S1 Own Workforce

S1 Introduction

FMO will continue its commitment to further increase its impact in the coming years. In addition to the total number of employees, different skillsets will need to be developed to meet changing requirements in respect of impact & ESG themes, regulations and stakeholder expectations, as well as our strategic ambitions. FMO is actively cultivating a culture that values diversity, quality, integrity, and making a positive impact on society. We have an ambitious strategy towards 2030 and recognize the role of culture in long-term value creation. FMO is committed to fostering a work environment that prioritizes the wellbeing and development of its workforce and enabling a healthy and inspiring working environment. Equal treatment and opportunities for all are fundamental at FMO and we strive to create a workplace where everyone can thrive.

In terms of FMO’s commitment to corporate culture, we comply with the Dutch Labor Law and Collective Labor Agreement (CLA Banks) to ensure employee rights and wellbeing are fully incorporated. Comprehensive onboarding and training programs give employees an understanding of FMO’s vision, strategy, and human rights fundamentals.

FMO’s strategy integrates the interests, views, and rights of its workforce through a strong commitment to human rights, and embedded impact management framework following international standards like the United Nations Guiding Principles on Business and Human Rights (UNGPs) and OECD Guidelines to guide its human rights practices and sustainability policy with a focus on investments and customers, but also with respect to our own organization. This approach ensures that the rights, including labor rights, of people within FMO are respected and upheld.

This sustainability statement describes FMO’s guidelines, processes, actions, metrics, and targets related to employees and non-employees, enabling the readers to understand its strategy, approach, processes, procedures, and performance in this area. FMO employees are individuals with an employment contract with FMO or a regional office subsidiary, whether for a fixed term or indefinite period. This includes the regional offices in South Africa, Kenya (branches), and Costa Rica (subsidiary). Non-employees include a variety of individuals such as contractors (including self-employed persons), consultants and secondees. Third Party contractors (security, catering, and cleaning) and Interns are excluded. All FMO employees and non-employees who can be materially impacted are included under this statement.

S1 Impacts, risks and opportunities

We identified the following impacts, risks, and opportunities (IROs) during the double materiality assessment (DMA).

Table 28. IROs, Policies, Actions, and Targets

The potential negative impact referenced in the S1 pertains to isolated incidents that may affect only those FMO employees who travel to regions where the likelihood of adverse events is elevated. These employees traveling to (remotely located) projects and/or clients are those that are identified as groups of workers in particular risk of harm.  All other material risks and opportunities arising from our workforce’s impacts and dependencies pertain to the entire workforce.  Following the DMA there are no material impacts resulting from climate transition plans of FMO.

S1-1 Policies

FMO employees in the Netherlands fall under the Dutch Labor Law and the Collective Labor Agreement (CLA Banks), and FMO employees in our regional offices fall under the local labor laws. To address material sustainability-related impacts, risks and opportunities for our employees, FMO has developed several procedures and frameworks/guidelines, such as the FMO Personnel Guide, which are in line with the Dutch Labor Law and CLA Banks. In 2025 FMO formalized a policy on Diversity, Equity, Inclusion and Belonging (DEIB) in line with the diversity charter.

Our procedures focus on objectives that cultivate diversity, quality, integrity, and a positive societal impact. Furthermore, where we have caused or contributed to a negative impact on our own workforce, we have procedures in place to raise complaints or grievances. The main procedures are outlined below.

Working conditions

FMO aims to foster a workplace environment that prioritizes the health, safety and well-being of our people (including the availability of grievance procedures, investment in health and wellbeing initiatives, investing in learning and development to maintain positive working conditions). This empowers employees to reach their full potential and make meaningful contributions through their work. This includes providing career advancement opportunities, a diverse array of professional development courses and training programs, as well as access to preventive health consultations aimed at promoting a healthy and sustainable work-life balance.

Our Code of Conduct outlines the guidelines that govern our workforce. These guidelines establish the common standards of behavior we expect in our professional activities. By implementing these guidelines, we aim to develop our people’s skills, knowledge, and experience.

Health, safety and wellbeing

Preventative measures

We recognize that actively managing health and wellbeing is more effective than managing the outcomes of illness and injury. In line with the CLA Banks and the FMO Personnel Guide, procedures are set in place to ensure the health, safety and wellbeing of everyone working at FMO. Our prevention procedures include working with a healthcare provider to support FMO and employees on prevention and management of absenteeism, having first aid kits available on every floor within the office and providing preventive medical checks relevant to the work undertaken for FMO, a company emergency response team (CERT), computer glasses, and vaccination for business travel.

Emergency situations and procedures

FMO has processes in place in preparation for any emergencies such as accidents, dealing with a bomb threat, and fire evacuation processes. In addition, any issues or hazards are to be reported to facility services.

Health, sick leave and reintegration

FMO implements various strategies to support the creation of a healthy work environment and to prevent and manage absenteeism. We provide a range of physical, mental and social well-being initiatives, like home office equipment and ergonomic work stations, sports events and preventative individual psychological support, as well as multiple social events for FMO communities, teams, departments and the entire organization. Additionally, there are processes in place for supporting difficult or sensitive conversations and handling sick leave. For reintegration, FMO has established clear roles and responsibilities, along with timelines for managing illness and reintegration as outlined in the FMO sickness absence protocol. These are set up in accordance with the applicable regulations and business standards.

Purposeful work

FMO is dedicated to creating a positive impact for its workforce by aligning employee roles with our core mission. This alignment fosters a sense of purpose and fulfillment, making FMO an attractive place to work and helping to retain and attract top talent. Our Values in Action program supports this by reinforcing our mission and integrating our core values into staff behavior, cultivating a corporate culture that resonates with our people. Our mission consistently ranks highest among factors that draw individuals to FMO.

Our employees find immense meaning in their work by contributing to projects in developing countries, where they can witness firsthand the transformative impact of their efforts. This commitment extends beyond those who travel for projects, encompassing all employees who contribute to our collective goals. By providing meaningful work and a values-driven environment, we have people who remain engaged and motivated, ultimately driving the success of FMO.

Learning and development

FMO is committed to developing its workforce to enhance skills, knowledge, and expertise, which will contribute to market and product creation, as well as investments in transition technologies. The FMO Academy offers a variety of training programs on a number of personal and technical topics that enable the development of our employees in line with their ambitions and role. Additionally, development opportunities are available in the form of other activities, such as the attendance at professional conferences and secondments between FMO and other DFIs.

Travel safety

As a DFI we know that our employees may be at greater risk of harm during site visits or engagements with customers in the countries where we operate. FMO manages safety and resilience for high-risk engagements by setting a safe travel procedure for travelers to high-risk areas. This includes restricting travel to high-risk countries and areas using the color coding of the Dutch Ministry of Foreign Affairs. In addition, frequent travelers are equipped with information, tools, and training, such as a mandatory one-day travel safety training, and specific travel-related risks are covered through insurances.

Diversity, Equity, Inclusion and Belonging

Equal treatment and opportunities

FMO is committed to being a diverse and inclusive employer and is an advocate of equal opportunities. We strive for diversity at all levels of our organization and do our utmost to create an inclusive and equitable work culture for our people. This includes striving for diversity based on gender, gender identity and sexual orientation, culture (topics around ethnicity and race), and age. Our diversity and inclusion statement outlines a clear commitment to an inclusive and diverse society. In addition, FMO has signed the diversity charter of SER (the Social and Economic Council of the Netherlands) to promote the application of the principles of equal opportunities at all levels. As mentioned earlier in this section, in 2025 FMO formalized a policy on Diversity, Equity, Inclusion and Belonging (DEIB) in line with the diversity charter.

Table 29. Minimum disclosure requirements for DEIB policy

Undesirable behavior including discrimination

FMO will not tolerate discrimination, harassment, bullying or any other form of undesirable behavior. In situations where an employee experienced undesirable behavior, they can file a complaint with the external confidentiality counselor. If an employee feels they are treated differently or unfair compared to the way another employee is or would be treated in a similar situation, individuals may file a complaint that will be processed by the internal Grievance Advisory Committee.  FMO takes all complaints and grievances seriously and aims to ensure that any complaint or grievance is discussed at the earliest possible stage, so that it can be addressed at the earliest opportunity and resolved as soon as possible.  This treatment may be either direct or indirect, on the basis of the following topics: religion, ethical belief, life conviction, political affiliation, race, gender, nationality, sexual orientation, civil status, age, disability or chronic illness, and/or where an apparently neutral stipulation, benchmark or action specifically affects people of a particular religion, ethical belief, life conviction, political affiliation, race, gender, nationality, civil status, age or sexual orientation or with a disability or chronic illness.

Gender distribution and Diversity, Equity and Inclusion

FMO strives for an equal gender distribution at the organizational and department level. FMO aspires to become one of the leading organizations in the Netherlands, as well as among DFIs, when it comes to diversity, equity and inclusion. As part of this commitment, we consider gender and other diversity-related factors, like age and cultural background for all positions (including management roles) important selection criteria.

Communities within FMO

FMO has various employee communities through which employees can express themselves. These are to be included in the DEIB policy, which was approved by the Management Board and adopted by the Supervisory Board in 2025. Below is an overview of these FMO’s internal communities and networks.

BYOU is FMO's informal network supporting LGBTIQ+ rights. The objective of this network is to make a call for action to LGBTIQ+ and non-LGBTIQ+ employees to promote LGBTIQ+ inclusion at all levels within FMO, and to raise awareness and emphasize FMO's position that a violation of LGBTIQ+ rights is a violation of human rights.

FMO Femmes is an informal internal network aimed to facilitate connection, sharing, and inspiration for both women and men. The network’s focus is on empowering women through advancing career development, enhancing self-leadership, and ensuring they have the support and resources to excel. By cultivating a culture where women feel valued and recognized, FMO Femmes actively contribute to creating an environment where women thrive, positively influencing the success of our clients as well as that of FMO.

Young FMO is an informal network of FMO employees that are under the age 35. Through organizing networking, content related and just fun events both within FMO and with other financial institutions, Young FMO aims to connect young employees to as many like-minded peers as possible.

S1-2 Processes for engaging with own workers and workers’ representatives about impacts

FMO engages with its employees through the regular operational structure (bilateral meetings and team/ department/ staff meetings) and the works council which ultimately represents the full workforce. The works council frequently interacts with senior management and employees about a variety of workplace and people related topics, such as work conditions, benefits, leadership, efficiency and company culture. Employees are furthermore engaged and asked for feedback through employee engagement surveys that are run every two years. In addition, shorter interim pulse surveys are run related to various specific topics, like corporate values, leadership, and undesired behavior. The results of these surveys are used to assess the effectiveness of the engagement with employees and the Employee Net Promoter Score (see 'S1 Entity specific metrics'), and enable FMO to make informed decisions on the actions that will impact our own workforce. These surveys are managed by the HR department on behalf of the Management Board/senior management.

All managers, directors and management board members (collectively referred to as ELT: Extended Leadership Team) and therefore, ultimately the CEO - are responsible for employee engagement within the processes and progress towards the IROs. The S1 sustainability statement is governed by HR ensuring the implementation of guidelines, procedures, and action plans, as well as the monitoring of metrics and targets. FMO operates mainly in the Netherlands, therefore it has not signed the Global Framework Agreement.  FMO recognizes its responsibility to respect human rights and is committed to acting consistently with the International Bill of Human Rights; the International Labor Organization Declaration on Fundamental Principles and Rights at Work; the OECD Guidelines on Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights (UNGPs).

S1-3 Processes to remediate negative impacts and channels for own workers to raise concerns

Raising a complaint, a grievance, reporting an irregularity or a risk event

FMO has established processes for raising concerns, complaints, and grievances. These include procedures for filing complaints, grievances, and reporting irregularities or risk events. Employees can file a complaint if they experience undesired behavior such as (sexual) harassment, intimidation, bullying, or discrimination. Complaints can be raised with line management at any appropriate level or directly with internal confidential advisors. Alternatively, employees can file a complaint with an external specialized confidentiality advisor. Furthermore, if an employee feels they are being treated unfairly, they can file a formal internal grievance.

Both formal and informal procedures for submitting complaints or grievances are detailed in the Personnel Guide. FMO has an internal Grievance Advisory Committee to assist in investigations and to advise senior management on the follow-up. If a complaint is not resolved through the internal processes, employees may also file a complaint with an external specialized consultant.

To report an irregularity, FMO provides a procedure that allows our workforce and third parties to report issues anonymously. The procedures for reporting suspicions are outlined in the Speak Up Policy, which is available to employees, non-employees, and third parties. For more information, refer to the Speak Up Policy and Procedure that is available on the FMO website and is also described in 'G1 Business Conduct'.

The Director HR is responsible for ensuring the Complaints and grievances processes are reviewed periodically and communicated, and ensures training is available for managers and employees. Thereby FMO ensures that our people are aware of and trust these structures as a safe and efficient manner to raise concerns. FMO ensures protection against retaliation for all individuals using these channels, as detailed in the Personnel Guide and Speak Up policy.

S1-4 Key actions

FMO sets out clear actions to pursue positive impacts and opportunities and remedy negative impact and manage risks. These are identified and conceptualized based on internal strategy and in pursue of a positive impact on our workforce or in response to negative impacts identified through the DMA process. The key actions are outlined below. Depending on the topic, our management, HR professionals, our internal employee communities and networks as well as some temporary non-employees in projects, have been involved in the design and change and adoption management.

Employee value proposition

One of our main actions is to periodically review and, if necessary, improve the employee value proposition (EVP) for FMO’s employees, in support of our goal of being an ‘employer of choice’. This initiative aims to attract and retain employees by creating more flexibility and, where possible, aligning our offerings better with FMO’s strategic goals, ultimately achieving a positive impact on working conditions.

As follow-up activities, we are preparing for possible future changes, including a possible adjustment to our incentive program and the introduction of an annual personal budget for professional development and well-being.

The effectiveness of these types of measures is monitored and assessed based on direct feedback from employees to management, HR, and/or the Works Council (employee representation) and through periodic employee engagement surveys.

Quality of interaction (Values in Action)

FMO has implemented a Values in Action program to ensure a positive impact on the working conditions of its workforce and integrate FMO’s core values into staff behavior. This initiative, which is designed to enhance corporate culture, is further detailed in 'G1 Business Conduct' (see 'G1 Key actions').

As part of the Values in Action program, FMO has created the ‘Culture Catalyst Network’, which is an informal internal network of FMO employees who have volunteered to support the adoption of FMO’s values and behaviors in line with our Values in Action program. The Culture Catalysts, through change management help the organization to bridge the gap between aspirations and actual daily actions that reflect and embody our core values, so we can thrive as One FMO.

The effectiveness of this action is tracked and assessed by conversations between employees and management as well as during biennial engagement surveys.

HR Connect

The main objective of HR Connect is to implement an integrated Human Capital Management System (HCMS) that will improve processes and enhance our workforce’s user experience. HR Connect will help us strengthen business continuity, and enable data-driven decision-making around HR topics, including talent acquisition, ultimately creating a more efficient work environment.

Significant progress has been made in the development and the preparation for the implementation of HR Connect, with the system’s go-live planned for the first half of 2026. This milestone will mark a key step toward achieving greater integration and efficiency across HR processes.

The effectiveness of this action is tracked and assessed by reduced (manual) administration, human errors and shorter throughput times.

Diversity, equity, inclusion and belonging (DEIB) action plan

To implement the DEIB action plan in line with FMO’s D&I (diversity and inclusion) statement and the Diversity Charter in Bedrijf of SER, we will conduct regular surveys, provide training, and promote flexible work arrangements to meet legal and societal expectations. Additionally, we will support employee expression through diversity days. This initiative aims to positively impact the working conditions and overall well-being of our workforce and address the material risk of not providing sufficient working conditions and an inclusive work environment that was identified during the DMA.

Progress has been made in executing the DEIB action plan, with tangible outcomes including increased employee participation in diversity-related initiatives, continued awareness-building through training, and broader integration of inclusion principles into our HR processes.

To further strengthen transparency and accountability, outcomes are also reflected in external reporting, and summarized insights or trends from the Confidentiality Counselors are considered in internal evaluations. In addition, grievances and related cases reported through the Grievance and Advisory Committee (GAC) process are reviewed as part of our ongoing monitoring and response framework.

Mitigation of undesirable behavior and discrimination

FMO will not tolerate discrimination, harassment, bullying or any other form of undesirable behavior. In situations where an employee is treated differently from the way another employee is or would be treated in a similar situation individuals may file a complaint which will be processed with two internal confidentiality counselors.  All leaders work together to discuss this to mitigate undesirable behavior. The Management Board and HR measure progress, check data and provide guidelines.

Mitigation of the potential negative impact due to an adverse event during site visits

To minimize potential negative impacts from adverse events during site visits, FMO implements measures to identify risks before employees travel to customers or projects. FMO also prepares its employees through regular mandatory training. Employees are encouraged to avoid unnecessary risks and seek advice when needed. Before traveling, all employees must obtain an FMO emergency pass and activate the BCM app to receive and communicate necessary information. They must also register on the AIG Travel Guard website. Prior to booking a trip, employees should check non-travel destinations and gather safety information from FMO colleagues, the AIG Travel Guard website, and the Dutch Ministry of Foreign Affairs website. In the event of an adverse situation, the FMO travel crisis team, which handles crises in foreign countries, collaborates with AIG Travel Guard to mitigate any adverse effects. Employees are provided with emergency contact numbers for both AIG Travel Guard and the FMO travel crisis team.

Table 30. Minimum Disclosure Requirements for Actions