ESRS 2 General Information

The EU Corporate Sustainability Reporting Directive (CSRD) was adopted by the European Commission (EC) in 2023 but has not yet been transposed into Dutch law. The CSRD revises and extends the requirements of the European Union's (EU) Non-Financial Reporting Directive (NFRD). As a large public interest entity, FMO is in scope of the NFRD and is, therefore, among the first wave of companies required to implement the CSRD. By implementing the CSRD, FMO covers all aspects required by the NFRD that are still applicable to FMO under the current situation. Companies subject to the CSRD have to report according to the European Sustainability Reporting Standards (ESRS).

This is the second year that FMO is publishing a report aligned with the ESRS. For this year’s report, we have applied the ‘quick fix’ amendments to the first set of ESRS, which were published on July 11, 2025, and aim to reduce complexity and reporting burden.28 However, the regulatory landscape may evolve further, particularly in light of the Omnibus packages submitted to the European Parliament on February 26, 2025. These packages aim to simplify EU requirements for businesses. We will continue to closely monitor these developments and assess their implications for FMO going forward.

In its Integrated Annual Report, FMO continues to disclose information in line with other regulations such as the Dutch Corporate Governance Code. For this reporting year, FMO will opt out from detailed reporting in accordance with the EU Taxonomy, making use of the relief option provided under the Omnibus proposal, which allows financial institutions to omit detailed taxonomy disclosures, provided they include a statement in their management report clarifying that they do not claim their activities are associated with environmentally sustainable activities under the EU Taxonomy Regulation. For further information, refer to the 'EU Taxonomy' section in E1 Climate Change.

Our sustainability reporting approach

We remain committed to monitoring regulatory developments and implementing requirements in line with the CSRD and other relevant frameworks, drawing lessons along the way, and we aim to revise the report’s structure and content in the coming years, with a focus on improving clarity and conciseness.

The 'Sustainability statement' consists of four sections:

1. General information ('ESRS 2 General information').

2. Environmental information ('E1 Climate change', 'E3 Water and marine resources', 'E4 Biodiversity and ecosystems').

3. Social information ('S1 Own workforce', 'S2 Workers in the value chain', 'S3 Affected communities', 'S4 Consumers and end-users').

4. Governance information ('G1 – Business conduct').

The double materiality assessment (DMA), explained in 'ESRS 2 Double materiality assessment', helped us identify FMO's material impacts, risks and opportunities, which then determined the material topic-specific ESRS standards and the underlying disclosure requirements to report on. Each section in this 'Sustainability statement' covers detailed information on FMO’s material sustainability-related matters including the relevant policies, actions, targets and metrics FMO has put in place to manage these matters.

Actions and resources

Because FMO’s mission is to enable entrepreneurs to increase inclusive and sustainable prosperity, FMO manages sustainability-related impacts, risks and opportunities (IRO) as an integral part of its core activities and functions. There are dedicated departments and teams that focus specifically on sustainability to maximize positive impact and minimize negative impact. To manage sustainability‑related matters, the OpEx involved reflects the expenditures of the departments and teams responsible for these activities. For an organization with a mission like FMO’s, it is neither feasible nor meaningful to allocate OpEx to individual material sustainability‑related matters or IROs, as the work is inherently cross‑functional and integrated across the organization.

Overall, our actions are focused on growing the investment portfolio towards our Sustainable Development Goal (SDG) 10 and SDG 13 strategic objectives. In addition, we continue to take action to enhance customer environmental, social and governance (ESG) management processes and address gaps by agreeing environmental and social action plans (ESAPs) and corporate governance action plans (CGAPs). Progress on these customer-related action plans is part of our ESG target performance. Updates on the sustainability-related actions initiated in previous years are provided in the relevant sections of the topical statements.

Incorporation by reference

To avoid duplication of information, FMO has chosen to disclose certain sustainability-related information that is required under the ESRS, but which is also critical to our strategy or corporate governance, in other parts of the 2025 Integrated Annual Report. The following chapters and sub-chapters in this Integrated Annual Report are referenced throughout in the 'Sustainability statement':

1. At a glance

2. Report of the Management Board
      a. Performance against our strategy
      b. Corporate governance

3. Report of the Supervisory Board

4. Risk management

5. Consolidated financial statements

The chapter ‘At a glance’ contains a snapshot of FMO as an organization and of its annual results. The Report of the Management Board consists of several sub-chapters that are referenced in the 'Sustainability statement.’ The sub-chapter ‘Performance against our strategy’ contains detailed information on FMO’s annual results, including those related to the sustainability matters covered by the 'Sustainability statement.' The sub-chapter ‘Corporate governance’ and the chapter ‘Report of the Supervisory Board’ contain information on FMO’s overall governance structure and processes as well as the role of the Management Board and Supervisory Board in monitoring, managing and overseeing sustainability-related matters that are material to FMO. The chapter ‘Risk management’ contains information on FMO’s overall risk management approach, governance and internal control system. The chapter ‘Consolidated financial statements’ contain disclosures regarding the basis for preparation that are similar to the financial information as well as the financial effects of sustainability matters on the financial statements.

The following disclosure requirements are also addressed outside the Sustainability Statement:

• BP1 and E16: Consolidated Financial Statements.

• GOV1 and GOV3: Report of the Management Board.

• GOV1 and GOV2: Report of the Supervisory Board.

• GOV5: Risk Management chapter.

The information that has been incorporated by reference is produced using the same basis for preparation of ESRS information, including the scope of consolidation and treatment of value chain information.

For a detailed overview of the ESRS disclosure requirements that are material for FMO as well as the (sub)chapters and sections in which these are addressed and disclosures for which we have applied applicable phase-in provisions, refer to the 'Reference tables - List of material ESRS disclosure requirements'.