*CSRD (Corporate Sustainability Reporting Directive): new European Directive on reporting non-financial information that regulates the requirements for
preparing sustainability reports. As of 2024, it replaces the Non-Financial Reporting Directive (NFRD), extending the contents to be disclosed.

1. Responsible governance
2. Sustainable management of the value chain*

3. Sustainability in products
4. Sustainability in investment

5. Diversity, equality and inclusion
6. Attracting and retaining talent
7. Contribution to society and local communities

8. Environmental footprint and climate neutrality
9. Natural Capital (environmental management andbiodiversity)
10. Reporting and transparency*Suppliers, associates and customers

STRATEGIC LINEGOALACTIONSRESPONSIBLE
GOVERNANCE

Strengthensustainability
in governance1. Comply with European and national regulations regarding the presence of the under-represented sex on the GCO Board of Directors
2. Increase the percentage of women on the Atradius Management Board
3. Link a percentage of the variable remuneration of senior management exclusively to ESG goals
4. Assess the Board of Directors every three years with the support of an independent expert
5. Establish ongoing sustainability training for GCO leaders
6. Establish a governance framework that integrates sustainability at all levels of the organisation, specifying actions andaccountabilities

SUSTAINABLE MANAGEMENT
OF THE VALUE CHAIN

Pursue ethicalexcellence andcompliance

7. Develop a GCO Human Rights Policy

Improve ESG
management of thevalue chain

9. Design a Human Rights and Environmental Due Diligence system for the value chain

8. Certify GCO's management of public corporate events as 100% sustainable under ISO 20121

10. Train employees on transparency and sustainability in the marketing of products and servicesSTRATEGIC LINEGOALACTIONSSUSTAINABILITY IN
PRODUCTS

Incorporate
sustainability criteria inthe underwriting policy

11. Establish environmental commitments in underwriting

Expand the number ofsustainable solutions
offered to customers

12. Design or adapt sustainable products and services aligned with the EU Taxonomy in traditional business13. Offer new sustainable solutions in the credit insurance business

Develop sustainableclaims management

14. “Zero paper” strategy towards customers and associates
15. Implement a sustainable claims management programme

Sustainable
management offuneral services

16. Have sustainable funeral services and facilities (sustainable materials, electric fleet, etc.)

Continue to promotea sustainability
strategy in property
management

17. Manage properties according to sustainability best practices

Increase the percentage
of annual sustainable
investment

18. Define a progressive increase in the sustainable investment goal, taking into account criteria such as margins, rating,diversification, etc. included in the investment policy.

SUSTAINABILITY IN
INVESTMENTSTRATEGIC LINETARGET AUDIENCEACTIONS

DIVERSITY, EQUALITY AND
INCLUSION

Increase diversity andequality in teams

19. Develop GCO's Diversity and Equality Policy
20. Reduce the pay gap for all levels of the organisation
21. Comply with the Pay Transparency Directive
22. Increase the presence of women in middle management and senior management

ATTRACTING AND
RETAINING TALENT

Focus on new ways ofworking

23. Evolve the teleworking model in traditional businesses
24. Improve the dissemination of social benefits for employees
25. Extend the annual performance appraisal to all employees
26. Offer continuous training that contributes to efficient use of technology and scheduling and for team unity

Create a comprehensive andconsistent healthprogramme across countries

27. Align the promotion of healthy habits among businesses and develop new initiatives to promote health care

Increase social contribution

28. Establish a common programme of social action and contribution to local communities among the different GCO
businesses

CONTRIBUTION TO SOCIETY
AND LOCAL COMMUNITIES

29. Annually increase the budget for social action projects of the Fundación Occident

STRATEGIC LINEGOAL

ACTIONSENVIRONMENTAL
FOOTPRINT AND CLIMATENEUTRALITY

Expand the reportedscope 3 emission
categories

30. Calculate emissions associated with employee commuting (commuting - category 7)

31. Calculate the emissions associated with business travel by car (category 6)
32. Calculate emissions associated with GCO's investment portfolio (category 15)
33. Calculate emissions associated with GCO's underwriting portfolio (category 15)

Increase electricity consumption
from clean energy

34. Achieve 100% of Spain and Portugal's electricity consumption from clean energy

Be more efficient in the energy
consumption of the facilities

36. Reduce energy consumption through the installation of solar panels and the use of efficient lighting

Reduce paper consumption

37. Reduce paper consumption linked to printing services

Reduce CO2 emissions

38. Define progressive, science-based decarbonisation goals for the underwriting portfolio to achieve carbon neutrality by2050

35. Achieve 50% renewable energy in the remaining major countries

39. Define emission reduction goals for the investment portfolio and operations

NATURAL CAPITAL(environmentalmanagement andbiodiversity)

Identify GCO's contribution tothe goals of theEnvironmental Taxonomy

40. Analyse GCO's investment and underwriting portfolios to determine the percentage of eligibility and alignment with
Taxonomy goals

Extend the scope of GCO'senvironmental management
system

41. Develop, implement and review environmental management systems for buildings throughout the GCO structure

Follow the recommendations ofthe Taskforce on Nature related
Financial Disclosures (TNFD)

42. Implement the disclosure framework on biodiversity risks and opportunities (TNFD recommendations)

STRATEGIC LINEGOAL

ACTIONSREPORTING AND
TRANSPARENCYInternal Control of NonFinancial Information

43. Implement a comprehensive system of internal control for non-financial information, for its collection, analysis, control andreporting

Continuous improvement in
the accessibility ofsustainability content

44. Make sustainability content available on GCO's public channels in line with stakeholder needs

All the actions and goals of theMaster Plan have specific people incharge of promoting and monitoring
them.

In
addition,
there
arerepresentatives in each of GCO'sbusinesses (traditional insurance,credit insurance and funeralbusiness) that enable greater
coordination in the implementationof the Plan's actions.

The
Sustainability
Committee
monitors the Sustainability Master
Plan and periodically assesses
compliance with it. For this, it ismade up of the heads of thedifferent areas of the Group, whorepresent the stakeholders, andmeets at least twice a year.

The Audit Committee
isresponsible, among other aspects,for supervising the Sustainability
Master Plan, as well as theeffectiveness of the control and risk
management systems associatedwith it.

The Board of Directors defines theGroup's ESG strategy and isultimately responsible for theSustainability Master Plan. The
Audit Committee reports to it
periodically to ensure that theGroup's practices in relation to theMaster Plan are in line with thestrategy approved by the Board ofDirectors.

Located within the Finance - Risk Division, the area is responsible for promoting and guiding compliance with the Sustainability Master Plan and theagreements adopted by the Sustainability Committee, supporting the responsible areas so they can achieve their actions and goals.