a.s.r. wants to have a leading role in the field of sustainable entrepreneurship in the financial sector. a.s.r. aims to positively contribute to making society more sustainable by continuously working to help create solutions that meet the needs of the current generation, without compromising those of future generations. a.s.r. does this through its products and services, but also through its investments. a.s.r. wants to facilitate the transition to an inclusive, sustainable society and limit negative impact as much as possible.

In its daily work, a.s.r. places the customer at the heart of everything. An insurance or banking product is only valuable if it perfectly meets the customer's needs. Therefore, a.s.r. adheres to a number of guidelines:

• a.s.r. offers insurance exclusively through independent advisors.

• a.s.r. uses clear and simple language.

• a.s.r. provides honest information.

• a.s.r. ensures prompt, careful service and good accessibility.

• a.s.r. monitors customer satisfaction.

• a.s.r. always strives for quality.

The following table presents a comprehensive overview of the material impacts, risks and opportunities identified, along with the corresponding policies, actions and targets. The purpose of this table is to highlight the linkages and dependencies among these elements.

6.3.3.1Managing impacts, risks, and opportunities

Interests and views of stakeholders

For a description how the interests, views and rights of a.s.r.’s customers inform the strategy and business model, see section 6.1.4.2.

a.s.r. aims to lead in sustainable entrepreneurship within the financial sector, contributing to a more sustainable society through its products, services, and investments. This includes providing clear and accessible information to help customers make informed decisions, ensuring data security, and promoting health and vitality through initiatives like the a.s.r. Vitality programme. a.s.r. is committed to financial and social inclusivity, making financial products accessible to diverse consumers. This is achieved through rigorous PARP and continuous monitoring of inclusive initiatives. To mitigate risks from irresponsible marketing, a.s.r. implements strict guidelines and training for marketing teams.

As stated in the value chain see section 6.1.4.1, a.s.r. recognises the following consumers and end-users: commercial customers, employees, participants, private customers and relatives.

Engagement with customers and end-users is maintained through various channels, including phone calls, emails, surveys, and social media. Platforms like the Raad van Doen and the Raad van Verzekerden involve customers in enhancing services and policies. Comprehensive processes are in place to address negative impacts, including multiple channels for reporting concerns and an annual complaints report.

a.s.r. has not identified any widespread or systemic negative impacts in the contexts where it sells or provides its products or services. No individual incidents or specific business relationships have been identified that have caused material negative impacts. a.s.r. has several initiatives that have positive impacts on consumers and end-users. For example, the design of products that improve accessibility for people with disabilities and promoting a healthy lifestyle through the a.s.r. Vitality programme. Inadequate data security management can lead to data breaches, which can compromise the confidentiality of customer information and reduce trust in a.s.r. Through initiatives like the a.s.r. Vitality programme, a.s.r. can improve the health and well-being of customers, leading to lower claims and costs, and an improved competitive position.

By implementing these measures, a.s.r. ensures customers have the information needed to make informed decisions, aligning with its strategy to create a positive societal impact and maintain customer trust. a.s.r. also recognises the needs of vulnerable groups and tailor made products to ensure access to essential financial services.

For the material impacts, risks and opportunities, see section 2 Business and strategy.

6.3.3.2Policies and actions

Policies

Access to (quality) information 12.112.212.313.113.214.114.2

a.s.r. has implemented various policies to manage material sustainability matters. The general objectives of these policies are aimed at promoting financial and social inclusivity, ensuring data privacy and security, and improving the health and vitality of employees and customers. a.s.r. recognises the importance of providing clear and accessible information to help customers make informed decisions. Given the complexity of its products and services, it is essential to ensure that customers fully understand the necessary information to avoid uninformed or incorrect decisions. It is essential that the information that a.s.r. provides is not only complete and accurate but also understandable for our customers. The financial literacy of our customers varies, and a.s.r. must ensure that everyone, regardless of their knowledge level, can understand the information needed to make informed decisions. This commitment is driven by a.s.r.’s dedication to consumer awareness and decision-making, ultimately leading to a positive societal impact.

To address the challenges posed by the complex nature of a.s.r.’s offerings, a.s.r. has implemented or will implement several measures:

• User-friendly online portals: a.s.r. has developed intuitive and accessible, conform the Web Content Accessibility Guidelines (WCAG) online portals that provide comprehensive information about its products and services. These portals are designed to be user-friendly, ensuring that customers can easily navigate and find the information they need. The WCAG standards ensure that all users, including those with disabilities, can access and understand online information. a.s.r. aims to achieve full compliance with Web Content Accessibility Guidelines 2.1 AA standards by mid-2025.

• Clear communication: a.s.r. prioritises clear and straightforward communication in all its customer interactions. This includes simplifying complex terms and conditions, providing detailed FAQs and offering step-by-step guides to help customers understand its offerings better.

• Customers can trust that the products offered to them are demonstrably the result of product development processes (PARP) that have carefully balanced the interests of the customer. Only products that are in the customer's best interest should be developed, offered to a defined group of customers for whom the product is suitable, and whose information and distribution are tailored to the target audience.

• Educational resources: a.s.r. offers a range of educational resources, including webinars, tutorials and informational articles, to enhance consumer understanding of its products and services. These resources are tailored to address common questions and concerns, making it easier for customers to make informed decisions.

• Customer support: a.s.r.’s dedicated customer support team is available to assist customers with any queries they may have. This team is trained to provide clear and concise explanations, ensuring that customers receive the support they need to understand a.s.r.’s products and services fully.

• Feedback mechanisms: a.s.r. actively seeks feedback from customers to continuously improve the clarity and accessibility of its information. This feedback is used to refine its communication strategies and enhance the user experience on the a.s.r. online portals. The net promoter score (NPS) also provides insight into how customers experience a.s.r. See section 2.4.2.

By implementing these measures, a.s.r. aims to mitigate the risks associated with the potential complexities of its products and services. a.s.r. is committed to ensuring that all customers have the information they need to make informed decisions, thereby promoting financial and social inclusivity. Looking ahead, a.s.r. will continue to explore innovative ways to enhance the accessibility and clarity of its information. Future initiatives may include the development of more interactive and personalised online tools, as well as ongoing collaboration with stakeholders to ensure that its communication strategies meet the evolving needs of its customers. a.s.r. makes its policies available to potentially affected stakeholders and those who need to help implement them. This is done through various channels, including the company website, customer portals, and direct communication with stakeholders.

Privacy 12.112.212.3

a.s.r. is responsible for processing personal data for various entities and brands under its umbrella. The Privacy Statement and the privacy policy outlines how a.s.r. handles personal data, ensuring compliance with applicable privacy laws and industry codes of conduct.

a.s.r. places great importance on the security of personal data. To ensure an appropriate level of protection against data breaches and unauthorised processing, a.s.r. has implemented various technical and organisational measures. These measures include securing IT systems, using encryption, and continuously monitoring data traffic to prevent unauthorised access. For example, employees are trained in data protection, and only authorised personnel have access to personal data. For access to sensitive data employees must sign additional confidentiality agreements.

Despite these measures, inadequate data security management can lead to significant negative impacts. One of the biggest risks is a data breach, where sensitive customer information such as financial details, health records and personal identifiers can be exposed. This can severely damage customer trust and a.s.r.’s reputation. Customers expect their personal data to be handled with the utmost care, and any breach can lead to a loss of confidence in a.s.r.’s ability to protect their information. Moreover, data breaches can result in legal and financial consequences. Regulatory bodies may impose penalties for non-compliance with data protection laws, and a.s.r. may face lawsuits from affected individuals.

To mitigate these risks, a.s.r. conducts regular audits and risk assessments to identify and address potential vulnerabilities in data security. a.s.r. also has a robust incident response plan to quickly address and mitigate the effects of any data breaches. Additionally, security measures and protocols are continuously updated to keep up with evolving threats and technological advancements.

a.s.r. is committed to protecting personal data and minimising the risk of data breaches through comprehensive data security management. By implementing stringent security measures and continuously improving its practices, a.s.r. aims to safeguard customer information and maintain trust.

a.s.r. follows a structured Data Protection Impact Assessment (DPIA) process to identify and mitigate privacy risks associated with the processing of personal data. This process includes:

1. Initiation and coordination: The DPIA process is coordinated by a privacy expert who ensures that all necessary stakeholders are involved. This includes representatives from the Legal, Compliance and Business Risk Management teams.

2. Risk assessment: The DPIA involves a detailed risk assessment using a predefined checklist to identify potential privacy risks. This assessment is based on the data collected through the Privacy by Design/Default process.

3. Mitigation measures: Based on the risk assessment, appropriate mitigation measures are identified and implemented. These measures are documented in the DPIA report, which includes a detailed analysis of the risks and the steps taken to address them.

4. Review and approval: The DPIA report is reviewed by relevant stakeholders and approved by the process owner. This ensures that all identified risks are adequately addressed before the processing activity begins.

5. Documentation and monitoring: All DPIA-related documentation is archived, and the implementation of mitigation measures is monitored to ensure ongoing compliance with privacy requirements.

By adhering to this comprehensive DPIA process, a.s.r. ensures that privacy risks are proactively managed, and personal data is protected in accordance with regulatory requirements and best practices.

a.s.r. has established a comprehensive Data Retention Policy to manage the lifecycle of data, ensuring that data is retained only as long as necessary for legal, regulatory and business purposes. This policy includes:

1. Scope and objectives: The policy applies to all data processed by a.s.r., including customer data, employee data and financial data. The objective is to ensure data integrity, availability and confidentiality throughout its lifecycle.

2. Governance and responsibilities: The policy outlines the roles and responsibilities of various stakeholders, including the Board of Directors, Compliance, Enterprise Risk Management (ERM) and data owners. Each stakeholder is responsible for ensuring compliance with the data retention requirements.

3. Data lifecycle management: The policy details the processes for data generation, processing, storage, archiving and deletion. It includes specific retention periods for different types of data, as outlined in the retention schedule.

4. Monitoring and compliance: Regular audits and reviews are conducted to ensure adherence to the data retention policy. Compliance with the policy is monitored by the Compliance and ERM teams, and any deviations are addressed promptly.

5. Legal and regulatory requirements: The policy ensures compliance with relevant legal and regulatory requirements, including the General Data Protection Regulation (GDPR) and other applicable laws. It specifies the retention periods for various types of data based on legal requirements and business needs.

By implementing this Data Retention Policy, a.s.r. ensures that data is managed effectively throughout its lifecycle, reducing the risk of data breaches and ensuring compliance with legal and regulatory requirements.

See section 5.5.2 for more detailed information about privacy.

Health and safety 13.113.214.114.2

Health and vitality are increasingly important topics in society, partly due to developments such as rising healthcare costs and an increase in pension age. This is the reason why a.s.r. encourages sustainable employability and focus on preventing work absence due to illness or disability, such as with the exercise reward programme a.s.r. Vitality.

Financial resilience and inclusion
a.s.r. believes it is crucial for individuals to be able to take responsible risks and make informed financial decisions. a.s.r. assists people in making conscious financial choices to prevent them from falling into debt or to help them recover from it. As an insurer for all residents and workers in the Netherlands, a.s.r. is attentive to the interests of vulnerable groups. Within the organisation, a.s.r. also strives for an inclusive culture where differences are recognised, valued and utilised.

Vitality and sustainable employability
Also at a.s.r. there is an increasing attention to health and vitality, driven by societal developments. As people live longer, healthcare costs rise, and the labour market changes rapidly, leading to challenges in work, well-being and health. a.s.r. focuses on preventing work absence due to illness or disability, aiming to help people work longer and healthier, thereby continuing to contribute to society. A large network of specialist intermediaries, occupational health service providers and in-house service teams with extensive knowledge of the disability insurance markets helps clients to meet their specific needs. Prevention, treatment and reintegration services assist employees and self-employed individuals with sustainable employability. a.s.r.’s science-based behaviour change programme (a.s.r. Vitality) helps to improve customers’ health and well-being. By shifting the focus from reactive to preventive service provision, a.s.r. supports customers in managing their physical and mental health more effectively.

Disability and P&C acknowledge the complex challenges associated with maintaining social inclusiveness, particularly when certain consumers face exclusion, coverage or higher premiums due to high-risk classification. The high risk identification is not based on profiling, but on risk-based (technical) motivation. This classification arises from internal acceptance policies that may restrict access to essential insurance products for high-risk individuals while always taking the human dimension into account. This practice, the classification of the risks, may contribute to social inequality and could limit the financial protection available to vulnerable groups. To manage the risk profile, a.s.r. has implemented a comprehensive risk management framework that includes a thorough screening process for new customers. This process ensures fair and consistent evaluation of all potential customers, although it may still result into a classification of the terms of acceptance of the high-risk individuals. a.s.r. continuously monitors the effectiveness of its acceptance policies and risk management practices. Regular evaluations are conducted to assess the impact of these policies on social inclusiveness and to identify areas for improvement. Looking ahead, a.s.r. is committed to exploring and implementing more inclusive acceptance policies that balance risk management with social responsibility. Future initiatives may include the development of tailored insurance products that cater to high-risk individuals without compromising a.s.r.’s financial stability.

a.s.r. sees an opportunity to promote financial and social inclusivity through its mortgage offerings, insurance products and investment strategies. These initiatives aim to contribute to accessibility and affordability, aiming to provide broader access to essential financial services. Inclusive initiatives at a.s.r. are designed to enhance social inclusiveness by making financial products more accessible to a diverse range of consumers. This approach helps ensure that more individuals can benefit from financial protection and investment opportunities, contributing to overall societal well-being.

As part of the product approval and review process, inclusivity is addressed by having a well-defined group of customers for whom the products and services of a.s.r. are suitable for. This process involves rigorous review, testing and evaluation to confirm that products are both fraud-resistant and in the interest of the defined group of customers. The effectiveness of the product approval and review process is regularly monitored through customer feedback, market analysis and internal audits. a.s.r. uses these insights to refine its products and strategies, ensuring they continue to meet the needs of all consumers. a.s.r. is dedicated to keep developing new products and services that address the evolving needs of society. Future plans include ongoing research and collaboration with stakeholders to enhance financial inclusivity and support positive societal impact.

a.s.r. aims that its services to customers do not discriminate based on factors including gender, age, religion, background or sexual orientation. By applying the Dutch Association of Insurers’ Ethical Framework for Data Applications and Data-Driven Decision Making by Insurers, a.s.r. reduces the risk of unjustified bias, exclusion and discrimination in core processes such as acceptance policies, premium determination, fraud policies, and claims or damage handling. When choosing to use data-driven systems, a.s.r. considers diversity and inclusion, particularly for vulnerable groups, such as those at risk of exclusion or disadvantage due to specific needs and/or disabilities. Preventing exclusion and discrimination is also the principle in a.s.r.’s non-data-driven decision-making processes and in a.s.r.’s communication with (potential) customers. a.s.r. continuously evaluates its services and communication, striving for maximum accessibility for target groups, including vulnerable groups such as people with low literacy or visual impairments.

When developing products and services, a.s.r. considers human rights. a.s.r.’s ambition is to develop products and services that contribute to solving societal issues. Therefore, a.s.r. also develops products and services for vulnerable groups to improve their financial resilience. Additionally, a.s.r. aims to prevent or mitigate any negative impact of its products and services as much as possible. The PARP is an internal process for assessing the quality of products and services and their relevance to the intended market. Part of the PARP includes considering (potential) risks related to human rights violations. The PARP development process encourages improvement based on feedback and expectations and needs of stakeholders, societal developments, current circumstances, and changes in laws and regulations. The PARP applies to both products and services a.s.r. actively offers, as well as existing (including non-selling) products and services that are regularly reviewed.

In the acceptance process for new business customers, a.s.r. also assesses signals of human rights violations. In the Customer Due Diligence policy, signals of human rights violations are a potential exclusion criterion. Additionally, an ESG risk assessment is conducted if necessary, as per the Policy on Sustainable Insurance.

Responsible marketing practices 14.3

a.s.r. acknowledges the significant risk posed by irresponsible marketing practices, which can harm a.s.r.’s brand and reputation. This risk is driven by potential ethical issues in marketing, such as misleading advertisements or lack of transparency, leading to financial repercussions and reduced revenue. Ethical issues in marketing, such as false claims or deceptive promotions, can erode trust among consumers and stakeholders. This loss of trust can result in a decline in customer loyalty and a negative public perception, ultimately impacting a.s.r.’s financial performance. When marketing practices are not aligned with ethical standards, it can lead to the exclusion of certain consumer groups and may potentially lead to fines and legal claims. Misleading information or lack of clarity in marketing materials can have an effect on a.s.r.'s stakeholders reducing their access to essential financial products and services. This exclusion contributes to social inequality and undermines the principles of social inclusiveness that a.s.r. strives to uphold. To mitigate this risk, a.s.r. has implemented guidelines. The guidelines include strict guidelines and training for marketing teams to ensure all promotional activities adhere to ethical standards. Additionally, a.s.r. conducts thorough reviews of marketing materials to ensure accuracy and transparency, thereby protecting consumers from misleading information.

a.s.r.’s communication policy plays a crucial role in supporting these efforts. The communication policy emphasises the importance of clear, transparent and ethical communication, both internally and externally. It aligns with a.s.r.'s mission to be a trustworthy insurer, a financially stable institution, a people-oriented employer and a valuable societal participant.

Corporate Communication at a.s.r. is tasked with enhancing a.s.r.’s reputation as a socially responsible insurer. This involves ensuring that all communication, including marketing, aligns with the a.s.r.’s core values: being helpful, forward-thinking and decisive. The communication policy also highlights the need for transparency and interaction, fostering a dialogue with stakeholders to build trust and credibility. By adhering to these communication principles, a.s.r. ensures that its marketing practices are not only effective but also ethical and inclusive. This approach helps mitigate the risks associated with irresponsible marketing and supports a.s.r.’s commitment to social responsibility and financial stability.

Access to products and services 12.112.2

At a.s.r., the commitment is to provide customers with insurance products that meet their specific needs and expectations. Determining the target audience for insurance products is essential to ensure that these products align with the needs, characteristics, and objectives of the customers and end-users. This process stems from the Insurance Distribution Directive (Richtlijn Verzekeringsdistributie), which mandates detailed target audience definitions for insurance products. By accurately defining the target audience, a.s.r. can develop insurance products that are suitable for specific customer groups, thereby reducing the likelihood of misunderstandings and incorrect decisions. This not only helps to improve customer satisfaction but also ensures compliance with legal requirements and minimises risks.

For its Health activities, a.s.r. has additional policies related to consumers and end-users:

• Duty of care policy (Zorgplichtbeleid); Health insurers have the obligation to make care available to insured persons within a reasonable time and distance when/for as long as they need care

• Healthcare procurement policy outlines the procedures for acquiring medical supplies, equipment, and services, ensuring efficiency, cost-effectiveness, and regulatory compliance. It includes supplier selection, contract management, risk mitigation, and sustainability practices to support high-quality healthcare delivery.

• Policy for involving and informing clients outlines the strategies and procedures to actively engage clients in decision-making processes and keep them informed about relevant developments. This policy promotes transparency, trust, and client satisfaction.

In addition to the laws and regulations, covenants and programs are also periodically concluded between the government, health insurers and other parties involved. These agreements (IZA and GALA and WOZO) and programs (TAZ) include additional agreements on quality, affordability and accessibility of care. The elaboration of the national policy and the agreements in laws and regulations, covenants and programs are included in the individual policies of a.s.r. Health and other health insurers.

Social inclusion of consumers and end-users 14.114.2

a.s.r. respects and endorses fundamental human rights as outlined in the Universal Declaration of Human Rights. a.s.r. also support the UN Global Compact, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises, both in letter and spirit. These principles are implemented in several policies (Human Rights policy, Policy on Sustainable Insurance, Privacy policy and PARP).

a.s.r. has defined vulnerable groups that include young people, high-risk individuals, and those with low literacy. a.s.r. offers certain products to improve financial and social inclusivity. These initiatives are driven by a commitment to accessibility and affordability, leading to broader access to essential services and a positive societal impact. a.s.r. will further develop the definition of vulnerable groups and integrates it into the material business lines.

Mortgage Offerings

In the responsible mortgage lending management policy (Verantwoord Hypotheek Verstrekken beheersbeleid, VHV) there are high-risk groups identified, with active measures in place to address their needs. These groups include customers who:

• have recently experienced payment arrears;

• are identified through early warning signals;

• hold an interest-only mortgage that have been classified as high-risk;

• are identified as high-risk based on analyses (manual and automated).

This approach ensures that high-risk groups are recognised and supported proactively, aligning with that the principles of social inclusion by offering tailored interventions and preventing further financial strain.

Mortgages also offers products specifically for certain groups. An example of an inclusive mortgage offering is the first-time buyer mortgage. This product is designed to support first-time homebuyers by providing access to affordable mortgages, even if they have limited financial resources. This promotes financial inclusivity by enabling more people to purchase their own homes.

Insurance Products

• Disability Insurance (AOV) for Entrepreneurs: If an entrepreneur is denied AOV and has started their business within a certain period, there is an agreement within the Dutch Association of Insurers that the first insurer to reject the application is obliged to offer a Safety Net Insurance. This is a disability insurance specifically for hard-to-insure self-employed individuals.

Langer mee AOV: For people in physically demanding professions who cannot always insure themselves until the state pension age, the Langer mee AOV was developed. This product allows them to insure themselves until the state pension age, provided they pass the medical assessment at the start of the insurance.

Individual life and Funeral 12.112.2

The acceptance policy of product line Individual life and Funeral includes several inclusive measures. In alignment with the guidelines set forth by the Verbond van Verzekeraars, the acceptance policy of a.s.r. for Individual life and Funeral includes providing support to individuals who have battled cancer. a.s.r. Life's Clean Slate Policy offers a favourable acceptance policy, helping them regain access to insurance. Furthermore, clients from vulnerable groups, such as clients under guardianship or people in small-scale living arrangements, can insure themselves without answering health questions. This ensures that even people from vulnerable groups have access to funeral insurance.

These initiatives demonstrate how financial institutions like a.s.r. are committed to inclusivity and accessibility, leading to broader access to essential financial services and a positive impact on society.

Distribution and other services

Robidus, Corins, and D&S Holding largely follow the same policies as a.s.r. They acknowledge the importance of clear and accessible information, the positive impact on physical and mental health, and the challenges that complexity can pose for customers in making certain decisions. Various policies have been developed to mitigate risks or enhance positive impacts.

Accountable

All policies are formulated at a.s.r. group level, while the product lines are responsible for their implementation and operation.

Engaging with consumers and end-users 12.112.2

Strategic, constructive and proactive consultation with consumers and end-users is very important to a.s.r. to properly align strategy, policy and activities with the expectations and interests of its stakeholders. The way a.s.r. communicates depends on the type of stakeholder, the topic and the purpose of the communication. a.s.r.’s means of communication range from personal contact to organising roadshows, customer and employee surveys, and roundtable and dialogue sessions. See the Stakeholder policy and section 8.5.

The following basic principles are used by a.s.r. to create and build engagement with stakeholders:

• Inclusion – enabling people to express their interests and expectations on issues and decision-making that affect them.

• Materiality – decision-makers should identify the impacts and issues that matter and factor these into their decision-making.

• Responsiveness – a.s.r. is transparent about material impacts and issues and how it deals with them.

a.s.r. applies the following principles when organising stakeholder engagement and stakeholder consultation:

• Stakeholder engagement aims to strengthen a.s.r.’s relationship with key stakeholders to create mutual insight and understanding, and opportunities for collaboration;

• Stakeholder consultation contributes to sustainable development and aims to create sustainable long-term value for a.s.r.’s stakeholders by giving them the opportunity to be involved in tightening a.s.r.’s policy, strategy and activities. Through dialogue, a.s.r. continuously reviews whether, in the opinion of its stakeholders, the organisation is still focusing sufficiently on the right policies;

• Stakeholders are asked to provide input and help with:

  • Defining, reviewing and prioritising material issues for sustainability strategy, policy and reporting;

  • Providing insight into the (negative and positive) impact a.s.r. has on its stakeholders;

  • Identifying sustainability risks and how to mitigate these;

  • Answering the question of how a.s.r. can further increase its social added value and positive impact in the short and longer term;

  • Expanding and improving its understanding of current and future themes and trends.

• a.s.r. believes in the power of collaboration and can explore social themes and issues with stakeholders and jointly tackle activities aimed at improvement.

a.s.r. engages with customers daily using various methods, including phone calls, emails, surveys, webinars and social media. This multi-channel approach ensures effective communication and feedback, allowing a.s.r. to continuously improve its services and address customer needs comprehensively.

To improve overall services and customer engagement, the Raad van Doen has been established. The Raad van Doen is the online customer and advisor panel for all a.s.r. brands. Through this panel, customers and advisors are involved in enhancing a.s.r.'s services. The panel functions as a sounding board for a.s.r.'s direction, as a forum for co-creation and product development, to advocate for customer interests and as a sparring partner. Product lines also use members of the Raad van Doen to conduct customer research on expectations regarding sustainability aspects for specific insurance products and services. This can be done through surveys or by organising dialogue sessions with panel members and this engagement is ongoing. The Raad van Doen can be used whenever there is a need.

In addition, Health has a system called the Raad van Verzekerden, which enables policyholders to actively engage in discussions about a.s.r.’s healthcare policies and products. Comprising up to 15 diverse members, the Council meets with the Health Board in Utrecht at least twice a year. Key topics like healthcare procurement and communication are discussed. The Council can provide both solicited and unsolicited advice and works in focus groups for in-depth analysis. This ensures that policyholders have a voice in a.s.r.'s policy decisions.

a.s.r.'s reputation for sustainability is measured weekly. Continuous net promoter score (NPS) measurements are conducted among customers regarding the overall relationship (NPS-r), at the process level (NPS-p) and at contact moments (NPS-c) to measure and improve customer satisfaction.

Raising concerns 12.112.213.1

a.s.r. has established comprehensive processes to address negative impacts on consumers and end-users, offering multiple channels for reporting concerns. Respecting and protecting human rights is a central principle of a.s.r.'s sustainability ambitions, and specific mechanisms are in place for consumers to report potential negative effects.

For complaints, a.s.r. offers a user-friendly online complaint form, directing complaints straight to a complaint handler. Consumers can also contact customer service, clearly indicating they are making a complaint. Alternatively, complaints can be mailed to the a.s.r. Complaints Service. A complaint handler will contact the consumer within three working days, and a substantive response will follow within ten working days. See section 3.1.3.1. for more information about the customer focus.

An essential part of this approach is the whistleblower policy, which allows consumers to confidentially report suspected misconduct or irregularities. Reports can be submitted in writing, verbally or anonymously, and a.s.r. provides protection against retaliation, ensuring consumers can safely express their concerns. The Compliance department handles all complaints, ensuring appropriate follow-up while safeguarding the confidentiality and protection of the reporter (Wet bescherming klokkenluiders). Protection also applies to the person who assists a Person Reporting (e.g. the confidential advisor of a.s.r.), a third party involved, the person to whom a report is made or who properly follows up on the report. Employees who, in good faith, report a violation are protected against retaliation in accordance with the whistleblower scheme.

a.s.r. has also set up a dedicated Human Rights Reporting Point. This channel is specifically designed for consumers who have concerns about potential negative impacts on human rights caused by the activities of a.s.r. or its business partners. Consumers can submit reports via the Human Rights Reporting Point, clearly stating the nature of the concern, such as equal treatment or the right to a safe working environment. An acknowledgement of receipt is sent within seven days, and if necessary, the report is forwarded to the appropriate channel, with notice to the reporter. To date, no complaints have been received at the Human Rights Reporting Point, and no serious human rights issues or incidents have occurred.

a.s.r. maintains an annual complaints report, detailing both received and resolved complaints, categorised by type. If consumers disagree with the outcome of a complaint, it can be referred to an independent party. a.s.r. fully cooperates in this process to ensure the effectiveness and integrity of the complaint resolution mechanism. Additionally, once a complaint is closed, a.s.r. invites consumers to participate in a satisfaction survey. a.s.r. seeks feedback on the complaint handling process and focus on identifying the root causes of complaints. This helps a.s.r. to monitor and improve the effectiveness of its channels, reflecting on its commitment to transparency and continuous enhancement in addressing consumer concerns.

If a consumer experiences an incident with an a.s.r. business partner, such as an intermediary, they are encouraged to report it to the Competence Center Intermediary (CC IM). The CC IM is a multidisciplinary team that addresses fraudulent or other undesirable behaviour by intermediaries. Intermediaries in this context include brokers, advisors, sub-brokers, and mandated brokers. While a.s.r. does not require the business partner to establish such a channel, a.s.r. provides consumers with a means to report concerns about the business partner.

If a customer disagrees with the handling of their complaint, they have three options:

1. Submit the complaint to Financial Services Complaints Institute (Klachteninstituut Financiële Dienstverlening - Kifid). Within three months the customer can submit their complaint to Kifid;

2. If a customer disagrees with the decision they can go to court. The customer needs to contact Kifid first. Kifid cannot handle complaints that have already been addressed by the court;

Customers can file their complaint at the Disciplinary Board for Insurers. Disciplinary law aims to ensure a proper level of professional practice, while Kifid focuses on dispute resolution (complaint law). The disciplinary board supervises the behaviour of insurers.

Actions

For material IRO's with no actions set for reporting year 2024, these will be addressed and prioritised in the coming years as for reporting year 2024 no sufficient time and resources were available. Below, a.s.r. describes the actions that are in place for material IRO's.

Access to (quality) information 12.112.2

a.s.r.'s products and services can be complex, making it challenging for customers to understand the necessary details due to the complexity of the offerings and extent of the information provided, leading to uninformed or incorrect decisions. In response, a.s.r. improves information clarity by conducting regular advertising campaigns to promote sustainable damage repair, offering a comprehensive sustainable living platform, providing clear financial information to help customers make informed decisions and maintaining user-friendly portals for customer access.

Below are the actions a.s.r. takes to ensure perceivable, operable, understandable and robust digital environments:

• Employee knowledge: a.s.r. employees regularly undergo training to maintain and stay updated with the latest developments in accessibility.

• Accessibility ‘by Design’: Accessibility is integrated from the start into all steps of the design, development, and editorial processes of a.s.r.'s digital environments.

• Testing: a.s.r. regularly tests its digital environments for accessibility using various online testing tools.

• Research: Independent experts regularly assess a.s.r.'s digital environments for accessibility, covering both functional-technical and editorial aspects. a.s.r. sustainably resolves any identified issues.

User feedback: a.s.r. involves users in the development process of its digital environments. a.s.r. uses feedback and reports from users to improve its website.

Privacy 12.3

Inadequate data security management could lead to data breaches, driven by the necessity to store and process sensitive personal data, leading to the exposure of customer information. See section 5.5.2 for more information about the actions a.s.r. takes to secure the privacy of its customers and end-users.

Product lines

The following product lines have defined actions.

Health 12.112.214.1

Main task for Health as health insurer is ensuring access to care, both in terms of affordability and availability, for its customers. In the integrated healthcare agreement (IZA), sector-wide agreements have been made about the necessary actions. The themes for which actions have been formulated in the IZA are:

1. Appropriate care.

2. Regional cooperation.

3. Strengthening the organisation of primary care.

4. Cooperation between the social domain, general practitioner care and mental health care.

5. Healthy living and prevention.

6. Labour market and unburdening healthcare professionals.

7. Digitalisation and data exchange.

8. Contracting.

Health contributes to this joint effort within the industry and with its own policies, contracting and waiting list mediation. Besides these permanent processes, Health started a number of actions, like:

• In the start-up phase of a new form of General Practitioner (GP) care: Gezond.nl. The GPs of Gezond.nl handle the majority of healthcare questions digitally. In this way, a.s.r. contributes to a solution for the pressure on GP practices and for patients who cannot find a GP;

• In addition, a.s.r. has developed the Thuisfysio app in collaboration with Physitrack. With a self-check, exercise programme or video consultation, users can easily remedy minor complaints themselves;

• In Mental Health Care, a.s.r. finances a platform for online care, the Welshop. This platform brings together supply and demand and focuses on offering online care. This is of particular importance, since the waiting lists for patients with mental health problems are very long;

• Stimulate a healthy lifestyle of a.s.r.'s policyholders to reduce the burden on healthcare.

Real Estate 12.114.1

For Real Estate, the relationship the organisation has with its tenants is very important, and as such, Real Estate wants tenants to be involved, aware and satisfied. The real estate funds focus on improving tenant satisfaction, health and well-being, and awareness of sustainable living. The real estate funds periodically send out a tenant satisfaction survey to find out how tenants rate the services, properties, and their living and working environments. The results of these surveys are used to improve the performance of Real Estate and its contractors with regard to quality of living. Real Estate continuously works on a participation program involving various forms of tenant participation. Activities range from taking an active role in sustainability projects and tenants’ associations to focusing on ESG in the bimonthly newsletters and events for tenants.

With regard to impact investing, a.s.r. has defined in 2024 several impact themes, such as affordable housing, Dutch Science parks and international non-listed real estate. See section 3.1.2.2.

Mortgages 12.112.214.1

a.s.r. aims to ensure that customers maintain an affordable mortgage throughout its term. In situations where (potential) financial difficulties arise, customers are encouraged to make early contact, either by phone or through their online account, to explore sustainable solutions. The primary objective is to support customers in remaining in their homes.

In addition to responding to customer enquiries, (potentially) vulnerable customers are proactively identified through active account management. These customers are those with an increased risk of affordability challenges or residual debt, identified using early warning models and periodic scenario analyses of the mortgage portfolio.

A personal and empathetic approach is taken when engaging with these (potentially) vulnerable customers. Information is provided to highlight affordability and residual debt risks, along with actionable solutions wherever possible. The ultimate goal is to prevent financial difficulties and ensure responsible home retention, placing the customer's needs at the centre of this approach.

6.3.3.3Targets and metrics

Targets

For most material IRO's, a.s.r. has set related targets. In case a target related to a material IRO is not yet set for reporting year 2024, these will be addressed and prioritised upon in the coming years, as for reporting year 2024 no sufficient time and resources were available. The targets are set by the responsible business line and established in policy. The monitoring of the effectiveness of the measures takes place through the current management reports and will be further optimised going forward.

See section 6.1.4.2 and 8.5 how a.s.r. included the customers in the stakeholder dialogue.

The real estate funds' tenants are very important partners, and as such, the funds want them to be involved, aware and satisfied. The real estate funds are conducting satisfaction surveys among their tenants. These surveys are recurring and are conducted periodically. The results of these surveys are used to improve tenant engagement, and to find out how tenants rate the services, properties and their living and working environments. The findings are processed by asset managers and, where applicable, discussed with the internal or external property managers. The target for this metric is a score of at least 7.0 out of 10.0 for retail, residential, office and science park tenants and 7.5 out of 10.0 for farmland tenants. As the surveys are recurring, a.s.r. aims to consistently meet the target.

See section 6.5.4.13 for CSRD reporting policies.

See section 6.5.4.14 for CSRD reporting policies.

Access to products and services 12.1 12.2

Customers are at the heart of a.s.r.'s purpose, and its strategy is designed to meet their needs. a.s.r. closely monitors customer satisfaction by continuously measuring feedback through the Net Promoter Score (NPS). And does so through various indicators, like the Net Promoter Score for customer relationship (NPS-r), which is an analysis of the customer relationship; this extends the methodology of the Net Promoter score for contact moments (NPS-c). NPS-c only measures customer satisfaction during contact moments. The NPS-r of a.s.r. is compared to the market average, where market average is equal to a score of zero. The target was to achieve an NPS-r higher than the market average at the end of 2024. For 2024 the adhered market average is -1. The 2024 result is -11 (difference between benchmark score and a.s.r. score). The main attention points from customer feedback for 2025 are to continuously improve online communication, accessibility, and user-friendliness. Additionally, attention for guidance during the migration of Aegon NL processes into a.s.r. processes also continue to be an attention point.

From January 2025, a.s.r. will only measure the NPS-i (interaction), which includes all forms of contact, including digital interactions. The baseline measurement will be conducted in 2025.

Responsible marketing practices 14.3

The aim of responsible marketing practices is to inform the customer accurately and without bias. To prevent reputational damage from irresponsible marketing practices, a.s.r. has all marketing communications reviewed in advance by the Legal and Compliance departments. This promotes consistency and prevents greenwashing by ensuring sustainability claims are accurate and comply with legal definitions. These measures are essential to avoid legal complications and protect a.s.r.’s reputation, thereby significantly reducing the risk of financial drawbacks and informs the customer right and unbiased.

General

a.s.r.'s commitment to sustainability is an ongoing process. a.s.r. continues to strive for improved performance and to keep its stakeholders informed about its progress. Although a.s.r. currently has no further specific sustainability targets established, a.s.r. remains committed to continuous improve in its sustainability practices. a.s.r.'s goal for the future is to present concrete targets and achieving a.s.r.'s sustainability objectives.

Distribution and other services

There are no actions or targets defined for the distribution and other services entities.

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