For a.s.r., it is key that the own workforce remains sustainably employable, which is why considerable attention is given to personal and professional development, physical and mental health, and work-life balance. a.s.r. has great confidence in its employees and encourages everyone to take control of their own careers, development, and the way they do their work.

To attract and retain the necessary skills, a.s.r. is dedicated to offering an attractive, at market level and flexible employment package. The organisation places significant emphasis on employee development, engagement and vitality. The aim is also to improve diversity, equal treatment and inclusion.

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. As indicated in the table below, certain staff functions hold an overarching and an oversight responsibility, extending their influence across multiple product lines. HR is such a department. The organisational scope of HR encompasses the following product lines and staff functions: P&C, Disability, Health, Pensions, Individual life and Funeral, Asset Management, Real Estate, Mortgages, Vitality, Procurement, Compliance, IT, Services and the managed services of Knab (until 31 October 2024) and TKP.

6.3.1.1Managing impacts, risks, and opportunities

Interests and views of stakeholders

a.s.r.’s approach to determining its material impacts, risks and opportunities is described in sections 6.1.4.1, 6.1.4.2 and 6.1.4.3.

a.s.r. places a strong emphasis on the sustainable employability and well-being of its workforce. This is an integral part of its strategy to promote a healthy and productive work environment. Examples include offering flexible working hours, vitality programmes, and a wide range of development opportunities through the a.s.r. academy. These initiatives help a.s.r. remain an attractive employer, which is essential for attracting and retaining talent. This allows the strategy and business model to be better adapted to the needs of the workforce and the labour market.

However, the business combination with Aegon also brings risks, such as uncertainty and potential redundancies, which can affect morale and stability within the workforce. This is addressed through an active policy on sustainable employability and career development support. At the same time, a.s.r.'s commitment to fair working conditions and equal opportunities attracts talent and fosters innovation and productivity. This is woven into a.s.r.'s strategy to create an inclusive and supportive work environment.

a.s.r. ensures that all persons in its workforce who may be materially affected by a.s.r. are included in its considerations and decision-making processes. This includes:

• Employees:

  • Permanent employees: Individuals with an ongoing employment contract.

  • Temporary employees: Individuals with a fixed-term employment contract.

  • Both part-time and full-time staff.

• Non-employees:

  • Self-employed individuals: Contractors who supply labour directly to a.s.r.

  • Agency workers: Individuals provided by third-party companies primarily engaged in employment activities.

Although a.s.r. has not reported widespread or systemic negative impacts, individual incidents are addressed through internal procedures and support. Positive impacts are promoted through initiatives such as the Participation Desk, which supports people with a distance to the labour market. Uncertainty due to mergers and restructuring poses a risk, while increased productivity and innovation through an inclusive and supportive work environment offer opportunities. Within a.s.r. no specific negative impacts from environmental and sustainability transition plans were reported.

a.s.r. has developed an understanding of how people with certain characteristics, working in specific contexts, or performing certain activities may be at greater risk of harm. This understanding is used to develop policies and initiatives to mitigate these risks. Certain material risks and opportunities relate to specific groups of people, such as employees in certain age groups or employees working in specific factories or countries.

6.3.1.2Policies and actions

Policies

Code of Conduct 8.18.210.110.210.3

a.s.r.'s Code of Conduct guides actions and decisions, ensuring duties are fulfilled with care and integrity. It applies to all employees, including temporary and external staff, and sets standards for interactions, customer service and environmental responsibility. The code is available on the a.s.r. website.

Upon starting employment, all employees must take an oath or make a solemn affirmation demonstrating their commitment to ethical principles and compliance with the Code of Conduct.

a.s.r. is committed to upholding human rights and adhering to international conventions and guidelines. The human rights policy was updated in 2024 and has been integrated across the business, applying to all roles. a.s.r. explicitly rejects and forbids any form of human trafficking, forced or compulsory labour, and child labour. The human rights policy is in line with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. The company ensures that its operations and those of its business partners are free from these practices as stated in the Code of Conduct. It includes e.g. a complaints procedure for customers, human rights desk and a whistleblower scheme for reporting potential abuses or irregularities and is in line with the international standards.

Distribution and services entities 8.18.210.110.210.3

The distribution and services entities place great importance on integrity, responsibility, and a positive work environment. The codes of conduct form the backbone of the business operations and are designed to foster a culture of honesty, respect, and transparency. While each entity has its own unique core values and accents, they share a common foundation that underscores the commitment to ethical business practices and social responsibility.

Compliance with Laws and Regulations

The distribution and services entities operate within a framework of national and international laws and regulations, as well as industry codes that promote controlled and ethical business operations. Fundamental human rights, as laid out in the Universal Declaration of Human Rights, are respected and endorsed. This forms the basis of their actions and ensures that obligations are met and contributions are made to a just society.

Respect and Safety

A safe and respectful work environment is essential for the well-being of employees. Collaboration takes place on a respectful and equal basis, with no tolerance for unwanted behaviour such as sexual harassment, aggression, discrimination, and abuse of power. Employees are encouraged to contribute to a positive work environment and to report unwanted behaviour. This fosters a culture of openness and trust, where everyone feels valued and respected.

The distribution and services entities are dedicated to creating a work environment that is fair, inclusive and supportive, driving both organisational success and employee satisfaction.

Collective Labour Agreement 8.18.210.110.210.3

a.s.r. has its own collective labour agreement (CLA), The Other CLA (De Andere CAO), which reflects ‘Het verhaal van a.s.r.’ (the narrative of a.s.r.) and is the backbone of a.s.r.’s HR policy. It contains schemes and agreements on employee development and sustainable employability, on behaviour and leadership, on results, evaluation and remuneration, and on mobility and time, with much attention paid to work-life balance. This collective labour agreement also includes arrangements on vitality, encouraging employees to take responsibility for their own career and well-being. It provides support through training, development programmes, and initiatives that contribute to a healthy work-life balance. The other collective labour agreement applies to employees of a.s.r. who are under a fixed-term or permanent employment contract and have not yet reached the state pension age. This is a related policy regarding the positive and negative impact for a.s.r. on working conditions and equal treatment and opportunities for all.

The CLA:

• is recognisable for everyone and forms the basis for all types of workers at a.s.r.;

• encourages a mature working relationship;

• encourages employees’ autonomy;

• increases the labour market value of employees;

• offers freedom of choice as an option, not as an obligation;

• is based on trust, not monitoring;

• contributes to a sustainable and future-proof a.s.r.;

• respects solidarity with and between employees.

The CLA has a duration of nine months, from 1 July 2024 until 31 March 2025, and will be periodically reviewed and approved by the MB.

Work-life balance

At a.s.r., employees have significant flexibility in determining their working hours and choosing their workplace, promoting a healthy work-life balance. This approach is part of a mature employment relationship that emphasises autonomy and responsibility. Employees are expected to manage their work schedules sensibly to ensure optimal and efficient performance, prioritising customer interests and mutual consideration.

Employees can set their own working hours within established frameworks. This flexibility allows for more effective and efficient work, better customer service and improved work-life balance. Working hours are expressed as an annual total, with the standard being 1,976 hours for full-time employees. This allows for flexibility in managing workloads throughout the year. Employees have the right to be unreachable outside agreed working hours.

Employees build up to 200 holiday hours annually, which can be taken in consultation with managers and colleagues. Special forms of leave, such as emergency care, parental and sabbatical leave, are also available to support employees’ personal needs and responsibilities. Employees can work more hours during busy periods and compensate by working fewer hours during less busy times, ensuring a balanced workload and preventing overburdening.

This flexible and supportive approach to working hours aligns with a.s.r.'s commitment to employee well-being and sustainable employability, contributing to a positive and productive work environment.

In the July 2024 update of the CLA, a study agreement was made with trade unions to explore the possibility of agreeing on a lower standard annual working hours norm (currently 1,976 hours per year, averaging 38 hours per week).

• In the CLA that was reached in 2024, an addition was made regarding special forms of leave, allowing employees to object to an undesirable outcome of a constructive conversation with their supervisor regarding leave in exceptional circumstances.

• In 2024, it was agreed that workload will be periodically addressed during regular quarterly meetings with the trade unions.

Sustainable mobility

a.s.r. aims to be a sustainable employer, which includes reducing the GHG emissions from employee commuting. In line with this vision, the Sustainable Mobility programme was established in 2018. This platform, for green transition, meets monthly to identify initiatives that contribute to a.s.r.'s sustainability goals as an employer and to closely monitor their progress.

The Mobility Steering Group, comprising representatives from HR, Corporate Communications, Services, Real Estate, and Procurement, monitors these initiatives and ensures that new developments, both internal and regulatory, are closely followed. This group meets at least twice a year and can convene as needed. They oversee current initiatives and explore future steps.

At the meeting in June 2024, their focus was on implementing new legislation regarding work-related personal mobility. This requirement mandates organisations to be transparent about their mobility patterns. a.s.r. aims not only to comply with these regulations but also to set an example. In addition, the steering group is exploring new sustainable mobility options at various locations. With each decision and adjustment, the Mobility Steering Group contributes to a.s.r.'s ambition to be a sustainable employer.

Training and skills development

Aligned with a.s.r.'s principles and the guidelines of the CLA, it is important that a.s.r.’s employees can shape their careers according to their needs. Based on their personal (development) needs, employees can flexibly design their careers, for example, by taking care leave or a sabbatical. a.s.r. also offers opportunities to focus on other activities (volunteer work) or to combine different jobs (hybrid professional). a.s.r. aims to change the perception of demotion and promotion, making it more natural to take a step back or sideways (remotion). a.s.r. also considers the needs employees may have at different stages of their lives (working more or less, senior policy). Personal control and choices are central to this.

In the context of increasing automation and Artificial Intelligence (AI), and the integration of a.s.r. and Aegon, developing employee talents is crucial to ensure they remain future-proof. In today's competitive labour market, a.s.r. prioritises employee retention through comprehensive training and development programs. These initiatives enhance sustainable employability and marketability.

Job security

To provide a high level of job security for employees, a.s.r. implements an active role in sustainable employability. Under the name “In Motion” (In Beweging), employees are encouraged to enhance their employability in the job market, both within and outside a.s.r. The a.s.r. academy offers inspiration sessions and training that contribute to increasing employee agility, developing future competencies and skills, and provides the opportunity to request non-job-related training that enhances job market opportunities, both within and outside the industry.

Additionally, there is a comprehensive offering in the area of vitality, and every employee can consult with a Talent Advisor for a career trajectory. Assessments can be part of this process to gain insight into which career directions align with the individual employee's motivations and competencies. Furthermore, every employee has access to a Talent Development Plan, which encourages them to reflect on their fit with their current role, helps them map out their ambitions, and create an action plan to achieve them.

The Other Plan 8.18.210.110.210.3

The reorganisation following the business combination with Aegon NL may lead to uncertain job security for employees due to potential redundancies and shifts in job roles or office locations. a.s.r. and Aegon have completed a legal merger, forming a single combined legal entity. This merger necessitates significant organisational restructuring.

The business combination may have implications for current employees. The consequences of the reorganisation following the business combination at a.s.r. significantly affect employee job security. As the company seeks to streamline operations and integrate systems, there may be job redundancies, which negatively impacts job stability. Additionally, employees with temporary contracts face the risk of non-renewal under the new organisational structure. This could negatively impact employee morale and loyalty.

The Other Plan is designed to mitigate the negative impact on employees and support them in finding new opportunities, both within and outside a.s.r.

Remuneration policy 8.18.210.110.210.3

All a.s.r. employees have job-weighted salaries within defined salary scales that they progress through over time. The link between roles and salary scales is consistent throughout the organisation. The principle of the a.s.r. remuneration policy is to reward around the median of the relevant reference group.

For employees, an annual growth of 3% of the maximum of the scale is applied (provided there is upward room in the scale). For EB members, the SB has the mandate to slightly adjust this growth path upwards or downwards (growth of 0% to 6%), taking into account a.s.r.’s performance and the principles of the remuneration policy. The SB accounts for this in the annual remuneration report. In line with the remuneration policy, the remuneration of a.s.r. employees consists solely of a fixed payment. a.s.r. does not have a group-wide variable remuneration scheme. See section 5.3.2.

Periodically, an independent consultant performs a market-based comparison of the remuneration benchmark. In the July 2024 update of the CLA, a.s.r.'s salary structure was adjusted to align with the outcomes of the financial services benchmark, to adhere to a.s.r.'s policy of rewarding around the median of the relevant comparison market, and to integrate the two salary structures of Aegon and a.s.r. This revised structure also provides more salary growth opportunities for employees and better reflects the complexity of job levels. HR is in charge of the remuneration policy and coordinates its formulation and evaluation throughout the a.s.r. group.

Diversity, Equity and Inclusion policy 8.18.210.110.210.3

a.s.r. believes that diversity makes the organisation stronger and better, and a.s.r. is committed to providing equal opportunities for everyone. a.s.r. strives for an inclusive culture where differences are recognised, valued and utilised. It is important that employees are skilled, but also different from each other, and that space is created to express these differences. Different perspectives, backgrounds, knowledge and experience contribute to achieving a.s.r.'s goals and are positively utilised in innovative, sustainable solutions for its customers.

a.s.r. aims to exclude no one and treat everyone equally. Everyone who wants to use their talents to achieve a.s.r. goals is given the opportunity to do so. a.s.r. achieves this by being aware of visible and invisible differences between people. This includes gender (expression), sexual orientation or preference, age, religious beliefs, culture, ethnicity, skin colour, and physical and mental abilities. a.s.r. also pays attention to differences in work styles, beliefs and perspectives. This is laid down in a.s.r.’s Diversity, Equity and Inclusion Policy, which is owned by HR and was revised in 2024. The policy contains the following subjects:

• Promoting diversity: Through recruitment and career progression, a.s.r. aims to create a diverse workforce that reflects society. See section 6.3.1.3 for the diversity target that has been set for the higher management on diversity. This target is one of the strategic non-financial targets as communicated during the Capital Markets Day (CMD) in June 2024. For more information, see section 2.5.2.

• Annual success measurement: a.s.r. conducts an annual culture scan by Denison. By 2026, a.s.r. aims to be among the top 15% of companies participating in the survey. In the Diversity & Inclusion module, a.s.r. aims to be in the top 25% by 2026. a.s.r. measures progress within the organisation based on four pillars:

  • Perceptions of inclusion and respect;

  • A work environment that is safe and free from discrimination;

  • Fair and equal access to opportunities;

  • Leadership that values diversity.

• Participation: By 2026, a.s.r. aims to have at least 70 people at a distance from the labour market working at a.s.r. (25.5 hours per week, approximately 45 FTE).

• Equal pay: a.s.r. ensures equal pay for equal work. To guarantee this, a.s.r. conducts an annual Gender Pay Gap analysis. Additionally, an independent external party analyses the situation every three years.

Gender equality and equal pay

Gender equality and equal pay are important topics within a.s.r.’s Diversity, Equity and Inclusion Policy. To monitor whether the policy is effective in practice, a.s.r. conducts an annual Gender Pay Gap analysis. The latest report, published in March 2025 and adjusting for variables such as type of work, age, and work experience, shows that men and women at a.s.r. are paid equally for equal work, resulting in an adjusted pay gap of 0%. This has remained unchanged with the integration of Aegon NL employees into the a.s.r. job structure. This performance is significantly better than the business sector in the Netherlands, where the adjusted pay gap was 6.9% in 2022, according to the most recent research by Statistics Netherlands (Centraal Bureau voor de Statistiek - CBS) in December 2023. See for the definition of 'adjustments' the website of the CBS. See table S1-16 in section 6.3.1.3 for the unadjusted pay gap of a.s.r.

Gender diversity

At a.s.r., there is a strong commitment to ensuring gender diversity and equal pay. Through inclusive employer branding and an objective recruitment and selection process, the focus is on attracting talent. Around International Women’s Day 2024, a.s.r. participated in a national billboard campaign highlighting female role models. The aim was to inspire and motivate women by sharing their personal stories.

Gender diversity is promoted through talent development. At a.s.r., everyone has the space and equal opportunities to develop themselves. Through training offerings and a focus on personal development, a.s.r. strives to create equal opportunities for all. With the Sustainable Employability budget, all employees are given the chance to develop broadly and enhance their labour market prospects.

Partnerships with organisations that emphasise the importance of women in leadership are also in place. For example, a.s.r. participates in the Talent to the Top mentoring programme, and COO/CTO Ingrid de Swart is an ambassador for the Dutch Top Woman of the Year election.

In the past year, slightly more women (51%) than men (49%) started in new positions at a.s.r. The proportion of women showing potential for advancement to management positions is also growing, identified as (upcoming) top talent.

Culture programme

The culture programme at a.s.r. was initiated to strengthen and unify the culture across all product lines. The primary goal is to build a cohesive and strong organisational culture that aligns with the core values and strategic objectives of a.s.r. This initiative is driven by the need to ensure that all employees understand and embody the values, which are helpfulness, forward-thinking and achieving results. The core values are essential for executing the strategy and achieving a.s.r.'s goals. The culture programme has set several actions to strengthen The story of a.s.r.

• Conduct round table discussions to analyse the product line's culture and identify sustainable improvements. The results are used as a basis for further actions.

• Create a connectors network. They identify and engage connectors to promote desired behaviour and sustainable practices. The connectors fulfil an important part of conveying core values and strengthening the culture. 

• a.s.r. has also identified key behaviours that require reinforcement, including collaboration, giving and receiving feedback, empowerment and transparency, all to strengthen the story of a.s.r.

Persons with disabilities

a.s.r. focuses on employees’ potential rather than their limitations. a.s.r. works together with employees to remove barriers and ensure optimal employability. To support individuals with a vulnerable position in the labour market, a.s.r. has established the Participation Desk. This initiative offers people who meet the criteria set by the Participation Act, the opportunity to develop skills and gain work experience through temporary assignments within the organisation. They receive intensive guidance, a tailored training programme and resilience training. The goal is to transition these temporary assignments into permanent positions within a.s.r. after two years. Through the Participation Desk and the regular recruitment policy, a.s.r. strives to fully utilise the talents of this group.

In 2023, a.s.r. maintained Stage 1 of TNO’s Corporate Social Responsibility Performance ladder (Prestatieladder Socialer Ondernemen). This means that, on average, a.s.r. employs more people who are at a distance from the labour market than other organisations of the same size, and that a.s.r. encourages suppliers and contractors to engage in social entrepreneurship. a.s.r. achieved Stage 1 in January 2020.

The Code of Conduct on Undesirable Behaviour 8.18.210.110.210.3

At a.s.r., great importance is placed on an inclusive and safe working environment where discrimination has no place. The Code of Conduct on Undesirable Behaviour defines discrimination as making unlawful distinctions based on religion, personal beliefs, political opinion, race, gender, nationality, sexual orientation, civil status, disability or chronic illness, age, working hours, or type of contract.

If an employee encounters undesirable behaviour, including discrimination, a.s.r. encourages them to discuss this with their manager, the manager's manager, or the HR Advisor. If this is not possible, employees can contact an external confidential advisor. These confidential advisors are independent and bound by professional secrecy. If internal steps do not lead to a resolution, employees can submit a formal complaint to the Undesirable Behaviour Complaints Committee. This committee will investigate the complaint and provide a written opinion on the validity of the complaint and possible measures.

Additionally, a.s.r. uses other tools to identify discrimination:

• Vitality scan: Every 1.5 years, employees receive an invitation from the occupational health service to participate in the Preventive Medical Examination (Preventief Medisch Onderzoek - PMO), known at a.s.r. as the vitality scan. One module of this questionnaire addresses undesirable behaviour.

• eMood®: Employees receive a weekly pulse check consisting of three statements about job satisfaction, vitality, and productivity. eMood® includes recurring statements related to a safe working environment, open culture, and the courage to speak up. This provides a.s.r. with a good understanding of employees’ experiences and allows us to detect trend changes over time.

• Denison Culture Scan: This annual survey provides insights into the organisation's cultural dynamics and their impact on performance. a.s.r.'s scores are compared to a benchmark of over 1,200 companies worldwide. One module of this scan focuses on Diversity and Inclusion.

• Risk Inventory and Evaluation (RI&E). To ensure the safety and health of employees, it is essential for employers to identify and address risks related to safety and physical and psychosocial working conditions, including undesirable behaviour. Therefore, a Risk Inventory and Evaluation (RI&E) is conducted periodically (once every three years). The RI&E documents the risks associated with the work and whether adequate precautions have been taken to prevent harm to employees’ health.

• Confidential Advisors’ Report: a.s.r. employees can contact two confidential advisors (one male and one female) from the occupational health service. These advisors are independent and provide an unbiased perspective on the situation. Employees can approach the confidential advisor without informing their supervisor. Together, they assess the problem, discuss the employee's actions so far, and determine possible next steps. Annually, a.s.r. receives a summary of the findings and the number of reports to the confidential advisors, broken down by type of undesirable behaviour, including discrimination.

Health and Safety Policy Plan 8.1

Reporting incidents is crucial for both a.s.r. and its employees. Reporting helps a.s.r. identify irregularities or errors, allowing action to be taken. It is also important because a.s.r. must report certain incidents to regulators. Managers proactively create a safe environment for reporting incidents; a.s.r. has a dedicated reporting point for this purpose.

Employees can raise their concerns through the following internal channels:

• The manager.

• HR advisor or vitality specialist.

• External confidant.

• Complaints committee for undesirable behaviour.

• Human rights reporting point.

• Integrity reporting point.

• Whistleblower policy.

• Works Council.

At a.s.r. there are two complaint procedures, namely the general complaint procedure and the unwanted behaviour complaint procedure. The procedures are documented in a policy that involves employee participation. The policies are accessible to all employees via the intranet (Sam). See section 6.4.1.3. for more information about the awareness.

Workplace accident prevention, registration and reporting

At a.s.r., various functions and roles are involved in the health and safety policy, including management, employees, HR, prevention officers, business support, employee participation, and the health and safety service. These functions have specific tasks and responsibilities to ensure safety and health in the workplace.

Preventive Measures

1. Risk Inventory and Evaluation (RI&E):

   • Periodic execution of the RI&E to identify and address risks in the areas of safety and health;

   • Developing a Plan of Action based on the RI&E, with specific measures to mitigate identified risks.

2. Preventive Medical Examination (PMO):

   • Periodic vitality scans to detect health risks early and provide recommendations for improving the health and vitality of employees.

3. Company Emergency Response (BHV):

   • Training and equipping BHV officers to provide first aid, fight fires, and conduct evacuations;

   • Annual testing of the company emergency response to ensure effectiveness.

4. Emergency Response Plan:

   • Availability of an emergency response plan for all a.s.r. locations to act adequately in emergency situations and limit damage.

Accident Registration and Reporting

• All workplace accidents are recorded in the accident register;

• Incidents requiring first aid are documented in an incident report;

• Serious workplace accidents (resulting in death, permanent injury, or hospitalisation) are reported immediately to the Labour Inspectorate.

Responsibilities and Tasks

• Managers: Responsible for implementing the health and safety policy within their department and overseeing safe and healthy working practices;

• Employees: Responsible for their own working conditions and the use of prescribed protective equipment;

• HR (vitality and absenteeism specialists): Preparing the RI&E and PMO, monitoring the implementation of the Plan of Action, and providing proactive advice on absenteeism prevention;

• Prevention Officers: Advising and collaborating with the Works Council, and monitoring the correct use of the workplace and protective equipment.

Other workforce-related themes 8.18.210.110.210.3

Employee engagement

Employee engagement is measured through the annually performed culture scan. Employees are asked to fill in a questionnaire on the basis of four drivers of engagement: vision, core values, empowerment and knowledge development. The results are compared with a global benchmark of more than 1,200 large organisations that use the scan. The target for 2026 is to achieve an engagement of at least 85. This target is one of the strategic non-financial targets as communicated during the Capital Markets day in June 2024.

Recruitment and career progression

To provide equal opportunities for everyone, a.s.r. works as objectively as possible in its recruitment, selection, internal career progression and promotion processes.

• Inclusive job descriptions: a.s.r.'s job descriptions adhere to rules preventing age and gender discrimination. a.s.r. is also trained in writing inclusive recruitment texts;

• Objective assessments: a.s.r. uses assessments that make selection objective and suitable for a diverse range of candidates;

• Internal job postings: All vacancies are posted internally for two weeks before being published externally if no suitable internal candidate is found. External employees working for a.s.r. can also apply for a.s.r.’s internal vacancies;

• Support from the Participation Desk: To help employees from the Participation Desk transition to permanent positions, HR actively highlights suitable vacancies and informs managers about suitable candidates;

• Diverse interview panels: a.s.r. ensures a diverse composition of interview panels in the recruitment process;

• Objective interview training: Managers are offered a workshop on conducting objective interviews;

• Talent committee: A talent committee provides insight into (upcoming) top talents and succession positions. This committee monitors the development of talents and ensures they are known to senior management.

Vitality and health check

a.s.r. believes that it is important that workload and capacity are balanced. Prolonged imbalance can lead to complaints or even absenteeism. a.s.r. periodically offers employees the opportunity to gain insight into the stressors and energy sources that affect their work through the Vitality Scan. With these individual insights, employees can work on their health or discuss it with their manager. Through the a.s.r. academy, employees have access to a wide range of workshops and training on vitality. Additionally, employees can have an annual health check through a.s.r. Vitality to gain insight into their health.

• In the fall of 2024, a comprehensive vitality scan has been conducted for all employees of a.s.r. This scan is conducted every three years, and an interim light version monitors ongoing progress. The results of these scans lead to targeted actions to improve employee vitality.

• Based on the outcomes of the light scan in 2023, ‘resilience’ among employees was identified as a key area of focus, particularly in light of developments following the acquisition of Aegon. To address this, the a.s.r. academy offers workshops on resilience for employees, and a.s.r. provides training for managers on how to support resilience. Additionally, in 2024, physical health checks will be offered on-site, linked to the outcomes of previous vitality scans.

• Furthermore, weekly pulse-checks via eMood® monitor topics such as vitality and social safety, and managers are regularly reminded of training opportunities in the a.s.r. academy.

• A predictive absenteeism module, developed and set to go live in the fall of 2024, is partially based on data collected from the weekly eMood® surveys. The results of this module will be included in the management dashboard, providing real-time insights into absenteeism trends and forecasts for the next three months.

• The manager of the HR Vitality team joined the HR Management Team (MT) in 2024, ensuring that the topic of vitality is well-represented in the MT’s discussions and decisions.

Absenteeism

In 2024, managers gained access to an interactive absenteeism dashboard developed by HR. This dashboard provides insights into historical and current absenteeism, associated costs, and uses AI to make predictions about future absenteeism. The dashboard aims to raise awareness about absenteeism and equip managers with tools to prevent manageable absenteeism. See section 3.2.3. for more information about absenteeism and see section 6.3.1.3 for the absenteeism targets that have been set.

Vital from home

Most employees at a.s.r. perform sedentary work. It is important that they move sufficiently during (screen) work and avoid sitting for long periods to prevent negative physical and mental effects. a.s.r. promotes a healthy movement and rest pattern through vitality software Work&Move, a.s.r. Vitality, an on-site gym, sit-stand desks and a QR Fit route around the building. Taking smart breaks is essential to staying vital throughout the workday.

As employees increasingly work from home, it is important that they also have a healthy and safe work environment at home, tailored to their personal needs. This means that the home workplace should comply with occupational health and safety regulations. a.s.r. also expects that employees continue to work on their vitality during hybrid working, taking sufficient breaks and moving regularly. Ensuring a good work-life balance is also crucial. a.s.r. shares this responsibility with its employees.

a.s.r. supports employees in various ways, including through a workplace check, an additional individual workplace assessment and a vitality check. a.s.r. also provides the necessary equipment for a home workplace on loan.

Employee participation

a.s.r. places great value on the involvement of its employees in the strategic goals of the organisation.

a.s.r. organises, when needed, dialogue and information sessions to inform employees about important developments and changes within the organisation. These sessions provide a platform for employees to ask questions and give feedback. Additionally, workshops and training sessions are held to enhance the knowledge and skills of employees, enabling them to better contribute to the strategic goals of the organisation.

The Central Works Council (Centrale Ondernemingsraad - COR) plays a crucial role in involving employees in decision-making. The COR provides, as stated in the Works Councils Act (Wet op ondernemingsraden), advice and consent on important decisions that affect employees, such as changes in employment conditions, reorganisations and strategic changes. Regular meetings between the COR and management ensure that the voice of the employees is heard and considered in decision-making. The COR holds consultation meetings with the Chief Executive Officer (CEO) and Chief Human Resources Officer (CHRO) every two months, and the Employee Council meets with the MB and the SB every two months. The members of the COR are exempt from work for 50% of their time. The Executive Board of the COR is operationally responsible for the COR. The Executive Board regularly reports to the COR on its operational activities.

The COR has established a subcommittee for each business line to make the work of the COR easier and more manageable, and to better organise employee representation. The members of the subcommittees always work at the respective business line and are elected by colleagues at that business line or appointed by the COR. This ensures that there is knowledge of the respective business unit. The members of the subcommittee are exempt for 10% of their time.

a.s.r. engages with the following trade unions: De Unie, CNV and FNV Finance. There are quarterly meetings with the trade unions. Additionally, a.s.r. schedules extra meetings as needed to timely agree on new CLA and social plan. See section 3.2.4 for the outcome of the latest trade union agreement and the actions.

The quarterly report on sustainable business includes information about activities related to the sustainability pillar of Sustainable Living and Climate. It provides an update on the progress of non-financial objectives such as emission reduction and other initiatives contributing to the transition to a more sustainable world. This report is shared not only with the MB but also more broadly within the organisation, including with the COR sustainability committee. The Sustainability team meets with this committee every quarter to update them on sustainable business practices within a.s.r. Through the a.s.r. academy, various training sessions are offered on sustainability in a broad sense, including vitality and inclusion. In 2024, an employee platform called Sustainable Doers was launched on the intranet, where employees can exchange sustainable ideas and set up initiatives.

a.s.r. believes that weekly employee feedback is key to continuous improvement in organisational culture, connection, and customer service. To stay attuned to how everyone is doing, a.s.r. uses the eMood® pulse-check. This short, weekly survey consists of three questions that change each week, focusing on job satisfaction, productivity, and vitality. The value of eMood® extends beyond the results; the ensuing conversations are equally important. a.s.r. tracks key performance indicators (KPIs) related to job satisfaction and vitality, allowing for timely interventions. This combination of employee feedback and data helps identify trends and guide efforts to improve workplace enjoyment and performance. Each week, the HR department provides follow-up suggestions based on the eMood® theme, focusing on personal growth and team development, such as assertiveness training, feedback workshops, and stress reduction. Based on employee feedback, HR policies are evaluated and developed. to implement improvements.

For more information about Employee participation, see section 5.6.

Distribution and services entities

The distribution and services entities with more than 50 employees have their own Works Council. The Works Council represents the interests of the staff within the entity.

Data Retention Policy 9.1

As a prominent employer, a.s.r. is entrusted with considerable amounts of employee data. This data includes personal information, employment records, and other sensitive details necessary for the effective management of the workforce. a.s.r. recognises the potential negative risks to the privacy of employees if this data is not handled in a secure and confidential manner. Therefore, stringent data protection measures are implemented to safeguard employee information.

The approach to data protection is guided in the Data Retention Policy, which emphasises the importance of:

• Confidentiality: ensuring that employee data is accessible only to authorised personnel and is protected against unauthorised access and disclosure.

• Integrity: maintaining the accuracy and completeness of employee data, preventing unauthorised alterations, and ensuring that data remains reliable and trustworthy.

• Availability: ensuring that employee data is available when needed for legitimate business purposes, while also protecting it from loss or destruction.

To achieve these objectives, a.s.r. has implemented the following measures:

• All employee data is encrypted both in transit and at rest to prevent unauthorised access.

• Strict access controls are in place to ensure that only authorised personnel can access employee data. This includes role-based access and regular audits of access permissions.

• Only the minimum amount of employee data necessary for operations is collected and retained, in compliance with legal and regulatory requirements.

• Employees who work with personal data are regularly trained on data protection policies and procedures.

• A robust incident response plan is established to quickly address any data breaches or security incidents, minimizing potential harm to employees.

By adhering to these principles and measures, a.s.r. aims to protect the privacy of its employees and maintain their trust in the commitment to data security.

General Data Protection Regulation

a.s.r. and its distribution and services entities are committed to safeguarding the privacy of its customers, third parties and employees. Proper handling and securing of personal data contribute to a.s.r.'s good reputation. The processing of personal data at a.s.r. and the distribution and services entities falls under the General Data Protection Regulation (GDPR). This European regulation imposes strict requirements on the processing of personal data, including the necessity of a lawful basis for processing, the protection of data through appropriate technical and organisational measures, and the rights of data subjects, such as the right to access, correction and deletion of data. See section 5.5.2 or a.s.r.’s privacy statement for more information. Compliance is policy owner and the privacy policy supports the IRO of other work-related rights.

Distribution and services entities

The distribution and services entities operate within a framework of national and international laws and regulations, as well as industry codes that promote controlled and ethical business operations. This includes compliance with the General Data Protection Regulation (GDPR) and other relevant laws, as stated in various Data Retention policies and Privacy Policies.

Data Security

Robust measures are taken to ensure the security of both physical and digital data. This includes the use of secure systems, regular audits, and controlled access to ensure that only authorised personnel have access to sensitive information.

Complaints mechanisms 8.18.210.110.210.3

General Complaint Procedure

If an employee feels been treated unfairly by a decision of a.s.r., they can use the General Complaint Procedure. If the employee encounters unwanted behaviour, they can file a complaint. The process is described in the Unwanted Behaviour Complaint Procedure. This policy is reviewed when environmental factors warrant it. The General Complaint procedure outlines the procedure for employees to file complaints if they believe they have been treated unfairly by a decision made by a.s.r. The General Complaints Committee (the Committee) ensures that the applicable procedures from the Collective Bargaining Agreement and other guidelines are followed correctly. The Committee reviews the reasonableness of the decision but does not re-evaluate the case substantively. Complaints that are related to termination of employment, legal proceedings, or those covered by other specific procedures are excluded. All information shared during the procedure is confidential.

The procedure and timelines that are followed after a concern is raised are stated in the policy. If there is a delay in the process, all parties involved are informed in a timely manner.

The reporting channels are as following:

• Internal: employees can report misconduct to their supervisor, HR, Compliance, or make use of the whistleblower policy. If senior management is involved, reports can be made directly to HR or Compliance.

• External: anonymous reports can be made to external bodies like the House for Whistleblowers, law enforcement or regulatory under which authorities Dutch Central Bank (De Nederlandsche Bank - DNB), the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten - AFM), Authority for Personal Data (Autoriteit Persoonsgegevens - AP), Authority for Consumers and Markets (Autoriteit Consument & Markt - ACM).

Reports are handled confidentially, and whistleblowers are protected from retaliation. If retaliation is suspected, it can be reported to a supervisor, HR or Compliance. Reports are documented, and an investigation team is formed. The team conducts a thorough investigation and communicates findings within three months. Appropriate measures are taken if the report is substantiated.

Incidents, such as data breaches or system hacks, are reported to the risk manager. The risk manager documents and assesses incidents, coordinating responses with relevant departments. Confidentiality is maintained, and regulatory reporting is done if necessary. Regular reviews and training ensure policies remain effective and aligned with legal requirements. Feedback from reports helps improve processes and create a safe environment for raising concerns.

Unwanted Behaviour Complaint Procedure

If contact with their manager, the manager’s superior, the HR Business Partner, the vitality specialist or the confidential advisor does not lead to a solution, the employee can file a complaint with the Unwanted Behaviour Complaints Committee. The Committee includes a lawyer from Bezemer and Schubad, a representative from the Investigations department, a compliance advisor and an HR representative acting as the Committee’s secretary. This policy is evaluated every three years, and earlier when required. The policy describes:

• A complaint can be filed after the Employee’s attempt to resolve the issue with the (higher) manager, HR business partner, the vitality specialist or confidential advisor of the employee have failed.

• The Committee investigates the incidents mentioned in the complaint and any directly related incidents that come to light during the investigation. The Committee does not independently uncover other irregularities or investigate whether other individuals are guilty of misconduct.

• The employee may be assisted during the procedure, for example, by the confidential advisor. Any costs are the responsibility of the employee.

• Filing a complaint should not negatively affect the employee's position within a.s.r., nor that of anyone assisting the employee.

• All information shared during the procedure is confidential. The Committee informs all parties of this at the start and, if necessary, during the complaint process. The privacy of those involved is protected as much as possible.

The complaints procedure is concluded with an aftercare conversation with the complainant (and possibly the accused) and the involved supervisor. The committee evaluates each procedure and evolves the procedures when possible.

Whistleblower Policy

a.s.r. believes it is important for employees to report (suspected) misconduct within a.s.r. in a careful, confidential and safe manner. Therefore, a.s.r. has established a procedure: If an employee cannot or does not want to report (suspected) misconduct to their manager or via other channels (see section 6.4.1.3 ‘reporting incidents’), the Whistleblower Policy can be used. Every report, whether anonymous or not, is investigated. a.s.r. will not take or allow any action against anyone who reports suspicions of abuse or irregularities. A suspicion of abuse or irregularities may be reported both internally and externally.

Reports under this scheme are seen as a contribution to improving the functioning of a.s.r. and a.s.r. therefore encourages employees to make reports, so that possible abuse or irregularities can be resolved. a.s.r. will therefore not disadvantage a person reporting who has reasonable grounds to believe that the reported information is correct at the time of reporting a suspicion of an abuse (internal or external) or irregularity during and after the handling of the report. If the person reporting nevertheless has the impression that adverse effects are involved, they can always discuss this with the Compliance Manager. The person reporting a suspected abuse is protected from legal proceedings under the Dutch Whistleblower Protection Act.

Accountability for policies

HR is accountable for the implementation of the various workforce-related policies, including the monitoring of the effectiveness of the policies. Compliance is accountable for the implementation of the various compliance-related policies, including the monitoring of the effectiveness of the policies.

Distribution and services entities

Avoiding Conflicts of Interest

Situations that may involve a conflict of interest between business and personal matters are avoided, as stated in the various codes of conduct. Transparency regarding potential conflicts of interest is crucial, and employees are encouraged to report these to the appropriate department. This promotes honesty and integrity in business relationships and ensures that actions are always taken in the best interest of the distribution and services entities.

Anti-Fraud Policy

The distribution and services entities have an active policy to prevent, detect, investigate, and address fraud and unethical behaviour. A zero tolerance policy is enforced regarding fraud, meaning that strict action is taken against any form of unethical conduct. This policy protects the entities and their stakeholders from financial and reputational damage.

Non-compliance and incidents

The distribution and services entities are committed to integrity and transparency. They have established whistleblower policies and incident policies to ensure concerns are reported and addressed appropriately. They can also use the channels of a.s.r.

By implementing these processes, the distribution and services entities ensure negative impacts are addressed promptly, and employees have safe channels to raise concerns. The above-mentioned policies are in line with a.s.r.'s policies.

Actions 8.18.210.110.210.3

For material IRO's with no actions set for reporting year 2024, these will be addressed and prioritised upon in the coming years as no measurable resources were available for the reporting year 2024.

Gender diversity in senior and middle management is a priority at a.s.r. To address this, the organisation has implemented the following interventions in 2024 and will continue with these in the coming years:

• Targeted training programmes: In addition to training for managers, HR professionals involved in recruitment and career advancements will also receive additional training. The goal is to equip them further with the knowledge and skills to promote the recruitment and advancement of women. The training covers inclusive communication and recognising and addressing unconscious biases. It is crucial that the diversity, equity and inclusion objective is widely supported. HR and team Sustainability oversee and report on this, but the realisation of the target lies with the entire organisation.

• Talent Committee: To promote the advancement of female talent, actions are taken at various career stages. The Talent Committee plays a crucial role in the progression to senior management. The committee provides insights into (future) top talents and succession positions at senior and higher management levels, monitors the development of these talents and ensures that they are known to senior management. The committee promotes fair opportunities and analyses female talent to encourage a more balanced leadership. Furthermore, it oversees the recruitment and selection of senior management, contributing to the achievement of target figures.

• To prevent unethical behaviour, a.s.r. implements control measures such as integrity screening for new hires and contracting parties. These measures aim to prevent physical, financial or reputational damage. a.s.r. has an internal reporting route for integrity incidents and incidents related to human rights. There is also a reporting point for reporting undesirable behaviour. 

6.3.1.3Targets and metrics

Targets

As part of the sustainability strategy, a.s.r. has established seven targets. For the other material sustainability matters, no specific targets have been formulated yet. This will be addressed in the coming years. a.s.r. remains committed to transparency and continuous improvement in line with the guidelines of CSRD. The monitoring of the effectiveness of the measures takes place through the current management reports and will be further optimised going forward.

This target is one of the strategic non-financial targets as communicated during the CMD in June 2024. Through recruitment and career progression, a.s.r. aims to create a diverse workforce that reflects society. By 2026, the ambition is as follows:

• At least 40% of top management, including senior, higher, and team management, will be women and at least 40% will be men;

• At least 40% of a.s.r.’s MB will be women and at least 40% will be men;

• At least 40% of a.s.r.’s SB will be women and at least 40% will be men.

Employee engagement is measured through the annually performed culture scan (Denison). The target for 2026 is to achieve a satisfaction of at least 85. This target is one of the strategic non-financial targets as communicated during the CMD in June 2024.

To support individuals with a vulnerable position in the labour market, a.s.r. has established the Participation Desk.

To achieve synergy benefits from the business combination of Aegon NL and a.s.r. the desired turnover rate is not lower than 10% and not higher than 16% to ensure business continuity. At a.s.r., employee development and internal mobility are prioritised to ensure ample growth opportunities. Internally filled vacancies help retain talent, reduce hiring costs, and maintain cultural fit. Employees can access vacancies for a.s.r. on the internal jobboard. This approach boosts morale, retains institutional knowledge, supports succession planning, and strengthens organisational resilience.

Metrics

Characteristics of the undertaking’s employees

See section 6.5.4.1 for CSRD reporting policies.

See section 6.5.4.1 for CSRD reporting policies.

Collective bargaining coverage and social dialogue

See section 6.5.4.2 for CSRD reporting policies.

79% of a.s.r.'s workforce is covered by CLAs. The workforce of D&S Holding and Robidus is not covered by the CLA but is covered by social dialogue. Corins' workforce is not covered by the CLA or social dialogue of a.s.r.

Diversity metrics

See section 6.5.4.3 for CSRD reporting policies.

Adequate wages

At a.s.r., all employees earn an adequate wage. This is ensured through a.s.r.'s remuneration policy, which aligns with the median level of the reference group.

See section 6.5.4.4 for CSRD reporting policies.

Social protection

a.s.r. is committed to ensuring the well-being and social protection of its workforce. a.s.r.'s policies are designed to providing comprehensive support, fostering a healthy work-life balance and promoting sustainable employability. a.s.r. is committed to social insurance, which is mandatory and covers all employees.

See section 6.5.4.6 for CSRD reporting policies.

See section 6.5.4.7 for CSRD reporting policies.

See section 6.5.4.7 for CSRD reporting policies.

See section 6.5.4.8 for CSRD reporting policies.

• ¹ Rate: number of cases per one million hours worked.

See section 6.5.4.8 for CSRD reporting policies.

See section 6.5.4.8 for CSRD reporting policies.

See section 6.5.4.9 for CSRD reporting policies.

a.s.r. understands the importance of a healthy work-life balance. Therefore, all employees are entitled to take family-related leave. The higher percentage of female employees who took family-related leave reflects the general division of family-related leave in the Netherlands.

Remuneration metrics

• ¹ Unadjusted.

The gender pay gap shows the difference in total compensation between genders. The pay gap disclosed under S1-16 is absolute and is not adjusted for compensation-related factors, such as seniority and performance. The unadjusted gender pay gap in scope of HR, excluding Corins, D&S Holding and Robidus, amounts to 18.0%.

See section 6.3.1.2 for more information on gender equality, equal pay and the adjusted gender pay gap and section 6.5.4.10 for CSRD reporting policies on the unadjusted gender pay gap.

For more information on how the remuneration ratio was derived, see section 6.5.4.10.

Incidents, complaints and severe human rights impacts

Four complaints have been registered against a.s.r. The estimation model attributed one complaint to D&S Holding. The four complaints filed against a.s.r. through the designated channels are handled as described in section 6.3.1.2.

See section 6.5.4.11 for CSRD reporting policies.

See section 6.5.4.11 for CSRD reporting policies.