Statement of the Sustainability policy

5.0

The Sustainability policy defines Spuerkeess’ sustainable development strategy, including our vision, commitments and action plans to achieve corporate sustainability and sustainable finance ambitions across our spheres of influence, business activities, banking activities and communities.

The sustainability policy which this statement refers to covers the following topics:

• Governance
• Missions and responsibilities
• ESG strategy
• ESG priorities
• Commitments
• Code of Conduct
• Data protection
• Fair advertising and marketing
• Diversity and inclusion
• Human resources
• Human rights
• Sustainable financing
• Supply chain
• Responsible investment portfolio
• ESG exclusions
• Whistleblowing
• Debt collection

With regard to service providers, subcontractors and external staff, the commitments are limited to a contractual obligation accepted by the latter and the controls and verifications of the Bank are limited to due diligence.

The Sustainable Development Statement highlights the importance of transparency in sustainable development policies, in particular with regard to CSRD requirements.

Spuerkeess has adopted the Global Reporting Initiative (GRI) reporting standards and is aligned with the European Sustainability Reporting Standards (ESRS) published by the European Financial Reporting Advisory Group (EFRAG) to meet European regulations and comply with the CSRD.

Generic information includes disclosure requirements of responsible business conduct and due diligence policies. In addition, it is essential to demonstrate that these policies are effectively implemented throughout the organisation, by monitoring and controlling the progress made on the commitments undertaken.

The ESG approach is integrated into the Bank’s overall strategy, in line with the Principles for Responsible Banking and the Net Zero Banking Alliance, with the aim of becoming a transition leader in Luxembourg. The Bank’s sustainable development strategy aims to integrate environmental, social and governance concerns into its actions, products and services, with a structured approach to effectively steer its efforts.

Standards and guidelines are defined centrally and implemented locally within the departments and agencies of Spuerkeess in order to ensure the consistency of all the measures undertaken.

The Strategic & Sustainability Office (SSO) team, centre of competence for all issues related to sustainable development, contributes to the proper application of the standards and strategic orientations arising from sustainable development by relying on ESG experts. In case of discrepancies between the Strategic & Sustainability Office and the concerned business line department(s), the disputed point will be escalated to the Extended Management.

• The “Sustainable Governance” and “Sustainable Products and Services” pillars are grouped under the terminology “Sustainable Finance”. “Sustainable Finance” integrates environmental, social and governance considerations into investment and financing decisions, for both internal activities and banking products and services.
• “Sustainable Staff Management” aims to make Spuerkeess an employer of choice, by promoting the transformation, adaptation and improvement of staff qualifications, as well as by promoting engagement and collaboration within the Bank.
• “Internal Sustainable Practices” involve partnering with suppliers to make supply chains transparent and consistent with sustainable development goals.
• “Social engagement” means financial education and awareness-raising programmes on sustainability issues to promote social inclusion.

The sustainable development policy, and thus the resulting statement, are reviewed at least annually or when the relevant practices and/or regulatory aspects require it.