Report - COP Prototype

2022 Communication on Progress

Mapfre

Published date

June 23, 2022

No. of questions

Supplemental files

environmental-policy.pdf Human Rights Policy diversity-and-equal-opportunities-policy.pdf promotion-selection-and-mobility-policy.pdf policy-on-health-well-being-and-prevention-of-occupational-risks.pdf Anti-corruption policy mapfre-group-corporate-security-and-privacy-policy.pdf politica-anticorrupcion-mapfre-2020-en-CE.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

MAPFRE, annually, prepares its Integrated Report in accordance with the Sustainability Reporting Standards of the Global Reporting Initiative (GRI Standards), in its comprehensive option and with the Financial Sector Supplement. As can be found on the Independent Assurance Report on the Integrated Report of MAPFRE, S.A. and subsidiaries for 2021 (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=224) "Management of the Parent (MAPFRE SA) is responsible for the preparation of the Report in accordance with the GRI Standards in its comprehensive option, in accordance with each subject area in the “Table of contents GRI” of the aforementioned Report" The table of contents GRI is complemented with other references as: the 10 Principles of the Global Compact and the SDGs. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=204) In the same manner, the table Correspondence of GRI content and non-financial information status (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=218) gathers information related to: the company’s commitment to sustainable development, its impacts on both people and the environment, likewise information on fighting corruption and bribery In accordance with legal and statutory provisions, the Board of Directors is the body in charge of managing, administering, and representing the Company. It may create within itself a Steering Committee and Delegated Committees to better perform its functions, as is the case of the Risk and Sustainability Committee (the Commitee). Functions, composition, and procedure for meetings of the commitee are available for consultation at art. 12 of the Regulations of the Board of Directors of MAPFRE SA (https://www.mapfre.com/media/regulations-of-mapfres-board-of-directors-2022-03-11.pdf)

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Human Rights Policy -> https://www.mapfre.com/media/shareholders/2021/politica-derechos-humanos-mapfre-2020-en-CE.pdf Labor Standards / Decent Work -> - Diversity and equal opportunities policy: https://www.mapfre.com/media/shareholders/2015/diversity-and-equal-opportunities-policy.pdf -Promotion, selection and mobility policy: https://www.mapfre.com/media/shareholders/2015/promotion-selection-and-mobility-policy.pdf - Policy on Health, wellness and occupational hazards: https://www.mapfre.com/media/shareholders/2015/policy-on-health-well-being-and-prevention-of-occupational-risks.pdf Environmental Policy -> https://www.mapfre.com/media/acionistas-investidores/environmental-policy.pdf Anti-corruption Policy -> https://www.mapfre.com/media/shareholders/2021/politica-anticorrupcion-mapfre-2020-en-CE.pdf

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

The code of conduct can be consulted at https://www.mapfre.com/media/sustainability/code-ethics-and-code-conduct.pdf - The application of the Code extends to employees and members of the Board of Directors, as well as suppliers and business partners "anyone who maintains a relation of close or permanent collaboration with MAPFRE and therefore subscribes or is submitted to compliance with the regulations that affect them, or that are mandatory owing to the nature or purpose of their activities" (Article 2) - The respect and safeguarding of Human Rights, as well as labor standards and decent work are included in Article 4.2 - Respect for the environment is addressed in Article 4. 4 - The fight against corruption in all its forms is covered in article 6 regarding: relations with customers (6.1), information to shareholders (6.2), relations with suppliers and partner companies (6.3), relations with competitors (6.4), relations with governments and authorities (6. 5), relations with partners (6.6), gifts and hospitality (6.7), conflicts of interest (6.8), corruption and bribery (6.9), transparency of information (6.10) and the prevention of money laundering and the financing of terrorism (6.11).

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Within the Sustainability Governance structure, MAPFRE has a Sustainability Operating Committee, under the MAPFRE Executive Committee, with the aim of providing support in matters related to sustainability, formulating the appropriate proposals in this area and supervising the correct execution of the agreements adopted in relation to it. Its functions include formulating, where appropriate, the proposal to update the Group's Sustainability Policy, adapting it to the reference standards, as well as the environmental, anti-corruption, human rights and socially responsible investment framework policies, and submitting them for approval to the corresponding governing bodies. Likewise, the bylaws of MAPFRE SA (https://www.mapfre.com/media/company-bylaws-2022-03-11-pendiente-de-inscripcion.pdf) Article 24 of the Regulations of the Board of Directors establishes the competencies of the Risk and Sustainability Committee, composed of non-executive members of the Board of Directors. Its competencies include supporting and advising the Board of Directors in defining and evaluating the Group's sustainability strategy and policy. MAPFRE's Sustainability Policy (https://www.mapfre.com/media/shareholders/2021/corporate-sustainability-policy-2021.pdf) includes: the commitment to Human Rights (5.5), the principles, commitments, objectives and action strategy in relation to the people who work at MAPFRE (6.1), the conservation and promotion of the environment (5.8) and compliance with current legislation and prevention of corruption (5.1).

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

The Sustainability Operating Committee, which reports to MAPFRE's Executive Committee, is made up of the general management or corporate areas manager of different functional areas, including, among others: people and organization, business and clients, finance and investment, external relations and communication, and safety and environment.

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

ESG risks are naturally integrated into our business processes, providing long-term solutions. The management of ESG risks and opportunities helps in decision making in areas such as underwriting, investment, innovation in products and services, which are key to generate trust among stakeholders. MAPFRE has, among others, the following internal risk prevention and evaluation systems and those derived from its activity: - Environmental, social and governance (ESG) analysis report in underwriting and investments, (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=71) - RepRisk report, to evaluate and monitor ESG risks of business conduct related, among others, to human rights, (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=157) - Internal audits, control and regulatory compliance including labor and anti-corruption standards (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=41) - The accreditation of suppliers with ESG criteria including aspects related to human rights, non-discrimination and compliance with environmental and labor regulations. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=125)

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Applying the commitments of the Sustainability Risk Integration Policy, at year-end 100% of the investment portfolio managed by MAPFRE AM is analyzed with ESG parameters, which corresponds to an investment of more than 33,932 million euros. Of the total portfolio, more than 87 % of the assets are rated with ESG criteria, of which 95 % have a high rating, above the minimum threshold established by the entity. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=72) For underwriting global risks, MAPFRE has developed an internal ESG evaluation model which, based on specialized tools, evaluates and quantifies the environmental, social and governance impact of the activity carried out by a business group, taking into account the sector and the countries where it operates. According to the established model, at the end of 2021, 94% of the global risk underwriting portfolio has been analyzed with environmental, social and governance (ESG) criteria. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=80) Within the scope of the 2019/2021 Sustainability Plan, an ESG supplier certification methodology was developed. This process includes, in addition to the assessment of the supplier's sustainability practices in the four areas analyzed, training and awareness of human rights and the 2030 Agenda. In the last three years, this model has been deployed in service providers in Spain, Brazil, the United States, Mexico and Colombia; and for support providers in Argentina, Spain, Honduras, Mexico and Paraguay. In relation to service providers, distinguished providers (Brand Ambassadors, Recommended + and Recommended) in the auto and home insurance lines have been deployed and approved in the five countries mentioned above. Overall, this selection of providers represents an average of 57.88 % of the services provided by MAPFRE in the different lines of business and a total of 66.7 % of turnover. The sustainable management of support providers is being carried out as the corporate tool is being implemented to consolidate information and standardize it. In 2021, the homologation tool was deployed in Spain, Mexico, Argentina, Argentina, Honduras and Paraguay. It is expected that, over the next two years, more territories will be included, such as the United States, Brazil and Puerto Rico, among others. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=126)

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

The application of human rights due diligence and human rights risk prevention procedures and, where applicable, measures to mitigate, manage and redress potential human rights abuses are reported in MAPFRE's corporate report (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf) both in epigraph 2.4.2. Ethical behavior: main compliance and prevention measures - human rights, and in epigraph 6.3. Note 1 - Principles of the Global Compact and MAPFRE's human rights compliance and prevention measures. These same headings report the measures implemented for the promotion of and compliance with the provisions of the ILO core conventions related to respect for freedom of association and the right to collective bargaining; the elimination of discrimination in respect of employment and occupation; the elimination of forced or compulsory labor; the effective abolition of child labor. Detailed information on the current and foreseeable effects of the company's activities on the environment and, where appropriate, on health and safety is dealt with in section 3.3.1 Risk management and chapter 5 Environmental commitments. Finally, the description and results of policies relating to the fight against corruption and bribery as well as the main risks related to these issues in connection with the Group's activities can be found in section 2.4.2. This section also includes measures adopted to prevent corruption and bribery as well as measures to combat money laundering.

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

See information provided in question G6.1.

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

MAPFRE provides all its stakeholders with access to the consultation and whistleblower channels associated with the Group’s pillars of ethical behavior. See information provided in chapter 2.4.2 ETHICAL BEHAVIOR: MAIN PREVENTION AND COMPLIANCE MEASURES at Integrated Report 2021 (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=33)

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

MAPFRE facilitates access by all its stakeholders to the consultation and whistleblowing channels associated with the Group's pillars of ethical behavior so that they can raise concerns about the company's conduct. (http://app.mapfre.com/buzones/canaldenuncias/inicio/en.html) The Code of Conduct establishes different channels of communication for ethical queries and complaints (optionally anonymous reporting), including those related to Human Rights, both for employees, executives and members of the governing bodies of the Group's entities, as well as for suppliers, contractors and other persons who maintain professional relationships with MAPFRE. In addition, the Financial and Accounting Whistleblower Channel allows Group employees, as well as directors, shareholders, suppliers, contractors and subcontractors to inform the MAPFRE S.A. Audit and Compliance Committee, confidentially and, optionally, anonymously, of any irregularities of a financial and accounting nature of potential importance that they may notice within the Company or its Group. Its operating rules are published both on the corporate intranet and on MAPFRE's corporate website.

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Among the principles of action included in MAPFRE's Code of Ethics and Conduct are behaviors associated with the four dimensions reported: - Human Rights: see section 4.2 Respect for and safeguarding of Human Rights . - Labor standards / decent work: see the following sections of the Code 4.2 Respect for and safeguarding of Human Rights (regarding the principles related more specifically to the protection of workers' rights) and 5. Standards of conduct in relations with and among employees. - Environment: see section 4.4. Respect for the environment - Anti-corruption: see section 6. Standards of conduct in relations with third parties of the Code. Section 7 of the Code sets out the mechanisms available to ensure the application as well as the supervision and control of compliance with the Code. These mechanisms include: - the ethics complaint channel accessible to all stakeholders, by electronic and postal means, to request access to remedy for adverse impacts caused by conduct contrary to the above; - the Ethics Committee, whose competencies include analyzing and resolving complaints of non-compliance with the Code of Ethics and Conduct submitted through the aforementioned channel

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

MAPFRE's Corporate Compliance Department periodically evaluates the degree of adherence and integrity of the commitments established in each of the policies in force, as an additional monitoring measure. In accordance with this measure, in 2021 the degree of compliance in the following policies was analyzed and assessed: Aptitude and Honorability Policy, Internal Audit Policy and Reinsurance Policy. The assessment was carried out in 44 entities: MAPFRE S.A. and the insurance and reinsurance entities domiciled in Spain, United States, Brazil, Germany, Italy, Mexico, Peru, Puerto Rico, Turkey, Malta, Portugal, Argentina, Chile, Colombia, and Panama. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=40) MAPFRE also has an Internal Control Policy approved by the Board of Directors. The Internal Control System consists of tasks and actions that are present in all of the organization's activities and as such is fully integrated into the Group's organizational structure. Internal control in MAPFRE involves all people, regardless of their professional level, who, as a whole, contribute to provide reasonable assurance to achieve the established objectives. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=41)

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Optional comment

Pursuant to the provisions of the MAPFRE 2022-2024 Directors' Remuneration Policy, approved by the General Shareholders' Meeting held on March 11th, the key executives of the MAPFRE Group, including the executive directors of MAPFRE, S.A., are part of an extraordinary, non-consolidated and multi-year Medium and Long-Term Incentive Plan consisting of three overlapping cycles with a three-year target measurement period each (2022-2024, 2023-2025 and 2024-2026), which will be paid partially in cash and partially through the delivery of MAPFRE, S.A. shares. The objectives of the first overlapping cycle (2022-2024) refer to (i) the relative Total Shareholder Return (TSR) (comparison between MAPFRE's TSR and the TSR of the group of companies comprising the Eurostoxx Insurance in the Plan's measurement period), (ii) the average Return on Equity (ROE), (iii) the Global Non-Life Combined Ratio (average) and (iv) objectives linked to sustainability. (https://www.mapfre.com/media/12-politica-de-remuneraciones-de-los-consejeros-2022-2024-v-final-enu.pdf) In this regard, at the 2022 General Shareholders' Meeting, held on March 11th, the Company's Chairman publicly stated in his report, once the Sustainability commitments had been broken down, that "in order to transparently show our own level of demand, as of this year, the 250 most relevant MAPFRE executives in the world have linked part of our variable remuneration to the fulfillment of these sustainability commitments". (ver https://www.mapfre.com/media/shareholders/2022/03-2022-agm-chairman-and-ceo-report.pdf)

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	14
Male (%)	64.3
Female (%)	35.7
Non-binary (%)
The Board of Directors of MAPFRE S.A. approved the Director Selection Policy on July 23, 2015, having been amended for the last time on December 21, 2020. This policy states that the selection process will promote the diversity of knowledge, experience, age and gender. (see https://www.mapfre.com/media/shareholders/2021/politica-seleccion-de-consejeros-en.pdf)
Under 30 years old (%)
The Board of Directors of MAPFRE S.A. approved the Director Selection Policy on July 23, 2015, having been amended for the last time on December 21, 2020. This policy states that the selection process will promote the diversity of knowledge, experience, age and gender. (see https://www.mapfre.com/media/shareholders/2021/politica-seleccion-de-consejeros-en.pdf)
30-50 years old (%)
The Board of Directors of MAPFRE S.A. approved the Director Selection Policy on July 23, 2015, having been amended for the last time on December 21, 2020. This policy states that the selection process will promote the diversity of knowledge, experience, age and gender. (see https://www.mapfre.com/media/shareholders/2021/politica-seleccion-de-consejeros-en.pdf)
Above 50 years old (%)	100
From minority or vulnerable groups (%)
The Board of Directors of MAPFRE S.A. approved the Director Selection Policy on July 23, 2015, having been amended for the last time on December 21, 2020. This policy states that the selection process will promote the diversity of knowledge, experience, age and gender. (see https://www.mapfre.com/media/shareholders/2021/politica-seleccion-de-consejeros-en.pdf)
Executive (%)	28.6
Independent (%)	50

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

The information reported in the questionnaire is aligned with the qualitative and quantitative information of the indicators that respond to the GRI standards (included in MAPFRE's integrated report 2021) that have been externally verified by the firm KPMG Asesores S.L., including the information provided for the activities of MAPFRE Asistencia, MAPFRE Global Risks, MAPFRE Re and MAPFRE Seguros carried out in Germany, Brazil, Colombia, Spain, USA, Italy, Mexico, Peru and Turkey, which together account for 90.29 % of the Group's business volume. In addition, a limited review of the data provided by the rest of MAPFRE's entities has been carried out.

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2021
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

The policy is available at https://www.mapfre.com/media/shareholders/2015/mapfre-group-corporate-security-and-privacy-policy.pdf

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

MAPFRE has participated in various Working Groups, including the one associated with the drafting of the document "Commitments to Privacy and Digital Ethics." To which MAPFRE adhered. Please refer to: - https://noticias.mapfre.com/mapfre-adhiere-compromisos-privacidad-etica-digital-cotec/ - NOTE 2. Cybersecurity and business continuity of Integrate Report 21 https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=161

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Additionally, in the reporting period with the aim of preventing/mitigating the risks/impacts associated with Digital security & Privacy MAPFRE has taken the following actions: - Development of different projects to adapt to the requirements that arise in the different jurisdictions. - Development of specific projects to improve the maturity of security and privacy controls implemented in the organization. - Participation in Working Groups of different associations: o Participation of MAPFRE in the COTEC Working Group - Privacy and Digital Ethics. o Participation in the Working Group associated with the Digital Transformation (Pan European Insurance Forum - PEIF). o Collaboration with Institutional Bodies Area - DIGITAL GROUP (Pan European Insurance Forum - PEIF, Insurance Europe, European Financial Services Round Table - EFR) o Participation in the Working Group - Security Breaches Guide (Data Privacy Institute - DPI of the ISMS Forum). - Different dissemination / awareness actions have been carried out: o International Data Protection Day o Differential Privacy Video o Data Privacy and Data Security Video in Dat@Cloud o PLUG & PLAY - Podcast - Cookies

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

In the last three years, a total of 18,118 hours have been allocated to training in cybersecurity and data privacy. The number of workers at MAPFRE trained, between 2019 and 2021, totals 25,778. At the close of the financial year, 68 percent of the workforce had completed training in this field. https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=43

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

MAPFRE has a Corporate Data Protection Officer (DPO) and an area specifically dedicated to ensuring the privacy and protection of personal data. Within this area and as a support to the Corporate DPO, the Corporate Office of Privacy and Data Protection (OCPPD), whose mission is to be the point of reference for all activities related to this area, providing a unique and global vision, promoting the homogeneity of all processes and criteria related to this matter. https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=164 The Group also has tools, methodologies and specialists dedicated to continuously reviewing and evaluating the company's cybersecurity level, covering all the assets and actors involved (information systems, people, etc.) and identifying deficiencies and lack of control at an early stage. https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=161

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
In compliance with the provisions of the European Data Protection Regulation (GDPR), throughout 2021, two potential incidents have been reported to the supervisory authorities of the countries in which it operates, having closed the files without any declaration of responsibility on the part of MAPFRE. It is also important to note that in 2021, as in previous years, MAPFRE has not received any sanctions for non-compliance with the GDPR by any of the supervisory authorities of the different countries where it operates. https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=44
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

In order to respond to the needs identified in terms of cybersecurity, MAPFRE has a General Control Center (CCG-CERT), integrated into the FIRST network and the CSIRT.es group, which receives alerts of global threats and attacks for the continuous monitoring (24 hours, 7 days) of both the information hosted on MAPFRE's technological platform and that of its property accessible on third-party systems. The center acts as a Global SOC allowing the early detection of possible cyber incidents and an agile response to them. MAPFRE's CCG-CERT is certified in ISO 9001, ISO 27001 and ISO 22301 standards. In terms of fostering relations with third parties in cybersecurity and privacy, in 2021, MAPFRE experts joined specialized cybersecurity groups, such as the Cybersecurity Working Group of the EFR, the Ransomware Working Group of the CRO Forum and the National Meeting of SOCs (Security Operations Centers) organized by the National Cryptologic Center in Spain. MAPFRE's privacy experts have joined specific working groups such as the Digital Transformation Working Group - GDPR of the Pan-European Insurance Forum (PEIF), the Working Group - Data Breach of the Data Privacy Institute (DPI) and have continued to collaborate in the Data Protection and Digitalization and Innovation working groups of UNESPA; as well as in the "Privacy and Digital Ethics" Working Group of COTEC. In this regard, it is also worth mentioning the work to adapt to the different regulations that are emerging in the different geographical areas where the Group is present. In 2021, the ICT governance and security guidelines of the European insurance supervisor (EIOPA) and the regulations enacted in Chile and Peru came into force, which join those already existing in other countries where we operate. For more information on Digital security / privacy, please refer to 2.4.4 CYBERSECURITY AND DATA PRIVACY in the Integrated Report 2021.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
2020
Forced labour
2020
Child labour
2020
Non-discrimination in respect of employment and occupation
2015
Occupational safety and health
2015
Working conditions (wages, working hours)
2019

Optional comment

Human Rights Policy -> https://www.mapfre.com/media/shareholders/2021/politica-derechos-humanos-mapfre-2020-en-CE.pdf Labor Standards / Decent Work -> - Diversity and equal opportunities policy: https://www.mapfre.com/media/shareholders/2015/diversity-and-equal-opportunities-policy.pdf -Promotion, selection and mobility policy: https://www.mapfre.com/media/shareholders/2015/promotion-selection-and-mobility-policy.pdf - Policy on Health, wellness and occupational hazards: https://www.mapfre.com/media/shareholders/2015/policy-on-health-well-being-and-prevention-of-occupational-risks.pdf - Mapfre Grupo Asegurador Collective Bargaining Agreement: https://www.boe.es/boe/dias/2019/04/12/pdfs/BOE-A-2019-5539.pdf

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

In terms of Human Rights, specifically with regard to; freedom of association and collective bargaining, child and forced or compulsory labor no operations or providers have been detected that could put at risk or violate the aforementioned rights. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=36) Fifty seven percent of MAPFRE's workforce is represented by legal representatives. It should be noted that countries such as Venezuela, France, Spain and Brazil have 95 to 100 percent of their workforce represented. The relationship between the company and the legal representation of the workers is managed via different channels (please refer to https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=118) MAPFRE, which has a Global Diversity and Equal Opportunity Policy in place, approved by MAPFRE’s Board of Directors on July 23, 2015, has been publicly committed to both gender diversity and disability. MAPFRE reaffirms and shores up its commitment to social inclusion of people with disabilities by signing its Global Business and Disability Network Charter with the International Labor Organization (ILO). (Please refer to https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=104 and following) MAPFRE’s Remuneration Policy includes and guarantees the principles of equality and nondiscrimination and establishes appropriate remuneration according to the role/job in relation to merit, technical knowledge, professional skills, and performance of each person. The company determines remuneration with the following principles in mind: • Transparency, since it is known by all affected parties • Competitiveness and flexibility in structure and adaptability to different groups and market circumstances (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=113) MAPFRE also adopts a prevention model through which workers may actively participate in everything that might affect their health and safety at work, for which there are legally established representation channels. A total of 28,307 employees, or 87 percent of the workforce, are represented on joint management-employee health and safety committees, which have been set up to help in monitoring and advising on this matter. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=120)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

The Human Rights policy establishes MAPFRE’s specific commitments in relation to employees, providers, business partners and customers; as well as the principles that should guide its actions on the basis of Human Rights. These commitments are reinforced by the signing of various principles and adherence to a number of United Nations-led human rights initiatives: Global Compact and the Ten Guiding Principles; Principles for Sustainable Insurance (PSI); Principles of Responsible Investment (PRI); Women’s Empowerment Principles (WEPs); and the Standards of Conduct for Business in relation to LGBTI rights. In Spain, the Group’s headquarters where it employs one third of the workforce, MAPFRE holds EFR certification (family-friendly company), granted by the Fundación Másfamilia and endorsed by the Ministry of Equality. The EFR initiative has been recognized as a Best Practice by the UN, which makes it one of the highest recognitions in the field of conciliation and equality that currently exists in this country.

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

In 2021, MAPFRE maintained its objective of extending its commitment to human rights across its value chain, including providers and intermediaries. Specifically: • 4,325 service providers have been trained on human rights, and 435 security providers were trained on this issue, which represents 89% of the total of this type of provider. • 31,496 Group employees participated in training courses on procedures related to MAPFRE’s Human Rights Policy and the ten Principles of the Global Compact. These training actions represent 81,962 hours. At the close of the financial year, 84 percent of the workforce had completed some or other of the training actions. • a new 45-minute e-learning course on the Code of Ethics was launched. During the year, a total of 15,273 hours of training in this area were carried out by a total of 20,234 employees, and by the end of the year, 60 percent of the workforce had been trained in this area. In addition, during this year 2021, “quick learning” training impacts related to this Code were also carried out through the MAPFRE People app. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=34) Additionally, one of the key factors in the healthy company model is training in health and healthy habits, and prevention of work-related risks. In this regard, in last fiscal year, MAPFRE's employees received a total of 35,944 hours of specific training. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=121)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

MAPFRE aims to ensure ethical and socially responsible behavior on the part of all service providers who serve either the Group or customers directly. Therefore, within the framework of the Sustainability Plan, MAPFRE has developed a methodology for determining ESG approval of providers. This process includes, in addition to assessing the provider’s sustainability practices, training and awareness-raising on human rights and the 2030 Agenda. An analysis is carried out through a specific questionnaire that includes the following risk factors: • Occupational health and safety of workers. • Anti-corruption practices in all its forms (including extortion, bribery and fraud to obtain competitive advantages). • Human rights: Child and forced labor, basic labor rights, etc. • Environmental practices and sanctions. • Inclusion, diversity and non-discrimination. • Information security and data privacy During the three years of the Sustainability Plan, distinguished providers (Brand Ambassadors, Recommended+ and Recommended) in the automobile and homeowners lines were deployed and approved in five of the Group’s most important countries: Spain, USA, Brazil, Mexico, and Colombia (Please refer to https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=123 and following)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	58.18

Optional comment

Given that collective bargaining is not structured in the same way in all countries, MAPFRE does not have an applicable collective bargaining agreement in several countries because the legal, social, business, or sector conditions are not in place. As a result, MAPFRE has 18,816 employees covered by collective bargaining agreements in 12 countries. However, the fifty seven percent of the workforce is represented by legal representatives. It should be noted that countries such as Venezuela, France, Spain and Brazil have 95 to 100 percent of their workforce represented. https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=118

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)

Optional comment

No employee unionization data collected to ensure non-discrimination

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	31.3
Non-executive board	33.33

Optional comment

MAPFRE had publicly committed to ensuring that by the end of 2021, at least 45 percent of annual vacancies in managerial positions were filled by women. At the close of the stated period, the relevant percentage was 49.1 percent. MAPFRE’s commitment to gender equality is unconditional and will continue to evolve in line with the objectives established more than three years ago: more than 40 percent of women in job positions of responsibility, more than 30 percent of management positions occupied by women and more than 45 percent of annual vacancies for positions of responsibility to be filled by women. https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=104

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	2.54

Optional comment

The overall adjusted gap of the group, considering 99 percent of the workforce (excluding Banco do Brasil and MAPFRE Salud Ars) is shown in the accompanying table at page 116 of the integrated report 2021. In addition, at pages 182-190 MAPFRE provides a breakdown of the average fixed remunerations by country, job level and gender, giving the salary ratio for each of them.

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	23.53

Optional comment

ACCIDENT FREQUENCY RATE (AFR): represents the number of lost-time accidents per million hours worked. In 2020 we worked to homogenize the accident rate data at a global level, scrupulously adhering to what is indicated in GRI 403. MAPFRE reports the data related to frequency and incidence rates segmented by sex on page 122 of its integrated report. The formulas used to calculate these rates can be found on page 149.

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	569.7

Optional comment

INDICATION OF WORK ACCIDENT RATE (TIAT): represents the number of occupational accidents with sick leave per 100,000 workers. In 2020 we worked to homogenize accident rate data at a global level, scrupulously adhering to what is indicated in GRI 403. MAPFRE reports data related to frequency and severity rates segmented by sex on page 122 of its integrated report. The formulas used to calculate these rates can be found on page 149.

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
MAPFRE provides all its stakeholders with access to the query and whistleblower channels associated with the Group’s pillars of ethical behavior. No complaints of freedom of association and the effective recognition of the right to collective bargaining were received in 2021.(https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=36)
Forced labour
MAPFRE provides all its stakeholders with access to the query and whistleblower channels associated with the Group’s pillars of ethical behavior. No complaints of forced labour were received in 2021.(https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=36)
Child labour
MAPFRE provides all its stakeholders with access to the query and whistleblower channels associated with the Group’s pillars of ethical behavior. No complaints of Child Labour were received in 2021. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=36)
Non-discrimination in respect of employment and occupation
MAPFRE provides all its stakeholders with access to the query and whistleblower channels associated with the Group’s pillars of ethical behavior. No complaints of discrimination were received in 2021. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=40)
Occupational safety and health
MAPFRE provides all its stakeholders with access to the query and whistleblower channels associated with the Group’s pillars of ethical behavior. No complaints of occupational safety and health were received in 2021.(https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=36)
Working conditions (wages, working hours)
MAPFRE provides all its stakeholders with access to the query and whistleblower channels associated with the Group’s pillars of ethical behavior. No complaints of working conditions were received in 2021.(https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=36)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Throughout the People and Organization report (https://www.mapfre.com/media/talento/people-organization-2021.pdf) we detail the progress made, as well as the fulfillment of the commitments acquired for the year 2021. MAPFRE maintains a permanent and direct dialogue with employees, reporting information on all relevant aspects, listening to their opinions and requesting their active participation through different channels, such as the workers' legal representation. On the other hand, the workers' legal representation communicates with employees through specific e-mail accounts or spaces on the intranet, visits to work centers and spaces for meetings or assemblies that the company facilitates for communication and dialogue with employees. The Integrated Report (pages 119-120) includes the main collective bargaining agreements reached with the legal representation of workers, in 2021, which are related to the topics indicated. Likewise, 100 % of the suppliers participating in the homologation process have been sensitized and trained in human rights (through contents developed by the Spanish Global Compact Network) and in the United Nations 2030 Agenda. Among others, 74 training programs have been developed for workers on health and safety at work (general training in this area and specific training on occupational hazards, hazardous activities or dangerous situations) and there has been a total of 19,672 completed enrollments by 13,046 employees in these programs. In addition, seven programs on prevention and anti-harassment procedures have been developed and there have been 600 completed enrollments in these programs by 599 employees The year 2022 marks the beginning of a new three-year strategy focused on organizational change management, which addresses three major challenges: to continue working on the transformation and development of capabilities to ensure the maximum employability of MAPFRE employees; to provide the company with the organizational flexibility and agility it needs; and the commitment to and promotion of transformational leadership.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2021 https://www.mapfre.com/media/acionistas-investidores/environmental-policy.pdf
Water
2021
Oceans
Forests / Biodiversity / Land Use
2021 https://www.mapfre.com/media/acionistas-investidores/environmental-policy.pdf
Air Pollution
2021 https://www.mapfre.com/media/acionistas-investidores/environmental-policy.pdf
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021 https://www.mapfre.com/media/acionistas-investidores/environmental-policy.pdf
Energy & Resource Use
2021

Optional comment

MAPFRE, aiming to be an active part of this necessary and urgent transformation toward a low-carbon economy, defines its strategy to combat climate change through the Corporate Environmental Footprint Plan 2021-2030, which gives continuity to the previous Energy Efficiency and Climate Change Plan 2014-2020, on this occasion incorporates other decisive environmental variables in the adaptation and mitigation processes. The MAPFRE S.A. Board of Directors also approved, in September 2021, a new update of the Group Environmental Policy in which key aspects such as Green Procurement are included and the Circular Economy (via the zero waste initiative) and natural capital are introduced into the Integrated Management System, corporate environmental management model, SIGMAYEc3 (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=137)

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

MAPFRE is working on adapting financial planning to climate change, both from a risk and opportunity approach (Goal 13.2). Chapter 5 Committed to the environment describes the levers for its transformation into a low-carbon company and its performance. (See 6.3 Note 12 Environmental Indicators at the Integrate Report 2021.) Given the nature of the insurance business, MAPFRE contributes to reinforcing resilience and the ability to adapt to climate risks and climate-related natural catastrophes (Goal 13.1). Information related to eligible economic activities of the Taxonomy can be consulted in section 3.3.2.2. Integration of ESG aspects in MAPFRE's underwriting processes. (Integrate Report 2021) As an expert in hedging risks, MAPFRE works to improve education, awareness and individual institutional capacities in relation to climate change adaptation, mitigation and early warning systems (Goal 13.3). It does so, not only directly through participation in the Spanish Green Growth Group, in events such as Green Weekend held in Spain or in the CONAMA (National Environment Congress) working groups, but also by promoting environmental products and services. (See Note 12 in Section 6.3. at Integrate Report 2021)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

The soundness of MAPFRE's corporate environmental management model, based on continuous improvement and the principle of risk prevention and precaution, has facilitated the Group in homogeneously expanding the environmental principles undertaken by the company. SIGMAYEc3, initiated in its environmental aspect (ISO 14001), currently integrates energy management (ISO 50001), the carbon footprint inventory (ISO 14064), the circular economy through zero waste (AENOR Regulation) and natural capital. Its transversal design also ensures success in achieving the defined objectives, in that it incorporates all areas with responsibility for the different areas it comprises. All actions in this area are verified annually by accredited third parties following the most relevant reference standards. The progress made under SIGMAYEc3 during 2021 can be seen in https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=137 and followings

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

In the context of the new Environmental Footprint Plan and thanks to the expansion of the SIGMAYEc3 model, the Group has established new objectives to be added to the previously existing ones: Objectives to 2024: • Reduce the Group’s carbon footprint by 19 percent compared to the 2019 baseline. • Neutralize MAPFRE’s carbon footprint in Brazil, the United States, Mexico, Peru, Puerto Rico, Germany, Italy and Turkey. Objectives to 2030: • Reduce the Group’s carbon footprint by 50 percent compared to the 2019 baseline. • Neutralize the remaining carbon footprint for the Group as a whole. (Please refert to https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=139)

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	MAPFRE's Environmental Footprint Plan 2030 targets to reduce the Group’s carbon footprint and energy consumption by at least 50 percent by 2030. For further details see at 2021 Integrated Report: - 5.2 Corporate Environmental Footprint Plan - 3. CARBON FOOTPRINT - 5.2 Corporate Environmental Footprint Plan - 4. SUSTAINABLE MOBILITY - 5.2 Corporate Environmental Footprint Plan - 7. GREEN PROCUREMENT
Energy & Resource Use	Reduce the Group’s carbon footprint and energy consumption by at least 50 percent by 2030. For further details see 5.2 Corporate Environmental Footprint Plan - 1. ENERGY EFFICIENCY at 2021 Integrated Report
Water	MAPFRE's Environmental Footprint Plan 2030 targets the reducton of 100,032 m3 of water consumption by 2024 and of 213,764m3 by 2030, with respect to 2019 baseline For further details see 5.2 Corporate Environmental Footprint Plan - 5. WATER MANAGEMENT at 2021 Integrated Report
Forests / Biodiversity / Land Use	Although MAPFRE work centers are not located in protected or cataloged spaces of high diversity, the development of the company’s activity depends directly on and directly impacts natural capital, which includes both biodiversity and the services provided by ecosystems, as well as natural resources (water, energy, fuels, etc.). In this regard MAPFRE's Environmental Footprint Plan 2030 targets at least 50% of the floor area of the Group’s main building will be certified as sustainable by 2030 For further details see at 2021 Integrated Report: - 5.2 Corporate Environmental Footprint Plan - 2. SUSTAINABLE BUILDINGS - 5.2 Corporate Environmental Footprint Plan - 8. NATURAL CAPITAL MANAGEMENT AND BIODIVERSITY PRESERVATION
Air Pollution	MAPFRE's Environmental Footprint Plan 2030 targets to reduce the Group’s carbon footprint and energy consumption by at least 50 percent by 2030. For further details see 5.2 Corporate Environmental Footprint Plan - 3. CARBON FOOTPRINT at 2021 Integrated Report
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	MAPFRE's Environmental Footprint Plan 2030 targets the salvaging of 84 percent of the waste generated in the Group’s operations worldwide by 2024 and 90 percent by 2030. In addition, the Zero Waste model will be extended from headquarters by 2024: Spain, Mexico, Brazil and Puerto Rico. For further details see 5.2 Corporate Environmental Footprint Plan - 6. CIRCULAR ECONOMY at 2021 Integrated Report
Oceans

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

Optional comment

Please refer to additonal information related at E3

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

10035.33

Scope 2 Emissions

Full

None

Emissions (tCO2e)

11114.46

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

29276.71

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

47.18

Unknown

Optional comment

Please refer to https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=202

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

43.71

Products and services according Regulation (EU) 2020/852 of June 18, 2020.

Unknown

Not applicable (Please provide additional information)

Optional comment

Details of the application of Regulation (EU) 2020/852 of June 18, 2020 can be found at 2021 Integrated Report in section 3.3.2.2.2. Integration of ESG aspects in MAPFRE's underwriting processes.

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

MAPFRE has an important role to play in helping society by identifying sustainable development opportunities for the insurance business and offering its customers products and services that further the transition to a low-carbon economy. In 2021 the Group has reviewed the environmental commitments assumed in terms of underwriting and investment, which will be applicable from 2022 (https://www.mapfre.com/media/sustainability/environmental-commitments-investment-underwriting-plan-22-24.pdf) By 2030, MAPFRE's portfolio will no longer include insurance programs related to coalfired power plants or operation of thermal coal mines in the OECD countries, or companies that have not implemented commitments on the energy transition and decarbonization. Beginning in 2040 this commitment will also apply to the rest of the world, in all countries where MAPFRE operates. Addionally, in 2021, MAPFRE renewed its commitment to the fight against climate change, defined in the Corporate Environmental Footprint Plan 2021-2030. The eight lines of action to reduce its environmental footprint are related at chapter 5. COMMITTED TO THE ENVIRONMENT of 2021 Integrated Report

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2020

Optional comment

MAPFRE has zero tolerance for corruption and bribery. Therefore, in addition to the provisions of the Code of Ethics and Conduct, the company has an anti-corruption framework in place that comprises, among other aspects, the following policies and regulations: Criminal Risk Prevention Model, Anti-corruption Policy, Prevention of money laundering and financing of terrorism and Prevention of fraud. https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=36

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

Please see: https://www.mapfre.com/media/shareholders/2021/politica-anticorrupcion-mapfre-2020-en-CE.pdf

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

Throughout 2021, 23,491 employees underwent some training in the fight against corruption. By the end of the year, 69 percent of the active workforce had completed some training action related to this matter. For details of workers, actively employed as of December 31, trained in this matter, broken down by geographical area and by level of responsibility please refer to https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=37 Additionally, board members also receive training on the matter, and in 2021, 100 percent of the external directors dedicated a total of 58 hours to training in relation to: • Code of Ethics and Conduct. • Prevention of money laundering. • Prevention of criminal risks. • Internal capital control model. • IFRS 9 and 17 standards. • European insurance regulations and regulations approved by the council.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

In accordance with the financial services regulatory frameworks for the admission of clients, all MAPFRE operations are evaluated in order to prevent and deter operations related to corrupt practices. In addition, each entity has mechanisms in place to prevent practices such as money laundering or fraud. The compliance departments of each entity periodically evaluate the validity of the existing controls for those processes in which criminal risks associated with these practices have been identified. Information related to GRI 205 (2016) can be found in section 2.4.2 Ethical behavior: main compliance and prevention measures of the integrated report.

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years
In 2021, there were no significant cases of corruption in the Group and, in the cases detected, all of which were of little relevance, the internal control mechanisms functioned correctly, allowing their detection and the application of the corresponding measures. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=209)
Confirmed during the current year, and related to this year
In 2021, there were no significant cases of corruption in the Group and, in the cases detected, all of which were of little relevance, the internal control mechanisms functioned correctly, allowing their detection and the application of the corresponding measures. (https://www.mapfre.com/media/shareholders/2021/integrated-report-2021.pdf#page=209)

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

Optional comment

The Criminal Risk Prevention Model and the Anti-Corruption Policy specify and implement the commitment to reject corruption in its forms, including extortion and bribery. The Criminal Risk Prevention Model identifies and assesses the crimes included in the Criminal Code that may impact MAPFRE in terms of exposure to risk and impact (monetary and non-monetary penalties, loss of reputation, and other financial losses). Likewise, the existing controls are identified and evaluated to prevent the aforementioned crimes from occurring along the value chain. The Corporate Compliance Management chairs the Criminal Risks Committee, enabling the company to react appropriately to the possible materialization of a criminal risk.

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

MAPFRE maintains a zero tolerance policy towards corruption and bribery. Throughout 2021, 23,491 employees undertook some anti-corruption training. Therefore, in addition to the provisions of the Code of Ethics and Conduct, the company has an anti-corruption framework comprising, among others, the policies and regulations detailed below: - Criminal Risk Prevention Model, - Anti-Corruption Policy, - Prevention of Money Laundering and Terrorist Financing - Fraud Prevention. In accordance with the regulatory frameworks of financial services for the admission of clients, all MAPFRE operations are evaluated in order to prevent and deter operations related to corrupt practices. In addition, each entity has mechanisms in place to prevent practices such as money laundering or fraud. The compliance departments of each entity periodically evaluate the validity of the existing controls for those processes in which criminal risks associated with these practices have been identified. In accordance with this measure, in 2021, the degree of compliance with the following policies was analyzed and assessed: a. Aptitude and Honorability Policy b. Internal Audit Policy c. Reinsurance Policy The evaluation was carried out in 44 companies: MAPFRE S.A. and insurance and reinsurance companies resident in Spain, the United States, Brazil, Germany, Italy, Mexico, Peru, Puerto Rico, Turkey, Malta, Portugal, Argentina, Chile, Colombia and Panama.