity of Rabobank and the financial system as a whole.

The Compliance Charter sets out the roles and responsibilities for managing compliance risk across Rabobank. Compliance risk management is grounded in external standards including laws, regulations, and industry codes, and our own Code of Conduct (Rabo Compass), which describes the organization’s values and expected behaviors. These principles are further detailed in Compliance Policies and Standards. Alongside these formal controls, we recognize the importance of the human element (soft controls) in fostering a strong risk and integrity culture, which we actively monitor and challenge.

Rabobank is committed to upholding the highest standards of honesty and integrity in all global operations and business dealings. Every employee is required to adhere to the Rabo Compass, which sets out our values and behaviors and demonstrates what drives us in our work: being customer-driven, cooperative, professional, and taking responsibility. It provides guidance on how we engage with customers, business partners, colleagues, and society.

Our Global Policy on Financial Crime Compliance (FCC), supported by underlying Global Standards, forms the foundation of our FEC framework. These documents guide the identification, assessment, management, and remediation of FEC risks. The FCC Policy and related standards are accessible to all employees via Rabobank’s intranet, and compliance with these requirements is mandatory for all staff.

Rabobank reviews its policies and standards on a regular cycle. As part of this process, the Global Standard on Anti-Bribery & Corruption and the Global Standard on Sanctions were updated in 2025. The revised Anti-Bribery & Corruption Standard now addresses a broader scope of Third-Party Risk - beyond the previous focus on Business Partner Risk - aligning with industry best practices to assess bribery and corruption risks that may arise from both direct and indirect relationships. The revision also reinforces a risk-based approach to interactions with Public Officials across customers, employees, and third parties.

Looking ahead, the Global Standard on Anti-Money Laundering/ Counter Terrorism Financing (AML/CTF) will be updated to align Rabobank’s compliance framework with the EU’s forthcoming AML/CTF legislative package, including the Anti-Money Laundering Regulation and Sixth Anti-Money Laundering Directive, by 2027.

To effectively prevent, detect, and address Financial Economic Crime (FEC) risks, Rabobank has implemented the following:

Risk and Control Framework:

• An internal control framework which includes the managing and monitoring of FEC risks.

• Implementation of FEC controls such as screening, customer due diligence (at onboarding and throughout the relationship), and transaction monitoring.

• Monitoring for the effectiveness of controls (either preventative, detective or corrective) related to the identified risks.

• The management and monitoring of findings, incidents, actions and remediation measures.

• Annual FEC risk assessments (and additional assessments triggered by specific events) conducted across all regions, business lines, and subsidiaries. These assessments feed into the global Systemic Integrity Risk Analysis (SIRA), which provides critical insights into perceived risk levels across business lines, locations, and activities, enabling the formulation of a group-wide risk profile.

Training of employees:

• All new employees complete the RiskWise Fundamentals global learning program during onboarding. This curriculum covers key topics such as fraud, privacy, security awareness, anti-bribery and corruption, and other areas related to FEC.

• In addition, a mandatory role-based FEC training program is assigned to 61.1% of employees (61% in 2024). This program includes both basic and advanced online modules tailored to roles involving AML/CTF and sanctions.

• The basic training target group includes employees in customer contact and support roles, FEC policy support, and those in the second and third lines of responsibility. Completing this program equips employees with essential knowledge on FEC themes, including risks (such as sanctions, geographic exposure, and customer profiles) and controls (such as transaction monitoring and adverse information screening), as well as Rabobank’s associated standards. These role-specific training programs ensure employees are prepared to protect both the organization and its customers from financial crime.

• Employees in higher-risk FEC functions, such as those with direct customer portfolio responsibility or specialized FEC roles across all three lines, receive advanced online training. This includes practical risk scenarios and an assessment to demonstrate their ability to apply knowledge in mitigating FEC risks. Employees who have not yet completed advanced training are required to work under the supervision of a qualified senior colleague until training requirements are met.

• FEC training is ongoing, with all employees expected to complete their assigned modules within 90 days. Completion is actively monitored. In addition to mandatory programs, tailored training and awareness initiatives are developed to address specific needs and promote continuous learning.

• Members of the Managing Board are required to complete the online FEC training program.

• The Managing Board and the Supervisory Board are offered FEC classroom education sessions.

• Furthermore, an advanced anti-bribery and corruption training was developed in 2025 and has been incorporated in the FEC advanced training program.

• Rabobank maintains records of training content, frequency, and participation, enabling us to monitor knowledge levels across the organization and take action where needed.

Whistleblowing:

• Rabobank encourages employees to speak up about integrity or compliance concerns. Such concerns can be shared with management or with a compliance officer.

• In addition, advice can be asked, or a report of suspicions of wrongdoing, can be made under the Global Policy on Whistleblowing (GPW). External individuals set out under the GPW can also lodge a report.

• The provisions of this GPW ensure confidentiality for the person raising this concern, as well as protection from retaliation.

• The GPW also facilitates anonymous reporting through the SpeakUp Platform or SpeakUp Hotline (contact details can be found in the above link to the GPW).

• All reports raised under the GPW are registered in the dedicated Case Management System. A Whistleblowing Representative, independently positioned within Compliance, stays in contact with the reporter.

• The Whistleblowing Committee (WBC), consisting of executive managers, keeps oversight of all reports made under the GPW.

• The GPW also applies to suspicions on internal fraud such as bribery and corruption.

Total number of convictions and the amount of fines for violation of anti-corruption and anti-bribery laws during the reporting period is (0). As there were no convictions within the reporting period, no actions were required.

The Management Board of Cooperative Rabobank U.A. (Rabobank) hereby declares that, to the best of its knowledge:

• The Financial Statements give a true and fair view of the assets, liabilities, financial position and profit of Rabobank, and the companies included in the consolidation.

• The Management Report gives a true and fair view of the state of affairs on the reporting date, and of the course of affairs during the financial year at Rabobank and those affiliated entities whose information is included in the Financial Statements.

• Information about internal control over financial reporting risk is provided in section Management Report on Internal Control over Financial Reporting.

• Information about internal control over sustainability reporting risk is provided in section Sustainability Statements.

• In light of and as set out in this report for the reporting year 2025, Rabobank manages operational and compliance risks in the manner and to the extent as described in this report. The Management Board is not aware that our internal risk management and control systems would not provide sufficient comfort that the operational and compliance risks faced by Rabobank, are effectively managed considering the risk appetite, where one should also consider the inherent limitations of such systems. Where breaches of the risk appetite occur, they are sufficiently managed. For further details, we refer you to the section on Risk Management.

• In this context, the Management Report provides sufficient insight into failings in the effectiveness of the internal risk management and control systems.

• The Management Report includes the principal risks as well as uncertainties, to the extent that they are relevant for Rabobank's continuity in the coming 12 months.

Managing Board

Stefaan Decraene, Chair
Bas Brouwers, CFO
Vincent Maagdenberg, CRO
Carlo van Kemenade, Member
Alexander Zwart, Member
Lara Yocarini, Member
Els Kamphof, Member
Janine Vos, Member
Philippe Vollot, Member

The Management Board of Rabobank is responsible for establishing and maintaining adequate internal control over financial reporting. Management is also responsible for the preparation and fair presentation of the Consolidated Financial Statements. At the end of the period covered by this Annual Report, Rabobank’s management carried out an evaluation under the supervision and with the participation of its Chief Executive Officer (CEO) and Chief Financial Officer (CFO) of the effectiveness of the design and operation of its internal control over financial reporting. Rabobank’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting for the preparation of its financial statements for external purposes in accordance with generally accepted accounting principles.

All internal control systems, no matter how well designed, have inherent limitations. Due to these limitations, internal control over financial reporting may not prevent or detect misstatements. Also, future projections on the basis of any evaluation of the effectiveness of internal control are subject to the risk that the control measures may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Management has assessed the effectiveness of Rabobank’s internal control over financial reporting as of December 31, 2025, in accordance with the criteria set out in 2013 by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), as defined in the Internal Control - Integrated Framework.

Based on that assessment, the Management Board of Rabobank concluded that the internal control systems provide reasonable assurance that the financial reporting does not contain material inaccuracies.

PricewaterhouseCoopers Accountants N.V., which audited the consolidated financial statements of Rabobank for the financial year ended December 31, 2025, also examined management’s assessment of the effectiveness of the internal control over financial reporting in Rabobank . The assurance report of PricewaterhouseCoopers Accountants N.V. is included in the section 'Other Information.'

Stefaan Decraene and Bas Brouwers

Utrecht, March 5, 2026

The above statement on internal controls should not be construed as a statement in response to the requirements of section 404 of the US Sarbanes-Oxley Act.

Corporate Governance

Rabobank Group Legal Structure

Rabobank Group means (i) Coöperatieve Rabobank U.A., including its local banks in the Netherlands and its foreign branches, representation offices and agencies (“Rabobank”), (ii) its subsidiaries and (iii) other entities in which Rabobank has a controlling interest, both in the Netherlands and worldwide. Based on applicable rules and regulations (for example if a foreign jurisdiction is involved) another definition may apply, depending on the circumstances at hand. Rabobank is a cooperative with excluded liability (“coöperatie U.A.”) and has its head office in Utrecht, the Netherlands. Its statutory seat is in Amsterdam, the Netherlands. Rabobank uses various trade names.

As a cooperative, Rabobank has members and does not have shareholders. Customers of Rabobank in the Netherlands have the opportunity to become a member of Rabobank. Members play an important role in Rabobank’s governance, as described below. At year-end 2025, Rabobank had approximately 2.3 million members. Membership does not entail making any capital contributions to Rabobank and does not entail having any claims on the equity of Rabobank. Any liability of members or former members to contribute to any deficit of Rabobank is excluded.

Rabobank has issued certificates (”Rabobank certificates”). These Rabobank certificates are part of the equity of Rabobank, but holders of the Rabobank certificates do not have any voting rights in Rabobank.

Rabobank has multiple Dutch and foreign subsidiaries with different legal forms. An overview of companies in which Rabobank holds a capital  interest of 20% or more, is published on Rabobank’s website.

Member Influence in the Cooperative Governance of Rabobank

Rabobank is an organization with a decision-making process on both a local and a central level. The local organization preserves a local orientation as a distinguishing feature of Rabobank. The governance reflects the principle of the cooperative and bank being a single unit.

Members in the Netherlands

Members of Rabobank (individuals or legal entities) are grouped into departments (“afdelingen”), based on geographical criteria (local areas or “leefgebieden”). Currently, there are 78 local areas and accordingly, 78 departments. Within each local area there is also a local bank and a local director.

These local directors are mandated by the Managing Board to safeguard the local orientation and firmly anchor the local banks in these local areas. They serve as Rabobank’s representative (‘’boegbeeld’’) in the local area, as the main contact for the Local Members’ Council and Local Supervisory Body and also hold a position in the Dutch retail banking business.

The members belonging to the department are responsible for appointing, suspending and dismissing the members of the local members’ councils.

Local Members’ Councils

Each department has a local Members’ Council which consists of 30-50 members. Local Members’ Councils are the ‘eyes and ears’ and act as sparring partners of the local director on the customer services and the social performance in the local area. Determining the frameworks and conditions for the cooperative dividend is a unique responsibility reserved specifically for the local Members’ Council. Each year, up to EUR 75 million is made available nationwide for local and regional initiatives that contribute to the well-being of the community and to social transitions. It is up to the local Members’ Council to decide how this cooperative dividend will be spent. A local Members’ Council also has a number of formal tasks and responsibilities including the appointment (upon nomination by the local supervisory body), suspension and dismissal of members of the local Supervisory Body, including its representative in the General Members’ Council (“GMC member”).

Local Supervisory Bodies

Each department has a local Supervisory Body consisting of three to five members. The local Supervisory Body exercises cooperative supervision and focuses on both the local bank’s customer services and social performance. In the functional employer role, it shares with the local director's hierarchical manager, the local supervisory body approves the appointment of the local director. The local Supervisory Body aims to strengthen the ties between the bank and the local community.

Districts

The local areas are grouped into 14 districts (“kringen”). There is a cooperative director in each district who is the representative of Rabobank at the district level and plays a connecting role in the various ecosystems. The districts are currently organized in five regions.

Each district convenes at district meetings to discuss societal impact in that district and local areas. There are also combined district meetings within the regions, where Rabobank delegates and GMC members attend. Topics discussed in these meetings are General Members’ Council matters, regional performance, customer services, and social performance.

General Members’ Council

The General Members' Council fulfils the role of steward (“rentmeester”), in the sense that it contributes to passing on Rabobank to future generations and therefore values healthy economic and social returns. Each department is represented by a GMC member in the General Members’ Council. This council is the highest decision-making member body in the Rabobank governance structure. Each GMC member has one vote. Although GMC members are at liberty to exercise their right to vote, they also take local points of view into consideration. The General Members’ Council safeguards the bank’s continuity and acts as the custodian of collective and cooperative values . The General Members’ Council has a focus on the strategic framework, identity, material investments, main points of the budget and financial results of Rabobank. The General Members’ Council has the right to approve, adopt or to be consulted on these matters. This includes, for example, approving Rabobank’s strategic frameworks and major changes in Rabobank’s identity, adopting Rabobank’s annual accounts, and the right to be consulted on a material investment in (or entering into or severing any long-term cooperation with) another company. The members of the Supervisory Board of Rabobank are appointed by the General Members’ Council upon nomination by the Supervisory Board.

The General Members’ Council currently has three permanent committees: the Urgent Affairs Committee, the Coordination Committee, and the Staffing and Remuneration Committee.

Several strategic topics were discussed in 2025, such as sustainability, resilience, IT developments, diversity, equity & inclusion, as well as updates on performance within the Dutch Retail Banking, Wholesale & Rural, and DLL business lines. The General Members' Council also approved the report and recommendations from the governance evaluation. Additionally, important decisions were made to increase Rabobank's global impact, including support for the strategic framework of cooperative initiatives and the increase of the cooperative dividend in the Netherlands. The General Members' Council appointed three new members to the Supervisory Board of Rabobank in 2025.

Supervisory Board

The Supervisory Board is made up of at least seven natural persons. Two thirds of the number of members of the Supervisory Board must be members of Rabobank. The Supervisory Board performs the supervisory role and renders account to the General Members’ Council. In this respect, the Supervisory Board supervises the conduct of affairs by the Managing Board and the general course of business at Rabobank and its affiliated enterprise(s) and monitors compliance with laws and regulations and inter alia the achievement of Rabobank’s’ objectives and strategy. The Supervisory Board has the right to approve material decisions of the Managing Board. The Supervisory Board also has an advisory role in respect to the Managing Board. The Supervisory Board currently has five permanent committees that perform preparatory and advisory work for the Supervisory Board: a Risk Committee, an Audit Committee, a Cooperative & Sustainability Committee, an Appointments Committee and an HR and Remuneration Committee. The Supervisory Board may set up ad hoc committees.

Managing Board

The Managing Board of Rabobank is responsible for the management of Rabobank and, indirectly, Rabobank Group. Business issues, priorities and operational considerations are discussed in this board. The Managing Board members are involved in strategic and operational discussions, choices, and execution and will take decisions based on the specific knowledge and expertise that they each bring to the table. They will cooperate closely from a group-wide and ‘one bank’ perspective.

The Managing Board has the ultimate responsibility for defining and achieving the targets, strategic policy and associated risk profile, financial results and corporate social responsibility. In addition, the Managing Board is in charge of Rabobank Group’s compliance with relevant laws and regulations. Certain Managing Board members participate in material committees, e.g. the Asset Liability Committee Group, Risk Management Committee Group and Central Credit Committee Rabobank Group. The Managing Board renders account to the General Members’ Council. The Managing Board members are appointed by the Supervisory Board.

1. List of trade names
2. List of interests

The Dutch Corporate Governance Code

The Dutch Corporate Governance Code, which was updated in March 2025, applies to listed companies and contains principles and best practice provisions for what is generally regarded as good corporate governance. Because of its cooperative structure, Rabobank is not required to comply with the Dutch Corporate Governance Code. Nevertheless, we have committed to comply with the code as much as possible. We depart from the code on only a few points, partly due to our cooperative structure. Please refer to www.rabobank.com for an overview.

The revision of the Corporate Governance Code in 2025, introduced the ‘Verklaring omtrent risicobeheer’ (VOR). The VOR requires companies to provide a clearly substantiated statement on the effectiveness of their internal risk management and control systems, specifically covering financial reporting risks, sustainability reporting risks, operational risks, and compliance risks. This enhances insight for stakeholders on how these key risk areas are identified, managed, and monitored. The statement is included in our Managing Board Responsibility Statement.

The Dutch Banking Code

The Banking Code aims to ensure stable, service-oriented, and reliable banks for stakeholders by setting out principles of conduct for Dutch banks in terms of corporate governance, risk management, audit, and remuneration. By complying with the Dutch Banking Code, Rabobank demonstrates what it stands for and what Rabobank wants to be held accountable for. A overview of Rabobank’s compliance with the principles of the Dutch Banking Code can be found on www.rabobank.com.

Governance Code for Cooperatives

Rabobank is a member of the Dutch Council for Cooperatives (NCR). As such, Rabobank adheres to the Governance Code for Cooperatives, which aims to contribute to improving the level of cooperative entrepreneurship, member engagement, and the collective ethos and mutuality. Rabobank adheres to virtually all the principles and rules, taking into account the fact that the bank as a financial institution encounters limitations as well as assurances with respect to some principles and rules. Material exceptions are that the NCR Code states that member control is related to the members' use and the extent of reciprocity. Within Rabobank that is not the case.  Moreover, Rabobank is managed to make a profit, which is added to the general reserves of the bank. For an overview of Rabobank’s application of the NCR Code, please refer to www.rabobank.com.

For Rabobank an important part of our people strategy is being a 'Great place to be' and shaping a future-ready organization. This ensures that Rabobank is able to retain, develop, connect, and attract talent in a competitive labor market. We also aim to empower our employees and stimulate diversity and inclusion. Therefore, we offer our employees a fair and competitive total remuneration package (including pensions), an attractive working environment and opportunities for personal growth. Our global performance management system GROW, our worldwide learning and development opportunities and the provision of a personal development budget contribute to our employees’ professional and personal development in line with the bank’s mission of ‘Growing a better world together’.

Our Group Remuneration Policy is aligned with Rabobank's business and people  strategy, our cooperative mission and our position in society.

Stakeholder involvement

As a cooperative it is in our genes to connect with a wide range of stakeholders. We consider society at large as a stakeholder for all aspects of our products, services and operations. This includes external and internal stakeholders such as our members, customers, regulators, investors, different interest groups, employee representative councils and last but not least, employees. Through various formal and informal networks and panels, including the Rabobank Dialogue Expertise Centre, we continuously reach out to these stakeholders to hear their opinions and seek input and feedback.

Our 2.3 million members are a special stakeholder group. These members are organized in Local Members’ Councils and with their diverse backgrounds are a reflection of society at large. The Local Members’ Councils are represented in the General Members’ Council (GMC). The GMC is involved in Board remuneration matters. A committee, consisting of delegates from the GMC, advises the GMC on remuneration for the members of the Supervisory Board and on the Remuneration Policy for the Managing Board. The Works Council is periodically informed about developments on remuneration and (via annual reporting) on pay levels and pay ratios within the Netherlands.

Our employees are another large and prominent stakeholder group with regard to the development of our Remuneration Policy. We engage with our employees through all kinds of channels. Employees in the Netherlands are organized via unions for negotiations on labor conditions and Works Councils represent the Rabobank employees on a broad range of social topics. Via regular conversations and meetings with our Works Council we obtain the views from our employees on our Remuneration Policy and actual practices.

Where relevant and possible, we will always ensure that the input received from our stakeholders is seriously considered in setting our remuneration policies. This can be a challenge when different stakeholders have different and sometimes conflicting interests. Changes in laws and regulations, compliance and risk ensure that we constantly balance between interests and legal frameworks. Therefore, a balanced view, taking into account all interests, is required to design a Remuneration Policy that is optimally aligned with the interests of different stakeholders. The remuneration principles below reflect a number of the key choices Rabobank has made in this respect.

Remuneration Principles

Strong governance and risk management 

Our Group Remuneration Policy applies to all Rabobank Group employees at all levels and entities and is updated annually and adopted by the Managing Board. It adheres to all legal and regulatory requirements, including voluntary application of the Dutch Corporate Governance Code and its principles on remuneration.

Our Group Remuneration Policy:

• is aligned with Rabobank Group's risk appetite;

• supports robust and effective risk management focused on the long-term performance of Rabobank Group, including Environmental, Social and Governance( ESG) risks;

• safeguards the interest of customers, society and investors by a number of specific regulations;

• discourages employees from taking undesirable risks (such as irresponsible sales practices);

• contributes to a strong capital position.

Internal alignment 

The policy promotes fairness and consistency in our approach to remuneration. It promotes equal treatment of all employees and aims to reward equal work equally. This is achieved using the Korn Ferry Hay job evaluation methodology, which analyses and measures jobs, and assigns a job grade for each position. Remuneration levels are linked to the job grade. We closely monitor our internal pay relativities to ensure internal fairness. Our historical pay ratios between average remuneration for Rabobank employees in the Netherlands and our Chair of the Managing Board remain significantly below 20:1, which is considered an important measure by external stakeholders such as trade unions.

External alignment 

We aim to reward at the median of the relevant markets for our broader employee base. This approach enables us to attract and retain the right talent with the right capabilities, at the right time and in the right markets at an appropriate cost. Our salary ranges are benchmarked every year against the general and the financial market in the Netherlands and outside the Netherlands against the relevant local market.

Modest approach with regard to variable remuneration 

Our Managing Board members do not receive variable remuneration as part of their regular remuneration package. Only a limited number of employees in the Netherlands are eligible to receive variable remuneration and only in case there is a compelling business reason for doing so. Variable remuneration is capped at 20% of fixed remuneration and, only in exceptional cases, individual variable remuneration up to 100% of fixed remuneration is awarded. On average, variable remuneration to our employees in the Netherlands does not exceed 20% of the fixed remuneration. For our employees outside the Netherlands, variable remuneration is capped at 100% of fixed remuneration. Rabobank does not apply the Dutch law provision allowing variable remuneration up to 200% of fixed pay for employees outside the EEA.

This approach to variable remuneration reduces adverse incentives for employees. Variable remuneration is never guaranteed, and performance management processes ensure that it does not reward for failure or misconduct. Several risk mitigating measures are in place for all variable payments, such as ex-ante and ex-post testing and the ability to apply malus and claw back. For those employees eligible for variable remuneration, a risk-mitigating target is part of their individual objectives. In exceptional cases, a sign-on or a buyout may be awarded to new hires, to compensate for the loss of (deferred) variable remuneration at their previous employer.

Sustainable performance  

The Group Remuneration Policy is focused on delivering long-term performance. Our cooperative identity and Environmental, Social and Governance (ESG) targets are reflected in our performance management approach. Any variable remuneration awarded is based on a balanced mix of performance objectives, subject to at least 50% non-financial performance objectives.

Total Reward 

In addition to pay, Rabobank offers an attractive total rewards package. Rabobank aims to be a Great place to be for employees where people can realize results for our customers, Rabobank and society. Rabobank offers employees a wide range of opportunities for learning and development, attention for employee well-being, a good pension scheme, workplace flexibility (Rabo@Anywhere) and ample career opportunities.   

Remuneration Practices 2025

Collective Labor Agreement (CLA) NL

At year-end 2025 30,884 employees, including Obvion (2024: 30,715), were employed under the terms of the (Dutch) Rabobank CLA. The remuneration includes fixed remuneration, the Employee Benefit Budget (which provides flexibility and choice of employment terms), a pension scheme, and fringe benefits. For 2025, a collective salary adjustment of 4.25% in April was agreed with the unions. Furthermore, all employees will be entitled to a 10% Employee Benefit Budget (EBB).

Executive positions (non-CLA)

The levels of management below the Managing Board are referred to as “executive positions”. At year-end 2025, globally 208 employees (2024: 208) were in an executive position. The fixed remuneration packages for executives are determined by job grades, based on Hay points. These job grades are linked to five executive salary ranges. The majority of executives receive fixed remuneration only. A small number of the executive positions are eligible for variable pay, dependent on the type of work and on the type of business in which they operate.

Identified Staff

The group of employees with a material impact on Rabobank’s risk profile is designated as Identified Staff. In addition to the specific performance management requirements, specific risk-mitigating measures have been established regarding variable remuneration for Identified Staff. This includes the payment of variable remuneration on a deferred basis which enables adequate consideration of the risks related to the underlying business activities. A deferral policy also applies to non-Identified Staff employees receiving variable remuneration above a certain amount. Generally, the payment of variable remuneration to Identified Staff is spread over a period of four years. For those employees identified as "Senior management", however, the deferral policy stretches to five years. As determined by regulation, variable remuneration is awarded in the form of cash and instruments (each 50%).

In 2025, 12 employees within Rabobank Group (all Identified Staff; 11 Rabobank, incl. MB members, and 1 DLL) (2024: 13; 12 Rabobank and 1 DLL) earned a total remuneration (including pension contributions) of between EUR 1.0 and 1.5 million, and 2 employees (Identified Staff, both Rabobank, incl. MB members) (2024: 2) earned a total remuneration (including pension contributions) of between EUR 1.5 and 2 million.

Variable pay

In 2025, the budgeted variable remuneration for Rabobank Group worldwide was EUR 282.7 (2024: 272.5) million, approximately 7.2% of the total amount reserved for remuneration (2024: 7.3%).

Pay ratio

The average remuneration for Rabobank Group employees at year-end was EUR 130,876 which resulted in a pay ratio of 1:12.1 between the average remuneration and the remuneration of the Chair of the Managing Board. This ratio increased slightly compared with the previous year.

Pay ratio

1. The annual total compensation represents the sum of base salary and pension expense.
2. In line with the Dutch Corporate Governance Code, the average annual total compensation of the employees is determined based on the total wage costs in the financial year and the average number of FTE during the financial year. These figures include both internal and external employees.

Managing Board

The Managing Board is responsible for the management of Rabobank Group. Its mandate centers on delivering customer value, driving a future-proof strategy, maintaining financial resilience, and safeguarding the bank’s cooperative identity across all operations. The Managing Board fosters a culture of active engagement, where each member contributes meaningfully to strategic and operational discussions and participates in collective decision-making. In doing so, the specific expertise of each member is fully leveraged to support the bank’s long-term success.

The remuneration policy of the Managing Board is designed to support the execution of Rabobank’s strategy, promote sustainable growth and reinforce the bank’s cooperative identity. It aims to attract and retain highly qualified executives, while ensuring that remuneration is aligned with Rabobank’s long-term sustainable interests, stakeholder expectations, and risk policy. As a cooperative bank, it is considered essential that cooperative principles are firmly embedded in our remuneration policy, with fair pay, a moderate pay philosophy and social responsibility being key elements reflected throughout. Changes to the Remuneration Policy are presented to the General Members' Council for adoption, following consultation and involvement of the GMC Staffing and Remuneration Committee.

Managing Board members are appointed for a period of four years and their individual remuneration is determined for that specific period. The remuneration and other terms of employment of the individual Managing Board members are set by the Supervisory Board, within the boundaries of the Managing Board remuneration policy and the Group Remuneration Policy. Determination of individual pay levels is guided by the principle of collective responsibility among Managing Board members. This encourages optimal use of the diversity and available competencies and experience, and leads to team members who help and support each other, by using knowledge, and skills where they are needed. Within this team culture, collaboration is strengthened and Managing Board members are encouraged to also move outside their own direct area of primary responsibility if they can provide added value there. Next to the collective responsibility of the Managing Board, the market value of the role and the skills and experience of the individual Managing Board members are taken into account in determining the individual remuneration.

To ensure fair and competitive remuneration, regular benchmarking is conducted against industry standards and market trends. Every two years, Managing Board positions are evaluated against peer groups consisting of a cross-industry group within the Netherlands and a pan-European banking group. These peer groups are selected based on factors such as geography, organizational size, talent market relevance, and the presence of a purpose-driven or cooperative foundation. In addition to an external market comparison, laws and regulations, pay philosophy, board composition, internal pay ratios, stakeholder expectations, internal- and societal developments are relevant in determining the remuneration levels of the Managing Board.

Total remuneration

The total remuneration of the Managing Board consists of both primary and secondary components, and includes the following elements:

• The pay mix of the Managing Board is strictly limited to fixed salary, with no variable remuneration included.

• A pension scheme based on a defined contribution pension plan. The maximum income for pension accrual (regulated by law) was EUR 137,800 as of January 1, 2025.

• In addition, the members of the Managing Board receive an individual pension budget of 24% of their individual fixed annual income above the threshold of the maximum pensionable income.

• A Mobility Policy is in place for all members of the Managing Board for the purpose of commuting and business travel.

Individual remuneration

As of January 2025, a salary increase of 4% was implemented for all Managing Board members. The following overview presents the individual remuneration of all Managing Board members for the year 2025.

Remuneration Managing Board 2025

1. The pension expense includes pension based on maximum pensionable salary cap and compensation for the maximum pensionable salary cap
2. The remuneration of the Managing Board is limited to fixed pay, members are not eligible for variable compensation. Any variable remuneration reported relate to variable pay from a previous non-MB role, a buyout or sign-on. Therefore these variable remuneration amounts are not taken into consideration in the calculation of the fixed portion of the total remuneration.
3. Fringe benefits vary and includes financial advisory services and discount on mortgage interest.
4. As per his appointment in 2023 a buyout has been awarded to compensate for the loss of the deferred variable remuneration at the previous employer. The vested part has been taken into consideration as multi-year variable.
5. The multi-year variable relates to the vested part of a deferred compensation from prior (non-MB) position.
6. As per his appointment in 2023 a buyout has been awarded to compensate for the loss of the deferred variable remuneration at the previous employer. The vested part has been taken into consideration as multi-year variable.
7. The role of Chief Financial Economic Crime Officer requires in-depth, international expertise in the field of financial economic crime, which is valued with an extended salary on base salary. As per his appointment in 2022 a buyout has been awarded to compensate for the loss of the deferred variable remuneration at the previous employer. The vested part has been taken into consideration as multi-year variable.
8. The multi-year variable relates to the vested part of a deferred compensation from prior (non-MB) position.

Remuneration Managing Board 2024

1. The pension expense includes pensions based on maximum pensionable salary cap and compensation for the maximum pensionable salary cap.
2. The remuneration of the Managing Board is limited to fixed pay, members are not eligible for variable compensation. Any variable remuneration reported relates to variable pay from a previous non-MB role, a buyout or sign-on. Therefore these variable remuneration amounts are not taken into consideration in the calculation of the fixed portion of the total remuneration.
3. Fringe benefits vary and include financial advisory services and discount on mortgage interest.
4. As per his appointment in 2023 a buyout has been awarded to compensate for the loss of the deferred variable remuneration at the previous employer. The vested part has been taken into consideration as multi-year variable.
5. The multi-year variable relates to the vested part of a deferred compensation from prior (non-MB) position.
6. Carlo van Kemenade has been appointed as MB member Retail NL as from April 4, 2024.
7. As per his appointment in 2023 a buyout has been awarded to compensate for the loss of the deferred variable remuneration at the previous employer. The vested part has been taken into consideration as multi-year variable.
8. The role of Chief Financial Economic Crime Officer requires in-depth, international expertise in the field of financial economic crime, which is valued with an extended salary on base salary. As per his appointment in 2022 a buyout has been awarded to compensate for the loss of the deferred variable remuneration at the previous employer. The vested part has been taken into consideration as multi-year variable.
9. Lara Yocarini has been appointed as MB member Vendor Finance as from June 5, 2024.
10. Kirsten Konst resigned as Managing Board member per April 4, 2024.  She is entitled to a severance payment as disclosed under 'Extraordinary items’. Until January 1, 2025, she was appointed as Advisor to the Managing Board on sustainability, receiving the same remuneration level. After that, a notice period started in which the employee is entitled to six-months’ salary.
11. Marielle Lichtenberg resigned as Managing Board member per April 4, 2024. She is entitled to a severance payment as disclosed under 'Extraordinary items’. Until June 1, 2024, she performed the transfer of her activities and completed some remaining tasks, receiving the same remuneration level. After that, a six-month notice period started. Her employment ended on December 1, 2024.

Individual Loans

The outstanding loans of the members of the Managing Board in office and the average interest rates on December 31, 2025 were as follows: 

Outstanding Loans Managing Board

Members of the Managing Board not listed in the table have not received any loans, advances or guarantees at year-end 2025.

Supervisory Board

The compensation fee levels for Supervisory Board roles are adopted by the General Members’ Council. These fees are benchmarked every two years against a cross‑industry peer group in the Netherlands and a pan‑European banking peer group. The Supervisory Board may apply annual indexation to the fees. For 2025, the Supervisory Board decided to increase the compensation fees by 4%. The fee structure for 2025 is as follows:

Fee Structure Supervisory Board

1. Temporary committee

Supervisory Board members living abroad receive a compensation for each multi-day official SB meeting they are required to attend physically in the Netherlands. The compensation, as adopted by the General Members’ Council, serves to compensate for additional time commitments as well as travel and accommodation expenses. The amount is determined based on the member’s country of residence. Supervisory Board members residing in the Netherlands are reimbursed according to the standard per-kilometer rate.

Individual remuneration

Remuneration Supervisory Board 2025

1. Fee as a SB member of Rabobank
2. Fee as a chair of a SB committee
3. Attendance fee for SB members living outside the Netherlands
4. SB members are not eligible for variable compensation
5. Driek Desmet has been appointed as SB member as from April 9, 2025
6. Brian Hirman has been appointed as SB member as from September 17, 2025
7. Bart Zegers has been appointed as SB member as from September 17, 2025
8. Petri Hofsté resigned as SB member as from March 3, 2025

Remuneration Supervisory Board 2024

1. Fee as a SB member of Rabobank
2. Fee as a chair of a SB committee
3. Attendance fee for SB members living outside the Netherlands
4. SB members are not eligible for variable compensation
5. Sandra Berendsen has been appointed as SB member as from December 11, 2024
6. Miriam van Dongen has been appointed as SB member as from September 25, 2024
7. Arian Kamp resigned as SB member as from December 11, 2024
8. Pascal Visée resigned as SB member as from December 11, 2024

Individual Loans

The outstanding loans of the members of the Supervisory Board in office on December 31, 2025 and the average interest rates were as follows:

Outstanding Loans Supervisory Board

Members of the Supervisory Board not listed in the table had not received any loans, advances or guarantees at year-end 2025.

As a cooperative bank with the mission “Growing a better world together,” Rabobank’s Supervisory Board remained committed to creating societal impact, advancing sustainability objectives, and ensuring the effective functioning of cooperative governance. In 2025, the Supervisory Board supported the Managing Board in further developing the bank’s medium term plans, with a focus on sustainable growth and cost control. The Supervisory Board also prioritized its supervision on the integration of digital innovation, cybersecurity, and third-party dependency management into the bank’s management agenda.

Rabobank’s Supervisory Board, in alignment with the cooperative bank’s mission of “Growing a better world together,” maintained its dedication to generating societal impact, advancing sustainability objectives, and upholding the principles of effective cooperative governance.

The composition of the Supervisory Board and Managing Board evolved further in 2025. The Supervisory Board welcomed new members Driek Desmet, Brian Hirman, and Bart Zegers. Marjan Trompetter and Johan van Hall were reappointed. The Supervisory Board also reappointed Stefaan Decraene as Chair of the Managing Board and Janine Vos as Chief Human Resources Officer. A key structural development was the establishment of the Chief Operating Officer (COO) role within the Managing Board as of 1 January 2026, reflecting the bank’s ambition to strengthen group-wide operational excellence, data management, and resilience. The Supervisory Board decided to appoint Philippe Vollot as COO, recognizing his proven track record in Financial Economic Crime (FEC), operations, and transformation.

FEC remained a central focus for the Supervisory Board throughout 2025. With the completion of the FEC remediation program, Rabobank transitioned from remediation to a business-as-usual (BaU) approach for FEC. The Supervisory Board conducted a comprehensive review of its own FEC oversight, ensuring that the governance, committee structure, and reporting lines were fit for purpose for the BaU phase, while maintaining heightened attention as long as the DNB instruction remains in place. The Supervisory Board continued to monitor FEC closely, both through dedicated committee work and integration into the broader risk and audit agenda, and remains committed to robust oversight and continuous improvement in this critical area.

Also, the Supervisory Board spent considerable time discussing sustainability goals, regulatory requirements, and technological developments aligning with the bank’s strategy, policies, operations, reporting, risk management, and governance. The Supervisory Board focused on enhancing the bank's core organization, including risk management, technology, digitalization, credit models, data management, and compliance with regulations like the Corporate Sustainability Reporting Directive (CSRD) and the Digital Operational Resilience Act (DORA). The Supervisory Board observed that Rabobank continued to focus on and invest time and effort in these key topics and noted progress.

Key topics for 2025

For 2025, the Supervisory Board identified a number of key topics for their oversight activities. Each quarter, progress on these priorities was evaluated, and adjustments were made, as necessary. This dynamic approach ensured that the Supervisory Board remained responsive to emerging challenges and opportunities. In addition to regular supervisory matters, the Supervisory Review and Evaluation Process (SREP) planning cycle, the Internal Capital and Liquidity Adequacy Assessment Processes (ICAAP/ILAAP), the Integrated Risk Reports, Compliance and Financial Economic Crime (FEC) reporting, interim financial statements, and the annual financial statements and audit outcomes, the following key topics received specific and focused attention from the Supervisory Board.

Continuity in and composition of the Managing Board and Supervisory Board

In 2025, the Supervisory Board was a driving force behind several important changes and reappointments within both the Managing Board and the Supervisory Board itself. As the employer of the Managing Board, the Supervisory Board shaped the changes to the Managing Board in 2025. The Supervisory Board ensured that the composition and leadership of the Managing Board continued to meet the evolving needs of Rabobank. The focus remained on appointing leaders who are result-oriented, client-focused, and cooperative-minded, and who are able to inspire, motivate, and deliver impact. Through careful succession planning and targeted development, the Supervisory Board safeguarded both continuity and renewal within the Managing Board, supporting Rabobank’s long-term ambitions and values.

Within the Managing Board, Janine Vos was reappointed as Chief Human Resources Officer (CHRO) and member of the Managing Board for a new four-year term, effective 1 September 2025.

The Supervisory Board guided the further development of the Chief Operating Officer (COO) role, reflecting Rabobank’s ambition to enhance group-wide operational excellence, data management, and resilience and maintain strong focus on FEC risk management. Following a thorough selection and assessment process, the Supervisory Board resolved to appoint Philippe Vollot as COO, as of January 1, 2026. The Supervisory Board also reappointed Stefaan Decraene as Chair of the Managing Board for a new four-year term, effective 1 January 2026. The Supervisory Board expressed its confidence in Stefaan’s leadership and vision, recognizing his pivotal role in guiding Rabobank through a period of transformation and strategic renewal. His reappointment ensures stability at the top of the organization and provides a strong foundation for the further execution of Rabobank’s strategy in the years ahead.

On April 9, 2025, the Rabobank’s General Members’ Council appointed Driek Desmet as a member of the Supervisory Board, bringing valuable expertise in technology, data, innovation, digitization, and artificial intelligence. On September 17, 2025, the General Members’ Council appointed Brian Hirman and Bart Zegers as new members of the Supervisory Board, further strengthening the board’s diversity and cooperative governance experience. Marjan Trompetter was reappointed for a final term, ensuring continuity and consistent leadership within the Supervisory Board. On December 10, 2025, the General Members’ Council reappointed Johan van Hall for a new four‑year term. Petri Hofsté stepped down from the Supervisory Board on March 3, 2025, with careful attention paid to succession planning.

Throughout the year, the succession plan for both the Managing Board and the Supervisory Board remained a recurring theme, with a strong focus on diversity, continuity, and the alignment of competencies with Rabobank’s strategic ambitions.

As the employer of the Managing Board, the Supervisory Board is responsible for the appointment, evaluation, and ongoing development of its members. To ensure a consistent and structured approach, the Supervisory Board applies the bank‑wide GROW assessment framework to the Managing Board. This includes the annual objective‑setting cycle, two informal mid‑year discussions focused on progress and leadership effectiveness, and a formal end‑of‑year appraisal. The mid‑year conversations, conducted by individual Supervisory Board members, serve primarily to take a qualitative pulse on performance, collaboration, and team dynamics. The formal end‑of‑year appraisal is conducted by the Chair and Vice Chair of the Supervisory Board for the Chair of the Managing Board, and by the Chair of the Supervisory Board and the Chair of the Managing Board for the other Managing Board members. These assessments are informed by results achieved, 180‑degree feedback, leadership behaviors, and the Supervisory Board’s collective judgment. Through this structured and transparent process, the Supervisory Board ensures that the Managing Board operates effectively, upholds Rabobank’s values, and remains equipped to deliver on the bank’s ambitions.

Strategy, governance, and transformation

In 2025, the Supervisory Board contributed to the development and monitoring of Rabobank’s strategy. The Mid Term Plan (MTP) process was strengthened into an integrated planning cycle that links strategic deliberations to business planning and performance steering. The refined MTP framework explicitly integrates financial implications, the Risk Appetite Statement (RAS), sustainability objectives, and strategic workforce planning with emphasis on quantitative and qualitative capabilities needed, ensuring that strategic priorities, resource deployment, organizational capacity, and long‑term impact are aligned.

The Supervisory Board participated in scenario-based discussions, including opportunities for mergers and acquisitions, capital allocation, and the bank’s long-term vision for 2030 and beyond, taking into account geopolitical developments and the need for resilience.

As advisor, the Supervisory Board provided input to the Managing Board on strengthening a business‑driven and client‑focused approach across Wholesale & Rural and Retail NL, with particular emphasis on cost management, operational efficiency, and the integration of innovation and digitalization. This included the continued rollout of W&R Next, the further development of the urban strategy for Retail NL, and cooperative initiatives. For Retail NL, a dedicated growth plan for urban areas was developed, aimed at attracting younger customer segments and enhancing the end‑to‑end customer journey, a topic explored in greater depth during one of the Supervisory Board’s offsite sessions. The Supervisory Board also discussed stakeholder engagement and the role of urban communities in shaping strategic direction, ensuring that client focus remained a guiding principle throughout.

In its supervisory role, the Supervisory Board monitored transformation programs within Wholesale & Rural (W&R) and DLL, focusing on product standardization, team integration, and a unified global operating model. The Supervisory Board reviewed progress on these programs, including growth, cost management, and compliance with regulatory and risk management requirements. For DLL, the Supervisory Board oversaw the development of a 2030 vision, leadership changes, and responses to market conditions in Brazil and the United States, assessing the impact on portfolio, costs, and risk management.

Regarding governance, the Supervisory Board approved the Managing Board’s decision regarding the amendment of the Articles of Association of Coöperatieve Rabobank U.A., the accompanying amendments to the Local Rules, and revisions to the rules of the GMC Urgent Affairs Committee, the GMC Coordination Committee, and the GMC Staffing & Remuneration Committee. These proposals, as prepared by the Managing Board, were endorsed by the Supervisory Board and subsequently adopted by the GMC in June 2025.

The Supervisory Board also reviewed the implementation of new organizational structures and reporting lines, ensuring alignment with the bank’s strategic objectives. Throughout the year, the Supervisory Board evaluated progress on cooperative development, strategic initiatives, transformation, and governance through offsite sessions, benchmarking, and stakeholder meetings, supporting a streamlined, customer-oriented, and future-ready organization with attention to societal impact, sustainability, and cooperative value.

Building organizational resilience and performance

In 2025, the Supervisory Board reinforced its oversight of data management, innovation, and IT to strengthen organizational resilience and performance. Key oversight priorities included the focus on, among others, Identity and Access Management (IAM), cybersecurity, legacy system modernization, business continuity management (BCM), recovery, and the adoption of artificial intelligence (AI).

Organizational resilience was a central theme throughout the year. The Supervisory Board monitored the bank’s preparedness for geopolitical risks, cyber threats, and regulatory developments, including the implementation of the Digital Operational Resilience Act (DORA). Oversight extended to key controls, the control framework, and the transition to a new external auditor. The Supervisory Board also supervised stress testing, recovery planning, and third-party dependency management, challenging the Managing Board to maintain vigilance and embed resilience into the bank’s culture and operations.

In parallel, the Supervisory Board continued to focus on business performance, cost management, and fostering a balanced performance and risk culture. Cost management programs were closely tracked, while leadership development, diversity, and collaboration between business and IT remained high on the agenda. Through these efforts, the Board supported the Managing Board in promoting accountability, innovation, and continuous improvement across the organization.

The Supervisory Board was pleased with the alignment of the risk, performance, sustainability, and HR approach in the Medium Term Plans 2026-2028, further building on the business plans. This integrated approach effectively balances financial projections, risk appetite, sustainability implications, and strategic resource planning.

Sustainability

In 2025, the Supervisory Board embedded sustainability impact, risk, and return in an integrated manner across its oversight activities. Building on the strengthened Mid Term Plan (MTP) process, sustainability was explicitly incorporated into strategic and business planning, including quantified targets on financed emissions, sustainable assets, and sector‑ and region‑specific ambitions. The Supervisory Board monitored progress against these objectives and challenged the Managing Board to maintain a forward‑looking and regulatory‑compliant approach, ensuring that sustainability considerations, financial performance, and risk appetite remained closely aligned.

Governance and strategic developments regarding sustainability remained high priorities for the Supervisory Board and its committees. Sustainability is central to Rabobank’s mission and its role in transitions related to climate, food and agriculture, and financial inclusion. The Supervisory Board addressed sustainability from multiple perspectives, including strategy, business opportunities, portfolio decisions, governance, risk management, compliance, and reporting. The Supervisory Board also monitored the bank’s interactions with external stakeholders.

Throughout the year, the Supervisory Board reviewed updates from the Chief Sustainability Officer and monitored the implementation of the Corporate Sustainability Reporting Directive (CSRD). The Supervisory Board discussed proof points for measuring and steering sustainability, and the reporting approach for 2026. Deep dives were conducted into sustainability themes within Wholesale & Rural, Retail NL, and DLL, as well as global standards on sustainability acceptance and performance.

Knowledge development was actively supported through Permanent Education sessions, which covered climate adaptation, CSRD and ESG reporting, strategic drivers for ESG, and regulatory developments. These sessions enabled the Supervisory Board to maintain up-to-date expertise and oversight of key sustainability topics, regulatory requirements, and emerging trends. Throughout 2025, the Supervisory Board ensured that sustainability remained embedded in Rabobank’s decision-making processes, organizational culture, and long-term strategy.

Cooperative impact

Over recent years, the Supervisory Board has overseen the development and implementation of various initiatives to strengthen Rabobank’s cooperative identity. The Supervisory Board has supported ongoing evaluations of cooperative governance, drawing on feedback from members’ councils, the Supervisory Board, the Managing Board, and broad dialogues across all levels of the organization. These efforts have contributed to meaningful improvements in cooperative governance and cooperative impact at all levels of the bank.

Throughout 2025, the Supervisory Board was closely involved in the further development of the cooperative. The Supervisory Board discussed a wide range of topics, including the Cooperative Initiatives Strategic Framework, execution of the governance evaluation results, updates on cooperative governance and cooperative development, recalibration of membership, the Rabo for Society Hub, and the evaluation and preparation of “Onze Dag.” It also reviewed progress on impact plans and the bank’s cooperative banking activities, ensuring that cooperative principles remained embedded in strategy and decision‑making. In addition, the Supervisory Board monitored the establishment of the Rabo Impact Foundation and discussed related (governance) implications.

Regular engagement with the GMC and its Committees, participation in district meetings, local bank visits, and ongoing dialogues with members and customers enabled the Supervisory Board to remain directly connected to developments within the cooperative domain. These activities supported the continuous evaluation and enhancement of cooperative governance, ensuring that Rabobank’s cooperative identity remains central to its mission and strategy.

Financial Economic Crime: Transition to Business-as-Usual

In recent years, the Managing Board and the Supervisory Board have maintained a focus on Rabobank’s responsibilities in preventing and quickly detecting financial economic crime and ensuring compliance with applicable regulations. Under instruction from the Dutch Central Bank, Rabobank implemented remediation plans to address anti-money laundering and counter-terrorism financing requirements. The Supervisory Board’s temporary Financial Economic Crime Committee monitored progress, supported by reporting from Financial Crime Compliance and Audit Rabobank. FEC topics were regularly discussed at Supervisory Board meetings, overseeing controls, compliance culture, and reporting, supporting Rabobank’s ongoing efforts to meet regulatory obligations in the area of financial economic crime prevention.

In 2025, the remediation program was completed and Rabobank transitioned to a business‑as‑usual state for financial economic crime activities. The Supervisory Board subsequently reviewed its oversight approach, focusing on how FEC topics would be embedded within the regular committee structure and how ongoing regulatory compliance would be monitored. As part of this transition, the Supervisory Board decided to maintain the FEC Committee from 2026 onwards to oversee the validation of the completed remediation program, while integrating all other FEC‑related topics into the agendas of the Audit, Risk, and HR & Remuneration Committees. This ensures that oversight of financial economic crime remains a permanent and well‑embedded element of Rabobank’s governance framework.

The Supervisory Board’s Core Team Regulatory continued to fulfil its role regarding matters related to the criminal investigation by the Dutch Public Prosecutor (DPP), as did the full Supervisory Board. In this context, the Supervisory Board considered scenarios, risks, and strategic implications, and weighed the interests of all stakeholders of the Bank. The Supervisory Board emphasized the importance of following a thorough and well-considered process, especially when engaging with the relevant authorities. The Supervisory Board noted that no agreement was reached in 2025 with the DPP on an amicable end to its investigation, that the case will therefore most likely proceed to court, and monitored that Rabobank continues to cooperate with the authorities in an appropriate manner.

Other topics considered by the Supervisory Board

In addition to regular yearly agenda items and the key topics mentioned above, the Supervisory Board addressed and discussed a wide range of topics in 2025, including:

• Business performance of Retail NL, W&R, and DLL, including growth, client satisfaction, and developments in the Netherlands and internationally, with specific attention to Rabo Investments

• Overall financial performance, capital and liquidity position, interest rate developments, inflation, and cost management

• Risk management and control, credit models, data, and digitalization

• (Inorganic) Growth, capital deployment, and cooperative initiatives

• Progress on IT projects and costs, finance, and risk projects

• Progress on strategic transformations, regulatory and change programs, and the Interest Only Mortgages de-risking strategy

• Progress on AI, specifically integrating AI into business processes, along with the mid-term impact on organizational structures and employees and creating new opportunities

• HR-related issues, including culture initiatives, leadership programs, and strategic resource planning

• Evaluation of the performance of the Managing Board and individual Managing Board members, and follow-up on appraisals

Offsites Supervisory Board and Managing Board

The Supervisory Board organized two offsite meetings to enhance strategic discussions, encourage reflection, and further strengthen collaboration.

The Spring offsite, with the Managing Board, focused on resilience, geopolitical developments, and Rabobank’s strategic positioning in key sectors. The program featured interactive sessions on risk preparedness and long-term resilience, complemented by dialogues with local Management that provided perspectives on business, market trends, and challenges. The Supervisory Board and Managing Board explored scenarios for geopolitical uncertainty, supply chain disruptions, and sustainability imperatives, fostering a shared understanding of strategic priorities. This offsite reinforced the importance of adaptability and cultural alignment in navigating external shocks and maintaining competitive advantage.

The Autumn offsite was dedicated to ‘Banking in the Metropolitan Context’. The Supervisory Board examined Rabobank’s role in urban banking, the energy transition, and Food & Agri, combining client visits, stakeholder dialogues, and thematic sessions to integrate internal and external viewpoints. Discussions centred on Rabobank’s societal role, strategic challenges, and opportunities for impact. Key themes included the need for cultural transformation, multi-year investments, and cooperative identity.

Overview Permanent Education sessions

In 2025, the Supervisory Board continued to invest in its own development and expertise through a comprehensive Permanent Education program. These sessions were designed to keep Supervisory Board members informed on the latest developments in governance, regulation, risk management, and strategic trends relevant to Rabobank and the broader financial sector, while also bringing in external perspectives to enrich discussions.

The program addressed a wide range of topics, including updates on tax developments and legal frameworks impacting the banking sector; insights into climate adaptation, nature-related risks, and Rabobank’s role in supporting environmental transitions; and peer analysis of sustainability reporting, ambition levels, legal disclaimers, and the implementation of the Corporate Sustainability Reporting Directive (CSRD).

Cybersecurity was a key focus, with discussions on emerging trends, real-world ransomware cases in the financial industry, and best practices for defense and resilience. The Supervisory Board explored strategic drivers for the bank, including Environmental, Social, and Governance (ESG) factors, and received updates on the Digital Operational Resilience Act (DORA) and ICT risk management.

Other sessions covered developments in crypto asset regulation and the emergence of central bank digital currencies, compliance, and anti-money laundering measures within the evolving regulatory landscape for financial crime prevention, and trends in financial markets, regulatory priorities, and market surveillance. The program also examined the competitive environment in banking and financial services, assessed geopolitical risks and scenario planning for 2030 and 2035, and provided deep dives into ESG regulations and commitments.

Additional topics included the impact and opportunities of generative artificial intelligence for banking operations and strategy, best practices and regulatory requirements for data protection and data governance, and principles of fair customer treatment, including consumer protection and fraud prevention.

Meetings and attendance

In 2025, the Supervisory Board convened nine times with the Managing Board, as part of the regular meeting schedule. Next to these regular meetings, the Supervisory Board held two off sites, and several dedicated Supervisory Board meetings with a specific topic and / or follow up on actual developments, in attendance of the relevant Managing Board members.

The Supervisory Board also had eleven private sessions (with or without the Chair of the Managing Board). These were mainly to discuss confidential and recruitment or appointment matters. More details on the meetings of the Supervisory Board and its committees are in the table below. For an overview of the composition of the Supervisory Board’s Committees, please refer here.

In addition to the permanent committee meetings, the temporary FEC Committee convened six times. These meetings were attended by Committee members Mark Pensaert and Matthew Elderfield, with Marjan Trompetter and Johan van Hall also participating.

Overview Supervisory Board and Committees in 2025

1. All Supervisory Board members may attend Committee meetings at their discretion.
2. Driek Desmet was appointed as Supervisory Board member during the GMC meeting in April 2025. He simultaneously joined the Risk Committee as of April 9, 2025.
3. Brian Hirman and Bart Zegers were appointed as Supervisory Board members during the GMC meeting in September 2025.
4. Petri Hofsté resigned as member of the Supervisory Board on 3 March 2025.

Contacts with stakeholders

Contacts with GMC and local banks

Members of the Supervisory Board attended the Combined District Assembly Meetings (“gecombineerde kringvergaderingen”) and the meetings of the General Members’ Council (GMC) to prepare for and discuss the topics on the GMC agenda. These included both formal items, such as updates on the bank’s performance, sustainability developments, statutory amendments, remuneration topics, and (re)appointments, and the regular reporting by the Chairs of the Supervisory Board committees on their committees’ activities.

The Chair and Vice‑Chair of the Supervisory Board also participated in meetings of the GMC Staffing & Remuneration Committee and the GMC Coordination Committee. The GMC’s Urgent Affairs Committee convened six times. These meetings, chaired by the Chair of the Supervisory Board, who also serves as Chair of the GMC and the Urgent Affairs Committee, and regularly attended by the Vice‑Chair, addressed confidential matters requiring timely advice or approval on behalf of the GMC. These meetings also provided an opportunity to jointly reflect on and refine the committee’s functioning, resulting in a mutually valued and effective collaboration.

Throughout the year, Supervisory Board members visited local banks to meet with local directors, Local Supervisory Bodies, Local Members’ Councils, and employees to discuss regional developments, the functioning of cooperative governance, and feedback from members and customers. These interactions played an important role in further strengthening the cooperative governance.

A substantial part of the Supervisory Board’s engagement in 2025 related to the follow‑up on the recommendations arising from the governance evaluation. The Supervisory Board valued the exchanges with the GMC and the Evaluation Steering Committee (“begeleidingscommissie”), discussing the findings, implementation priorities, and bank‑wide implications. This joint effort resulted in concrete actions aimed at strengthening communication, onboarding and education, diversity and composition, and the alignment between local and group governance.

The Supervisory Board expressed strong appreciation for the active and constructive stance taken by the GMC throughout this year, particularly the thoughtful challenge and feedback provided.

Contacts with customers

During 2025, each of the Supervisory Board members paid visits to Wholesale and Rural Client Advisory Boards globally and visited Rabobank offices and Wholesale and Rural customers abroad. These visits have provided insights into key strategic issues, opportunities, and the challenges our customers and the bank are facing worldwide. They provided input for the Supervisory Board in challenging and supervising the execution and development of several topics related to Rabobank’s strategy. In addition, the Supervisory Board visited customers in the Netherlands as part of the offsite, as referenced in paragraph 3 (Offsites Supervisory Board and Managing Board).

Contact with external supervisory authorities

Members of the Supervisory Board met regularly with representatives of supervisory authorities, both national and international, through a combination of formal meetings and more informal exchanges. These interactions contributed to a constructive and increasingly collaborative relationship with the supervisory authorities.

In 2025, discussions focused on Rabobank’s strategy and performance, the transition from FEC remediation to business-as-usual, geopolitical developments, climate and sustainability topics, mortgage lending, and board successions. This dialogue helped ensure transparency, early alignment, and mutual understanding of key developments affecting the bank.

Contact with Rabobank’s Works Councils

As a participant in the Three Councils Consultation (‘drieradenoverleg’), the Supervisory Board remains informed about the topics and debates discussed in the Rabobank Works Council. Members of the Works Council attend these meetings alongside members of the Managing Board, the Chief HR Officer, and representatives from the Supervisory Board. In addition, the Chair and Vice‑Chair of the Supervisory Board meet regularly with the Works Council’s Appointment and Dismissal Committee (, where they discuss all relevant matters relating to appointments and reappointments of both the Managing Board and the Supervisory Board. Supervisory Board members are regularly attending meetings of the Rabobank (European) Works Councils. The Supervisory Board values the constructive relationship and the high‑quality dialogue with the members of the Rabobank Works Council and the European Works Council.

Conflict of interest and independence

In 2025 there were no transactions in which there are conflicts of interest involving Supervisory Board members that are of material significance to Rabobank or the Supervisory Board members.

The Supervisory Board, in its current composition, continued to meet best practices provisions 2.1.7 thru 2.1.9 of the Dutch Corporate Governance Code, concerning requirements of independency.

In addition, the Supervisory Board strengthened its overall framework for managing conflicts of interest. This included updating governance documentation, formalizing expectations for Supervisory Board members, and embedding more structured processes to ensure that potential or perceived conflicts are identified and addressed consistently and transparently. These measures also help to mitigate potential risks arising from the revised governance structure relating to DLL.

Self-evaluation of the Supervisory Board

In the final quarter of 2024, the Supervisory Board conducted a self-evaluation, gathering input from both its own members and the Managing Board. The assessment confirmed a constructive culture, with open dialogue and mutual respect. The Supervisory Board was recognized for its effective engagement with key stakeholders and its commitment to maintaining a diverse and skilled composition. Areas identified for further development included strengthening expertise in technology and data, refining strategic focus, and enhancing communication of expectations.

Throughout 2025, the Supervisory Board continued to build on these insights, guided by a dedicated “Way of Working” action plan. This plan emphasized improved team dynamics, ongoing reflection on the Supervisory Board’s level of involvement, and enhanced collaboration with the Managing Board. Key actions included optimizing meeting effectiveness, streamlining document preparation and submission, and integrating external perspectives into strategic discussions. The Supervisory Board also prioritized structured agenda planning and considered how to further strengthen its oversight of IT governance and business performance.

A new self-evaluation was conducted in the last quarter of 2025, again involving both boards. The results reflected a positive baseline in core oversight and governance, with continued progress on previously identified themes. Both boards expressed appreciation for the open and constructive atmosphere, effective collaboration, and the Supervisory Board’s commitment to continuous improvement. New oversight priorities for 2026 were established after the Supervisory Board’s reflection on its role in December 2025.

Quarterly evaluation sessions throughout 2025 supported ongoing reflection and adjustment, helping to maintain high standards of governance and strategic guidance. This iterative approach has reinforced the Supervisory Board’s effectiveness and adaptability, ensuring it remains responsive to the evolving needs of the organization and its stakeholders.

Supervisory Board Committees

The responsibilities and duties of the Supervisory Board and its permanent committees are described in the respective Rules of Procedure as can be found on www.rabobank.com. These Rules were updated and amended in 2025.

Risk Committee

General responsibilities and duties

The Risk Committee prepares the Supervisory Board’s decision-making regarding the supervision of the integrity and quality of the bank’s development and implementation of the risk governance framework, risk control system, and risk appetite. This entails, among others, reviewing and effectively challenging the risk analysis scenarios and promoting risk awareness within a strong risk culture.

Meetings

In 2025, the Risk Committee held nine regular meetings. As in previous years, one of the meetings was a combined meeting of the Risk Committee and the Supervisory Board to discuss the ICAAP/ILAAP stress testing outcome. In addition to the regular Risk Committee meetings, the Risk Committee and Audit Committee convened five times for joint meetings.

Annual recurring topics

The Risk Committee reviewed quarterly Integrated Risk Reports, covering all financial and non-financial risk types. The CRO provided updates on geopolitical and macroeconomic issues via the Risk Dashboard. The agenda featured focused reports on specific non-financial risks such as Operational Risk and Information Security. Regular briefings included Rabobank’s model landscape, SREP, product governance, regulatory requirements (BCBS239 and DORA), IT risk profile, mortgage portfolio, and changes to global policies.

The Chief Information Security Officer gave regular reports, giving the Risk Committee deeper understanding of how information security risks, especially cybersecurity, were being managed. The Risk Committee also guided the Supervisory Board on approving key regulatory topics such as ICAAP/ILAAP, the Group Risk Appetite Statement—which aligned with Rabobank's medium-term plans and budget—the Rabobank Group Recovery Plan, and the Group Remuneration Policy.

To stay current on relations with (home state) supervisors, including findings and investigations, the Risk Committee received ongoing updates from Supervisory Relations. Throughout the year, they discussed in detail the results and follow-up actions from various on-site inspections.

The Compliance reports, State of Privacy reports, and Legal reports were tabled for discussion in the joint meetings of the Risk Committee and Audit Committee.

Year-specific topics and deep dives

In 2025, the Risk Committee had frequent discussion about regulatory and geopolitical developments, such as shifting US policies, trade tariffs, and global tensions, particularly those affecting credit, liquidity, and country risk, remained a consistent point of attention. Beyond these recurring topics, the development of the Rabobank Group Survival Plan was a notable focus. This included refining crisis management protocols, clarifying the formal roles and responsibilities of the Managing Board and Supervisory Board, and strengthening measures for business continuity, data center resilience, and liquidity risk.

The Risk Committee also reviewed and challenged the results of stress test scenarios in light of geopolitical developments, Rabobank’s real estate portfolio, and risk management approach.

Operational risk and control effectiveness received sustained attention in 2025. The Risk Committee monitored progress on remediation plans for IT and cyber risks, including third-party risks, and held deep dives on vulnerability management, ransomware recovery, identity and access management, and was updated regularly about a bank-wide program aimed at strengthening business continuity management.

The discussions also included deep dives of various topics:

• Rabobank’s interest-only mortgage portfolio (de-risking measures, balancing regulatory requirements with client impact and duty of care, communications strategy)

• (Highly) Leveraged Transactions

• Business continuity

• Rabobank’s real estate portfolio and market developments

• Regional developments (Europe, Africa & Asia region)

• Trends in Private Equity and Private Credit markets

• Basel IV implementation

• DLL’s risk profile and interventions to implement structural improvements

• Risk culture

• Information security, including ransomware recovery and vulnerability management

Audit Committee

General Responsibilities and Duties

The Audit Committee prepares the Supervisory Board’s decisions on all matters regarding the integrity and quality of Rabobank group’s financial and sustainability reporting, the effectiveness of Rabobank group’s internal control systems framework, the reporting and functioning of the external auditor, the reporting and functioning of Rabobank Group’s internal audit function and the functioning of the Rabobank group’s compliance and risk function. The Audit Committee submits recommendations to the Supervisory Board on matters referred to in the Rules of Procedure either on request or at its own initiative.

Meetings

In 2025, the Audit Committee convened seven times, held one working session in preparation of the discussion on the 2026 budget, and five combined meetings with the Risk Committee. The internal auditor and external auditor were present at every Audit Committee meeting, and the Chief Compliance Officer was present based on the agenda setting. In addition, the Audit Committee had a private session with each of the internal and external auditors. Ernst & Young will be the new external accountant as of the financial year 2026 and therefore was present from the Audit Committee meeting of December 2025 on, initially as observer.

Annual recurring topics

Every quarter, the Audit Committee discussed the financial performance of Rabobank Group and the sensitivities of the results. In those meetings the Audit Committee challenged, among other things, the development and steering on the performance of the group and the key indicators of the performance to achieve the objectives set for the year. Other topics of discussion and challenges tabled for the Audit Committee were updates on relevant developments in the financial markets, benchmark reporting, global tax developments, quarterly internal audit reports, and quarterly compliance reports. The revision of the Corporate Governance Code in 2025, introduced the ‘Verklaring omtrent risicobeheer’ (VOR). The Supervisory Board supervised the company’s design and operating effectiveness of the internal risk management and control systems, as well as the integrity and quality of financial and sustainability reporting. The Audit Committee prepared the Supervisory Board’s deliberations and decision-making hereon including the way of substantiating the VOR and external auditor follow‑up.

In preparation for the approval by the Supervisory Board of the budget and discussion of the Medium Term Plan, the Audit Committee discussed the financial performance and budgets of the businesses in more detail during a working session with the responsible CFOs of the group functions and business units including the CFO of DLL, and the Chief Sustainability Officer. Thereafter, the Audit Committee reviewed the budget, considering among other things, Rabobank’s ambitions, capacity for growth and risk appetite, sustainability impact goals and financed emissions limits, and other critical assumptions applied. An important topic discussed was the development of the returns on capital within the different business lines. Also, the cost developments were discussed.

The Audit Committee reviewed the Interim Report and the Annual Report including the financial statements, the press release, and the Impact Report. As part of the review of these reports and on the basis of audit reports of the internal and external auditor, the Audit Committee challenged the application of critical accounting policies and reporting topics that require considerable judgment and estimation, including loan impairments and top-level adjustments on model outcomes of impairment allowances, the evaluation of legal claims and provisions, and the development in tax and other positions.  CSRD was reported for the first time and PwC submitted a ‘limited assurance’ on this. The Audit Committee noted that although this is compliant, further maturity of the reporting is needed.

Also, the Audit Committee reviewed the disclosure of non-financial key figures and the integrated reporting approach, including sustainability reporting. The Audit Committee has welcomed the fact that the bank has continued to progress its non-financial and sustainability reporting in the Annual Report and the Impact Report. The Audit Committee considered the management’s report on internal controls on financial reporting and paid specific attention to controls in respect of IT security, access management, loan classification, and loan impairments.

Annually, the Audit Committee discusses and advises the Supervisory Board on approval of the internal auditor’s audit plan and reviews the Internal Audit charter. With the support of the quarterly internal audit reports, the Audit Committee discussed the quality of the control environment of the bank, the progress in addressing audit findings, and the performance of the internal audit function. Based on the positive outcome and a discussion on the findings and actions agreed, the Audit Committee appreciates the performance, the development of the function and audit approach, and focus of the Audit quality and effectiveness of the function.

Furthermore, the Audit Committee reviewed and discussed the funding plan and discussed and advised the Supervisory Board to approve the updated Compliance annual plan.

The Audit Committee has approved the audit plan of the external auditor (PricewaterhouseCoopers Accountants NV (PwC)) and has discussed the audit reports of the external auditor on the half year report, the Annual Report, the COREP and FINREP reporting and the non-financial information. The Audit Committee has monitored the independence of the external auditor. The Committee appreciates the insightful reporting and discussion with the auditors as well as the response to the annual evaluation of the audit team and engagement.

Year-specific topics and deep dives

In 2025, the Audit Committee held several in-depth discussions on specific topics, including an update on the interest policy and the implementation of Basel IV. Deep dives were conducted into the financial and risk performance of group companies DLL and BPD.

Cooperative and Sustainability Committee

General responsibilities and duties

The Cooperative and Sustainability Committee advises the Supervisory Board on all matters regarding the cooperative structure, organization and identity of Rabobank and shall make the preparations for the requisite decisions of the Supervisory Board, consisting of:

1. the assessment of the Managing Board’s reports on the cooperative organization and operations of Rabobank.

2. the submission of advice on cooperative affairs to the Managing Board, either on request or on its initiative.

In addition, the Cooperative and Sustainability Committee advises the Supervisory Board on client-, stakeholder-, market-, or service-related topics (also in relation to the sustainability ambitions, visions, and strategy on the basis of the sustainability targets formulated by the business units), either at the request of the Managing Board or at its own initiative.

The Cooperative and Sustainability Committee assesses and advises the Supervisory Board on how Rabobank’s cooperative identity and sustainability ambitions translate into strategic direction, stakeholder expectations, and market developments. It reviews the Managing Board’s insights into the cooperative organization and activities to create impact and provides targeted guidance to ensure decisions remain aligned with Rabobank’s member‑driven foundation.

For sustainability, the Committee sharpens Board oversight by identifying material themes, elevating the quality of strategic discussions, and monitoring shifts in the bank’s external environment. It supports the Supervisory Board in steering and supervising the sustainability elements of Rabobank’s strategy, helping ensure that ambitions are grounded, measurable, and consistently executed across the organization.

Meetings

In 2025, the Cooperative & Sustainability Committee convened five times.

Year-specific topics and deep dives

Throughout the year, the Supervisory Board's Cooperative and Sustainability Committee focused on strengthening Rabobank’s cooperative foundations: simplifying governance, modernizing member engagement, and reinforcing a coherent national cooperative model.

The bank advanced toward a more structured and forward‑looking cooperative organization, supported by the rollout of impact plans across all regions and the conclusion of the multi‑year Governance Evaluation program, which was approved in the General Members’ Council meeting in April 2025, marking the end of governance evaluation and initiating the implementation thereof.

Rabobank sharpened its intended societal impact by implementing a unified, purpose‑driven framework. With the creation of the Rabobank Impact Foundation - an independent foundation - the cooperative initiatives gained a clearer strategic anchor—focused on measurable impact, strong governance, and long‑term relevance. The overarching direction emphasizes a modern interpretation of what a cooperative bank contributes to society.

Across all business lines, sustainability shifted further into the heart of our daily business.

Retail NL, DLL, and W&R deepened their transition agendas, strengthening client resilience and integrating climate and nature considerations into portfolio steering—even amid shifting international regulation and rising stakeholder expectations.

The Committee’s oversight centered on maintaining credible progress, improving data foundations, and ensuring Rabobank remains a cooperative leader navigating a rapidly evolving sustainability landscape.

Remuneration and HR Committee

General Responsibilities and Duties

The Remuneration & HR Committee (R&HR) prepares the Supervisory Board’s decision making on remuneration and general human resource and organizational issues, such as strategic workforce planning, risk culture, performance management, employee engagement, and other current people issues. In addition, the R&HR Committee considers, whilst assuring compliance with the relevant rules and legislation, the consequences of these topics for our risks and risk management, considering the long-term interests of our stakeholders and acceptance by societal practice, as well as Rabobank’s long-term business, risk appetite, performance, and control environment. The R&HR Committee cooperates with the Risk Committee to evaluate the incentives created by the remuneration system and directly supervises the remuneration of senior management staff who perform control duties.

The R&HR Committee advises the Supervisory Board on decisions related to the Rabobank Group Remuneration Policy and assesses the remuneration practice within Rabobank Group for the highest earning employees based on an annual report, which in addition to the fixed and variable remuneration also contains information about the relevant retention, exit and welcome packages within Rabobank Group. Furthermore, the R&HR Committee prepares a central, independent, internal assessment to review (at least once annually) the general principles governing the remuneration policy and its implementation. Rabobank continues to pursue a prudent, restrained, and sustainable remuneration policy.

Information on remuneration in general and on variable remuneration can be found in the Remuneration section of this Annual Report and in the Pillar 3 report.

Meetings

In 2025, the R&HR Committee convened five times.

Annual recurring topics

As every year, the R&HR Committee addressed the remuneration of individual Managing Board members, (risk) culture and the One Rabobank Culture Plan, the Remuneration Policy for executives, Strategic Workforce Planning, the People Strategy, reports on misconduct, fraud and integrity, and Employee Engagement.

The R&HR Committee prepared the evaluation of the individual members of the Managing Board, in close cooperation with the Chair of the Managing Board and following the yearly GROW-cycle, and made provisions for the proper documentation of the appraisals.

In addition, the R&HR Committee discussed the performance targets for the Managing Board and the group targets for Identified Staff (please see the section on Remuneration [LB2] in this Annual Report for more information). The Committee carried out preparatory work for the Supervisory Board regarding the total spend on variable remuneration with an underlying risk assessment for Rabobank Group, and for the individual variable remuneration of employees classified as Identified Staff.

Also, the R&HR Committee spent considerable time to the policies around Talent Management.

Finally, the R&HR Committee discussed the Remuneration section [LB3] of the annual report before submitting it to the GMC Staffing and Remuneration Committee.

Year-specific topics

During 2025, the R&HR Committee evaluated the remuneration policy for the Managing Board, based on benchmark research, and discussed this subject multiple times with the SB and the GMC Staffing and Remuneration Committee. As a result, an updated remuneration policy was adopted by the GMC in December 2025, which will allow to follow market developments for the coming years. The committee advised about a general indexation with 3,0% of the remuneration of the members of the Managing Board, and about indexation with 3% of the fees of the Supervisory Board, per 1 January 2026.

The committee advised about an updated appointment contract for SB-members, including a non-competition clause, which was signed by all members.

The committee also spent in-depth time on specific HR-related themes, such as the People @ Work Strategy, (Gen)AI and its impact on employees and productivity, new upcoming rules about Equal Pay, geo-political developments in relation to Diversity, Equity and Inclusion (DEI), Talent Management, Leadership, and Strategic Workforce Planning.

Appointments Committee

General Responsibilities and Duties

The Appointments Committee advises the Supervisory Board for its decision-making in relation to the composition of the Supervisory Board, the Managing Board, and higher senior management positions, and the related (re)appointments.

For vacancies in the Supervisory Board or Managing Board, first a job profile is adopted by the Supervisory Board, after advice from the Staffing and Remuneration Committee of the General Members Council. For each vacancy, the Supervisory Board takes the general profile of the Supervisory Board as a starting point. This profile (which was updated in 2025) describes the tasks and responsibilities, composition, competencies, and areas of experience of the Supervisory Board as a whole. The Supervisory Board's multi-year succession plan is based on this profile and is updated at least once a year by the Supervisory Board and discussed with the GMC Staffing and Remuneration Committee.

Following the job profile, a longlist of candidates is drawn up, usually with the support of an executive search agency. In several iterations, the Appointments Committee selects a small number of candidates for a first round of interviews with Supervisory Board members and most times the Chair of the Managing Board and the CHRO. If these interviews result in a mutually positive view, more interviews follow with other members of the Supervisory Board and depending on the position also of the Managing Board. For Managing Board members, external assessments may be part of the procedure. Once a candidate is selected, compliance and integrity checks are organized, and if no objections occur, the Fit and Proper procedure by the external supervisory authorities is initiated, and the Works Council is asked for advice (Managing Board members) or for a declaration of no objection (Supervisory Board members). In the case of a Supervisory Board member, also the GMC Staffing & Remuneration Committee is asked for advice before the candidate is nominated for (re)appointment. Members of the Managing Board are (re)appointed by the Supervisory Board; members of the Supervisory Board are (re)appointed by the General Members Council.

Meetings

In 2025, the Appointments Committee convened six times.

Annual recurring topics

As every year, the Appointments Committee has discussed and adopted an update of the succession plan of the Supervisory Board, after having asked the Staffing and Remuneration Committee of the General Members Council (GMC) for advice. This committee advised the Supervisory Board on all personnel changes in the Supervisory Board and was informed beforehand about changes in the Managing Board, based on the respective boards’ succession plans and profiles.

The Appointments Committee evaluated the ongoing suitability of the members of the Managing Board and the Supervisory Board and reported according to regulations to the Joint Supervisory Team of the ECB and DNB. Also, the Appointments Committee discussed the succession planning of the Managing Board, reviewing the talent pipeline available for immediate succession, as well as the succession in the longer term. Also, meetings were organized with groups of newly appointed top executives and promising talents of the bank.

The Appointments Committee monitored the outside interest positions of the members of the Managing Board and the Supervisory Board, which are registered by Compliance. As part of talent management and in the context of searching and assessing potential candidates for the Supervisory and the Managing Board, the Appointments Committee regularly addressed the subject of (gender) diversity.

Year-specific topics

In 2025, the Appointments Committee discussed the profile for the new position of Chief Operating Officer and prepared the selection of a suitable candidate for this position. After careful considerations and based on interviews and an external assessment, Philippe Vollot was nominated for this position.

The Appointments Committee proposed to reappoint Stefaan Decraene per January 1, 2026, a year before his first term came to an end. With this reappointment clarity was provided about the continuation of the commitment of Stefaan Decraene to Rabobank and the continuity of the current good results, under his leadership. Also, the reappointment of CHRO Janine Vos for her third term was discussed and prepared by the Appointments Committee. The Supervisory Board (re)appointed all of them after the preconditions had been met.

In 2025, the GMC (re)appointed five Supervisory Board Members after careful preparation by the Appointments Committee and nomination of the candidates to the GMC. The Appointments Committee prepared the nomination of SB-member Driek Desmet, who was already selected in 2024, to the GMC in April 2025, bringing an IT/digital/AI/Data profile to the Board. Also, the selection of two other new SB members was prepared. Both Brian Hirman and Bart Zegers were recruited from the internal Rabobank organization (both were SB-members of local banks) for the profile of an experienced Dutch entrepreneur with board experience at a local Rabobank and/or the GMC, and knowledge of and experience with societal transitions and inclusive society. After a careful selection process, they were nominated by the Supervisory Board for appointment by the GMC in September 2025.

The Appointments Committee advised on the reappointments of Marjan Trompetter (Chair of the Supervisory Board) and Johan van Hall (Vice-Chair of the Supervisory Board). For Marjan Trompetter, the reappointment by the GMC in September 2025 is the start of her last term at Rabobank, pursuant the Dutch Corporate Governance Code. Reasons for reappointment are that the composition of the Managing Board and the Supervisory Board has changed significantly in recent years. As a consequence, the level of banking, management, and cooperative experience (especially regarding Rabobank) has decreased. All stakeholders highly value the way Marjan Trompetter fulfils her tasks and duties, and she brings in depth knowledge and experience with Rabobank’s specific cooperative governance, also in her role as Chair of the General Members’ Council.

Johan van Hall was reappointed for a second term by the GMC in December 2025.

Financial Economic Crime Committee

General Responsibilities and Duties

The Supervisory Board's ad hoc Financial Economic Crime (FEC) Committee was established in the last quarter of 2020. The main tasks and responsibilities of the FEC Committee are to monitor and signal important developments with respect to Rabobank FEC compliance with AML/CFT laws and regulations, to advise on, to deepen and to prepare discussions and decision-making within the plenary Supervisory Board and other committees on this critical topic. The FEC Committee reports its findings to the Supervisory Board. The FEC Committee thus supports Rabobank’s full commitment to fulfil its gatekeeper role in society and to comply with the AML/CFT laws and regulations.

From January 1, 2023, the scope of the FEC Committee included the remediation activities of the group leading towards AML/CFT compliance of Rabobank with a focus on the DRB and Wholesale & Rural remediation activities in response to the Instruction from DNB. AML/CFT compliance is furthermore discussed in the Supervisory Board’s (joint Risk and) Audit Committees based on the reports of the compliance function and internal audit function.

The prime role of the FEC Committee is the review, challenge, and monitoring of the progress of the remediation based on a plan that contains an integrated approach for the DRB and Wholesale & Rural remediation activities. The FEC Committee also discusses the findings and opinions of FEC Compliance and internal audit as part of the quarterly progress update.

Meetings

In 2025, 6 meetings, including deep dive sessions, of the FEC Committee were convened. In addition to the CFECO, representatives of internal audit and FEC Compliance are present at all meetings of the committee, together with invited members of the Managing Board and members of the FEC management team.

Annual recurring topics

In the quarterly meetings, the focus is on monitoring and discussing the status and progress made with respect to the remediation, as well as the regular business operations. Topics on the agenda included the quarterly progress reports, reports from FEC compliance, and internal audit as well as business updates on FEC.

Year-specific topics

In 2025, the FEC Committee discussed and noted steady and thorough progress towards the completion of the FEC remediation program focusing on the achievement of milestones in the remediation plan, quality of the work performed, validation by FEC Compliance and internal audit, and the development of adequate management information. Furthermore, the set-up, including robust reporting, of the business as usual was discussed, including the development of the target operating model.

In addition, several deep-dive sessions with Supervisory Board, Managing Board, and subject matter experts were organized to support the FEC Committee’s understanding of dilemmas and issues related to FEC activities in Rabobank’s daily working environment. A deep dive was organized on Low Risk Portfolio, Payment Service Providers, AMLA regulatory developments, and Agentic AI solutions.

In conclusion

Proposal to the GMC and conclusion

In accordance with the relevant provisions of the Articles of Association of Rabobank, the Supervisory Board has reviewed Rabobank’s Annual Report 2025 and annual accounts, as well as other relevant, associated information. The Supervisory Board discussed these documents with the Managing Board, the internal auditor and external auditor (PwC) and took note of the unqualified external auditor’s report that PwC issued on the annual accounts in 2025[SR4] . The Supervisory Board advises the GMC to adopt the 2025 annual accounts.

Words of appreciation

The Supervisory Board extends its great appreciation and respect to the members of the Managing Board and all Rabobank employees for their dedication to Rabobank’s customers and other stakeholders. Notable progress has been made in several key areas, including remediation and regulatory delivery, simplification, a more efficient organizational structures, strengthening the cooperative framework, particularly in the context of the governance evaluation, and ongoing sustainability actions whilst achieving a high financial result.

Furthermore, the Supervisory Board is grateful for the continuous cooperation and support of the members of the bank and its customers. Special gratitude is extended to the members of the GMC for their support, challenge, dialogues, and commitment during the year.

Members of the Managing Board

• Stefaan Decraene, Chair

• Bas Brouwers, Chief Financial Officer (CFO)

• Vincent Maagdenberg, Chief Risk Officer (CRO)

• Els Kamphof, Director Wholesale & Rural

• Carlo van Kemenade, Director Retail NL

• Phillipe Vollot, Chief Operating Officer (COO)

• Janine Vos, Chief Human Resources Officer (CHRO)

• Lara Yocarini, Director Vendor Finance

• Alexander Zwart, Chief Innovation & Technology Officer (CITO)

From left to right:
Alexander Zwart, Lara Yocarini, Bas Brouwers,
Phillipe Vollot, Els Kamphof, Carlo van Kemenade,
Stefaan Decreane, Janine Vos, Vincent Maagdenberg

Stefaan Decraene (S.L.G.)

(Male, 1964, Belgian nationality)

Appointed to the Managing Board with effect from January 1, 2023.
His current appoint term expires on January 1, 2030.
Stefaan Decreane is Chair of the Managing Board and is also responsible for Audit, Legal, Sustainability & Climate, Corporate Strategy Office, Communication & Corporate affairs, and the Corporate Secretary & Cooperative.

Bas Brouwers (B.C.)

(Male, 1972, Dutch nationality)

Appointed to the Managing Board with effect from January 1, 2016.
Bas Brouwers is Chief Financial Officer and responsible for Finance and Control, Treasury, Group Tax, Investor Relations, and Portfolio Management. His current appointment term expires on September 1, 2027.

Carlo van Kemenade (C.G.M.)

(Male, 1964, Dutch nationality)

Appointed to the Managing Board with effect from April 4, 2024.
Carlo van Kemenade is responsible for Retail NL: Housing, Wealth Management, Payments, Digital Customer Processes, Digital Platform, Insurance & Pension, Business Lending, and B2B Services. His current appointment term expires on April 4, 2028.

Vincent Maagdenberg (V.)

(Male, 1976, Dutch nationality)

Appointed to the Managing Board with effect from April 1, 2023.
Vincent Maagdenberg is Chief Risk Officer and responsible for Risk Management and Compliance. His current appointment term expires on April 1, 2027.

Els Kamphof (E.G.)

(Female, 1967, Dutch nationality)

Appointed to the Managing Board with effect from September 1, 2023.
Els Kamphof is Director Wholesale and Rural, and also responsible for Global F&A Knowledge and Rabo Partnerships. She is member of the Board of Directors of Rabobank International Holding B.V., and member of Rabobank North American Board. Her current appointment term expires on September 1, 2027.

Phillipe Vollot (P.G.R.)

(Male, 1967, French Nationality)

Appointed to the Managing Board with effect from October 1, 2022.
Philippe Vollot was during 2025 Chief Financial Economic Crime Officer and responsible for counteracting Financial Economic Crime and money laundering, and compliance to the Wwft. As from January 1, 2026, he is appointed as Chief Operating Officer. That appointment expires on January 1, 2030.

Janine Vos (B.J.)

(Female, 1972, Dutch nationality)

Appointed to the Managing Board with effect from September 1, 2017.
Janine Vos is Chief Human Resource Officer, and responsible for the Human Resource policies and practices. Her current appointment term expires on September 1, 2029.

Lara Yocarini (L.)

(Female, 1980, Dutch nationality)

Appointed to the Managing Board with effect from June 5, 2024.
Lara Yocarini is responsible for Vendor Finance. She is also CEO of De Lage Landen International B.V. Her current appointment term expires on June 5, 2028.

Alexander Zwart (A.G.J.M.)

(Male, 1973, Dutch nationality)

Appointed to the Managing Board with effect from December 1, 2023.
Alexander Zwart is Chief Innovation & Technolgy Officer, responsible for Technology, Innovation, Digital Transformation, and Data & Analytics. His current appointment expires on December 1, 2027.

Relevant additional positions of the Managing Board members (December 31, 2025)

Members of the Supervisory Board¹²

• Marjan Trompetter, Chair

• Johan van Hall, Vice-Chair

• Sandra Berendsen

• Driek Desmet

• Miriam van Dongen

• Matthew Elderfield

• Brian Hirman

• Gail Klintworth

• Mark Pensaert

• Bart Zegers

From left to right
Mark Pensaert, Sandra Berendsen, Johan van Hall,
Driek Desmet, Bart Zegers, Marjan Trompetter,
Matthew Elderfield, Brian Hirman,
Miriam van Dongen, Gail Klintworth.

Marjan Trompetter (M.)

(Female, 1963, Dutch nationality)
Appointed to the Supervisory Board with effect from 2015.
Her current appointment term expires in 2027.

Johan van Hall (J.)

(Male 1960, Dutch nationality)
Appointed to the Supervisory Board with effect from 2021.
His current appointment term expires in 2029.

Sandra Berendsen (J.W.)

(Female, 1973, Dutch nationality)
Appointed to the Supervisory Board with effect from 2024.
Her current appointment term expires in 2028.

Driek Desmet (D.H.B.)

(Male, 1966, Belgian nationality)
Appointed to the Supervisory Board with effect from 2025.
His current appointment term expires in 2029.

Miriam van Dongen (M.R.)

(Female, 1969, Dutch nationality)
Appointed to the Supervisory Board with effect from 2024.
Her current appointment term expires in 2028.

Matthew Elderfield (M.)

(Male, 1966, British nationality)
Appointed to the Supervisory Board with effect from 2023.
His current appointment term expires in 2027.

Brian Hirman (B.P.R.)

(Male, 1969, Dutch nationality)
Appointed to the Supervisory Board with effect from 2025.
His current appointment term expires in 2029.

Gail Klintworth (G.A.)

(Female, 1963, British and South-African nationality)
Appointed to the Supervisory Board with effect from 2023.
Her current appointment term expires in 2027.

Mark Pensaert (M.R.C.)

(Male, 1964, Belgian nationality)
Appointed to the Supervisory Board with effect from 2020.
His current appointment term expires in 2028.

Bart Zegers (B.)

(Male, 1982, Dutch nationality)
Appointed to the Supervisory Board with effect from 2025.
His current appointment term expires in 2029.

Relevant additional positions of the Supervisory Board members (December 31, 2025)

1. The members of the Supervisory Board committees are listed in the Report of the Supervisory Board.
2. Information about the profession, the main position, and the additional positions of Supervisory Board members can be found on https://www.rabobank.com/en/about-rabobank/profile/organisation/board/supervisory-board.html

Appendices

In this appendix the methodology and definitions used in Rabobank's Consolidated Sustainability Statements are disclosed.

Methodology & Definitions related to General Information