DELA Group takes its responsibility for a sustainable future seriously. We want to be clear and open about what we do. So in this sustainability report, we present what steps DELA is taking and how we are working on sustainability.

Even though the Corporate Sustainability Reporting Directive (CSRD) is not mandatory for DELA in the year under review, we report according to those rules as much as possible in order to stay transparent and be well prepared in this area. Although we have prepared this report with due care, it has not been reviewed by an independent auditor. As part of the audit of the financial statements, however, the auditor engaged with us to determine DELA's status on preparing to publish a CSRD-compliant report starting in financial year 2027.

A key component of the European Sustainability Reporting Standards (ESRS) is the double materiality assessment, which identifies material sustainability matters across three areas – environmental, social, and governance (ESG) – that are relevant to our business, value chain, and stakeholders. This process involves assessing the potential impact of our activities on the environment and people, the risks that sustainability-related matters pose to us, and the opportunities that sustainability initiatives can create.

In accordance with the materiality assessment, we report on the following topics:

• General disclosures
• Climate change
• Sustainable resource use
• Personal services
• Privacy
• Good employment practices
• Business conduct 

Financial and sustainability reports both follow the same governance framework. The audit committee oversees the financial and sustainability reporting process. The risks, internal controls and their operational effectiveness are also assessed in the risk committee. These responsibilities are clearly outlined in the regulations of both committees, which have been approved by the Supervisory Board.

We provide services that include prepaid funeral insurance and savings-linked insurance in the Netherlands, funeral endowment insurance in all three countries, and term life insurance in the Netherlands and Germany. These policies ensure a diverse offering that meets various cultural and financial preferences. The premiums received are invested to minimise inflationary price rises for our policyholders. We work with providers of products and services in the upstream insurance value chain, such as IT and facility services, and with asset managers.

We also provide comprehensive funeral services in the Netherlands and Belgium. We assist bereaved families in arranging a funeral regardless of whether the deceased was insured with DELA or another provider – or not insured at all. In the upstream value chain, we work with service providers such as funeral transportation companies and facility services, as well as suppliers of coffins, workwear, and cremators.

There have been no significant changes in the products and/or services offered in the reporting period. More details about our business model can be found in the report of the Executive Board.

Our overall sustainability objective is to amplify positive impacts, reduce negative impacts, make the most of sustainability-related opportunities, and manage sustainability-related risks. Our strategy explicitly considers DELA's impact on customers and employees. During the past year, we outlined a new strategic course for 2026-2030 that incorporates sustainability.

The table below presents the parts of DELA's strategy related to sustainability topics, with a focus on key current and future challenges and the main solutions or projects initiated within the framework of sustainability.

As an important building block for us as an organisation, stakeholder engagement is structurally embedded in our way of working. In 2025, we further refined our stakeholder dialogues to put what we learn from them to better and more consistent use in our strategic choices and in achieving our long-term goals. We distinguish between proactive dialogue about topics that are important for our strategic course and the regular dialogue that runs via departments and employees in their daily contact with stakeholders.

The following table outlines how we engage in dialogue with stakeholders.

Proactive dialogue is fleshed out systematically in close consultation with functional officers and based on the input from the stakeholders themselves. This takes account of aspects such as topic, timing, and way of working to shape this dialogue as carefully and efficiently as possible.

In 2025, we used e.g. the input from the materiality assessment, feedback from suppliers, and regular dialogue to refine our strategic priorities and sustainability approach. Interviews with members of the cooperative panel, the sessions of the general meeting, and dialogue with suppliers were important sources in this process. In our regular dialogue with suppliers, we aim to address matters such as climate change and our joint optimisation of the provision of personal services to customers.

The Executive Board, Management Board, and Supervisory Board regularly obtain information about stakeholder interests and expectations. They receive information about customer feedback, the materiality assessment, supplier evaluations, and from what is discussed at times such as the general meeting and in the cooperative panel.

Every year, we review whether the outcomes of the double materiality assessment are still fit for purpose. In 2025, we therefore included the following in the assessment:

• An analysis of the material topics of similar companies
• Input received from stakeholders
• Organisational changes, i.e. the new strategic course and the acquisition of DFW Group B.V.

In 2025, we also defined a policy that sets out the frequency and the process behind the double materiality assessment and who shoulders which tasks and responsibilities.

We have incorporated the interests of key stakeholders, such as suppliers, employees, policyholders, visitors, and the environment, into the materiality assessment. DELA thoroughly weighs the interests of all these stakeholders. As part of the double materiality assessment, the Supervisory Board, Executive Board, and Management Boards have been informed about the stakeholders identified and their sustainability-related impacts. The views of employees (via works councils) and members (via the general meeting and confidential committee) are shared with the Executive Board.

For the materiality assessment, we go through the following process:

Step 1: Identification of stakeholders
Our internal project group of experts analysed the stakeholders. The conclusion was that members, customers, employees, suppliers, and the environment are the most affected stakeholders. This remained unchanged in 2025.

Step 2: Value creation and insight into value chains: insurance and funeral services
The value chains have been mapped out for both core activities, with key actors identified upstream and downstream.

Because of the acquisition in 2025 of DFW Group B.V., a company that operates in a different sector, i.e. the production and maintenance of crematorium equipment, a separate value chain was defined. When analysing the sustainability topics of this value chain, no additional material topics, impacts, risks or opportunities were identified. Consequently, we provide no further information about this value chain in the sustainability report.

Step 3: Preparation of long-list of possible material topics
We start the materiality assessment with a long-list of topics taken from the standard topics in ESRS, material topics of peers, literature and interviews with internal specialists and stakeholders. The review for 2025 produced no additional topics.

Step 4: Assessment of possible materiality of the long-list
We assessed the list of topics from step 3 with the aid of internal experts, additional testing, and analytical reviews of potential material positive/negative impacts, risks and/or opportunities. A separate analysis was conducted to assess the potential material impacts of our investment portfolio.

Step 5: Definition of impacts, risks, and opportunities
We specifically described the potential impacts, risks, and opportunities for the topics identified as material during Step 4. Internal expertise and input from stakeholder dialogues were used for this purpose.

Step 6: Prioritisation of material topics
We assessed the materiality of each impact, risk, and opportunity using internal expertise and input from stakeholder dialogues (see the 'notes to prioritisation' for the methodology).

To determine the material impacts of an investment portfolio, insurers generally assess whether they have an above-average concentration of investments in a particular country or sector with a material (often negative) impact. These assessments are mainly performed by internal professionals and external experts. The availability of quantitative data on ESG aspects – apart from carbon data – is still limited. Our investment portfolio is very well diversified with respect to risk distribution and rates of return. Based on this diversification, we conclude that our investments have a material impact only in relation to the topic of climate change.
The results of the regular ORSA were used to determine the likelihood and magnitude of the sustainability-related risk in the investment portfolio. The ORSA is used to evaluate whether our strategy can withstand the effects of sustainability-related risks in the investment portfolio.

Risk specialists assessed whether financial and non-financial risks identified in our risk management system needed to be added and whether material impacts would lead to additional sustainability-related risks. This did not result in any additional material sustainability-related risks.

Ultimately, we identified 14 material impacts, risks, and opportunities, which were grouped into six material topics.

Step 7: Stakeholder consultation
We discussed the identified material topics and related impacts, risks, and opportunities with different stakeholder groups as well. The first was our customers, represented by the confidential committee and members of the general meeting. Earlier, we had asked the general meeting in a survey to assess the possible material topics and to put forward any topics that were lacking. We also discussed these topics in a dialogue session with the confidential committee. In 2025, we subsequently discussed the sustainability report for 2024 at the general meeting.

The second group consisted of our employees, represented by the works councils in the Netherlands and Belgium. In 2024, we validated the potential sustainability topics with them as well. In 2025, we discussed the sustainability report with the Dutch works council, and material sustainability topics were discussed by both works councils during their regular meetings with the Executive Board and Management Board.

In 2025, we started thinking with some of our suppliers about topics that affect both of us, such as climate change and sustainable resource use. We will follow up on that in the coming year. This is an addition to the regular times that we are in contact with our suppliers.

We incorporated the information that we obtained in steps 3 to 6 of the double materiality assessment.

Step 8: Approval and finalisation
The double materiality assessment and the identified impacts, risks, and opportunities were approved again by the Executive Board at the end of 2025.

Climate change: DELA has a negative environmental impact due to its carbon emissions and those of our chain partners. The high use of energy in our funeral business also has a negative impact. Carbon emissions contribute to global warming. In addition, we have a negative impact via investments that have a negative environmental impact related to carbon emissions. The only material sustainability-related risk is the risk of a decline in value of our investment portfolio due to climate change. The Risk Management section presents how this risk, as part of market risk, relates to DELA's other risk categories.

Sustainable use of resources: DELA uses products and raw materials for its insurance business and the provision of funerals. The use of raw materials and waste generation have a negative environmental impact. Important resources in our provision of services are coffins, paper, funeral flowers, and workwear.

Personal services: We have a positive impact on the well-being of our customers. We seek to provide support before, during and after a person's decease and for quality of life in the broadest sense: physical, social and emotional, of people and their loved ones.

Privacy: Any failure to properly protect our customers' personal data could have a negative impact on their well-being.

Good employment practices: We have a positive impact on the well-being of our employees by offering good terms and conditions of employment. That said, working in the funeral services sector can have potential negative impacts such as disrupting the work-life balance, performing mentally and physically demanding work and being confronted with aggressive behaviour.
In addition, we have a potential negative impact on the well-being of current and potential permanent employees due to insufficient focus on diversity and inclusion.

Business conduct: We have a positive impact on our stakeholders via our corporate culture.

DELA is involved in material impacts through our own activities, the procurement of services and products from suppliers (upstream), via intermediaries (downstream), and the other funeral providers who use our locations and services (downstream).

Our business model is aligned with the interests of members, policyholders, and bereaved families. We can increase our positive impact and reduce the negative impact without having to adjust our business model. Since we are not making significant changes to our strategy or business model, we expect all material effects to occur in the short, medium, and long term.

The impacts and risks are concentrated in the value chain as follows, including the stakeholders affected:

Various policy documents support the management of sustainability-related impacts, risks, and opportunities. Unless stated otherwise, this policy is not aligned with internationally recognised frameworks such as the UN Guiding Principles on Business and Human Rights (UNGPs), the International Labour Organization Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises.

The long-term targets, including those for sustainability topics, have been included in the strategic course for 2026-2030. Each year, the Executive Board prepares a letter specifying the proposed frameworks for the upcoming year. Then the Management Boards prepare annual plans in which they describe in detail which targets they will pursue and which activities they will undertake. These annual plans are based in part on input from the management teams, which can, for instance, indicate the resources and support needed to meet the targets. Internal experts provide support. This results in a cohesive and goal-oriented plan that provides direction for the entire company.

The finalised annual plans, including the targets and projects for the upcoming year, are discussed annually with a representative body of employees known in the Netherlands and Belgium as works councils. Since we do not have a works council in Germany, the annual plans are shared and discussed with all employees. Additionally, DELA Group's annual plan is shared with the members of the general meeting.

Monitoring and controlling different sustainability topics takes place via regular, periodical disclosures at business unit and group level. In addition, the Management Boards receives regular monthly updates on key insights from customers and employees via reports on NPS, eNPS, and absenteeism. Progress on the actions from the climate transition plan is reported every quarter. These reports are intended for the Management, Executive, and Supervisory Boards. Departments report monthly and quarterly to the Management Boards. The Management Boards submit monthly and quarterly reports to the Executive Board, which then reports to the Supervisory Board. In the coming year, management information on the progress of the transition plan for sustainable resource use and the action plan for diversity will be included.

Furthermore, the regular ORSA shows whether the current strategy can withstand the impact of sustainability-related risks in the investment portfolio. An ad-hoc ORSA is conducted to reassess these risks in the case of trigger events such as major acquisitions.

The Supervisory Board has three roles: the role of providing oversight, the role of an adviser, and the role of an employer for the members of the Executive Board under the Articles of Association. The Supervisory Board ensures that customer-centric values and interests are central to the business strategy and oversees the effectiveness of internal risk management and control systems, including those related to business conduct. The topics of good employment practices and business conduct are specifically discussed in the Supervisory Board's remuneration and appointments committee. The external sustainability reporting is discussed in the Supervisory Board's audit committee.
The Executive Board is jointly responsible for the strategy, structure, and outcomes, including those of the sustainability topics. It also provides adequate safeguards for business conduct and integrity. It is accountable to the Supervisory Board and the general meeting for the performance of its tasks. Policy for all of DELA Group is approved by the Executive Board. An officer is designated within the Executive Board for all material topics.
The Management Boards along with the Executive Board conduct DELA's day-to-day management, implement and realise the business strategy, manage the material impacts, risks, and opportunities, strengthen our ability to innovate, and improve our customer focus. A Management Board approves policy that falls within its authority and which applies solely to the relevant business unit. One or more officers are designated within the Management Boards for all material impacts, risks, and opportunities.

When appointing members to the Supervisory Board, Executive Board and Management Boards, we ensure a balanced mix of knowledge, experience, education, and perspectives. This in turn enables decisions to be made that take into account a range of viewpoints. The Executive Board consists of two group directors whose positions are named in the Articles of Association and three group directors (with one position still vacant) who are not specifically named therein. DELA does not have independent directors. Our Executive Board is 50 per cent female and 50 per cent male, meeting the diversity standard of at least 30 per cent for both women and men. Employees are represented in the management body by the HR director. The Supervisory Board currently includes two officers who represent members. The general meeting has regional representation to ensure that local insights and interests are included in our decision-making.

The Executive Board has broad experience in the financial sector and in-depth knowledge of relevant laws and regulations, including in the area of business conduct. Our competence and suitability policy is based on the Suitability Policy Rule set by the Dutch central bank (DNB) in 2012. We also assess the suitability of individuals in key leadership positions under Solvency II regulations, including risk management roles, the actuarial department, and the internal audit function.

In general, the Management, Executive, and Supervisory Boards maintain their expertise levels through continuous education, covering topics such as cybersecurity, General Data Protection Regulation (GDPR), ethics, and risk management. In addition, an annual review is made of the performance of the Executive Board and Supervisory Board, the retirement and reappointment of Supervisory Board members, and the application of the recruitment and selection policy for new appointments. Knowledge and expertise in the area of sustainability, particularly environmental topics, is strengthened via training and knowledge-sharing from external and internal experts.

The Management Boards, the Executive Board, and the Supervisory Board and their committees took additional action on various sustainability topics in 2025. The double materiality assessment and responsibility for sustainability were emphasised again in the sustainability report. In addition, they worked on broadening and following up on the transition plan for climate change, and they defined a transition plan for sustainable resource use as well as policy and an action plan for diversity, equity, and inclusion. The remuneration policy and the results of the employee experience surveys were carefully discussed, just as were the results of the customer satisfaction surveys. They also focused on addressing sustainability-related risks and refining the socially responsible investment policy.

Performances in relation to sustainability (including carbon reductions) are not linked to variable remuneration at DELA except at DELA Belgium, where a variable remuneration system is in place. Up to 10.5 per cent of the fixed salary may be awarded as variable remuneration based on meeting specific targets, such as a minimum customer satisfaction score (NPS), which is considered sustainability-related performance. DELA Belgium's works council is involved in setting the annual variable remuneration objectives (CLA 90). Members of DELA's Executive Board and Supervisory Board do not receive any variable remuneration.

See the 'Strong and clear governance' section in the report of the Executive Board for more information about our governance.

Our procurement and outsourcing policy currently governs our relationships with and selection of suppliers. Due diligence checks are carried out for all new partnerships to identify potential abuses, corruption or non-payment of suppliers further down the supply chain. Existing contracts are continuously monitored, primarily focusing on payment behaviour and compliance with sanctions legislation.

Our corporate social responsibility (CSR) procurement code has a broad scope and requires suppliers – including subcontractors – to adhere to its principles. Suppliers must commit to socially responsible business practices, specifically regarding labour law and human rights, as outlined in the Universal Declaration of Human Rights of the United Nations.
They are also expected to respect the environment and comply with all applicable national and supranational environmental laws and regulations. In addition, we expect suppliers to comply with all applicable national and supranational competition laws and regulations. We inform new suppliers about our CSR procurement code during the selection procedure. This code is publicly available on our website. We should point out, however, that local contracts concluded in the past that are still running today may vary.
In addition, supplier and contract management is an integral part of our procurement function and processes. Contract managers and buyers perform this on a constant basis in addition to due diligence and compliance with our CSR procurement code.

1. Carbon emissions from own operations
Carbon emissions contribute to global warming. To assess DELA's impact on climate change, we have identified our annual carbon emissions, including those from both the upstream and downstream value chain. Based on this analysis, we estimate that there is currently a negative impact which occurs on a global scale and is difficult to remedy. Assessment shows that there are no other pressures within our activities or value chains that create a significant climate impact.

The carbon emissions from our own operations stem from the likes of crematoriums, offices, funeral locations, and transport. In addition, the upstream value chain – such as the supply of products and services or commercial transport – also contributes to carbon emissions. The majority of our carbon emissions are concentrated within the funeral services chain. This is due to the energy-intensive cremation process and the products and services associated with funerals. Our carbon emissions are a direct consequence of our core activities.

2. High energy consumption from own operations
Energy consumption has a significant impact on the environment as it places pressure on the total availability of finite energy resources, both fossil and renewable. Moreover, the use of fossil energy results in carbon emissions.

DELA currently has a negative environmental impact due to energy consumption within its own operations. This includes crematoriums, office and funeral locations, and company-owned vehicles. According to the European Energy Efficiency Directive, we are classified as a major energy consumer. Most of this impact is related to the funeral services chain, more specifically to the funeral locations and the cremation process.

3. Carbon emissions from investments
Our investment portfolio has a net emission of carbon dioxide, which has a negative impact on people and the environment. Based on our assessment, we estimate that there is currently a negative impact which occurs on a global scale and is difficult to remedy.

4. Risk of a decline in value of the investment portfolio
The value of our investment portfolio may grow at a slower rate or even decline due to climate change, which represents a transition risk. This sustainability-related risk is an explicit part of the existing market risk and system risk that we already control within our investment portfolio. This risk has been assessed in the resilience analysis.

In 2025, we conducted a sensitivity analysis, calculating the impact of a 15 per cent investment loss due to climate change. The investment loss has an impact on the premium development for our policyholders. The results confirm that our solvency remains just above the regulatory threshold, which is consistent with previous analyses. An early full recalculation is therefore unnecessary.

We have set the following carbon reduction targets.

The carbon emissions from our own operations (Scopes 1 and 2) are an absolute target, measured as a percentage of the emissions in the base year. We are aiming for net zero in 2050, with maximum 10 per cent compensation. This target concerns 100 per cent of the emissions in Scopes 1 and 2, which stem from carbon dioxide and refrigerants (HFCs). DELA aims for an absolute reduction of carbon emissions irrespective of any core activity growth. We estimate that the current target with associated actions will also provide sufficient progress in renewable and other energy. This is why specific targets for reducing energy usage or expanding renewable energy have not been set at this time.

For the carbon emissions in the value chain (Scope 3), we have set a target for Scope 3.15 investments only, which covers 98 per cent of our emissions in Scope 3. This is the intensity target, measured as the reduction of carbon emissions per million of assets invested, which allows us to account for the Scope 1 and 2 emissions of the companies in which we invest.

We take 2021 as the reference year for our own operations. This decision is based on the availability of group-level measurement data from 2021 onwards. The carbon emissions in 2021 provide a realistic reflection of our organisational size following the acquisition of Yarden. Furthermore, operations were less affected by the COVID pandemic compared with 2020.
Our targets are based on market-based carbon emissions. We take 2019 as the reference year for the investments (Scope 3.15). The reason is that 2019 is widely accepted in the financial sector as the base year. To measure the GHG emissions from our investments, we use the PCAF method (Partnership for Carbon Accounting Financials): the international standard for financial institutions. The PCAF method advises us to choose the earliest year in which complete and reliable data is available. For DELA, that is 2019.

To define our climate change mitigation targets, DELA has followed the guidelines of the internationally recognised Science Based Targets initiative (SBTi). Since no sector-specific benchmark is available, we have taken the SBTi economy-wide scenario as our reference. SBTi requires a linear annual reduction of 4.2 per cent for Scope 1 and 2 carbon emissions in the first five to ten years. This target is considered 'scientifically grounded' as it is aligned with the goal of limiting global warming to 1.5°C, in accordance with the Paris Agreement. Our targets comply with this guideline as DELA aims for an annual linear reduction of 5.6 per cent. The targets have not been submitted to SBTi for testing. At present, we find following their guidance sufficient.

In the climate transition plan, we distinguish between short / medium term and the long term. Each year, we prepare a detailed schedule for the main actions over the next five years: the short and medium term. For the long term, a less detailed plan has been prepared, which does, however, show that all actions will be ready by 2050. Progress on the actions is monitored every quarter. The plan and actions are revised annually and extended by an extra year so that we always keep a five-year horizon of detailed plans.

More information is provided below for the elaboration of the climate transition plan, first for our own operations and then for investment.

All actions were implemented in 2025, with the exception of the purchase of green electricity for our office in Liege. The reason for this is that the lessor was not willing to change the energy contract. Some extra savings were also achieved in addition to the aforementioned actions. In the Netherlands, seven locations were sold and two gas-fired cremators were replaced with an electric cremator. In Belgium, somewhat fewer locations were sold than foreseen. At the same time, the renovation of buildings led to more savings than expected. In addition, an extra saving was achieved for the cars in Belgium on top of the plan because the purchase of the electricity used to charge the electric vehicles was demonstrably sustainable (with a Guarantee of Origin), which means it does not have any carbon emissions. Together, these developments led to an additional reduction of carbon emissions by some 200 metric tonnes in comparison with the planned actions.

The following actions are planned for the period 2027 to 2030:

In the coming five years, €58.6 million is expected to be invested on balance for the renovation of locations. These costs fall under the investment expenses item in the financial statements because our own property (head offices, crematoriums and funeral centres) is seen as an investment. Operating expenses for locations are expected to decrease due to lower energy consumption. An extra investment of €2.7 million has been budgeted for the electrification of the fleet of vehicles. The investments are fully funded from DELA's own cash flow.

About ten internal experts and contract managers were involved in achieving these climate change goals.

The use of fossil energy decreased by 3,865 MWh in 2025 compared with 2024, representing an 8 per cent reduction. Total energy consumption also decreased by 8 per cent to 56,617 MWh. In 2025, we registered a 9 per cent decrease in the use of natural gas; this is in line with the transition that we initiated to reduce the use of fossil fuels and to aim for electrification.

The emissions in Scopes 1 and 2 were 10 per cent lower than last year and 42 per cent lower in comparison with the base year. This shows that DELA is making good progress on achieving the reduction targets for the medium term.

The emission intensity of the investments in 2025 was 81.7 metric tonnes of carbon dioxide per million euros of assets invested. The carbon intensity of the shares, real estate, and agriculture and forestry categories is relatively low. This is a result of the actions mentioned before. The carbon intensity of the infrastructure category is still relatively high at this time. Virtually all funds in which we invest within this category have a net-zero commitment and are actively engaged in decarbonising their portfolio companies. We are therefore confident that the current downward trend will continue in the years to come.

The table below shows the development of the emission intensity.

The environmental impacts have been assessed based on three aspects. Firstly, we looked at the types of products we use, consume or offer in our services and whether these products could cause significant negative environmental impact. We then identified the volume of material resource flows as an important indicator of negative environmental impact. Finally, we considered the interests of our stakeholders. In this analysis, we consulted internal experts and an external party with specific knowledge of the wood and paper industry, the clothing industry, and flower cultivation outside the EU.

We are involved in the material impacts through our suppliers who manufacture the products used in our services and handle our waste processing.

Our material resource flows are coffins, paper, funeral flowers, workwear, and waste. Based on our expenditures and an estimate of the weight of the resource inflows, we concluded that coffins and paper are substantial and, from this perspective, have the greatest negative impact on the environment. Funeral flowers are also important to our stakeholders. According to the National Survey on Death in October 2025, 32 per cent of respondents expect sustainable options for their farewell ceremony. Of all respondents, 27 per cent find sustainability important for their own farewell ceremony, and 11 per cent call a sustainable approach an important aspect of a fitting farewell. By responding to this expectation, we can encourage customers to make more sustainable choices and influence consumer behaviour on a broader scale. In addition, we aim to make the workwear worn by our funeral service employees more sustainable. For resource outflows related to waste, we assessed the total volume of waste generated and the extent to which waste is separated.

We also assessed financial materiality by considering the substitutability of the products we use and consume. Our conclusion is that there are sufficient alternatives to mitigate the risk of reduced supply or higher prices.

In 2025, we revised our formulation of the target for coffins to make this goal simpler and clearer. DELA aims to reduce the environmental impact of coffins on a structural basis. Our guiding principle is that the wood used must be FSC or PEFC certified. These certificates ensure that the wood comes from responsibly managed forests, with an emphasis on ecology, social circumstances and economic continuity.
In addition to certified wood, we also actively research innovative and more sustainable alternatives. At present, we take these alternatives to mean coffins made of secondary wood with sustainable types of glue and coffins based on mycelium – a biodegradable material that grows from threads of fungus. These resources offer a smaller environmental footprint and meet the requirement of bereaved families to make conscious choices.
DELA has tasked itself with having at least 30 per cent of all coffins be made from sustainable alternatives in 2030. This percentage is ambitious but feasible; it will contribute to our broader sustainability goal.

For paper, we aim for a 35 per cent reduction in the use of paper in 2030 in comparison with 2025. The absolute target that we set in 2024 has been changed to a relative target with the same goal. Strategies to achieve this reduction in paper are aimed at the digitalisation of communications with customers and members, the reduction of paper use by using lighter paper and the digitalisation of other paper flows. Since our analysis of the use of paper in 2025 proved to be incomplete, we have now added the necessary data. We measure progress as a percentage reduction in comparison with base year 2025.

For workwear, we focus on the development of a sound end-of-life programme for the current line of clothing. The aim is to use the clothing that has been produced for us as long as possible and to encourage its high-grade reuse. This also means that we will use up the existing supply of clothing before we turn to new clothing with a different, more sustainable composition. We are working up to source textile for workwear as sustainably as possible. This target has been revised in comparison with 2025 because a target of 100 per cent sustainable textile seems impossible within the bounds of comfort of wear. In this respect, we take account of not only the type of material but especially its origin and certification. Textile is seen as sustainable if it demonstrably meets the criteria of a recognised sustainability certificate, such as the Global Recycled Standard. In this respect, we do not distinguish between new resources of sustainable origin and secondary resources, i.e. recycled resources. We measure our progress based on weight: the proportion of sustainable textile is calculated as a percentage of the total weight of the textile purchased. This method provides transparency and an objective basis for monitoring and disclosure.

We have not yet set a specific target for funeral flowers. In 2025, we focused on the further development of our plans for the other resource flows. As the first step to working towards a target, in 2026 we want to understand the positive and negative impact of funeral flowers on people and the environment. We recognise that funeral flowers have great ritual, emotional, and cultural value in the Netherlands and Belgium for saying farewell. Flowers play an important symbolic role in expressing compassion, respect, and remembrance; they contribute to a meaningful funeral experience for bereaved families. This deeply rooted ritual function is an essential aspect of the considerations that we make. Sustainability strategies must therefore not only be environmentally effective, but they must also do justice to this social and emotional value.

Our aim to reduce residual waste in the Netherlands is focused on increasing waste separation to promote recycling. We calculate the percentage based on the total amount of non-hazardous waste that is not collected separately. The target is a maximum of 50 per cent residual waste. We collect hazardous waste (such as medical waste from the final care of the deceased and fly ash from crematorium filtration systems) that is separated in accordance with applicable laws and regulations. These waste streams are therefore excluded from the target to separate more waste. We have not yet set a target for waste for Belgium due to the lack of aggregated data. Since the collection of data on waste for all locations in Belgium has been established since November 2025, we expect to be able to set a goal for residual waste in Belgium in mid-2026. We are not setting a target for Germany because the amount of waste there is very limited.

In the funeral services chain, we can only apply the principles of the circular economy to a limited extent because few recyclable products are involved in this line of business. We primarily focus on the procurement of sustainable resources. The principles of the circular economy reflected in our set targets are as follows:

• For coffins, we prefer secondary resources such as ecoboard (provided it is produced with sustainable glue) over primary resources (such as FSC or equivalently certified wood).
• For paper, we prefer to use secondary resources (recycled FSC paper).
• For workwear, we are developing a robust end-of-life programme.
• Waste management is aimed at increasing waste separation to promote recycling.

To make DELA's use of resources more sustainable and to meet our targets, we take three main actions:

1. Less resource use, such as lighter paper, or digitalisation
2. More sustainable resource use, such as recycled FSC paper
3. Encouraging decision-makers towards less or more sustainable resource use, such as customers who opt for digital communication

Because we are still learning about sustainable resource use, we have further developed the plan for actions in the short term (2025 and 2026) and set the course for the medium term (2027 to 2030).

About 30 employees, mostly contract managers and internal experts, are involved in achieving our goals for sustainable resource use.

In 2025, we were engaged in fine-tuning the targets and preparing our transition plan. As it will take some time for the actions taken in this area to produce visible improvements, the results for 2025 are virtually the same as for 2024.

Waste diverted from disposal is waste that is given a new purpose, such as plastic that is melted down to create new products and paper that is recycled. This also includes waste used to generate energy through incineration. Waste directed to disposal is waste that is no longer given a new purpose, such as fly ash from filtration systems.

In Belgium and the Netherlands, we separate the following waste streams for recycling:

• Regular waste that we separate at different office and funeral locations. This separated waste is collected and processed by our suppliers. This includes confidential documents, plastic, drink cartons, glass, swill, and batteries.
• In the Netherlands, we send precious and other metals that remain in the cremation ashes (e.g. protheses) to Stichting Orthometals, which provides the metal recycling for crematoriums.

In 2025, there was a decrease in the total amount of waste in comparison with 2024. The main reason for this is that a better way to measure this metric was established for waste collection in Belgium.

The results for the waste target set for 2030:

The percentage of residual waste in the Netherlands decreased in comparison with 2024, which means that in 2025 we moved one step closer to reaching the target for 2030.

In our double materiality assessment, we identified two material impacts on the topic of customers:

1. Personal services: Positive impact on the well-being of customers, especially policyholders and bereaved families, around a final farewell, that goes beyond financial security alone
2. Privacy: Potential negative impacts should we fail to protect the personal data of our customers

All customers who are impacted by our activities are included within the scope of our report.

In addition, we also conduct more formal discussions, such as through our general meeting. The members of the general meeting contribute ideas on DELA's overall policy and current and future services. This approach ensures that changes to our business model, strategy, policy, or services do not lead to significant negative impacts on our customers. The board secretary organises the general meeting on behalf of the Executive Board and Supervisory Board, communicates the outcomes of the general meeting, and initiates follow-up actions within the organisation.

We also conduct research as part of our dialogue with customers. The online cooperative panel regularly seeks our members' views on current topics and regularly conducts research on industry-related topics.
In 2025, we surveyed the Belgian members panel about the new DELA Nalatenschapzorgplan estate insurance to obtain their view on the clarity of the product, its difference from the existing Uitvaartzorgplan funeral insurance, and its core message. They were given information about the death benefit that bereaved families receive and the support for arranging the estate, followed by questions about their interpretation, preferred means of communication, short texts, photos, and colour combinations. The aim was to determine which tone, visual style and message resonates the best so that DELA can launch the product in a clear, attractive, and appropriate manner. Members' interest in this product was gauged as well. More than 500 members said they would like to be contacted once the product becomes available.

In addition, DELA has an independent market research agency conduct the National Survey on Death. This annual survey covers trends in how people in the Netherlands deal with and make choices about their own death, the loss of loved ones and support for bereaved families. People in the Netherlands do not want to burden their next of kin, but they often have yet to make any funeral arrangements. Less than half of them have made funeral arrangements and shared that information with others. One third has also not made any provisions for the costs. As a result, bereaved families often have to make important decisions on their own in an emotional period, such as the location, music, and arrangements of the farewell. Most people want a small-scale and personal farewell with room for sharing memories and arranging things as they see fit. They want clear information and professional support in organising the funeral.
Sustainability also plays an important role in funeral arrangements. Fifty-three per cent expect there to be sustainable options, especially in the choices regarding the body, coffin, flowers, and catering. People find it important to have environmentally friendly alternatives and for those to be clearly presented in the services offered. What is certain, however, is that cremation is still preferred.

These stakeholder dialogues provide valuable information, and we use the results to further optimise our operations, products and services.

For insurance products, we apply the product approval and review procedure to both the development of new products and adjustments to existing products. We set clear acceptance criteria, such as customer interests and financial contribution. We also regularly evaluate our products. The product development criteria (cost-efficient, useful, safe, and comprehensible) of the Dutch Authority for the Financial Markets (AFM) serve as a guiding principle for our insurance products in the Netherlands and Germany. Our funeral insurance in Belgium complies with the guidelines of the work programmes of the Financial Services and Markets Authority (FSMA).

Our funeral locations operate in a clear and consistent manner while considering local customs and preferences. We use protocols and manuals to ensure compliance with applicable laws and regulations, such as the Dutch Burial and Cremation Act. We conduct our funerals in the Netherlands according to the Keurmerk Uitvaartzorg (Funeral Services Quality Mark), which stands for quality of service in the funeral industry. In addition, we apply the Greenleave principles for customers who wish to incorporate more sustainable elements into their funeral arrangements.
We regularly update the funeral protocols and manuals. For instance, in 2025 we redefined our minimum quality standards in Belgium for e.g. ceremonies, collecting the deceased and the final care of the deceased.
We also monitor compliance with our protocols and manuals. In 2025, about 200 mystery calls and 200 mystery visits were made in Belgium in order to monitor and further improve the quality of our service.

While the needs of our customers are important to us, we also consider the interests of other stakeholders when defining our policy. There is demand for laying out the embalmed deceased. In 2025, we therefore set up eight locations in the Netherlands where the decreased can be laid out after embalming and where the safety of employees and bereaved families is paramount. At these locations, we comply with all legal requirements, use special measuring equipment and work with special work instructions and personal protective equipment. We have opted for a regional spread, at locations where demand is the greatest.

Our employees implement our policy on personal services on a daily basis. Our integrity policy for employees explicitly outlines how to address issues such as discrimination, health, and safety. This policy focuses on our employees and how they interact with each other as well as with our customers, bereaved families, and guests.

The Executive Board is the highest echelon of responsibility within the organisation for the policy on personal services. The Management Boards of the business units and the management teams are responsible for developing and implementing the policy within their specific area of focus.

We see the Net Promoter Score (NPS) as an important indicator of our customers' well-being and the extent to which impacts are experienced. It is a widely used metric that reflects how likely customers are to recommend our products and services to others. We measure customer satisfaction among policyholders and bereaved families.

Like any organisation, we strive for a high customer satisfaction and review that target annually as part of the business planning cycle. The Management Boards propose these targets in their annual plans. The Executive Board then sets the targets and the Supervisory Board approves them. We inform the general meeting about this annually via the presentation of the business plan.

The Executive Board and the Supervisory Board are informed about the NPS results on a monthly and quarterly basis through internal reports. The Management Boards and the Executive Board review these results monthly and compare them with the annual objectives. During these discussions, they critically assess progress and make the necessary adjustments to ensure the organisation remains on track to achieve its targets.

We are optimising our current products and services and developing new ones. This enables us to continually improve our service for customers in all sectors and countries where we operate, based in part on the input that we receive during the year from customers, the general meeting, and the cooperative panel. This involves discussing results, input, and potential improvement actions at team and departmental meetings.

In the funeral business in the Netherlands, the chain processes have been improved so we can provide customers with even better service. The online environment for bereaved families has also been improved. As a result, the online environment provides an overview of appointments that have been made and of relevant information so bereaved families are not dependent on fragmented communications. Bereaved families can use this environment to prepare themselves before discussing things with the funeral provider, which gives peace of mind and clarity.
In addition, the schedules have been adapted to seasonal patterns in order to reduce waiting times. This has made the availability of funeral providers throughout the country easier to follow so bereaved families can be served more quickly.

For our business customers (funeral directors), meetings are regularly organised at our locations in the Netherlands to inform them about the services we offer, catering, and relevant topics for the sector. In addition, these businesses receive the necessary support so they can focus fully on the direct bereaved families for whom they provide the funeral. As DELA, we consequently survey their needs for our services and support to see how we can improve our service. This has led to an extra farewell concept where the family can choose to say farewell informally in a living room setting or in the brasserie.

When things go wrong, we actively offer a sympathetic ear and look for solutions. In the Netherlands, customers can find the complaints procedure for complaints and comments on our website and in the policy conditions. Special customer feedback coordinators ensure that complaints, compliments and comments are reported and addressed. In Belgium, complaints are handled according to the guidelines set by Assuralia (the professional association of insurance companies). Customers can file complaints by email or on the website. In Germany, the complaints procedure is documented in the 'Operations Manual', ensuring compliance with the Insurance Supervision Act and European Insurance Distribution Directive. Customers can file complaints on the website or by phone.

Complaint handlers aim to resolve complaints to the satisfaction of the complainant. Customers dissatisfied with the solution can contact our own disputes committee in the Netherlands. This committee consists of four dedicated members of the cooperative and provides binding advice to the Executive Board. In 2025, DELA established an independent disputes committee in Belgium as well for customers who remain dissatisfied after an internal complaints procedure. The committee consists of five Belgian members from the cooperative and one independent chair. This is a free and low-threshold way to handle disputes; it creates transparency, customer centricity, and trust within the cooperative. Its full operation and rules are described on our website. Bereaved families can also contact the Funeral Industry Ombudsman. Dissatisfied policyholders can approach the Institute for Financial Disputes in the Netherlands or the Ombudsman in Belgium. We have not explicitly evaluated whether customers are aware of the complaints procedures.

Our whistleblower policy states that whistleblowers and employees supporting them must not be disadvantaged whether during or after reporting an abuse or disclosing a suspected abuse.

Our handling of complaints is not only focused on resolving specific issues for customers on an ad hoc basis. We also strive to translate their comments into structural adjustments to our working methods to proactively prevent problems. We therefore define actions with clear ownership to address recurring issues and report complaints internally on a quarterly basis through customer feedback reports.

Our commitment to privacy protection is not only a legal requirement but also a fundamental value for maintaining strong relationships with customers. We understand that our customers' trust depends, among other things, on the careful and safe handling of their personal information. Cyberattacks, such as phishing, ransomware, attacks via third parties and insiders, are a permanent and substantial threat. Ransomware attacks are often accompanied by data theft, which can harm both us and our customers.

The identified potential negative impact concerns our customers, such as members, policyholders, and bereaved families given that their personal data is saved in our systems. All customers who are impacted by our activities are included within the scope of our report. For customers within the insurance chain in particular, we manage certain sensitive data such as Citizen Service Numbers (BSN)/National Register Numbers (RN) for reporting purposes and behavioural and medical data for insurance purposes. We also manage the personal data of potential, current, and former employees as well as the employees of our suppliers and partners. While the potential impact on these groups has not been deemed material, we manage this impact as well with the stated policies and actions.

We are committed to maintaining adequate standards of privacy protection, following such guidelines as issued by the Dutch Data Protection Authority, the Dutch central bank, EIOPA, the General Data Protection Regulation (GDPR), and the ISO/IEC 27001 standard, which also applies to our IT suppliers. Our data protection policy is primarily aligned with the GDPR, the leading European legislation. Laws and regulations serve the interests of all stakeholders. Although there has been no specific dialogue with stakeholders regarding privacy policies, policy changes resulting from evolving laws and regulations may be discussed with members at a general meeting.

The Executive Board is responsible for implementing these policies. We provide a comprehensive general privacy statement and a specific privacy statement for employees and suppliers.

We follow a procedure to address every data breach appropriately. Employees are encouraged to report all data breaches so we can handle them quickly and effectively and learn how to prevent future breaches. Once a report is received, we determine whether the data breach needs to be reported to the relevant authorities (Autoriteit Persoonsgegevens in the Netherlands, Gegevensbeschermingsautoriteit in Belgium and Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen in Germany) and/or to the data subjects. We perform a required risk assessment to determine the risk profile of the data breach. We report data breaches to the authorities within the required period if there is a risk to the data subjects, and directly to the data subjects themselves if the risk is high.
In the case of incidents and data breaches at processors or sub-processors, the processor reports the incident to the relevant contact person at DELA and our data protection officer. This process is laid down in the contract provisions of the processing agreement. DELA then decides whether to notify the authorities and/or the data subjects.

We reported seven data breaches to the authorities in 2025. We informed customers about 23 data breaches. These data subjects received information from us about the nature of the incident, possible consequences for them, improvement actions from DELA to prevent a repeat, and actions that they can take to prevent damage. There were no severe human rights violations involved in these incidents.

Our data protection officer (DPO) can be contacted regarding the processing and protection of personal data. The data protection officer is available to assist customers in the event of suspected privacy violations or incidents. Contact details are published on our website.

Any complaints about how we process personal data generally reach us via the complaints department. Specific complaints about the processing of personal data are forwarded to the data protection officer. It is then possible to submit a complaint to the authorities, as required by the GDPR. We do not evaluate whether customers are familiar with and/or trust this way of working. Our whistleblower policy states that whistleblowers and employees supporting them must not be disadvantaged during and after reporting an abuse.

We assess the lawfulness of the basis for data processing with instruments such as a data protection impact assessment and the Data Protection Control Framework. The substantive assessment involves input from a privacy officer; no processing will take place without a legitimate basis.

Addressing material negative impacts requires an integrated approach. We align product design, marketing, and sales with principles of safety, privacy, and transparency. 'Privacy by design' is a crucial principle in this approach.

In addition, we have an information security management system to monitor security risks. We also have a responsible disclosure programme for reporting vulnerabilities, are connected to relevant central cybersecurity platforms such as i-CERT and CCB and collaborate with a cybersecurity company that monitors our IT environment 24/7. This allows us to ensure data is not breached, respond quickly to incidents, and minimise potential damage.

Since data breaches are often unique, we evaluate each incident individually to determine appropriate internal controls. A consistent documentation process is used to support our learning ability. To further refine processes, the data protection officer provides feedback to the management body and data owners when patterns or recurring issues are identified. The responsible department is accountable for taking appropriate actions to prevent the recurrence of privacy violations.

No specific metrics or targets have been defined for this impact – nor do we intend to do so. Instead, we focus on preventing and responding to data breaches, minimising data collection, raising employee awareness, and monitoring security risks.

Privacy officers play an operational role and act as the daily point of contact for employees regarding data protection. They respond to operational and GDPR-related questions, investigate and handle data breach reports, assist with data protection impact assessments, and provide advice during risk assessments related to outsourcing.

We also utilise technology such as access security, encryption, and data loss prevention.

Additional figures regarding our employee demographics can be found in the sustainability report appendix. See also section 7 of the financial statements: Average number of employees.

During the past year, 587 employees (2024: 581) left DELA. That brings employee turnover in comparison with the average number of employees to 16 per cent (2024: 16). When monitoring employee turnover, we choose to exclude on-call workers because they often have a flexible and temporary employment relationship. Their turnover is less representative of the stability of our organisation as their contracts are by nature short-term and their departure more often driven by external factors. Employee turnover excluding on-call workers amounts to 362 employees (2024: 364) and comes to 12 per cent (2024: 12) in comparison with the average number of employees excluding on-call workers.

DELA also has more structured forms of engagement with employees. In the Netherlands, the works council plays a central role in employee representation. It has the right to advise on major business decisions, must approve HR policies, can propose topics, and has access to all necessary information. This approach ensures that changes to our business model, strategy, policy, or services do not lead to significant negative impacts on employees. The works council regularly engages with the CEO and other members of the Executive Board, both formally and informally. It holds six formal meetings a year and engages in ten to twelve informal meetings annually between works council representatives and the CEO. There are also two meetings a year under Section 24 of the Dutch Works Councils Act that members of the Supervisory Board also attend.

In Belgium, employee representation is divided across three bodies. The committee for prevention and protection at work focuses on employee well-being and the prevention of workplace accidents, with ten to twelve meetings per year. The works council addresses financial, economic, and social issues, also meeting ten to twelve times annually. One of these meetings is specifically dedicated to reviewing the previous year's figures, known as the EFI meeting. In addition, the trade union delegation negotiates collective labour agreements and discusses individual cases. These bodies, comprising representatives of both employees and the employer, meet monthly, and elections are held every four years to elect employee representatives.

There is currently no works council in Germany. Due to the current size of the workforce, employees are entitled to initiate the establishment of one.

In 2025, the works councils were actively involved in and provided advice about organisational changes, alteration of the social framework, alteration of the terms of employment, follow-up on the employee experience survey, and the diversity, equity, and inclusion policy. Their input helps to carefully weigh the effect for teams, processes, and development opportunities.

The secretaries of the works councils (for the Netherlands and Belgium) are responsible for organising the meetings. In principle, the group directors and the members of the Management Boards are tasked with considering the outcomes, while the works council has a review role in this process. Since there is no works council in Germany, the responsibility for initiating dialogue lies with the employees themselves, with the organisation facilitating this process.

While there was no proactive evaluation of the effectiveness of the employee dialogues mentioned in 2025, there was no indication that their effectiveness was in doubt.

For employees seeking protection against retaliation, DELA's whistleblower policy includes clear guarantees that no employee will face negative consequences for reporting an abuse. The channels for handling complaints are systematically communicated to employees during their onboarding and through regular HR publications. These channels are an integral part of DELA's organisational culture and policy, ensuring that employees feel heard and supported. This approach ensures that all employees, regardless of their role or location, have the opportunity to raise issues in a safe and confidential manner.

1. DELA's terms of employment policy offers additional benefits beyond the collective labour agreements for the insurance and funeral sectors in the Netherlands and Belgium. This policy emphasises fair pay, transparency and attractive terms of employment. In Germany, where we have no collective labour agreement, DELA has a terms of employment policy which is similar to that in the Netherlands and Belgium.

2. DELA's remuneration policy is based on the strategy, risk appetite, objectives, and long-term interests of the organisation. The remuneration policy is also competitive, ensuring that total remuneration and growth opportunities are appropriately aligned with the market (which is regularly evaluated externally), job level and personal performance.

3. DELA finds it important for everyone to keep developing themselves so that employees derive more pleasure from their work. Individual development takes place in conjunction with team development, where development needs are aimed at strengthening and achieving DELA's strategic objectives. Employees are given room for personal and professional growth by putting an emphasis on learning in daily practice, training, education, and coaching, whereby they can boost their competences, skills, job satisfaction, and motivation.

Potential employees receive (or are referred to) the key policy documents along with their employment contract. This also applies to employees with a service contract. For non-employee workers, the key policy topics are explained during their introductory programme. Managers are the primary stakeholders responsible for helping implement the policy, supported in this role by the HR departments.

The Executive Board is the highest echelon of responsibility within the organisation for the policy on good employment practices. The Supervisory Board ensures that DELA maintains a diligent, controlled, and sustainable remuneration policy that is aligned with the long-term strategy, risk appetite, objectives, and core values. The Executive Board is responsible for implementing the remuneration policy as approved by the Supervisory Board and for making proposals regarding this policy. HR departments are responsible for developing HR policy in line with the strategy, with managers being responsible for its implementation.

In 2025, we aimed for an eNPS of 39. For 2026, we aim for a continuation of the average score of 7.7 across all topics and an increase in the eNPS by 2 points to 32.

These factors can negatively impact employee well-being, potentially leading to health issues, absenteeism, or even employees leaving their job prematurely.

This is anchored in three policy documents within DELA on integrity, health and safety / prevention, and employability / attendance:

1. Integrity policy
   This emphasises the importance of safe and pleasant working conditions, where everyone feels comfortable and enjoys their work. Respectful interaction is a core principle at DELA.
2. Health and safety / prevention policy
   This policy promotes employee health and safety and reduces workplace risks. Our approach embraces the concept of positive health and personal responsibility. The policy not only contributes to reducing work-related accidents and diseases but also boosts employee satisfaction and motivation. An emphasis on healthy and safe working practices has a positive effect on motivation and productivity and also reduces absenteeism.
3. Employability / attendance policy
   The basis for this policy is our vision on employability, absenteeism, and health. At DELA, we do everything we can to create a working environment that is pleasant and enjoyable. The policy focuses on employees who are fit for work, employees who are on sick leave and those who are returning to work.

As the terms of employment policy mentioned in the previous section also has an effect on a healthy and safe working environment, it was revised in 2025 for employees in the Belgian funeral business to create a better work-life balance. One aspect that is included now is the timely announcement of work schedules.

We continuously ensure that employees are aware of the various factors that influence their health and employability. An employee's own behaviour also plays a significant role in this regard. We view health not only as the absence of sickness but also as enjoying one's work.

The responsibility for setting up workplace health and safety services rightly lies with us as the employer. We comply in this respect with the law, which requires us to be assisted by registered experts, such as company medical officers, occupational consultants, or a certified health and safety service, in our absenteeism and rehabilitation process. We apply the statutory customised approach, which is aligned with our view on employment practices. This means we offer tailored support that suits the individual situation of each employee.

In Belgium, the committee for prevention and protection at work oversees the health and safety of all employees in the workplace. The committee keeps watch over health and safety at work, oversees the well-being policy within DELA, and takes active initiatives to promote employees' well-being.

In 2025, we saw optimisation of the work schedule policy for funeral providers in the Netherlands. The Scheduling topic group has translated the existing national policy rules into five basic rules to give regions more autonomy and practical flexibility. The content of the policy has remained unchanged, but now its application is better aligned with the daily practice.
In addition, we obtained more information on the availability of funeral providers nation-wide, and work schedules are better aligned with demand. This enables us to remain adequately responsive during busy periods as well without sacrificing quality and personal attention. Employees' work-life balance has also been analysed in order to further improve the work schedule policy where necessary.

For Belgium, a Comprehensive Health and Safety Plan 2026-2031 (policy plan) is in place. Along with its associated actions, this plan has been communicated to employees and is available for reference on the intranet. Topics such as the prevention of workplace accidents, fire safety, ergonomics, and managing psychosocial work stress are included. The plan also provides for regular training and includes periodic inspections. Reports on these activities are regularly shared with the committee for prevention and protection at work.

We place great emphasis on the rehabilitation of those employees who become incapacitated for work in spite of all precautions. We focus strongly on sustainable rehabilitation programmes and the consistent application of the employability / attendance policy. This policy is aimed at actively promoting high attendance, the timely detection of and follow-up on absence, and support for employees for a speedy, responsible, and lasting return to work. This concerns integrated collaboration where the HR business partner, manager, company medical officer, and the health and safety officer are closely coordinated with one another.

To prevent workplace accidents, we use protocols and organise various training sessions focused on health, safety and well-being. Some examples are training on the correct way to carry coffins and on how to handle aggressive customers. The health and safety officer regularly visits locations to assess and advise on working conditions. An audit team also conducts regular inspections to identify risky situations and ensure that all activities comply with the applicable safety regulations. For employees at the head office, an emphasis is placed on ergonomics and preventing physical strain. We also strive to prevent workplace accidents by ensuring that all incidents, whether large or small, as well as hazardous situations, are reported through our HR system, health and safety officers, HR business partners, confidential advisers, managers, or anonymously via whistleblower software, in order to take appropriate action.

In 2025, all Belgian managers completed resilience training with a view to dealing with the pressure of work in a healthy manner and boosting their resilience. Employees were also given the opportunity to take part. The sessions provided insight into how pressure of work is experienced – aside from the actual workload – and practical tools were offered for how to deal with it.
At the same time, an emphasis was placed on promoting positive team dynamics and a supportive working culture. Resilience is seen as a shared responsibility, where both the organisation and employees play an active part.

The possible negative impact may be felt especially by employees from minority groups. However, there is no information on whether these employees actually run a higher risk of negative impact due to inadequate diversity, equity and inclusion.
In 2025, we defined policy, targets, and actions to manage this potential negative impact. This includes the involvement of a working group with interested employees in addition to several members of the Management Board, HR departments, and the works councils in the Netherlands and Belgium.

In addition, the integrity policy specifies that discrimination and intimidation are inappropriate. In Belgium, the work regulations explicitly refer to inappropriate behaviour based on age, marital status, birth, fortune, religious or philosophical conviction, political conviction, trade union affiliation, language, current or future state of health, disability, physical or genetic characteristics, social background, nationality, race, skin colour, descent, national or ethnic origin, gender, sexual orientation, gender expression, and gender identity.

At DELA, we understand that our services are often connected to significant moments in the lives of our customers. At DELA, integrity comes first in everything we do. As a service provider, employer and buyer, we are determined to act with integrity in all our activities. It is for good reason that this is one of our core values.

Our double materiality assessment has identified one material impact in this area. We have a positive impact on stakeholders through our corporate culture by influencing their well-being. When identifying and assessing our impacts in the area of business conduct, we considered our role in the insurance and funeral services value chains in all three countries where we operate.

• Safeguarding performance of integrity-sensitive roles
  Integrity-sensitive roles carry an increased risk. All members of the Management Boards and employees who fall directly under a director and who manage or are part of a management team qualify as integrity-sensitive roles. Various other roles such as actuaries, auditors, lawyers, portfolio managers, and risk managers are also considered integrity-sensitive. As a result, we place extra emphasis on integrity during the recruitment and selection of new employees and internal appointments to such positions. This approach is documented in our pre- and in-employment policy (PEIS), which includes a list of integrity-sensitive roles in accordance with the Dutch Financial Supervision Act.
• Conflicts of interest and corruption
  Conflicts of interest can undermine the integrity of our employees, posing a risk to our organisation. Sometimes, a conflicting personal interest may arise alongside a business interest, potentially (or seemingly) influencing our operations or decision-making. It is crucial that employees actively strive to prevent this, remain vigilant and deal with such situations appropriately. Doing so will prevent or minimise potential harm to the organisation and individuals involved.
• Inappropriate behaviour
  We foster a safe working environment where all employees, internal and external, feel comfortable and safe and can perform to the best of their ability. In line with our core values, we treat each other with respect. Inappropriate behaviour such as bullying, aggression, discrimination, violence, and sexual or other harassment is unacceptable. What matters is that the individual involved perceives the behaviour as inappropriate. We understand that this boundary is different for everyone and can change over time.
• Whistleblower policy
  DELA's policy on protecting whistleblowers is outlined in our whistleblower policy, which is aligned with laws and regulations. We aim to create a safe and ethical environment for all individuals who work for and with us. Nevertheless, irregularities can occur, and we encourage everyone who works or has worked for or with us to report any suspicions. The whistleblower policy states that whistleblowers and employees supporting them must not be disadvantaged whether during or after reporting an abuse or disclosing a suspected abuse. A condition for this protection is that employees must have reasonable grounds (supported by facts) to believe the information accurate at the time of the report.
• Unfair competition
  Competition is an important foundation of good business conduct and integrity. It keeps us focused on costs and our products and services, which is essential to generating customer appeal. At DELA, we run our business with respect for honest competition. Members of the Management Board and employees who fall directly under a director and who manage or are part of a management team in the Netherlands therefore fall under the Competition Compliance Regulations.
• Private investment transactions
  DELA invests in financial instruments, partly through external asset managers. Price-sensitive or other confidential market information may be present within the organisation, and this is handled with great care. The information must never be used for personal gain, and our private investment transactions regulation applies to all employees. This regulation is based on the Dutch Financial Supervision Act and underlying decrees. Compliance with this regulation is essential to manage integrity risks and protect our good reputation.

Although we do not accept any integrity-related incidents that could harm our reputation or financial position, they can sometimes occur despite all the precautionary measures. Our incidents regulation clearly outlines the steps we take in the event of an actual or suspected incident to minimise the negative impact as much as possible.

The integrity policy applies to the value chains and focuses on both our own employees and the parties we work for (customers) and with (suppliers, intermediaries and funeral directors). The works councils in the Netherlands and Belgium were consulted in developing the integrity policy, while the interests of customers are represented by e.g. the general meeting, which is also consulted on major policy changes. The integrity policy has been approved by the responsible Management Board.

We place great value on aligning ourselves with existing initiatives and standards. As a voluntary member of the Dutch Association of Insurers, we commit to complying with several codes of conduct, including the following:

• The Code of Conduct for Insurers 2018 (the Netherlands): this code of conduct covers the core values of the Dutch insurance industry.
• Competition Compliance Regulations: we follow the scheme of the Dutch Association of Insurers to safeguard fair competition.
• Code of Conduct for Handling Complaints: we have adopted the rules from this code so that complaints by customers are handled correctly and in a timely manner.

Compliance with these codes of conduct by the members of the Dutch Association of Insurers is monitored by the foundation for insurer compliance, Stichting toetsing verzekeraars.

The integrity policy is made available to various target groups. New employees receive a copy along with their employment contract, and significant emphasis is placed on this during introduction days and the onboarding programme. In addition, new Dutch policyholders receive a reference to the Code of Conduct of the Dutch Association of Insurers with their policy, which outlines our core values regarding integrity. For our Belgian policyholders, a summary of our duty of care policy is included in the 'General Duty of Care' brochure, which is easily accessible via our website and the product webpages of the Uitvaartzorgplan funeral insurance. Our general website also highlights how integrity is a core value for policyholders and suppliers. Our customer contact centre supports compliance with these standards, with employees well-informed about our policy and ready to answer questions and provide support.

Promoting a culture of integrity begins with integrating our core values into our everyday work. By embedding these into personal and team development plans and discussing them in team and department meetings, we keep the topic front of mind and ensure it resonates within the organisation. Moreover, a culture of learning and performance encourages employees to take responsibility for their own actions and hold each other accountable for behaviour that deviates from our standards. All salaried employees take an integrity oath upon joining our company. The annual employee experience surveys show how integrity is experienced and complied with within the organisation; they offer points for improvement. These are ongoing actions.

In 2025, a programme was started in Belgium that will place further emphasis on our core values (engagement, integrity and innovation, EII) internally and will continue in 2026. In this programme, we together with managers and 16 EII ambassadors will ensure step by step that our warm family culture goes hand in hand with a strong focus on results. This programme includes the introduction of a package of tools, the use of coaches during the familiarisation process for new employees, and 'Giving feedback on EII conduct' training.

In addition, we have had an ethics committee in the Netherlands since 2024. Made up of the CTO, the secretary of the board and four employees from the insurance business, funeral services, and holding company and central services, this committee is facilitated by a professor of ethics. The committee discuses ethical dilemmas put forward by the organisation. The meetings are aimed at deepening our norms and values and showing their impact. The ethics committee gives advice that contributes to ethical decision-making by the management. In 2025, it met twice to discuss matters such as centenarians in the portfolio and the bereaved families desk's telephone contact with confused callers.

In 2025, we placed an extra emphasis in the Netherlands on improving the psychological safety of employees. Several teams took an e-learning course followed up by a team session to work on this point. Good leadership also contributes to the psychological safety in teams. The scores in the employee experience survey for both leadership and social safety have improved since the previous measurement.

We also believe in the continuous development and education of our employees, including in the area of business conduct. We therefore offer a range of training programmes tailored to the needs of different roles and locations. For example, the Dutch account managers, product managers and quality managers who work for the insurer have all obtained certification related to the Financial Supervision Act. This certificate is essential for their work and enables them to advise customers competently. In the Netherlands, new colleagues at the customer contact centre and the external in-house call centre must obtain the basic certification within four months of employment to ensure they are well-prepared for their role. They also follow the 'permanent education' programme to keep their knowledge up to date. In Belgium, customer contact centre colleagues who interact with Belgian DELA intermediaries follow the FSMA 'basic knowledge' and 'general life insurance' modules.
Customer care colleagues who also have direct contact with Belgian insurance customers likewise complete these modules within two years of employment. This ensures they are well-informed and can provide customers with optimum support. Our portfolio managers and analysts pursue training for VBA or CFA certification, where acting with integrity is a central focus.

Within our funeral business in the Netherlands, funeral directors undertake training to become registered and obtain a nationally recognised diploma (NaVU). This diploma confirms their expertise and their ability to deliver high-quality services. New funeral directors must successfully complete this training within one year of joining. To keep their knowledge and skills up to date, they earn NaVU points annually as part of their permanent education programme. In Belgium, employees in the funeral sector follow a training programme at our own DELA Funerals Academy. Specific training requirements and completion timelines have been established for all roles, and participation is monitored.

In the Netherlands and Germany, those involved can report an abuse to a hotline or via our website. In Belgium, this can be done by using special whistleblower software. Reports can come from employees, volunteers, board members, service providers, suppliers, and subcontractors. An impartial officer evaluates each report and responds within seven days. If an abuse is identified, we initiate an internal or external investigation and keep the whistleblower informed. Within eight to twelve weeks of the acknowledgement of receipt, we provide information on the substantive assessment and any follow-up steps. If the report concerns the Executive Board or Management Board, the Supervisory Board clarifies the approach to be taken.

Integrity-sensitive incidents without any actual or suspected abuse can be reported to anti-fraud coordinators and contact persons. They assess and follow upon the report. The follow-up process varies depending on the nature of the incident. If necessary, we report to the relevant regulator. In the Netherlands, this way of working had already been established in the 'Handling report of suspected fraud' (Afhandeling melding vermoeden van fraude) process. In 2025, this way of working was also established for Belgium and Germany.

Employees can always approach confidential advisers or their manager for advice and support in cases of an actual or suspected abuse, integrity-sensitive incidents and other irregularities. Five confidential advisers are available in the Netherlands, including one external adviser. Eleven internal confidential advisers are available in Belgium. All of our confidential advisers have taken part in external training with specialised professionals. This provides them with the knowledge, skills, and sensitivity needed to provide employees with optimum support in confidential matters. A confidential adviser will be appointed in Germany starting in 2026; employees can seek advice from the HR manager until that time.

In addition, employees in Belgium can contact the external service for prevention and protection at work. In that case, the confidential adviser from the external service will invite the colleague to a meeting at one of their offices. Further follow-up will depend on the situation.