13 The company must explain its policies for managing its material impacts on Consumers and/or End-users and the associated Material risks and Opportunities.

14. the objective of this disclosure requirement is to provide an understanding of the extent to which the entity has policies in place to address the identification, assessment, management and/or improvement of material impacts specifically on Consumers and/or End-users, as well as policies that cover Material risks or opportunities related to Consumers and/or End-users.

15. the information required under paragraph 13 shall include information on the policies the company applies to manage its Material Impacts, Risks and Opportunities related to Consumers and/or End-users in line with the ESRS 2 MDR-P Approach to addressing Material Sustainability Aspects. In addition, the company indicates whether these policies cover specific groups or all Consumers and/or End-users.

16 The company describes its human rights policy commitments (123) relevant to Consumers and/or End-users, including processes and mechanisms for monitoring compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises. In its disclosures, it focuses on the aspects that are material to, and the general approach to: (124)

17. the company shall indicate whether and to what extent its policies in relation to Consumers and/or End-users are consistent with internationally recognized instruments relevant to Consumers and/or End-users, including the United Nations Guiding Principles on Business and Human Rights. The company shall also indicate the extent to which cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises involving Consumers and/or End-users in its downstream Value chain have been reported and, where applicable, the nature of such cases. (125)

AR 9. the description shall include the key information necessary for a true and fair view of the policies in relation to Consumers and/or End-users; to this end, the company shall consider whether it should provide explanations of any material changes that have been made to adopted policies during the reporting year (such as new expectations for business customers, new or additional approaches to due diligence and remediation).

AR 10 The policy may take the form of a stand-alone policy related to Consumers and/or End-users, or may be included in a broader document such as a Code of Ethics or a general sustainability policy that the company has already disclosed as part of another ESRS. In these cases, the company shall provide a specific cross-reference to indicate the aspects of the policy that meet the requirements of this disclosure requirement.

AR 11 When reporting on the compliance of its Policy with the United Nations Guiding Principles on Business and Human Rights, the company shall consider that the Guiding Principles refer to the International Bill of Human Rights, which consists of the Universal Declaration of Human Rights and its two implementing covenants, and may report on compliance with these instruments.

AR 12 In disclosing how externally focused policies are incorporated, the company may consider, for example, its internally focused sales and distribution policies and alignment with other policies related to Consumers and/or End-users. In addition, the entity considers its policy for ensuring the accuracy and usefulness of information provided to potential and actual Consumers and/or End-users, both before and after the sale.

AR 13 The company may explain the ways in which it communicates its policies to the individuals, groups of individuals or companies to whom they are relevant, either because they are expected to implement them (e.g. company employees, contractors and suppliers) or because they have a direct interest in their implementation (e.g. Own workforce/own workers, investors). It may specify means and channels of communication (e.g. flyers, newsletters, dedicated websites, social media, face-to-face interactions, Workers' representatives) to ensure that the Policy is accessible and that the different audiences understand its Impacts. The company can also explain how it identifies and removes potential barriers to dissemination, e.g. through translation into relevant languages or the use of graphical representations.

Product stewardship principles

Our Product Stewardship Principles, adopted in September 2021, provide a clear framework for responsible and compliant action by all employees. They set out guidelines for the development, marketing and provision of our products and services. We attach particular importance to fair and solution-oriented dealings with customers and equal access to financial services. Data protection, information security and protection against over-indebtedness are further key components. Compliance with these principles is monitored by managers and supporting control functions. The aim is to minimize Risks for customers and at the same time strengthen trust in our services.

Code of Conduct

Our Code of Conduct, also introduced in September 2021, formulates clear rules for ethical and compliant behavior. They cover topics such as dealing with conflicts of interest, data protection, product development and transparent communication. Training and a whistleblower system help to raise awareness among our employees.

The guideline helps to reduce Risks from potentially detrimental behavior and promotes a Corporate culture that is geared towards customer satisfaction and sustainable business success.

Principles for respecting human rights

With our principles for respecting human rights, we are committed to complying with international standards, including the ILO core labor standards and the UN Global Compact. We are committed to avoiding Discrimination, protecting personal rights and respecting human rights along the entire Value chain.

A robust reporting system enables employees to submit reports of violations securely and confidentially. Through regular reviews and targeted actions, we help to minimize Risks and promote positive effects for customer satisfaction and corporate reputation.

Common principles

All guidelines are binding for all employees and are ensured through regular monitoring and supporting processes within the organization. They provide orientation, promote trust and contribute to the sustainable further development of our company. The consideration of stakeholder interests and the integration of external standards underline our claim to responsibility and transparency.