What did ANZ Group Holdings Limited announce?

ANZ Group Holdings Limited (NZX: ANZ) filed “ANZ 2025 ESG Documents” with NZX on 9 November 2025, as an esg announcement.

From the announcement:“Report ANZ Group Holdings Limited (ANZ) today released its 2025 ESG Report. It has been approved for distribution by ANZ’s Board of Directors.”
When was it filed?
9 November 2025
Where is the original?
NZX announcement
ANZ Group Holdings Limited logo

ANZ 2025 ESG Documents

ESG9 November 2025ANZFinancials

ANZ Group Holdings Limited
9/833 Collins Street Docklands Victoria 3008 Australia

ABN 16 659 510 791

10 November 2025


Market Announcements Office

ASX Limited

Exchange Place

Level 27

39 Martin Place

SYDNEY NSW 2000


ANZ 2025 ESG Report


ANZ Group Holdings Limited (ANZ) today released its 2025 ESG Report.


It has been approved for distribution by ANZ’s Board of Directors.


Yours faithfully


Simon Pordage

Company Secretary

ANZ Group Holdings Limited

2025
ESG Report

Approved for distribution by ANZ Group Holding Limited’s Board.

Our ambition is for ANZ to unlock
our potential to win the preference

of customers, shareholders and

the community.

Our ESG approach is focused on responding to

our seven most material ESG issues:

Environmental

sustainability

Financial

wellbeing

Housing

Information

technology

Responsible

customer

engagement

Ethics, conduct

and culture

Acknowledgement of Country

and Traditional Owners

ANZ acknowledges the

Traditional Custodians of

Country throughout Australia

and recognises their continuing

connection to lands, skies and

waterways. We pay our respects

to Aboriginal and Torres Strait

Islander cultures, and to Elders

past and present.

Whakatauākī, ANZ

New Zealand’s Proverb

Tākiri-ā-Rangi

The expansive universe above

Tākiri-ā-Nuku

The beauty of the proceeding

lands below

Tākiri te Awatea

A new dawn beckons

Kia Puāwai ki te Ao

A blossoming to the world

Te Kare ā-Roto e

With ripples of compassion

and hope for all.

Improving

non-financial risk

management

We are continually seeking to improve our reporting suite and welcome feedback

on our ESG and climate reporting. Please address any questions, comments or

suggestions to esg@anz.com

B

ANZ 2025 ESG Report

Overview and governance 2
Our 2025 reporting suite 2

Disclaimer and important notices 3

CEO’s message 4

Our ambition and strategy 5

About our business 6

Governance 7

What matters most to

our stakeholders 10

Stakeholder engagement 12

Our ESG targets and performance 13

2025 ESG targets performance

summary 13

Improving non-financial risk

management 16

Ethics, conduct and culture 18

Code of Conduct 18

Whistleblower Program 19

Responsible customer engagement 20

Putting our customers first 20

Supporting customers in need of

extra care 22

Financial hardship 24

Customer complaints 26

Environmental sustainability 27

Our Climate and Environment Strategy 27

Supporting our customers’ transition

through financing 29

Financial wellbeing 30

Financial education programs 30

Housing 32

Suitable and affordable housing 32

Information security 34

Fraud and scams 34

Cyber security 36

Data protection and privacy 37

Regulation and risk management 38

Financial crime 38

Social and environmental

risk management 39

Managing ESG risks and opportunities

in our supply chain 41

Digital banking experience 42

Banking in the Pacific 42

Diversity and inclusion 43

Diversity and inclusion 43

Gender pay equality 44

Gender balance 45

First Nations Strategy 46

ANZ’s commitment to Māori 47

Accessibility and inclusion 48

Employee experience 49

Simplifying the bank 49

Engagement and wellbeing 50

Developing our people 51

Human rights 52

Human rights 52

Thriving communities 53

Community investment 53

Appendix 54

Glossary of terms 56

Independent Assurance 

Statement 58

Contents

1

ComprehensiveKey messages
About this report

Our 2025 ESG Report provides

stakeholders with detailed information

on ANZ’s ESG performance and

challenges. This report covers ANZ Group

Holdings Limited (ANZGHL) ABN 16 659

510 791 and its subsidiaries’, referred to

as “ANZ” or “the Group” or “our” or “we”.

ANZ has prepared this report in

accordance with the GRI Universal

Standards 2021. A GRI Content Index is

provided in our 2025 ESG Data and

Frameworks Pack available at anz.com/

esgreport.

In 2019 we were a founding signatory to

the United Nations Principles for

Responsible Banking. We have reported

our Responsible Banking Progress

Statement in our 2025 ESG Data and

Frameworks Pack available at anz.com/

esgreport.

KPMG has performed assurance over

the disclosures in this report. A copy

of KPMG’s limited assurance conclusion

can be found on pages 58-59.

Reporting boundaries and periods

This report covers ANZ's operations over

which, unless otherwise stated, we have

control for the financial year commencing

on 1 October 2024 and ending 30

September 2025, referred to as “2025”

throughout the report, unless otherwise

stated. Where data is still maturing and

may only be for a part of our operations,

the data boundary will be noted.

The processes, approaches and

policies described in this report may vary

in application across ANZ’s operations,

for example, to reflect specific legal

requirements of the jurisdictions in

which ANZ operates.

Suncorp Bank

On 31 July 2024, the Group acquired

100% of the shares in SBGH Limited, the

immediate holding company of Norfina

Limited (ABN 66 010 831 722) (previously

called Suncorp-Metway Limited)

(“Suncorp Bank”).

Following the acquisition, Suncorp Bank

commenced a phased transition to adopt

the policies and processes of ANZ. During

the transition period, Suncorp Bank will be

subject to a combination of ANZ and

Suncorp Bank policies. As part of the

ongoing transition, Suncorp Bank will seek

to align to ANZ policies and practices,

where appropriate. Where Suncorp Bank

is included or excluded in programs,

policies, standards or metrics throughout

the report, this is denoted, noting Suncorp

Bank is excluded from prior year metrics,

unless otherwise stated.

Suncorp Bank’s operations continue to be

supervised by key regulatory bodies, and

seeks to meet all due diligence obligations

mandated by law.

The following ANZ policies, which embed

our approach to ESG, currently apply to

Suncorp Bank:

• Anti-Bribery and Anti-Corruption

Business Integrity Policy

• Anti-Bribery and Anti-Corruption

Third-Party Due Diligence Standard

• Anti-Fraud Policy

• Code of Conduct

• Diversity and Inclusion Policy

• Equal Opportunity, Bullying and

Harassment Policy

• Information Security Policy

• Non-Financial Risk Policy

• Performance and Remuneration

Policy – Group

1


• Procurement Policy

• Third-Party Risk Management

Framework

• Supplier Code of Practice

• Wellbeing and Safety Policy

• Whistleblower Policy

During the reporting year Suncorp Bank

retained the following policies:

• Anti-Money Laundering, Counter-

Terrorism Financing and Sanctions

Policy

• Competition Policy

• Complaints Management Policy

• Privacy Management Policy

• Responsible Banking Policy

• Security Management Policy

• Operational Resilience Policy

• Credit Risk Management Policy

Reading this report

Words underlined like ‘this’ are

explained in the Glossary of terms

on pages 56-57. Monetary amounts

in this document are reported in

Australian dollars (AUD), unless

otherwise stated. Throughout this

report, the sum of parts within

charts and commentary may not

equal totals due to rounding.

1. The Suncorp Bank Performance and Remuneration Policy forms part of, and should be read in conjunction with, the ANZ Group Performance and Remuneration Policy.

Our 2025 reporting suite

Where to find

Annual

Report

Full Year

Results

announce-

ments

Corporate

Governance

Statement

Climate

Report

ESG

Report

ESG Data

and

Frameworks

Pack

Modern Slavery

and Human

Trafficking

Statement

Voluntary Tax

Transparency

Report

Financial

Governance

Strategy

Risk

ESG disclosures

and performance

Climate disclosures

and performance

ANZ 2025 ESG Report

2

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Disclaimer and important notices
The material in this report contains

general background information about

the Group’s activities current as at

7 November 2025. It is information

given in summary form and does not

purport to be complete. It has a

sustainability focus and does not

reflect the totality of the Group’s

business activities. For a more

complete overview of the Group’s

business, see the 2025 Annual Report

available at anz.com/annualreport.

It is not intended to be and should not

be relied upon as advice to investors

or potential investors, and does not

take into account the investment

objectives, financial situation or needs

of any particular investor. These should

be considered, with or without

professional advice, when deciding if

an investment is appropriate.

Forward-looking statements

This report may contain forward-

looking statements or opinions

including statements regarding our

intent, belief or current expectations

with respect to the Group’s business

operations, market conditions, results

of operations and financial condition,

sustainability objectives or targets, and

risk management practices. Those

matters are subject to risks and

uncertainties that could cause the

actual results and financial position of

the Group to differ materially from the

information presented herein. When

used in the report, the words

‘forecast’, ‘estimate’, ‘goal’, ‘target’,

‘indicator ’, ‘plan’, ‘pathway ’, ‘ambition’,

‘modelling’, ‘project’, ‘intend’,

‘anticipate’, ‘believe’, ‘expect’, ‘may’,

‘probabilit y ’, ‘risk ’, ‘will’, ‘seek ’, ‘would’,

‘could’, ‘should’ and similar

expressions, as they relate to the

Group and its management, are

intended to identify forward-looking

statements or opinions.

Those statements are usually

predictive in character; or may be

affected by inaccurate assumptions

or unknown risks and uncertainties

or may differ materially from results

ultimately achieved. As such, these

statements should not be relied upon

when making investment decisions.

There can be no assurance that actual

outcomes will not differ materially from

any forward-looking statements or

opinions contained herein.

Also see the notice about climate-related

information on this page which may affect

climate-related forward-looking

statements or opinions.

The forward-looking statements or

opinions only speak as at 7 November

2025 and no representation is made as

to their correctness on or after this date.

No member of the Group undertakes to

publicly release the result of any revisions

to these statements to reflect events or

circumstances after this date to reflect the

occurrence of unanticipated events.

Climate-related information

This report may contain climate-related

statements, including in relation to

climate-related risks and opportunities,

climate-related goals and ambitions,

emissions reduction pathways and

climate projections. While the statements

were prepared in good faith, climate-

related statements are subject to

significant uncertainty, challenges and

risks that may affect their usefulness,

accuracy and completeness, including:

1. Availability and reliability of data –

emissions and climate-related data

may be incomplete, inconsistent,

unreliable or unavailable (including

information from the Group’s

customers), and it may be necessary

to rely on assumptions, estimates or

proxies where that is the case.

2. Uncertain methodologies and modelling

methodologies, frameworks and

standards used for calculations of

climate-related metrics, modelling and

climate data are not universally applied,

are rapidly evolving and subject to

change. This may impact the data

modelling, approaches, and targets

used in preparation of this report.

3. Complexity of calculations and

estimates – estimating financed or

facilitated emissions (including

allocating emissions to banking

activities) and emissions reduction is

complex and relies on assumptions

and judgments, often made in respect

of long periods of time.

4. Changes to climate-related governing

frameworks – changes to climate-

related policy, laws, regulations and

market practices, standards and

developments, including those resulting

from legal proceedings and regulatory

investigations.

The information in this notice should

be read with the qualifications,

limitations and guidance included

throughout this report and in:

Appendix 5 ANZ Financed and

Facilitated Emissions Methodology

included in the 2025 Climate Report

available at anz.com/esgreport

Appendix 7 Scope 1, Scope 2 and

Scope 3 Operational Greenhouse Gas

Emissions Reporting Methodology

included in the 2025 Climate Report

available at anz.com/esgreport

ANZ Social and Environmental

Sustainability Target Methodology

available at anz.com/esgreport

2025 ESG Data and Frameworks Pack

available at anz.com/esgreport

5. Lack of consistency in definitions

and climate-science terminology

subject to changes – definitions

and standards for climate-related

data and assessment frameworks

used across industries and

jurisdictions may vary, and

terminology and concepts relating

to climate science and

decarbonisation pathways may

evolve and change over time. These

inconsistencies and changes can

also make comparisons between

different organisations’ climate

targets and achievements difficult

or inappropriate.

6. Reliance on third parties for data or

involvement – the Group may need

to rely on assistance, data or other

information from external data and

methodology providers or other third

parties, which may also be subject

to change and uncertainty.

Additionally, action and continuing

participation of third parties, such

as stakeholders, may be required

(including financial institutions and

governmental and non-

governmental organisations).

Due to these uncertainties, challenges

and risks, statements, assumptions,

judgments, calculations, estimates

or proxies made or used by the

Group may turn out to be incorrect,

inaccurate or incomplete. Readers

should conduct their own independent

analysis and not rely on the information

for investment decision-making.

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

3

CEO’s
message

Nuno Matos

Chief Executive Officer

Across our communities in Australia and

New Zealand, access to affordable

housing and cost of living continue to be

a key focus. Pleasingly, we have funded

and facilitated more than $892 million

this year against our target of delivering

$10 billion of more affordable, accessible

and sustainable homes to buy and rent by

the end of 2030. We have also continued

to deliver our financial education programs

– MoneyMinded, MoneyBusiness and

Saver Plus – reaching more than 126,000

participants this year.

Our Climate and Environment Strategy

sets out our objective to be a trusted

partner for our customers, supporting

them to adapt and become more resilient

to a changing environment and economy.

We continue to make progress against our

climate and environment targets, including

funding and facilitating more than

$84 billion towards our $100 billion target

in social and environmental activities by

2030. This is discussed in more detail in

our 2025 Climate Report.

Our teams are continuing to work hard to

put our customers first by keeping their

money safe, reviewing and adjusting our

capabilities to manage the security of

customer information, and helping to

detect and prevent scams - something

we know is of the utmost importance.

By improving our customer propositions,

we also seek to support inclusion and

economic self-determination through our

First Nations Strategy in Australia and

our Tākiri-ā-Rangi Te Ao Māori Strategy

in New Zealand.

A key area of focus is improving our

management of non-financial risk to

improve customer outcomes. We

acknowledge our existing non-financial

risk management practices have not met

expectations and recognise we have more

work to do to uplift our management of

non-financial risk and to improve risk

culture across the bank.

Importantly, in October 2025 we also

launched our refreshed strategy, ANZ

2030, based on our ambition to unlock

our potential to win the preference of

customers, shareholders and the

community. You can learn more about

ANZ 2030 in our 2025 Annual Report.

A cultural reset is fundamental to

fulfilling these responsibilities and

meeting the expectations of regulators,

communities and other stakeholders.

A key element of this change is a keen

focus on simplifying the bank to deliver

for our customers and improving our

risk management. I believe we will be

a better bank with an energised and

engaged workforce to enable the

delivery of market-leading services to

our customers that our teams can be

proud of.

Delivering long-term value to our

shareholders and meeting the evolving

needs of our customers requires

continuous improvement and purposeful

action. Effective management of ESG risks

and opportunities enhances our ability to

serve customers responsibly, strengthens

governance, reduces risk and supports

more sustainable financial outcomes for

our shareholders.

This ESG Report sets out our performance against a

range of ESG risks and opportunities where we have

the greatest impact as a financial institution.

Nuno Matos

Chief Executive Officer

ANZ 2025 ESG Report

4

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Our ambition and strategy
Our ambition is for ANZ to unlock our potential to

win the preference of customers, shareholders and

the community.

For more information about ANZ 2030

see our 2025 Annual Report available

at anz.com/annualreport

Delivering on this vision

In delivering these priorities, we are supported by our core enablers:

CulturePeople Technology

Our strategy is focused on four strategic pillars:

Customer first

With market leading,

differentiated and

superior propositions,

we will raise the standard

of every digital and

human interaction for

our customers.

Simplicity

To set the market standard

for productivity, we will

deliver organisational

simplification, divest

non-core assets and

improve efficiency.

Resilience

Leading the industry in trust,

safety and risk management,

we will adhere to the highest

standards of non-financial risk

management and strengthen

end-to-end accountability

across the bank.

Delivering value

To sustainably improve

our financial performance,

we will create lasting value

by delivering higher

returning growth and

results that matter for

our stakeholders.

5

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Our business model

Australia Retail

Banking products and services

provided to Australian consumers

including home loans, deposits,

credit cards and personal loans.


Australia Commercial

Banking products and services

provided to small-to-medium

enterprises, large commercial

customers and high-net-worth

individuals and family groups in

Australia.


Institutional

Services to institutional and

corporate clients, including

governments, via Transaction

Banking, Corporate Finance,

and Markets business units.


Suncorp Bank

Banking and related services

to retail, commercial, small

and medium enterprises and

agribusiness customers in Australia.


New Zealand

Banking products and services

provided to New Zealand

customers through Personal,

Business and Agribusiness units.


Pacific

Banking products and services

provided to retail and commercial

customers, and to governments

located in the Pacific region.


Group Centre

Supporting functions including technology, property, risk management, financial management,

treasury, human resources, corporate affairs, and shareholder functions. It also includes minority

investments in Asia and interests in the ANZ Non-Bank Group.

ANZ provides banking and financial products and services

to more than 11 million customers

1

across 29 markets.

About our business

1. Includes Suncorp Bank.

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

6

ANZ 2025 ESG Report

Our ESG governance framework is
evolving with our ESG approach

and the expectations of our

stakeholders. This year, the

following changes have occurred

relating to committees with

oversight of our ESG approach and

climate risks and opportunities:

The Board Ethics, Environment,

Social and Governance (EESG)

Committee was discontinued

and its responsibilities

reallocated, as appropriate,

to the Board and its sub-

committees.

The management Ethics

and Responsible Business

Committee (ERBC) was

discontinued and where

appropriate, matters previously

considered by the ERBC are

referred to the Executive

Committee (ExCo).

1

A new and more focused

management Climate and

Environment Committee (CEC)

was established in March

2025 reporting to ExCo.

Governance

ANZ Board and committees

ANZ Group Holdings Limited’s Board

(Board) is responsible for oversight of

the Group. The Board, with the support

of its committees, is also responsible

for overseeing ANZ’s governance

framework. The framework seeks to

provide for effective and responsible

decision making, assisting ANZ to deliver

on its strategy and purpose.

The Board and each Board

committee has its own charter

setting out its roles and

responsibilities available at

anz.com/corporategovernance

More information on ANZ’s

governance framework is provided

in the 2025 Corporate Governance

Statement available at

anz.com/corporategovernance

Board skills and experience

The Board has the collective skills,

capabilities and experience needed to

allow the Board to perform its role and

discharge its responsibilities. The 2025

Corporate Governance Statement (refer

to anz.com/corporategovernance) details

the categories that the Board considers

relevant to assessing the collective skills

and experience of the Board and is what

the Board is looking for in its own

composition. One of the categories

is sustainability, including climate.

Principal Board


committees

Audit

Committee

Risk

Committee

People

and Culture

Committee

Digital Business

and Technology

Committee

Nomination and

Board Operations

Committee

Board of Directors

1. Executive Committee (ExCo) comprises ANZ’s most senior executives. The members of ExCo are available on ANZ’s website at anz.com/exco.

Our governance framework seeks to provide a structure

for effective and responsible decision making at ANZ.

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

7

ANZ Group Holdings Limited Board

Audit Committee

Oversees financial

reporting principles

and policies, controls

and procedures.

Risk Committee

Oversees the

implementation and

operation of the

Group’s Risk

Management

Framework, including

climate risk.

Responsible for

endorsing the Risk

Appetite Statement.

People and

Culture Committee

Oversees the

effective operation of

the Performance and

Remuneration

Framework, and

other Talent and

Culture matters.

Digital Business

and Technology

Committee

Oversees the

Group’s digital

transformation,

data, technology-

related innovation

and information/

cyber security

strategies.

Nomination and

Board Operations

Committee

Oversees matters to

do with the proper

functioning of the

Board, including in

relation to ongoing

composition and

overall Board

operations.

The Board and management committee structure below outlines relevant committees that have

oversight of ESG risks and opportunities across the Group. It reflects changes to our ESG governance

structure this year with the Board committee changes effective from 5 September 2025.

Board committees

Support activities

Key management committees

Credit and Market Risk

Committee

Primary Group

management

forum responsible for the

oversight and control of

credit, market and other

material financial risks

across the Group.

Chaired by the Chief Risk

O fficer.

Executive Committee

Comprises ANZ’s most

senior executives. A

delegations of authority

framework outlines those

matters delegated to the

Chief Executive Officer

(CEO) and other members

of senior management.

Chaired by the CEO.

Climate and Environment

Committee

A decision-making

committee that is responsible

for the execution of our

Climate and Environment

Strategy. This includes past,

current and emerging climate

and environment risks and

opportunities and climate

and environment targets.

Chaired by the Group

Executive, Institutional.

(Established March 2025)

Operational Risk

Executive Committee

The primary senior

executive management

forum responsible for

overseeing non-financial

risks, expected and

unexpected risk profile

and the related control

environment across the

Group.

Chaired by the Chief Risk

O fficer.

Climate and Environment Forum

Responsible for overseeing delivery of our C&E Strategy,

and provides recommendations and escalations to the

CEC, Board and other management committees.

(Established February 2025)

Climate Disclosure Program Steering Committee

Responsible for overseeing delivery of the Group-wide

Climate Disclosure Program to meet Australian mandatory

climate-related disclosure requirements.

(Established October 2024)

Alongside climate-focused committees, during 2025 the Executive Committee is supported by the Group ESG function

(reporting to the Group Head Corporate Affairs) to monitor social and environmental impacts across industries, customers,

and communities. Key activities include:

• Managing ESG risks and opportunities through senior executive decision-making processes.

• Advising on social and environmental issues influencing lending decisions, including public policy, regulation, and

community expectations.

• Delivering financial education programs (Saver Plus, MoneyMinded, MoneyBusiness) and overseeing employee

volunteering and community investment initiatives.

• Providing guidance on ESG and climate disclosures, including emerging reporting standards and frameworks.

Support is also provided by other teams on matters including supporting customers in need of extra care, First Nations

Strategy and Tākiri-Ā-Rangi Te Ao Māori Strategy, health and safety, and diversity and inclusion.

Other management

committees and forums

ANZ 2025 ESG Report

8

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

ESG focus areas of Board
management and committees

During 2025, we engaged on a range

of ESG topics with our Board, senior

executives, regulators, government and

non-government organisations. This

provides opportunities to build knowledge,

including about our most material ESG

issues discussed on pages 10-11 and

listed below.

Board EESG Committee and

Management ERBC

This year, the Board EESG

1

Committee

and management ERBC

2

considered

topics, including:

Modern slavery and human rights

Accessibility

Whistleblower Program

ESG external operating

environment

Climate and Environment Strategy

Climate-related targets including

sectoral pathways

Preparation for mandatory

climate-related disclosures in

Australia

Customer engagement on

climate and nature, including

our Large Emitters Engagement

Program

Governance over ESG targets

The setting of ESG targets is reviewed by ExCo and approved by the Board.

Targets are also monitored by ExCo and the Board. For more information on

governance over climate-related targets, including sectoral pathways, see page 7

of our 2025 Climate Report available at anz.com/esgreport.

1. The Board EESG Committee had its last meeting in May

2025. 2. ERBC was discontinued in July 2025. 3. These

are a subset of ANZ’s ESG targets. Targets that contribute

to ANZ’s Group Scorecard are set out on page 13.

Executive remuneration

ANZ’s Remuneration Report within

our 2025 Annual Report, available at

anz.com/annualreport, details how

performance and remuneration

outcomes are determined for our

most senior leaders.

The CEO’s Short Term Variable

Remuneration (STVR) is assessed

against the ANZ Group Scorecard,

adjusted by the ‘How’ Modifier,

which takes into consideration the

CEO’s leadership of ANZ’s values

and behaviours and ANZ’s risk and

compliance standards.

Performance objectives are set for

Disclosed Executives through Divisional

Scorecards, aligned with the ANZ

Group Scorecard. For Disclosed

Executives, STVR is assessed on

‘What’ assessment (ANZ Group

Scorecard and Divisional Scorecard) x

‘How’ Modifier. The weighting to

Divisional Scorecards varies from 50%

to 75% for Disclosed Executives.

ANZ’s Group Scorecard includes relevant

objectives and key performance indicators

(KPIs). For example, the 2025 Group

Scorecard includes delivery against

Environmental, Social and Governance

(ESG) objectives and KPIs, such as:

Strengthen our reputation; enhancing our

employee value proposition and our social

license to operate:

Improved Inclusion Index

Deliver environmental ESG targets

as planned

3

Divisional Scorecards also include

objectives and KPIs as relevant to the

particular business. Group/Divisional

Scorecards are not designed to capture

all of our ESG targets – however our senior

leaders are accountable for ensuring we

focus on and seek to adhere to our

commitments and policies.

For more information on climate risk

governance, refer to the 2025 Climate

Report available at anz.com/esgreport

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

9

This year, we have conducted
a materiality assessment

where we engage with

internal and external

stakeholders to seek to

identify and assess our most

material ESG issues. The

results help inform our

business practices, ESG

targets and key topics in

our external ESG reporting.

What matters most to our stakeholders

Environmental sustainability remains one of the highest priority issues

identified by our stakeholders, in terms of both risks and opportunities.

Ethics, conduct and culture remains top of mind for stakeholders, particularly

the importance of trust.

Financial wellbeing, for customers and the broader community, was noted

as integral to the role of a bank.

Housing was identified by many of our stakeholders as a long-term issue of

profound impact.

Information security, encompassing cyber security and financial crime, was

raised by many, including the potential for cyber threats to cause reputational

damage, and the rapidly evolving and sophisticated nature of scams.

Responsible customer engagement, such as the need for ANZ to support

customers, including those experiencing financial hardship.

Improving non-financial risk management was highlighted in response

to the court enforceable undertaking from the Australian Prudential Regulation

Authority (APRA) and resolution agreement with the Australian Securities and

Investments Commission (ASIC). For more information on these matters see

p a g e s 1 6 -1 7.

Our most material ESG issues

ANZ's most material ESG issues are largely consistent with

our 2024 assessment, with the addition this year of improving

non-financial risk management.

Our assessment process

A list of ESG topics for stakeholder

feedback was prepared drawing from

investor priorities, themes from leading

ESG researchers, sustainability reporting

standards (e.g. Sustainability Accounting

Standards Board (SASB)), media analysis,

industry research, peer reviews and our

operating environment.

External and internal views were sought

to prioritise and validate issues through

stakeholder surveys in Australia, New

Zealand and the Pacific, and through

interviews with institutional investors,

consumer and environmental non-

government organisations, community

partners, customers and employees.

Our approach asked stakeholders to

consider in what areas ANZ has the most

impact (positive and negative) on the

economy, environment and people

(including their human rights), as well as

the impact these issues may have on the

Group’s ability to create value through its

financial or operating performance.

We asked stakeholders to consider

what impacts may be actual or potential,

short-term or long-term, intended or

unintended, and reversible or irreversible.

Stakeholders used significant judgement

when identifying ESG issues and in

assessing their impacts.

Our assessment process involved using

the quantitative survey data to guide the

ranking and consolidating of topics. This

was overlayed with qualitative feedback

from stakeholder surveys and interviews,

and discussions with ANZ senior

executives and the Board to validate and

approve the ESG issues considered the

most material.

Our assessment approach is in

accordance with the GRI Standard G3:

Material Topics 2021 and considers

the SASB Conceptual Framework 2017.

A GRI Content Index is provided in our

2025 ESG Data and Frameworks Pack

available at anz.com/esgreport.

01. Identifying

02. Prioritising

04. Disclosing

03. Validating

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

10

ANZ 2025 ESG ReportANZ 2025 ESG Report

Our most material ESG issues (not ranked)
Material issueDescription of issue

1

Location of disclosure

Environmental

sustainability

Climate change and the energy transition, nature

including biodiversity, circular economy, and ANZ’s

own emissions

2025 Climate Report available at

anz.com/esgreport

2025 ESG Report, pages 27-29

Ethics, conduct

and culture

Corporate values, conduct and culture, and corporate

governance

2025 ESG Report, pages 18-19

Financial

wellbeing

Customer and community financial wellbeing2025 ESG Report, pages 30-31

HousingHousing access, affordability and sustainability2025 ESG Report, pages 32-33

Information

security

Financial crime prevention (including fraud and scams),

cyber security and data management (including

privacy and security)

2025 ESG Report, pages 34-37

Responsible

customer

engagement

Responsible marketing, sales and lending practices;

fair, accessible and affordable products and services;

customer support (e.g. hardship), experience and

satisfaction

2025 ESG Report, pages 20-26

Improving

non-financial risk

management

Financial system risk and resilience, regulatory compliance,

anti-money laundering (AML), counter-terrorism financing

(CTF), anti-bribery and anti-corruption (ABAC)

2025 ESG Report, pages 16-17, 38-41

1. The survey included a more granular list of topics, which were then aggregated into the issues set out in this table. Sub-topics within an individual issue were not necessarily

identified as ‘material’ in their own right.

Our foundational ESG issues (not ranked)

Our foundational ESG issues are topics that continue to be fundamental to our license to operate and are also included in this report.

Material issueDescription of issue

1

Location of disclosure

Digital banking

experience

Digital innovation and emerging technology, including

artificial intelligence

2025 ESG Report, page 42

Diversity and

inclusion

Diversity, equity and inclusion; Indigenous rights and

cultural heritage (e.g. First Nations in Australia, Ta n g ata

Whenua Aotearoa and other Indigenous peoples)

2025 ESG Report, pages 43-48

Employee

experience

Workforce planning, attraction and retention, including

remuneration; employee support (e.g. health, safety,

wellbeing and engagement)

2025 ESG Report, pages 49-51

Human rightsHuman rights and modern slavery, supply chain

management and procurement that is sustainable,

responsible and diverse

2025 ESG Report, page 52

Thriving

communities

Community engagement, investment and contribution2025 ESG Report, page 53

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

11


One of the ways we help create long-term value and deliver on our business

strategy is through a collaborative approach to building and maintaining relationships

with stakeholders.

Stakeholder engagement

1. This list is not exhaustive or exclusive to one stakeholder group. 2. Key memberships include the Australian Banking Association, the Business Council of Australia, the New Zealand Banking

Association, and Business New Zealand. Our key membership payments are included in the 2025 ESG Data and Frameworks Pack available at anz.com/esgreport.

Our approach to stakeholder engagement aims to provide direct access for stakeholders, allowing us to respond to issues and consider

stakeholder concerns when making decisions.

Outlined below are the material topics raised by our stakeholders throughout the year.

Our stakeholders How we engage

Material topics identified through

our engagement

1

CustomersWe engage with customers via our branch network, home loan specialists,

contact centres, private bankers, relationship managers and digital channels.

• Access to capital and lending

services for businesses

• Conduct and ethical culture

• Cost of living

• Customer protection from fraud

and scams

• Financial inclusion, including

financial education programs

• Financial performance and

shareholder returns

• Implementation of the revised

Banking Code of Practice

• Integration of Suncorp Bank

• Macroeconomic, geopolitical

and localised issues impacting

customers, including impact of

tariffs

• New business strategy and

organisational change

• Regional and rural banking

access

• Regulatory engagement and

compliance, including ASIC and

APRA matters

• Remuneration and reward

• Support for customers

experiencing vulnerability

• Supporting our customers’

transition to net zero

• Technology and artificial

intelligence

EmployeesOur employee engagement surveys and employee listening strategies are

an opportunity for employees to provide feedback and insights on our

behaviours, values and culture; and their experience working at ANZ.

GovernmentWe listen to, and seek to engage with, Ministers from state and national

government, and public officials, including through participation in

government consultations and parliamentary inquiries.

Industry

associations

2


and bodies

We are members of a number of industry associations and bodies. Through

these memberships we contribute to discussions and submissions on

industry-wide economic, social and environmental issues affecting our

customers, shareholders and the broader community.

Non-government

organisations

We engage with non-government organisations (NGOs) through

relationships that benefit our customers, stakeholders and the broader

community. This enables us to understand perspectives from external

stakeholders and build our knowledge.

Regulators ANZ has relationships with more than 800 regulatory bodies globally. These

bodies play an important role in enabling financial stability, protecting

consumers, preventing fraud and maintaining trust in the financial system.

ANZ is committed to dealing with regulatory bodies in an open, constructive

and cooperative way. Our engagement with regulators includes meetings,

correspondence, breach notifications, regulatory enforcement matters,

requests for information, and reviews or inspections.

ShareholdersWe provide shareholders with information in a timely manner through our

reporting suite, announcements and briefings to the market, Annual General

Meeting, shareholder communications and a dedicated shareholder

website.

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

12

ANZ 2025 ESG Report


Continuing targets

Concluding targets

Our ESG targets and performance

Our ESG targets support the delivery of our business practices, strategy and

purpose. This year, four of our ESG targets concluded and three were achieved.

For our operational emissions target, we achieved four of the five sub-targets.

Related targets are summarised below.

Ta rg e t

1

headlineEnd date and outcomeFurther details

Savings program pilots2025 Achieved2025 ESG Report, pages 14, 31, 42

Large Emitters Engagement Program (LEEP)

2

2025 Achieved2025 ESG Report, page 14

2025 Climate Report, pages 12-15

Operational emissions and non-emissions

2

2025, 20302025 ESG Report, page 14

2025 Climate Report, pages 52-53

• Scope 1 and Scope 2 emissions

Achieved

• Renewable electricityNot achieved

• WaterAchieved

• WasteAchieved

• PaperAchieved

New Zealand retail lending

2

2025 Achieved2025 ESG Report, pages 14, 33

2025 Climate Report, page 17

Gender equity targets

3,4

20252025 ESG Report, pages 14, 45

2025 Corporate Goverance

Statement, page 22

• Key Management PersonnelNot achieved

• Women in LeadershipAchieved

We have withdrawn our financial resilience target in 2025 after identifying anomalies in the calculation methodology.

Ta rg e t

1

headlineEnd date and statusFurther details

$10 billion social and affordable housing2030 Continuing2025 ESG Report, pages 15, 32-33

$100 billion social and environmental activites

2

2030 Continuing2025 ESG Report, pages 15, 29

2025 Climate Report, page 31

Sectoral pathways

4

2030 Continuing2025 ESG Report, page 15

2025 Climate Report, pages 32-51

Operational emissions

5

• Scope 1 and Scope 2 emissions

2030 Rebaselined2025 ESG Report, page 15

2025 Climate Report, pages 52-53

Gender equity targets

5

20262025 ESG Report, pages 15

2025 Corporate Governance

Statement, page 22

• Key Management PersonnelContinuing

• Women in LeadershipRebaselined

1. Targets exclude Suncorp Bank unless otherwise stated. 2. Target contributes to ANZ’s 2025 Group Scorecard (Deliver environmental ESG targets as planned). Refer to the

Remuneration Report contained within the 2025 Annual Report available at anz.com/annualreport. 3. Target contributes to ANZ’s 2025 Group Scorecard (Improved inclusion index).

Refer to the Remuneration Report contained within the 2025 Annual Report available at anz.com/annualreport. 4. Our 2025 Climate Report available at anz.com/esgreport details

important information about the scope of our sectoral pathways. Revised pathways and targets include customers of Suncorp Bank that meet our in-scope criteria for inclusion in our

pathways. 5. Includes Suncorp Bank.

13

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance


Ta rg et s

1

2025 outcomes and performance

Savings program pilots

Pilot a savings program

2

for people on lower incomes

in Fiji and Vanuatu by end 2025, with at least 80% of

participants having demonstrated a savings habit

3

upon

completion. (Pacific)

Achieved

The savings program

2

pilots were successfully completed in Fiji and

Vanuatu. Both pilots exceeded their targets, with 85% of participants

in Fiji and 90% of participants in Vanuatu demonstrating a savings

habit

3

upon completion. A third pilot commenced in Solomon Islands.

Large Emitters Engagement Program (LEEP)

Enhance our management of climate risks and opportunities

by intensifying our engagement with our largest emitting

business customers. We will expect and encourage them to

strengthen their low carbon transition plans, by focusing our

engagement and raised expectations on our 100 largest

emitting business customers with the aim that by end 2025,

compared to their starting point more customers are assessed

as being in a ‘mature’ phase of their low carbon transition plans.

Achieved

45 customers were assessed as being in a ‘mature’ phase of their low

carbon transition plans, up from 42 in 2024.

4

Operational emissions and non-emissions

Reduce the direct impact of our business activities on the environment

5

by:

Reducing combined Scope 1 and Scope 2 emissions

85% by 2025 and 90% by 2030 (against 2015

baseline);

6

Achieved

Our combined Scope 1 and Scope 2 emissions have decreased by

96% since 2015.

Being powered by the equivalent of 100% renewable

electricity by 2025;

7

Not achieved

97% of ANZ's electricity needs were from renewable sources, just falling

short of our target of 100%. This was principally due to the absence of

recognised schemes or renewable electricity infrastructure in Papua

New Guinea and Pacific countries.

Reducing water consumption

8

by 40% by 2025

(against 2017 baseline);

Achieved

Our water consumption has decreased by 61% since 2017.

Reducing waste to landfill

9

by 40% by 2025

(against 2017 baseline);

Achieved

Our waste to landfill has decreased by 79% since 2017.

Reducing paper consumption (both office and ANZ

originated customer paper use) by 70% by 2025

(against 2015 baseline).

Achieved

Our paper consumption has decreased by 77% since 2015.

New Zealand retail lending

Helping New Zealand homeowners improve the

sustainability of their homes and/or reduce their transport

emissions through discounted lending of at least NZ$825m

in aggregate to at least 19,700 households by end 2025.

(New Zealand)

Achieved

Since October 2020 we have supported 23,397 households into

healthier homes and NZ$938.86 million lending through:

• Our Healthy Home Loan Package;

• Our Good Energy Home Loan Top Up;

• Interest-free Insulation Loans.

10

Gender equity targets

11

Maintain representation of women as Key Management

Personnel (KMP)

12

of at least 40%.

Not achieved

As at 30 September 2025, women as KMP

12

has decreased from four

out of ten, to three out of nine and is now below target at 33%. When

the recently announced permanent Executive Committee

13

appointments

of Stephen White, Pedro Rodeia, Christine Palmer and Donald Patra

commence from October to December 2025, women as KMP will

increase back to 40%.

Increase the representation of Women in Leadership (WIL)

by 1.2 percentage points (ppt) from baseline of 39.0%.

14

Achieved

We have exceeded our WIL target this year by 0.3 ppt to 40.5% – an

annual increase of 1.5 ppt.

1. Targets exclude Suncorp Bank unless otherwise stated. 2. Saver Plus. 3. Eight out of 10 months saving (as per Saver Plus program), measured by participant survey data. 4. In 2024, 42

customers were assessed as ‘Mature’. Between 2024 and 2025, four of our 100 largest emitting customers upgraded to ‘Mature’, and one customer who was assessed as ‘Mature’ in 2024 was

removed from LEEP due to acquisition. In 2025, we expanded LEEP to additional customers subject to the Safeguard Mechanism, certain customers in our sectoral pathways and other large

emitters. Within this expanded LEEP cohort, there are 77 customers assessed in the 'Mature' phase as at end 2025. For further detail, refer to page 12 in the 2025 Climate Report available at anz.

com/esgreport. 5. Environmental reporting year is 1 July – 30 June, in line with the Australian regulatory reporting year. 6. Using a market-based method for Scope 2 calculations. Refer to Appendix

7 Scope 1, Scope 2 and Scope 3 Operational Greenhouse Gas Emissions Reporting Methodology in the 2025 Climate Report available at anz.com/esgreport. 7. Self-generated renewable

electricity, direct procurement from offsite grid connected generators e.g. Power Purchase Agreement (PPA) and default delivered renewable electricity from the grid, supported by credible

attributes in accordance with RE100 technical guidelines. 8. Total potable water consumed from ANZ’s global properties. From 2021 includes global water consumption values, 2018 – 2020 values

represent water consumption in our Australian commercial offices (>10,000m2) excluding 347 Kent Street which was sold in the 2020 reporting year. 9. Total waste to landfill generated from ANZ’s

global properties. From 2021 includes global waste consumption values, 2018 – 2020 values include Australia and New Zealand only. 10. Product discontinued in July 2022. 11. Includes Suncorp

Bank. 12. ‘Senior Executive’ means “KMP”, which means Chief Executive Officer and Disclosed Executives as set out in the Remuneration Report contained within the 2025 Annual Report. 13.

Executive Committee (ExCo) comprises ANZ’s most senior executives. The members of ExCo are available at anz.com/exco. 14. FY24 Women in Leadership result of 38.8% excluded Suncorp

Bank, whereas FY24 Women in Leadership baseline for FY25 Women in Leadership target is 39.0% including Suncorp Bank.

Concluding targets, including outcomes and performance

14

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

1. For further detail on ANZ’s approach for assessing the eligibility of transactions for inclusion towards the target, refer to the ANZ Social and Environmental Sustainability Target
Methodology available at anz.com/esgreport. 2. Targets exclude Suncorp Bank unless otherwise stated. 3. Eligible housing transactions that also meet the eligibility criteria for the

social and environmental target to achieve $100 billion by end 2030 may contribute towards both targets. 4. FY25 includes transactions validated as eligible for inclusion in the target

from 21/09/2024 to 19/09/2025. 5. Our 2025 Climate Report available at anz.com/esgreport details important information about the scope of our sectoral pathways. Revised

pathways and targets include customers of Suncorp Bank that meet our in-scope criteria for inclusion in our pathways. 6. Includes Suncorp Bank. 7. ‘Senior Executive’ means “KMP”,

which means Chief Executive Officer and Disclosed Executives as set out in the Remuneration Report contained within the 2025 Annual Report.

Targets continuing in 2026, including performance update, and new targets

In 2026 we will continue our $10 billion social and affordable housing target, $100 billion social and environmental activities

target

1

, and sectoral pathways and targets. Both the 2025 and 2030 combined Scope 1 and Scope 2 operational

emissions reduction targets have now been achieved. Since the 2030 target was achieved earlier than expected, a more

ambitious 2030 target with a revised baseline has been set. We have also rebaselined our gender equity targets.


Ta rg et

2


2025 performance or status


End date

$10 billion social and affordable housing

Fund and facilitate at least $10 billion of investment

by end 2030, including $750 million in 2025, to deliver

homes to buy and rent that are more affordable,

accessible or sustainable.

3

Since October 2018, we have funded and facilitated

$7.37 billion to support the delivery of more affordable,

accessible or sustainable homes to buy and rent. This

includes $892.79 million allocated towards the target in

2025

4

, exceeding our $750 million 2025 sub-target.

2030

$100 billion social and environmental activities

Fund and facilitate at least $100 billion by end 2030,

including $18.5 billion in 2025, in social and

environmental activities through customer transactions

and direct investments by ANZ. This includes initiatives

that aim to help lower carbon emissions, protect

nature, increase access to affordable housing and

promote financial wellbeing.

1

Since 1 April 2023, we have contributed $84.72 billion

towards the target, across 412 customer transactions,

of which $42.09 billion is funded, $38.96 billion is

facilitated, and $3.67 billion is from direct investment

through 61 bond purchases. This includes $45.75 billion

allocated towards the target in 2025

4

, exceeding our

$18.5 billion 2025 sub-target.

2030

Sectoral pathways

5

Sectoral pathways and 2030 interim targets in place

for 10 sectors or sub-sectors, to transition lending to

net zero financed emissions by 2050.

Eight are ‘on-track’, two are ‘close to on-track’, and none

are ‘off-track’.

For more information, refer to pages 32-51 of the 2025

Climate Report available at anz.com/esgreport.

2030

Operational emissions

6

Reducing combined Scope 1 and Scope 2 emissions

by 85% by 2030 (against a 2024 baseline).

Having achieved our 2030 target of a 90% reduction

(against a 2015 baseline) earlier than expected, we have

revised our combined Scope 1 and Scope 2 emissions

reduction target with a more ambitious baseline year of

2024.

2030

Gender equity targets

6

Increase representation of women as Key Management

Personnel

7

to at least 40%.

Increase the representation of Women in Leadership by

1 percentage point from baseline of 40.5%.

Rebaselined targets for 2026.2026

15

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Improving non-financial
risk management

Material ESG issue

Non-financial risk

management

Strengthening non-financial risk

management is a strategic imperative

for ANZ to protect customers, enable

resilient operations, and sustain trust

in the bank’s integrity.

Robust non-financial risk management

practices underpin a strong, resilient bank

that delivers for all customers, and therefore

for shareholders. We acknowledge our

existing NFR management practices have

not always met expectations and

recognise we have more work to do to

uplift our management of NFR and to

improve risk culture across the bank.

Regulatory oversight

ANZ’s non-financial risk management

is a key priority for its core regulators.

On 3 April 2025, the bank confirmed

it had entered a court enforceable

undertaking (CEU) with APRA for matters

relating to NFR management practices

and risk culture across the Group. In

addition to accepting the CEU, APRA

required that ANZ to hold a further

operational risk capital overlay of $250

million, taking ANZ’s total operational risk

capital overlay to $1 billion.

ANZ’s response to the CEU

As part of the CEU agreed with APRA,

ANZ appointed an independent reviewer

to identify root causes and behavioural

drivers of shortcomings in ANZ’s

non-financial risk management

practices and risk culture.

The enterprise-wide review informed

the development of ANZ’s Root Cause

Remediation Plan (RCRP) which was

submitted to APRA on 30 September 2025.

The RCRP includes a defined set of Target

States and outlines deliverables across

seven core workstreams including

Governance, Accountability and Operating

Model, NFR Framework and Processes,

Culture, Performance and Remuneration,

Capabilities, and Data and Systems.

The RCRP was approved by APRA on

7 November 2025. Its approval marks

the next phase in the delivery of our

obligations under the CEU.

Delivering on the RCRP

ANZ has an opportunity to improve the

way it operates to ensure it is providing

customers a simple, efficient, and reliable

service that meets their needs, keeps its

promises, and consistently delivers the

experience they should expect from ANZ.

ANZ expects to spend approximately

$150 million on implementing the plan

required under the RCRP in 2026.

This will be funded by de-prioritising

other initiatives.

Delivering on the RCRP is a multi-year

process. This work will take approximately

three years with the first year dedicated

to design, followed by two years to

implement and embed.

ANZ will emerge a stronger, confident

organisation with solid risk management

and customers at its core.

ANZ have appointed Promontory to

provide independent assurance of its

progress against the RCRP and reports

outlining progress will be available on

anz.com.

Establishment of an

Enterprise NFR Program

To lead the bank in its NFR uplift and

response to the CEU, ANZ has established

an Enterprise Non-Financial Risk Program,

Program PACT (People, Accountability,

Customers and Trust).

Program PACT, alongside the prioritisation

of Critical Risk Programs (CRPs) like the

Retail ASIC matters and Global Markets

remediation responses, reflects a

commitment to deeply embed NFR

frameworks, governance (see "Settlement

of ASIC investigation" section on page 17),

practices and behaviours that improve

customer outcomes by driving sustainable

business outcomes and risk ownership

- underpinned by a proactive culture and

disciplined execution.

Over the next three years, the focus

of Program PACT is on demonstrating

that our approach to NFR management

is embedded and sustainable. It will be

measured not by task completion but

proof of:

Behavioural adoption

Reinforce a culture where risk is

proactively managed, and where

divisional leaders are empowered

- and expected - to own and

prioritise NFR management.

Governance maturity

Strong governance is the bridge

between intent and action. ANZ

is committed to ensure that the

systems, frameworks, and controls

introduced – not only for the

Enterprise NFR Program – are

consistently maintained and applied

to other programs across the bank.

Outcome delivery

Following behavioural change and

governance, ANZ committed to

deliver the intended outcomes and

demonstrate impact. ANZ needs

to do what it said it will do–on time,

to standard, and with external

validation from the Independent

Reviewer and APRA.

Continuous improvement

Across the bank, ANZ will be able to

consistently identify, detect, improve

on and fix NFR deficiencies.

16

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

ANZ's relationship
with regulators

ANZ has relationships with

more than 800 regulatory bodies

globally. These bodies play an

important role in enabling

financial stability, protecting

consumers, preventing fraud and

maintaining trust in the financial

system. ANZ is committed to

dealing with regulatory bodies

in an open, constructive and

cooperative way.

Responding to the CEU

ANZ’s response to the CEU

has culture at its core. Its

commitment extends beyond

the design, implementation,

and embedding of a

framework and system. It

encompasses critical focus

areas such as leadership,

NFR capability, and a

strengthened control and

process environment – all

of which is underpinned by

the enterprise-wide cultural

change the CEU requires.

The program is business

owned and led.

Settlement of ASIC investigation

On 15 September 2025, ANZ

announced it had reached an

agreement with Australia’s

financial regulator, ASIC, to resolve

five regulatory investigations into

our Australian Markets business

(Institutional) and Australia

Retail division.

Under the agreement, which is

subject to Federal Court approval,

ANZ has agreed to pay a total penalty

of $240 million. ANZ is undertaking

specific remediation programs in both

its Australia Retail division and Australian

Markets business, which have

interdependencies with the broader

matters covered under the APRA CEU.

Australia Retail

The agreement covers three key issues:

1. Hardship support – Some customers

didn’t receive timely support when they

were struggling financially, because ANZ

didn’t respond within required timeframes.

2. Deceased estates – ANZ didn’t always

respond to families in a timely way, and

some accounts were charged fees after

a customer had passed away.

3. Online Saver accounts – Some eligible

customers missed out on bonus interest

they were promised due to system and

process errors, and ANZ didn’t always

show correct rates on its application form.

Markets

The penalty for our Markets business

relates to two separate issues:

1. Role as Duration Manager for an

AOFM Bond Issuance

• ANZ was appointed by the Australian

Office of Financial Management (AOFM)

to act as the Duration Manager for

a large bond issuance in April 2023.

• ANZ agreed with ASIC that in its role as

Duration Manager, it didn’t adequately

communicate with the AOFM about the

intended manner of its trading or the

progress of its hedging activity, given

the timing and manner of ANZ’s trading.

This was unconscionable conduct.

• ANZ also failed to accurately report to

the AOFM after the transaction and in

doing so, made false or misleading

representations and agreed that in

carrying out its role as Duration

Manager, ANZ breached some of

its licence obligations.

• ASIC has not alleged that ANZ engaged

in market manipulation or over-hedging

on the AOFM issuance. All of ANZ’s

trading as Duration Manager was to

hedge the risk borne by it in connection

with our role.

2. Incorrect data reporting

ANZ provided inaccurate monthly

secondary bond turnover data to the

AOFM over a period of almost two years

and made a false annual attestation to the

AOFM about that data. ANZ also failed to

comply with its breach reporting

obligations in relation to the inaccurate

data reporting.

17

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

The Code requires that all ANZ
employees and contractors:

are ethical and professional; 

act with integrity; 

treat everyone with dignity and

respect; 

manage conflicts of interest; 

protect privacy and

confidentiality;

comply with the Code, policies

and the law; and

call out unacceptable behaviour

and stand up for what is right.

Code of Conduct

ANZ’s Code of Conduct

(the Code) sets the

standards for behaviour

expected at ANZ.

Our approach

The Code is supported by a suite of

policies that are regularly reviewed to

ensure they reflect legislative changes

and good practice.

ANZ also expects partners (including

suppliers, service providers and other

relevant third parties) to adopt and uphold

similar standards of ethical behaviour as

outlined in the Code and ANZ’s Supplier

Code of Practice. 

ANZ’s Code of Conduct is available at anz.

com/corporategovernance. For more

information on how ANZ is managing ESG

risks in our supply chain see page 41.

Training

To manage ethical conduct and

compliance with the Code, all employees

and contractors must complete

mandatory training courses within two

months of joining ANZ and regularly

thereafter.

Key mandatory training courses related

to the Code and its supporting policies

include:

• Living the Code

1

• Equal Opportunity (including anti-

discrimination and sexual harassment)

• Privacy, Data Protection and Ethics

• Conduct Risk

• Anti Money Laundering/Counter

Terrorism Financing

• Sanctions

• Anti-Bribery and Corruption

• Internal and External Fraud

• Whistleblowing

ANZ monitors the completion rate for

mandatory training courses, which was

99.86% enterprise-wide in 2025.

Employees who do not complete training

within 30 days of the due date (without

exceptional circumstances) are ineligible

for fixed remuneration increases or

variable remuneration payments during

the annual Performance and

Remuneration Review (PRR), ensuring

accountability and incentivising

compliance.

Performance management guides and

other materials are made available to all

employees on our intranet. This guidance

includes impacts to performance and

remuneration outcomes in our annual PRR

for employees who do not meet expected

standards of performance or behaviour.

Outcomes

We monitor compliance with the Code by

tracking employee relations cases, with

analysis of breaches and outcomes to

identify trends and areas for improvement. 

In 2025, there were 1,569 employee

relations cases involving alleged breaches

of the Code

2

, (1,400 in 2024) with 567

cases resulting in formal consequences

or the employee leaving ANZ. This was an

increase from 488 cases in 2024.

Outcomes following investigations of

Code breaches in 2025 included 337

warnings, 127 terminations and 103

employees otherwise leaving ANZ. 

A breakdown of alleged breaches of ANZ's

Code of Conduct is provided in the 2025

ESG Data and Frameworks Pack available

at anz.com/esgreport.

Matters relating to conduct were

highlighted in the court enforceable

undertaking from the Australian Prudential

Regulation Authority (APRA). More

information on these matters is available

on pages 16-17.

1. Completion of Living the Code requires participants to confirm their understanding of, and compliance with, the Code’s principles over the past year. 2. Includes Suncorp Bank.

Material ESG issue

18

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Whistleblower Program
Training

All employees and contingent workers

are required to undertake annual

mandatory training on their obligations

and responsibilities under the policy.

Whistleblower Investigators,

Whistleblower Protection Officers,

and eligible recipients of whistleblower

reports (including Executive Committee

1


and Board members) receive role-

specific training to help ensure they

understand their obligations under

applicable laws including how to

appropriately handle and, where

applicable, investigate reports.

Outcomes

We received 264 whistleblower reports

in 2025, an increase from 222 in 2024

2

.

This year, 61% of assessed reports were

within the scope of the Program. Reports

involved themes and allegations of

breaches of the Code of Conduct and

other policies; bullying and harassment;

discrimination; conflicts of interest; fraud;

maintaining safe work environments;

privacy and confidentiality breaches; and

other misconduct.

Recommended actions and outcomes

from investigated reports included

termination of employment, formal

warnings, coaching and informal

counselling, review and remediation of

policy, process and procedures, improved

oversight, additional training and

communications reinforcing expected

standards of behaviour.

1. Executive Committee (ExCo) comprises ANZ’s most senior executives. The members of ExCo are available at anz.com/exco. 2. Report volumes for 2024 include Suncorp Bank from

31 July 2024 to 30 September 2024. Suncorp Bank is also included for 2025.

Material ESG issue

Our approach

ANZ’s Whistleblower Policy and Program is a key component of our conduct

risk management and corporate governance framework. The Board has

oversight and governance of the policy and program. A de-identified

summary of material whistleblower matters is also reported to the relevant

Board committee quarterly and to the Operational Risk Executive Committee.

Program processes are also set out in the policy, including how eligible

whistleblowers can report concerns, the protections that will apply, how the

concerns will be considered and/or investigated, and resources.

Key actions in 2025

Introduced a new external whistleblower reporting, and integrated case

management and reporting service.

Delivered 201 awareness sessions to business units by the Group Integrity

team who conduct investigations into allegations of internal fraud, theft,

bribery, corruption and insider crime involving ANZ employees and

contractors.

Jurisdiction and business specific awareness sessions delivered by the

Program team designed to build trust in the process and program,

improve understanding of whistleblower protections, and promote

available channels.

Updated the Program’s training course for eligible recipients of

whistleblower reports.

ANZ’s annual employee survey indicated continued high levels of awareness and

confidence in the program, and reporter protections across the organisation.

ANZ’s Whistleblower Policy is available

at anz.com/corporategovernance

19

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experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Putting our customers first
Material ESG issue

We acknowledge that, at times,

we have let our customers down.

Despite our good intentions, we have

not consistently lived up to their

expectations.

In particular, some of our failings occurred

when our customers were at their most

vulnerable. For this we are deeply sorry, and

we are making changes to better support

our customers when they need us most.

On 15 September 2025, ANZ announced

it had reached an agreement with the

Australian Securities and Investments

Commission (ASIC) to resolve five

regulatory investigations into our Australian

Markets business (Institutional) and

Australia Retail division.

For our Australian Retail division this

includes three key issues: hardship

support, deceased estates and Online

Saver accounts – as covered on page 17.

We have established an ASIC Matters

Resolution Program in Australia Retail,

ensuring we bring the appropriate

governance, oversight and accountabilities

to resolve these and other outstanding

ASIC regulatory matters.

We will not accept these sorts of failures

that impact on our customers: it is why we

are committed to driving a company-wide

transformation to uplift non-financial risk

(NFR) to strengthen our core processes,

systems and controls.

However, it’s important to note that we

are not uplifting NFR simply to meet

regulators’ expectations. We are doing it

because it is better for our customers

and the quality of our business.

This uplift is already underway with

measurable improvements across the

bank to better protect and care for

our customers. For example, we are

rebuilding the customer proposition for

deceased estates, including improving

both response times to freeze accounts

after being notified of a customer's

passing, and responding to beneficiaries

and executors in formalising their estates.

We also discuss on the next pages

our approach to hardship, supporting

customers with extra care, customer

complaints, prioritising access for

low-income customers and

enhancements we have been making

in line with the revised Banking Code

of Practice.

A key pillar of our refreshed strategy,

ANZ 2030, is putting our customer first.

With market leading, differentiated and

superior propositions, we will raise the

standard of every digital and human

interaction for our customers.

We are also re-engineering and

automating lending submissions and

manual processes, and using artificial

intelligence to improve, among other

things, quality control and complaints

analytics.

We are acutely aware that delivery and

execution are central to our ability to meet

and exceed the expectations of our

shareholders, customers and colleagues.

Further information on our ANZ

2030 strategy is provided in the

2025 Annual Report available at

anz.com/annualreport

For more information on how

ANZ is improving non-financial

risk see pages 16-17

20

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

1. Non-Financial Risk Framework are procedures that define how ANZ employees should consistently and effectively identify, assess, manage, monitor and report on non-financial risk.
2. Customers of the participating banks who lived in the Indigenous pilot locations or received ABSTUDY payments between 1 July 2019 and 31 August 2024 and customers (where

identifiable) who interacted with a participating bank’s specialist Indigenous service channels such as an Indigenous call line. 3. Customers who qualify for remediation and identified as

eligible for a basic account between the review period (July 2019 – June 2025). A portion of these customers have either moved to a basic account, may be included in future

migrations, or are no longer eligible for migration.

We continue to prioritise access

for low-income customers to

products and services that best

meet their needs, having already

simplified the account opening

process by removing the

requirement to prove eligibility for

basic accounts in branches. In

addition, we continue to enhance

our banking services to provide more

inclusive and accessible banking

services for First Nations customers.

Suncorp Bank

ASIC also engaged with Suncorp

Bank on refunding fees to low-

income Australians. Suncorp Bank

has committed to refund more than

$3 million to over 43,000 eligible

customers, which commenced in

2025 and is expected to conclude

in 2026. Customers will receive an

amount greater than the fees

originally incurred to account for the

time value of money. Suncorp Bank

has implemented an opt-out

migration to a low-fee account,

moving 7,260 customers over the

months of May and June 2025.

Going forward this opt-out migration

process will occur on a semi-annual

basis.

Revised Banking

Code of Practice

During the year, ANZ’s Australia Retail

and Australia Commercial divisions,

and Suncorp Bank implemented key

enhancements in line with the revised

Banking Code of Practice (the Banking

Code) which came into effect on

28 February 2025. The ANZ Non-

Financial Risk Framework

1

and Policy

have governed compliance with the

Banking Code of Practice this year.

Key enhancements to the Banking

Code included:

• new deceased estates provisions;

• expanded definitions of small

business and vulnerability;

• a new requirement for banks to

meet with prospective guarantors

before accepting a guarantee; and

• requirements for banks to organise

free interpreter services where

appropriate.

The Banking Code is important to

our customers because it provides

consumer protections, which often

go beyond the law.

ANZ is tracking the effectiveness

of the changes through various

mechanisms, including monitoring

how key processes are working in

practice, relevant training completion

by employees, preventative and

detective controls, and monthly

reviews of complaints and risk events

to identify incidents of non-

compliance and identify uplift

opportunities.

ANZ and Suncorp Bank continue to

report breaches to the Banking Code

Compliance Committee as required

and respond to its inquiries and

requests for information.

Key actions in 2025

Providing low-income

customers access to products

and services that best suit them

In July 2025, the Australian Securities

and Investments Commission (ASIC)

released the Better and beyond report

(Report 811), highlighting follow up

work from its Better banking for

Indigenous consumers report in July

2024 (Report 785).

We have delivered several

commitments as part of ASIC’s review

in 2025. These include:

Providing approximately

$2 million in refunds to

customers in ASIC’s project

cohort

2

.

Committing to refund more than

$50 million to approximately

600,000

3

low-income

customers nationally in 2026.

Moving over 300,000 eligible

customers to a basic account

(low or no fee accounts).

We have committed to continuing

to migrate eligible customers to basic

accounts on an ongoing basis.


21

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experience

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Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Our approach
ANZ aims to provide extra care to

customers who may be experiencing

vulnerability, while also taking measures

to enhance access to its banking

products and services.

Australia

1

ANZ’s Australia Retail and Australia

Commercial divisions have High Impact

Processes (HIPs) in place for specific areas

where customers may experience greater

levels of detriment if we fail to provide

extra care. HIPs aim to ensure the bank’s

processes with the greatest potential

impact to customers requiring extra

care are operating effectively and are

appropriately governed. HIPs related to

supporting customers in need of extra

care were introduced during the year

including culturally appropriate and

accessible banking for First Nations

customers and supporting victim-

survivors of family violence.

In September 2025, ANZ entered into an

agreement with the Australian Securities

and Investments Commission (ASIC) to

resolve five matters within our Australian

Markets business and Australia Retail

Supporting customers

in need of extra care

division that were the subject of separate

regulatory investigations, including

matters relating to hardship support

and deceased estates. The agreement

with ASIC sends a clear signal that our

approach to delivering good customer

outcomes needs to improve. For more

information on these matters and how

we will improve see pages 16-17.

Training

Building our capability remains a focus

area, equipping employees to recognise

when a customer is experiencing

vulnerability and respond to their

circumstances with tailored support.

In preparation for commencement of

the revised Banking Code of Practice

in February 2025, ANZ reviewed and

enhanced its suite of related training and

resources, including to ensure it aligned

with the new strengthened provisions

around vulnerability, accessibility and

inclusivity. This training is mandatory for

employees in the Australia Retail and

Australia Commercial divisions who

engage directly with customers or who

support others who engage directly

with customers.

ANZ’s Extra Care Hub (ECH) is a

specialised pathway team of trained

bankers whose role is to support

customers impacted by family violence,

financial abuse or cognitive capacity

concerns. In 2025, the ECH team almost

doubled, enabling them to extend support

to additional teams including Customer

Protection, Financial Wellbeing Assist and

Mobile Lending. The ECH’s contact details

Key actions in 2025

Resources and support

available to our customers

available online:

Dealing with the

unexpected

Family violence support

Financial hardship

First Nations Customer

Support Line

are available via the ANZ website, the

ANZ App and internet banking platforms,

allowing for faster access and responses

to customers requiring assistance. In

2025, the ECH team assisted more than

5,500 customers, a 101% increase

from 2024.

In 2025, we continued to partner with

Uniting CareRing to support customers

impacted by family violence. CareRing

connects customers to services

including housing support, social

workers, drug and alcohol support,

employment services and financial

counselling.

Last year, we reported on a pilot

program involving the use of dynamic

algorithms to identify indicators of

financial abuse. In 2025, this program

was made permanent.

1. Excludes Suncorp Bank.

Material ESG issueMaterial ESG issue

Additionally, through our partnerships with

external organisations, training has been

provided on specific areas of focus. For

example, providing extra care to customers

who are incarcerated, or recently released from

incarceration, is a new characteristic listed in

the revised Banking Code of Practice. About

Time, in conjunction with ICAN Learn, delivered

training to complaint-handling employees in

Customer Resolution on the experiences of

people in prison and their challenges

maintaining and regaining financial

independence. Additionally, training has been

provided to our specialised teams, such as

the Extra Care Hub, on financial abuse.

Vulnerability impacts people in different ways. It can reduce

a customer’s ability to engage with banking services,

make informed decisions, consider choices, and evaluate

information. These consequences may affect the way that

the customer engages with their bank.

22

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

New Zealand
Our approach

ANZ Bank New Zealand supports customers needing extra

care through a structured and compassionate approach.

This is achieved by empowering and coaching employees to recognise signs

of vulnerability and respond with empathy. When further support is required, employees

can access internal resources or escalate complex cases to the Customer Vulnerability

Team via a specialised pathway. Where a case is more complex, they will work with

cross-functional teams to find the appropriate solution.

Our branch network

Over the past decade, we have

seen a long-term shift in how our

customers choose to bank with us,

with the number of customers

coming into a branch for transactions

reducing significantly.

We understand however that there

are many occasions where it’s

important for our customers to

engage with us via our customer

contact centre and our branch

network. Our branch bankers both

assist and educate our customers on

how to navigate their banking needs

in a safe manner. We continue to

operate a large network of branches,

offering access to specialist bankers

across Australia’s metropolitan and

regional hub locations. Branches also

provide access to cash withdrawals

and deposits via telling services or

Smart ATMs.

In the event that we make changes

to individual branches within our

network, analysis of customer

behaviour is considered before

decisions are made. We also aim to

proactively contact our customers,

prioritising those requiring assistance

with their banking.

Under the Federal Treasurer’s approval

conditions for purchasing Suncorp

Bank, the number of Suncorp Bank

and ANZ’s regional bank branches

may not be reduced during the three

years from the date ANZ acquired

Suncorp Bank.

Escalation volumes are tracked by the Customer Vulnerability Team to help

ANZ Bank New Zealand maintain effective support and ensure appropriate care is

provided. Following targeted training for senior customer-facing leaders in late

2024, escalation volumes doubled, indicating improved employee awareness and

responsiveness. These escalations enable earlier intervention and more

consistent support for vulnerable customers. Escalation data is reported to the

New Zealand Leadership Team and the ANZ New Zealand Board.

In 2025, ANZ Bank New Zealand further strengthened governance by appointing

a dedicated manager to uplift our approach to customers requiring extra care and

lead initiatives. These include strengthening our Vulnerability framework to

enhance governance, improve processes, and provide guidance to support

customers experiencing vulnerabilities. The framework builds on ANZ New

Zealand Bank’s existing processes, guidance, and specialist teams, to bring them

together in a cohesive and structured way.

Key actions in 2025

IMAGE TBC

 

Building our capability

remains a focus area,

equipping employees

to recognise when a

customer is experiencing

vulnerability and respond

to their circumstances

with tailored support.

23

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Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Financial hardship Financial hardship
While financial conditions have begun to ease across Australia and

New Zealand, higher inflationary environments continue to influence

borrowing and household spending – shaping broader economic

resilience. There are occasions when customers are unable to meet

their financial obligations. While in some cases these difficulties

are temporary, others may be prolonged or permanent, requiring

tailored support and careful review to restore financial stability.

Australia

1

Our approach

Our teams are trained to have respectful

and empathetic conversations to identify

the options that are appropriate for each

customer’s individual circumstances.

They are also trained to identify hardship

triggers and support customers

holistically, considering all lending facilities.

Data-driven insights play a critical role

in early identification of customers at risk

of hardship. Analysis of savings, credit,

and offset accounts allows us to

proactively contact customers who may

have experienced a significant income

reduction or are receiving unemployment

benefits.

Available assistance includes:

Temporary reduction or pause

of repayments

Interest-only repayment periods

Loan restructuring, including

capitalisation of late payments

Access to financial literacy

programs, MoneyMinded and

Saver Plus

Debt reduction and, in exceptional

cases, debt forgiveness

Referrals to external support

services

2

– Way Forward Debt

Solutions, CareRing, Fitted for Work,

and 1800RESPECT

Referral to financial counselling

via the National Debt Helpline and

Small Business Debt Helpline

In October 2025, we launched our

refreshed strategy, ANZ 2030. Under the

customer first pillar of ANZ 2030, we

aspire to raise the standard of every digital

and human interaction for our customers.

Further information on our strategy is

provided in our 2025 Annual Report

available at anz.com/annualreport.

Current environment

With continued cost-of-living pressures,

we expect the number of customers

facing hardship to persist.


In 2025,

Australian customers that were new in

hardship and receiving assistance

3

remained steady at 13,931, compared

to 14,031 in 2024.

Currently 4 in every 1,000 Australian ANZ

home loan customers and approximately

2 in every 1,000 Australian ANZ small

business customers are receiving hardship

assistance.

Importantly, over 68% of customers who

entered hardship have either paid out their

facility in full or are up-to-date on their

repayments within 12 months.

Over the past 12 months, we have

proactively contacted more than 191,000

home loan customers to review the

suitability of their loan arrangements.

Interventions ranged from early hardship

offerings to payment reminders, with

on-time payments improving by an

estimated 24% among contacted

customers.

Settlement of ASIC

investigation

In Australia, financial hardship practices

are governed by multiple regulators and

bodies as well as the Banking Code of

Practice and National Credit Code.

In September 2025 ANZ entered into an

agreement with the Australian Securities

and Investments Commission (ASIC) to

resolve five matters within our Australian

Markets and Australia Retail businesses

that were the subject of separate

regulatory investigations.

Under the agreement, which requires

Federal Court approval, ANZ is subject

to a $40 million penalty for breaching its

obligations in relation to its handling of

customer hardship notices. ANZ failed to

respond to 488 Australian customers’

hardship notices within required

timeframes and failed to have proper

hardship processes in place.

1. Excludes Suncorp Bank. 2. Way Forward Debt Solutions provides free debt management services to assist people struggling to manage multiple debts to establish affordable

arrangements with their creditors and assist management of debt repayment. CareRing connects customers to a coordinated range of support services including housing support,

social workers, drug and alcohol services, home energy assessments and employment services. Fitted for Work supports female-identifying jobseekers to improve their employment

prospects by developing a résumé, writing a cover letter and provisioning appropriate work clothes. 1800RESPECT is a domestic family and sexual violence counselling service. 3. The

statistic quoted uses underlying data which captures the number of accounts which are receiving hardship assistance, which include Home Loans, Personal Loans, Credit Cards and

Small Business Banking. Multiple customers can be a party to an account. As of September 2025.

For further information on ANZ’s

financial hardship assistance is

available at anz.com/financial-

hardship

For more information on ANZ’s

settlement of ASIC’s investigation

see page 17

Material ESG issue

24

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

The results of the pilot proactive
calling program showed:

Contacted customers were

38%

less likely

to become delinquent.

47%

took positive action such as

hardship applications, loan term

extensions, interest-only

arrangements.

New Zealand

Our approach

ANZ Bank New Zealand's approach to

hardship includes working with customers

to explore options to help them through

difficult times and provide financial

assistance.

Available assistance includes:

Repayment arrangements

Temporary pause of repayments

Interest-only repayment periods

Loan restructuring, including

capitalisation of late payments

Debt consolidation

Debt reduction and, in exceptional

cases, partial or full debt forgiveness

Interest rate concessions

Referral to financial counselling

via MoneyTalks (free financial

mentoring)

Hardship practices in New Zealand are

governed by the Credit Contracts and

Consumer Finance Act (CCCFA), which

outlines obligations for lenders in

supporting customers experiencing

financial hardship.

Further information on ANZ Bank

New Zealand's financial hardship

support is available at anz.co.nz/

banking-with-anz/financial-

hardship/

Key actions in 2025

A review of 2,951

ANZ Bank New Zealand

customers who exited

hardship treatment in the

six months to July 2025 was

conducted to understand

the outcomes from our

hardship assistance.

The results showed

91%

of customers have either paid

off their facility in full or are up-to-date

on their repayments, indicating that

most hardship events are temporary

and treatments are effective.

9%

of customers transitioned to active

Customer Financial Wellbeing (CFW)

case management, requiring longer-

term support.

In 2025, the number of New Zealand customers newly receiving hardship

assistance increased 19% from 4,021 in 2024 to 4,780 in 2025. Common

hardship drivers remained consistent and included redundancy, reduced

working hours, illness, relationship breakdowns, and financial stress due to

interest rates and living costs.

In 2025, leveraging enhanced data analytics to identify customers at risk of

missing payments, ANZ conducted outreach via the goMoney App and SMS

to the top 2% of at-risk customers identified, with over 135,900 messages

sent. The aim was to encourage customers to engage with ANZ if support

was needed.

In addition, a pilot proactive calling program was run, targeting a cohort of

high-risk home loan customers each month, with the aim to provide early

intervention support.

25

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experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Customer complaints
Data relating to complaints in Australia

and New Zealand is available in our

2025 ESG Data and Frameworks Pack

available at anz.com/esgreport

1. Suncorp Bank has retained their Complaints Management Policy. Following the acquisition on 31 July 2024, Suncorp Bank commenced a phased transition to adopt the policies and

processes of ANZ. During the transition period Suncorp Bank will be subject to a combination of ANZ and Suncorp Bank policies, outlined on page 2. 2. Excludes Suncorp Bank.

3. Multiple categories may be allocated to a single complaint.

Our approach

Our process is governed by our

Complaints Handling Policy

1

, and Australia

and New Zealand each have a Complaints

Guide. We strive to deliver excellent

products and services to our customers,

but when we get things wrong, we are

committed to working with customers to

understand what’s happened and to try

to resolve the complaint promptly.

Customers can lodge a complaint with

ANZ online or with customer-facing

employees for Retail and Commercial

in Australia and through a number of

channels in New Zealand. We strive to

resolve complaints at first point of contact

and where additional support is required

complaints are escalated to internal

specialist complaint resolution teams in

Australia and New Zealand to work with

the customer to do our best to find a fair

and timely resolution.

If a customer is not satisfied with the

proposed resolution of their complaint,

they can escalate their complaint to the

Australian Financial Complaints Authority

(AFCA) or the New Zealand Banking

Ombudsman Scheme (BOS).

Complaints data and insights are

analysed and regularly reported to

senior management with a key focus

on monitoring performance, complaint

volumes, trends, actions being taken to

address complaint drivers, and customer

experience improvements.

Australia

2

Outcomes

Throughout 2025, Australia Retail

deployed a number of initiatives to support

complaint transparency, including:

• complaint awareness sessions for

frontline bankers to enhance their ability

to detect complaints and accurately

capture relevant information; and

• an automated complaint detection tool

to identify complaints received via the

Message Us service in the ANZ App.

These initiatives are helping our bankers

more effectively recognise and respond

to complaints. These uplifts contributed to

a material increase in the number of

complaints recorded through the year of

44%, but also improved the insights into

customer pain points allowing targeted

service improvements.

Despite the increase in the volume of

complaints, prompt resolution remained

a priority with 86% resolved within five

working days (2024: 83%) and

approximately 99% of all complaints

resolved within the 30-calendar-day

timeframe (2024: approximately 99%).

Further comprehensive guidance and

training have been developed for Australia

Retail and Commercial employees. The

first phase of the rollout commenced with

the Leadership Team in June 2025,

followed by a broader rollout scheduled

for November 2025.

The core complaint categories

3

included

service quality, account set-up and

maintenance, channel accessibility, fees,

interest and rewards, and fraud and

scams. Service quality accounted for 28%

of total complaints received (2024: 31%),

followed by channel accessibility

accounting for 20% of total complaints

received (2024: 16%).

ANZ continues to report internal

complaints data to the Australian

Securities and Investments Commission

(ASIC) on a six-monthly basis.

A Complaint Governance Forum is held

monthly and provides end-to-end

oversight of the Australia Retail and

Australia Commercial disivions' complaint

handling processes with a key focus on

monitoring the performance and

effectiveness of these processes,

complaint volumes, trends and themes

including actions being taken to address

complaint drivers. Complaints data and

insights are also reported to the Board and

the Operational Risk Executive Committee

on a six-monthly basis.

New Zealand

Outcomes

This year, ANZ Bank New Zealand

recorded over 33,800 complaints, a

decrease of 3.8% compared to 2024. ANZ

Bank New Zealand have also seen a 40%

decrease (from 70 in 2024 to 42 in 2025),

in complainants seeking an independent

review from BOS of their concerns and our

resolution offer due to a decrease in fraud

and scams complaints. We continue to

identify insights and opportunities to

improve, from complaints managed

internally and those that require escalation

to BOS, and continuously refine our

complaints handling approach to

consistently target a fair and balanced

outcome.

Fees, charges and rates accounted for

41% of total complaints received, with

'fee, charge or rate excessive/unfair' the

top issue in 2025. 'Personal transaction

account', 'Credit card', and 'Home Loan'

were the products with the most

complaints, in line with the higher share

of customers who hold these products.

The most common concerns included

'Fee, charge or rate excessive/unfair',

'Error with fee, charge or rate', and 'Failure

to act as instructed/promised'.

The percentage of complaints resolved

within five working days increased to

90%, compared to 89% in 2024; and the

percentage of complaints resolved within

30 calendar days of receipt increased to

98% compared to 97% in 2024.

More information on Australia’s

customer complaints process is available

at anz.com/support/complaints

More information on ANZ Bank New

Zealand’s customer complaints process is

available at anz.co.nz/about-us/

complaints

Complaints are an important

way for our customers to voice

their concerns, and for us to

learn where we can improve

our products and services to

deliver better outcomes for

our customers.

Material ESG issue

26

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Material ESG issue
Refer to the 2025 Climate Report

for relevant Indexes, available at

anz.com/esgreport

Our Climate and

Environment Strategy

1. Our disclosures do not purport to be comprehensive

or to satisfy all aspects of GFANZ or TPT’s framework.

2. The Climate Change Commitment excludes Suncorp

Bank and ANZ Bank New Zealand. 3. For further detail

on ANZ’s approach for assessing the eligibility of

transactions for inclusion towards the target, refer to

the ANZ Social and Environmental Sustainability Target

Methodology available at anz.com/esgreport. 4. Refer to

the 2025 Climate Report available at anz.com/esgreport

including Appendix 7 Scope 1, Scope 2 and Scope 3

Operational Greenhouse Gas Emissions Reporting

Methodology. 5. Refer to the 2025 Climate Report

including Appendix 5 ANZ Financed and Facilitated

Emissions Methodology available at anz.com/esgreport.

6. Applying to ANZ Group for the financial year

commencing 1 October 2025.

Our vision at ANZ is to finance a sustainable transition. Our Climate and Environment Strategy

(C&E Strategy) sets out our objective to be a trusted partner for our customers, supporting

them to adapt and become more resilient to a changing environment and economy.

In particular, we aim to be a leading bank in supporting an effective and orderly transition for

our large business customers.

We have established three core

ambitions, supported by four action

pillars that bring together the themes of

the steps we are taking to deliver on our

ambitions. These ambitions and action

pillars are supported by having specific

focus areas and prioritised action plans

for our Institutional, Australia Commercial,

Australia Retail and New Zealand divisions

that we commenced implementing

aspects of this year.

Our approach to

transition planning

In 2025, we took further steps to progress

our transition planning. Our C&E Strategy

forms the basis for our approach,

including how we plan to support an

effective and orderly transition for our

large business customers. We also draw

on guidance from the Glasgow Financial

Alliance for Net Zero (GFANZ) and the

Transition Plan Taskforce (TPT) transition

planning frameworks to inform areas of

focus in our C&E Strategy.

Our C&E Strategy ambition is supported

by our Climate Change Commitment of

transitioning our lending portfolio to

net zero financed emissions, reflecting

where we can have the most significant

impact. We estimate our lending to

Institutional customers contributes

approximately two-thirds of our total

financed emissions. The remaining

financed emissions arise from our lending

to our commercial and retail customers.

Our Climate Change Commitment will

be available prior to our Annual General

Meeting at anz.com/climate-change.

2

The actions under our C&E Strategy

demonstrate our progress towards

credible transition planning. We

acknowledge that ongoing work is

required to satisfy a robust and well-

developed transition plan.

In this report, we set out the actions we

have progressed and how we have been

supporting our customers’ transition.

Our climate and

environment targets

Our climate and environment targets

support the delivery of our C&E Strategy.

We continue to make progress, including

funding and facilitating $84.72 billion

towards our $100 billion target in social

Financing a sustainable transition

Vision

Building our capability to help

customers understand climate

and nature risks

Transitioning our lending

portfolio to net zero financed

emissions

Supporting our customers’

transition and resilience

Ambition

Understanding risks

and opportunities

Building capability

and capacity

Driving customer

engagement

and propositions

Collaborating with

stakeholders to support an

economy wide transition

Action

pillars

and environmental activities

3

by 2030.

Separately, eight of our revised sectoral

pathways are ‘on-track’, two are ‘close

to on track’, and none are ‘off track’. We

also recognise our role in reducing the

emissions from our operations and have

continued to reduce our Scope 1 and

Scope 2 emissions across our operations.

4


Refer to the 2025 Climate Report available

at anz.com/esgreport for further details

on our 2025 climate and environment

targets and progress, including our

sectoral pathways.

5


Reflecting the upcoming mandatory

climate disclosures in Australia

6

and a

changing internal and external operating

environment – we are reviewing our

climate and environment targets to ensure

they continue to be relevant and aligned

with our strategy.

27

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

How we are driving our C&E Strategy ambitions
The below initiatives and activities illustrate how our actions connect to our three

ambitions, supporting the progress of our C&E Strategy in 2025.

Ambitions

Implementing our Large Emitters Engagement Program


Supporting our customers’ transition through financing


Understanding nature risks and opportunities


Building our capability to help our customers understand climate and nature risks


Collaborating with stakeholders to support an economy wide transition

Managing climate risk


Progress on our targets and metrics

For further information see the 2025 Climate

Report available at anz.com/esgreport

Our future focus

We continue to evolve our approach to enable us to deliver

our C&E Strategy ambitions.

Building our capability to

help customers understand

climate and nature risks

Improve our understanding of

how climate and nature risks

and opportunities affect

customers and our lending

portfolio by continuing to

focus on training, data and

tools used to support our

customer engagement.

Transitioning our lending

portfolio to net zero

financed emissions

Continue to engage with our

LEEP and certain sectoral

pathways customers to support

our commitment to transition our

lending portfolio to net zero.

Continue to integrate climate risk

and opportunities into policies,

financing and risk decision

making where relevant.

Supporting our

customers’ transition

and resilience

Enhance customer

propositions and

engagement to support

our customers’ transition

and improve their resilience.

28

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Material ESG issue
Supporting our customers’

transition through financing

1. This is the first year we have included direct investment contributions towards our target. To limit complexity, we have not included those made prior to 8 November 2024 (publication

of the latest version of the target methodology) and those on or after 8 November 2024 where the overlapping facilitation amount in relation to the relevant bond issuance was included

towards the target under the version of the target methodology that applied before 8 November 2024. 2. 2025 includes transactions validated as eligible for inclusion in the target from

21/09/2024 to 19/09/2025. 3. Funded $42.09 billion includes deals in “Waste” and “Water” which have deal values less than $0.10 billion. 4. Note that for the purposes of this reporting,

Sustainability-Linked transactions (i.e., where the economic characteristics (e.g., pricing outcomes) of the financial instrument are linked to predetermined sustainability performance

objectives) are reported as a separate category. 5. Includes activities which cover both environmental and social categories. 6. Includes renewable energy, energy efficiency, clean

transportation, green buildings, and other environmental activities. Other environmental activities include activities which cover multiple environmental categories and/or activities such

as waste, sustainable water and waste water management, and climate change adaptation. 7. Includes construction or operation of buildings or portfolios of buildings that deliver

positive environmental outcomes, which meet, or renovation or retrofitting of buildings, so that they can meet regional, national or internationally recognised standards or certifications

(e.g., under the Australian NABERS rating system). 8. Includes affordable housing and other social activities. Other social activities include activities which cover multiple social

categories and/or activities such as socioeconomic advancement and empowerment.

Progress towards our $100 billion social and environmental

sustainability target – 1 April 2023 to 30 September 2025

Facilitated

$38.96

billion

14.93% Social and Environmental

$5.82b Other social and environment

5

27.90% Sustainability-Linked

4

$10.87b Sustainability-Linked

51.22% Environmental

6

$1.49b Clean Transport

$

10.72b Energy

$

4.35b Other environment

$

3.40b Green building

7

5.94% Social

8

$0.20b Aordable housing

$

2.12b Other social

Direct

investments

$3.67

billion

$0.73b Green

$0.47b Social

$2.47b Sustainability

Funded

$42.09

billion

3

1.35

% Social and Environmental

$0.57b Other social and environmental

5

1.45

% Sustainability-Linked and Environmental

$0.61b Sustainability-Linked and Environmental

40.32% Sustainability-Linked

4

$16.97b Sustainability-Linked

8.51

% Social

8

$2.04b Aordable housing

$1.54b Other social

$1.93b Clean Transport

$8.83b Energy

$7.95b Green building

7

$1.55b Other environment

48.37% Environmental

6

For further detail on ANZ’s approach

for assessing the eligibility of customer

transactions and direct investments for

inclusion towards the target, refer to

the ANZ Social and Environmental

Sustainability Target Methodology

available at anz.com/esgreport

This year, we continued to make good

progress towards our target to fund and

facilitate at least $100 billion by end

2030 in social and environmental

activities through customer transactions

and direct investments by ANZ.

As at 30 September 2025, we have

contributed $84.72 billion in total towards the

target since it commenced on 1 April 2023.

The total comprises funding and facilitating

$81.05 billion across 412 customer

transactions and directly investing $3.67 billion

through 61 labelled green, social and

sustainability bond purchases held on ANZ’s

balance sheet.

1

This includes activities that

aim to help lower emissions, protect or restore

nature, increase access to affordable housing

and promote financial wellbeing.

This year, we exceeded our 2025 goal to

contribute at least $18.5 billion towards our

target, with $45.75 billion added across 186

customer transactions and 61 bond

purchases.

2

This comprised:

• $21.86 billion attributed to ANZ’s on-

balance sheet loans and other credit lines;

• $20.22 billion facilitated by ANZ; and

• $3.67 billion via direct investments (labelled

bond purchases) held on ANZ’s balance

sheet.

In order to count towards the $100 billion

target, customer transactions and direct

investments are assessed against the criteria

for eligible banking activities and eligible social

and/or environmental activities specified in the

methodology for the target. They may include:

• labelled sustainable finance;

• unlabelled banking activities; and

• ANZ’s direct investments.

29

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

MoneyMinded
MoneyMinded is ANZ’s flagship

financial education program,

supporting adults on lower incomes

to build their financial skills,

knowledge, and confidence. The

program is delivered by community

organisations in Australia and

New Zealand as well as by community

organisations and ANZ employees

in 15 markets across Asia and the

Pacific region.

MoneyMinded’s success relies on

ANZ’s partnerships with community

organisations and individuals who are

best-placed to deliver the program

within vulnerable and disadvantaged

communities.

In Australia, community professionals

working in client facing roles within the

not-for-profit sector are eligible to attend

MoneyMinded Coach Training, delivered

in person and virtually across the country.

Accredited Coaches are provided access

to resources to use with their clients free

of charge.

This year, MoneyMinded in New Zealand

was extended by partnering with budgeting

providers to reach more communities in

need.

In the Pacific, five new community

partnerships were established – including

three in Fiji and two in Timor Leste – to

support the delivery of MoneyMinded.

More than 1.1 million people have

participated in ANZ's financial education

programs, since 2002. 126,422

participated in the program this year,

including 107,236 in Australia, 18,596

across Asia and the Pacific, and 590 in

New Zealand. Feedback from Coaches

and participants about the impact of

MoneyMinded is available in our annual

Impact Report at anz.com/moneyminded.

Building digital confidence

To further support vulnerable

communities, new MoneyMinded content

designed to build digital confidence and

capability using digital devices was

introduced this year. The Digital

Confidence module starts with the basics

of how to use a device and participate

online safely and builds skills to engage

with internet and mobile app banking.

Financial

education

programs

Financial literacy is an

essential skill in modern

society – our programs

build the financial

capability and wellbeing

of individuals so they

can be more resilient

to changes in their

financial circumstances.

We have developed financial

education programs in consultation

with community partner

organisations and government.

These programs aim to provide

real social benefits to the

community by improving financial

inclusion and capability of lower

income individuals.

In partnership with ANZ, The Smith Family

is offering specialised training in this

new module to all existing MoneyMinded

Coaches as they begin to use the

resources with their clients. For more

information on how ANZ is supporting

customers in need of extra care see

pages 22-23.

Doug Taylor

CEO, The Smith Family

“We are thrilled ANZ is taking steps to work with

community partners to improve digital literacy and

confidence in the community. We recognise that

technological advancements can disproportionately

affect those already facing financial challenges, and

the Digital Confidence module will directly support

those who need it most.”

Material ESG issue

30

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

MoneyBusiness in Australia
MoneyBusiness was developed

in partnership with the Australian

Government to build the money

management skills and financial

confidence of First Nations people

in 2005.

In 2025, supported by the Australian

Government Department of Social

Services, ANZ partnered with Indigenous

Consumer Assistance Network (ICAN),

a First Nations training organisation to

expand the reach of MoneyBusiness.

During the year training was delivered

across Australia including remote

communities in Western Australia,

South Australia and the Northern Territory.

MoneyBusiness Coach Training is a

two-day program for community

professionals working in First Nations

communities. The strength-based training

equips and prepares MoneyBusiness

Coaches with practical tools and resources

to use with their clients. “The training has

given me valuable resources to use with

participants and in my own personal life

which will help with financial decision

making and goal setting” said a recent

MoneyBusiness Coach Training attendee.

Saver Plus

Saver Plus is a matched savings and

financial education program developed

in 2003 by ANZ and the Brotherhood

of St Laurence. Funded by ANZ and the

Australian Government, Saver Plus is

delivered in partnership with Berry Street,

Brotherhood of St Laurence, and

The Smith Family.

The Saver Plus program supports lower

income earners to build a savings habit,

access financial education and receive

matched savings of up to $500 from

ANZ to support their own, or their

children’s, education.

More than 4,000 Australians

participated in Saver Plus this year,

totalling approximately 66,700 since

2003 who have saved over $32.8 million

and received more than $27.9 million

in matched savings from ANZ for

education costs.

More information about the impact

of Saver Plus is available in our impact

reports at anz.com/saver-plus.

Saver Plus in the Pacific

In 2024, ANZ set a target to pilot a

savings program (Saver Plus) for people

on lower incomes in Fiji and Vanuatu by

the end of 2025, with at least 80% of

participants having demonstrated a

savings habit upon completion.

In Fiji, 60 participants consisting of market

vendors and farmers that supply to the

Suva, Nausori and Ba municipal markets,

successfully completed the program,

saving FJ$36,981 collectively, with ANZ

contributing FJ$29,039 in matched

savings. In Vanuatu, 28 participants

collectively saved VT$1,572,529 with

ANZ matching VT$701,200.

A Saver Plus pilot is also underway in the

Solomon Islands, with 23 market vendors

expected to complete the program in

December 2025.

Suncorp Bank has also partnered with the

Financial Basics Foundation since 2017

as part of their commitment to supporting

young people and building up their

financial confidence. More information

is available at suncorpbank.com.au/

about-us/partnerships/financial-basics-

foundation.html

More information about ANZ’s ESG

targets can be found on pages 13-15.

Further information on the launch of the

Saver Plus pilot in Fiji and Vanuatu can

be found on page 42. More information

on financial wellbeing can be found at

anz.com/financialwellbeing

Meet Jan, a domestic

and family violence

case worker

As a domestic and family violence

case worker, Jan focuses on a range of

issues such as child protection, safety

planning, housing, risk assessments

and building resilience.

Enabling individuals to regain financial

independence is a core component

of her role, and for the last three years

Jan has integrated MoneyMinded for

Family Violence – an extension of

MoneyMinded introduced in 2016 –

into the programs she facilitates.

“For many clients, it is challenging to

start over, particularly if they haven’t

had access to finances within their

relationship” she explains. “The

MoneyMinded program creates a

more comprehensive, sustainable

framework for supporting clients in

regaining financial control, sometimes

for the very first time”.

Jan emphasises the importance of

planning for the future. “It not only

helps people address immediate

financial needs but also equips

survivors with the skills they need to

navigate their financial futures with

confidence and independence. The

program is adaptable to suit each

client, and I feel this makes it a lot

easier to utilise”.

Berry Street Yooralla trains family

violence specialists in MoneyMinded

for Family Violence, which includes a

specific range of resources to support

community professionals having

conversations about financial abuse

with their clients.

Case study

This year

4,525

people completed the

MoneyBusiness program

and

340

community professionals

completed the Coach Training.

31

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Our approach
In 2018, ANZ set a target to fund and

facilitate $1 billion in housing investments

by 2023

1

. After surpassing this objective in

2020, the target was extended. Today,

ANZ’s target is to fund and facilitate at

least $10 billion of investment by end

2030 to deliver homes to buy and rent

that are more affordable, accessible or

sustainable.

Since 2018, ANZ has invested $7.37 billion

in the housing sector, with $892.79 million

invested in 2025, highlighting our ongoing

lending to the housing sector to deliver

more residential outcomes and to support

customers into their own homes.

The target aims to increase housing

supply with a direct focus on emerging

markets, innovative models and scalable

projects. Specifically, projects under the

target demonstrate how financial

institutions can play their part in changing

the market to deliver more of the right

housing, in the right locations, at the right

price point for both rental and purchase.

For more information on how ANZ

is helping to improve the availability

of suitable and affordable housing

visit anz.com/housing

Suitable and

affordable housing

Housing continues to

be a key focus of the

community across Australia

and New Zealand, including

challenges associated with

the cost of living and

housing affordability and

availability.

We have continued to focus on

helping improve the availability

of suitable and affordable housing

options for all Australians and

New Zealanders by:

Increasing overall housing

supply, including both new

social and affordable, into

the market;

Supporting new housing

models from pilot to scale to

delivery of new pipelines; and

Contributing funding solutions

for first home buyers, specialist

disability accommodation and

land lease communities.

Projects that have contributed toward

the target this year include social and

affordable housing delivered in

conjunction with partners such as Tetris

Capital and Community Housing Ltd;

continued growth of the leading players

in the Specialist Disability Accommodation

(SDA) sector and the affordable seniors

living space.

ANZ continues to engage with key

stakeholders across all three levels of

government to provide financial insights

to support housing policy and programs,

alongside offering expertise to community

and customers.

1. Explanatory note for the $10 billion target is available on page 55.

$1 billion invested in Queensland

A key delivery area this year has been supporting housing outcomes

across Queensland. Overall, ANZ has funded over $1 billion of housing

outcomes since 2023.

Funding this year included:

More than $800 million to support the Queensland Government

through their Housing Investment Fund (HIF), including the construction

of 156 social and affordable dwellings in Greater Brisbane, and 313

social and affordable homes in partnership with Community Housing

Limited Queensland across Brisbane and regional Queensland. In total,

we have delivered 1,443 homes to support this initiative.

Over $96 million of lending to support SDA housing outcomes

across Queensland.

Approximately$165 million of lending to deliver affordable seniors

living outcomes.

Key actions in 2025

Material ESG issue

32

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Backing growth in the Specialist
Disability Accommodation (SDA)

market

ANZ has been a leading financier in the

SDA sector since 2018, providing over

$700 million in funding to support partners

such as:

• Enliven Housing Group – housing that

is sustainable, safe and supported by

person-centred tenancy management

services Australia-wide.

• The Synergis Fund – one of Australia’s

first wholesale investment funds aimed

at transforming the disability housing

sector.

• Sana Living – expanding opportunities

for independence, connection to

community and achievement of

individual goals across Western Australia,

Queensland and South Australia.

• Australian Unity – investing in social

infrastructure and sustainable

communities to support wellbeing.

ANZ has also been an active supporter

of PowerHousing’s SDA Community

of Practice and as a member of the

Specialist Disability Accommodation

Alliance to ensure there are clear policies

in place to support institutional investment

in the sector.

Community housing in

New Zealand

As part of our $10 billion target, ANZ Bank

New Zealand provided a NZ$150 million

lending facility this year, subsequently

matched by the Government to the

Community Housing Funding Agency

(CHFA), supporting affordable housing

finance for community housing providers

across the country. In addition, ANZ

acted as sole sustainability coordinator

to establish CHFA’s Social Finance

Framework and sole lead manager for

its inaugural NZ$200 million social

bond issue.

ANZ Community Foundation

housing grants

This year, the ANZ Community Foundation

provided grants to not-for-profits

supporting vulnerable Australians and

those at risk of homelessness, including:

• Disability accommodation – YoungCare

At Home Care Grants Program (QLD)

• Support for young people – Stepping

Stone House Independent Living

Program (NSW) and Conscious Creative

HoMie Pathway Alliance (VIC)

• Aboriginal led housing design – Wilya

Ajjul Janta Aboriginal Corporation (NT)

• Transitional housing to at-risk young

mothers – The Lady Musgrave Trust

Logan Housing Project (QLD)

• Supporting better rental outcomes –

Anika Legal Ltd Eviction Support Service

(VIC) and Goldfields Community Legal

Centre Inc Tidy Tenant Project (WA)

For more information on ANZ’s community

giving see page 53.

Affordable and sustainable

housing in New Zealand

In 2025, ANZ Bank New Zealand

continued to support New Zealanders

aiming to reduce emissions and improve

the environmental sustainability of their

homes through the ‘Good Energy Home

Loan’ and ‘Healthy Home Loan Package’

products. More information on these

products is available at anz.co.nz/

good-energy.

This year, we exceeded our target to

help New Zealand homeowners improve

the sustainability of their homes and/or

reduce their transport emissions through

discounted lending of at least NZ$825

million in aggregate to at least 19,700

households by end 2025. For information

on the performance of this target, and

ANZ’s other ESG targets, see pages 13-15.

ANZ Bank New Zealand offers

lending products that may support

households and businesses to transition

to a lower emissions economy. For more

information see page 17 in the 2025

Climate Report available at

anz.com/esgreport

Render image of affordable apartment homes in Rivervale, Western Australia Source: Tetris Capital

33

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

1. Includes ANZ Plus, ANZ Classic, ANZ Bank New
Zealand, and Suncorp Bank. 2. Excludes Suncorp Bank.

3. Includes Suncorp Bank.

We continued to apply friction to transactions by delaying the payment process

for high-risk transactions. We also broadened our fraud and scams detection

and prevention capability in response to increasingly sophisticated cybercrime

threats by implementing the following detection and prevention measures.

Industry collaboration

Partnered with other banks to deliver BioCatch Trust

3

, an inter-bank financial

crime intelligence sharing network. This provides an additional layer of

protection against fraud and scams, by assessing in real-time the potential risk

of every receiving account on the network, before a payment is processed.

BioCatch Trust indicators have been integrated into our Falcon fraud detection

platform, which has significantly enhanced our ability to detect complex scam

typologies while reducing friction for legitimate customers. This initiative builds

on our existing collaboration with other banks, which involves sharing fraud

and scams intelligence through the Australian Government’s intel loop and the

Australian Financial Crimes Exchange.

Confirmation of Payee

Launched Confirmation of Payee across our ANZ banking platforms, a name

matching tool designed to help protect customers from scams and mistaken

payments. The service confirms whether the account name matches the

details held by the receiving bank. Since the tool went live in June 2025,

ANZ has seen over 200,000 payments abandoned by customers after being

presented with a mismatch result.

CallSafe

Launched CallSafe, a feature designed to help protect ANZ Plus customers

from falling victim to bank impersonation scams. CallSafe offers secure

authentication, enabling customers to verify they are speaking to an ANZ

employee, and for employees to authenticate the customer’s identity. Since

this feature went live in November 2024, CallSafe has been used to securely

authenticate customers more than 40,000 times.

Digital Padlock

Implemented Digital Padlock, an Australian-first fraud and scams feature that

provides ANZ customers with the ability to instantly ‘lock down’ access to their

accounts if they suspect they are being targeted by cybercriminals.

In 2025, our Customer Protection

teams investigated more than 39,000

scam cases and prevented and

recovered more than $220 million in

fraud and scams-related funds across

Australia and New Zealand.

1

Our approach

ANZ is committed to minimising the

harm caused by fraud and scams to our

customers, shareholders, employees, and

to the wider community. ANZ’s Anti-Fraud

Policy and Standard sets the minimum

requirements for the prevention,

detection, investigation and reporting

of fraud and scams.

Scams education customer

referral pathway

This year, ANZ’s financial education

program MoneyMinded, established a

customer referral pathway for repeat and

entrenched scams victims to access a

free scams financial education workshop.

Delivered in partnership with the

Brotherhood of St Laurence, scams

victims are referred to a free facilitated

workshop which outlines how to

identify and protect yourself from various

types of scams, including investment,

dating, phishing, remote access, and

employment scams.

The education workshops follow the

launch of a Scams module in 2024, which

is available to all MoneyMinded Coaches.

More information on ANZ’s financial

education programs can be found on

pages 30-31.

In February 2025, the Australian Government passed the Scams Prevention

Framework (SPF), setting out a series of general principles that will apply to

regulated sectors. Broadly, the framework introduces obligations for banks to

detect, prevent, and disrupt scams.

The SPF will be supported by sector specific Codes that will detail the steps

that each sector can take to comply with the legislation's principles.

We have commenced work to understand what changes are required to meet

the new obligations.

Australia

2

– Key actions in 2025

In recent years scams have evolved rapidly and become increasingly

sophisticated. To keep our customers’ money safe, we continually review and

adjust our capabilities and educate customers and employees on new fraud

and scams as they emerge. We safeguard the confidentiality, integrity and

availability of our systems, services and information to ensure operational

success, business growth and our customers’ financial wellbeing.

Fraud and scams

Material ESG issue

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

34

This year, ANZ Bank New Zealand implemented several new detection and
prevention measures as well as taking part in industry initiatives to help protect

customers and the community from scams and other financial crimes.

Industry collaboration

ANZ Bank New Zealand is part of the new Anti-Scam Alliance, a cross-sector

initiative launched to improve New Zealand’s ability to prevent and respond to

online financial scams. The alliance brings together government agencies,

banks, telecommunications providers, digital platforms, and consumer groups

to coordinate efforts and enhance consumer protection.

In April 2025, ANZ Bank New Zealand, along with the New Zealand banking industry,

agreed to deliver a suite of consumer protections. The protections have been

progressively rolled out across New Zealand and will conclude in November 2025.

The consumer protections will include:

• Pre-transaction warnings to customers for certain payments.

• Confirmation of Payee, a service that confirms whether the account name

matches the details held by the receiving bank. Since November 2024 over

17.7 million checks have been completed.

• Identification of and response to high-risk transactions or unusual account

transaction activity, and the ability to delay or block transactions in some cases.

• Providing a 24/7 reporting channel for customers who think they’ve been scammed

and responding to protect accounts.

• Sharing scammer account information with other banks to help prevent criminal

activity, and freezing funds where appropriate.

Behavioural Biometrics

During the year ANZ Bank New Zealand introduced behavioural biometrics, a

technology that identifies patterns in the way customers use the goMoney and

Internet banking channels. This helps to identify when scammers are attempting to

take over customer accounts. Since implementation in June 2025, the technology

has saved ANZ Bank New Zealand customers over NZ$1.2 million.

Enhanced fraud detection capabilities

Investment in analytical resources and capability has lifted ANZ Bank New Zealand’s

ability to identify changes in attack methods by scammers, enabling a reduction in

card fraud transactions by 28% for the 12 months ending in September 2025,

compared to the 12 months ending September 2024.

goMoney App

To strengthen customer capability in detecting scams, we’ve delivered over 7.9 million

scams education messages via email and the goMoney App, reinforced by targeted

communications. This included promoting the Digital Security Code (DSC), a security

code available in the goMoney App that changes every 12 hours instead of using the

security code at the back of the physical card. In September 2025, DSC made up

7.8% of transactions. For the first six months since implementation, fraud rates are half

of those of static verification methods.

More information on

how ANZ Bank New

Zealand is helping to

protect customers from

fraud and scams is

available at anz.co.nz/

fraudprotection

IMAGE TBC

New Zealand – Key actions in 2025

35

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Our approach
Cyber security is central to ANZ’s

operations.

1

It safeguards customer data,

ensures regulatory compliance, and

supports innovation, all of which are

crucial to maintaining trust and resilience

in today’s digital banking environment.

Our Enterprise Security Strategy is

guided by three key objectives: enabling

transformation, strengthening resilience,

and embedding security. Each objective

is supported by key priorities, including:

Ensuring ANZ can confidently

move into new areas of growth

by creating a secure, flexible

environment for our customers,

employees, and partners to do

business – anytime, anywhere.

Advancing ANZ’s readiness to

rapidly detect, respond and recover

from a major cyber-attack.

Minimising the likelihood and

consequence of a cyber-attack.

Progress against each objective is

systematically tracked and reported

through annual key results, providing

visibility into execution and measures of

success. The strategy is underpinned by

threat mapping, industry benchmarking,

penetration testing (the simulation of

attacks to identify system vulnerabilities)

and risk evaluation.

The strategy also identifies opportunities

to harness and address new threats

introduced by evolving technologies

such as artificial intelligence and quantum

computing. This enables ANZ to adapt

safely to new technologies, whilst

fostering everyday habits that safeguard

employees and customers.

ANZ has a Group Information Security

Policy

2

and Standards which outline the

mandatory security requirements and

responsibilities across ANZ. Cyber security

updates are provided to the Board Risk

Committee and Board Digital Business and

Technology Committee on a regular basis.

Training

Education is key to building a security-

focused culture. Educating employees

starts with a clear, shared understanding

of our security operating model, enabling

everyone to contribute to protecting ANZ

and our customers.

We maintain a strong emphasis on

embedding security behaviours across all

divisions, leveraging security metrics and

data-driven insights. Key behaviours are

evaluated through our internally developed

Security Behaviour Index (SBI)

3

. We have

established a network of experts which

includes over 100 divisional Security

Behaviour Index representatives, an

increase of 37% since 2024.

We also aim to enhance cyber resilience

and phishing awareness through more

frequent, intelligence-led exercises.

In 2025, we conducted seven cyber

exercises, including a Group wide exercise.

1. Excludes Suncorp Bank. 2. This policy applies to Suncorp Bank. They have also retained their Security Management Policy.

3. Provides an indication of how well our employees are fulfilling their security obligations.

Cyber security

These exercises strengthen our readiness

by clarifying roles, validating crisis

response plans, and supporting effective

decision-making under pressure.

All contractors are required to complete

annual cyber security training to ensure

awareness of their responsibilities. This

includes specialised instruction tailored

for frontline personnel, software

developers and engineers.

Customers and third parties

With a growing prevalence of cyber

threats, protecting our customers is

more vital than ever. Our customer

security education service encompasses

tailored cyber security content, direct

business engagements, strategic

education partnerships, and active

industry collaboration.

Continued uplift to ANZ’s Security

Hub in 2025 saw new and refreshed

content provided to enhance customer

understanding of common scam types

and cyber threats. These resources were

further reinforced through personalised

security awareness campaigns with

ANZ successfully engaging over

4.4 million customers

1

.

Third-party providers handling sensitive

ANZ information must meet strict security

standards. ANZ supports this through

a robust governance framework and a

mature security testing program aligned

with Australian Prudential Regulation

Authority (APRA) CPS 234.

Cyber security is a strategic priority for every organisation. In a hyperconnected

world, resilience is a new currency of trust – customers, partners, and regulators

aren’t just asking if companies are secure, but if they’re ready.

Material ESG issue

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

36

Robust data protection and privacy practices
underpin trust in the digital economy. In

an increasingly data-driven society, strong

governance supports regulatory compliance.

Data protection and privacy

Our approach

1

At ANZ, safeguarding personal information

is essential to maintaining the trust of our

customers, shareholders, employees and

the communities we serve. We continue

to focus on delivering long-term value

through robust privacy and data protection

practices, which are supported by strong

governance, regulatory compliance, and

a culture of accountability.

Our practices, procedures, and systems

provide a framework for ANZ to identify

and control privacy risks in line with

legal obligations and handle personal

information responsibly. ANZ’s Privacy

Policy

2

also provides clear expectations

to help build trust with customers,

employees and stakeholders by

demonstrating a commitment to

protecting privacy.

Oversight is provided through regular

reporting with privacy events reported to

the Operational Risk Executive Committee

and the Board Digital Business and

Technology Committee when required.

Training

We recognise that our people play

a critical role in protecting personal

information. To support this, in 2025

we developed an ANZ wide Privacy,

Data Protection and Ethics Essentials

mandatory learning course to ensure

a consistent learning experience for

employees across multiple markets.

We continue to foster a speak up culture

that encourages our people to report

suspected or actual data issues. These

issues can be raised internally via the

Non-Financial Risk Hub or directly to the

Privacy Office.

Notifiable data breaches

In 2025, ANZ Group reported four data

breaches across the markets we operate

in, under our data breach reporting

obligations. One incident was reported

to the Office of the Australian Information

Commissioner (OAIC) and involved the

notification to a single impacted individual

under the Notifiable Data Breach Scheme

(Scheme). ANZ Bank New Zealand

reported three notifiable privacy breaches

under their Privacy Act to the Office of the

Privacy Commissioner (OPC), involving

statutory notification to four impacted

individuals.

Suncorp Bank has continued to retain its

Privacy Policy since ANZ’s acquisition on

31 July 2024, with a focus on uplifting

capability in alignment with the Australian

Privacy Act reforms. No notifiable data

breaches from Suncorp Bank were

reported to the OAIC under the Scheme

in 2025.

1. Excludes Suncorp Bank. 2. Suncorp Bank has retained their Privacy Policy.

Further information on privacy

at ANZ, including our Privacy Policy,

is available at anz.com/privacy

ANZ has established a dedicated program with a cross-functional working

group to prepare for tranche 1 of the Privacy Act reforms which came into

effect in December 2024. A significant scope of work in this program relates

to the use of Automated Decision Making.

Streamlined our Privacy Impact Assessment to ensure consistency across

ANZ markets in the identification and mitigation of privacy risks.

Continued to promote and raise awareness with employees of the importance

of data protection and privacy through Privacy Awareness Week, an initiative

led by the Australian Government’s Office of the Australian Information

Commissioner (OAIC). This year’s theme, “Privacy – it’s everyone’s business,”

emphasised the shared responsibility of protecting personal information

across the markets in which ANZ operates.

Key actions in 2025

Material ESG issue

37

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Financial crime
We maintain a strong focus on financial crime prevention, detection and

disruption by continually reviewing ANZ’s Anti-Money Laundering / Counter-

Terrorism Financing (AML/ CTF), Sanctions, Anti-Bribery and Anti-Corruption

(ABAC) programs, and ongoing platform upgrades to improve our ability to

collaborate with external parties to fight financial crime, including a long

standing relationship with the Australian Federal Police (AFP).

1. Excludes Suncorp Bank. 2. Includes Suncorp Bank. 3. ANZBGL means Australia and New Zealand Banking Group

Limited. 4. Suncorp Bank was acquired by ANZ on 31 July 2024. Following the acquisition, Suncorp Bank commenced

a phased transition to adopt the policies and processes of ANZ. During the transition period Suncorp Bank will be

subject to a combination of ANZ and Suncorp Bank policies.

Insights from these partnerships inform

our Financial Crime team’s refinement of

proprietary algorithms and intelligence

platforms, enabling analysis of billions of

transactions and delivery of actionable

data. These partnerships also support

specialist training exchanges—ensuring

our teams maintain current knowledge in

a dynamic and evolving threat landscape.

In New Zealand, ANZ is a member of the

Financial Crime Prevention Network (FCPN)

which is a public private partnership with

the aim of enabling information and

intelligence sharing and collaboration with

law enforcement to identify and prevent

financial crime. This includes regulatory

working groups and engagement on

tactical investigative and discovery work.

Training

Our employees and contractors are

required to undertake mandatory annual

training to ensure they understand their

role in preventing financial crime. This year,

99.93% of employees and contractors

completed the training. Additional training

is also tailored for specific roles and we

offer additional educational content and

hold ABAC awareness sessions to continue

to promote our operating standards.

The ANZ policies mentioned

above are available at anz.com/

corporategovernance

Our approach

Anti-Money Laundering and

Counter-Terrorism Financing

Our AML/CTF program and Policy

Summary

1

summarises our approach to

detecting and deterring money laundering

and terrorism financing (ML/TF). Risk

assessments are completed at an

enterprise, country, product and channel

level to identify, manage and mitigate

ML/ TF risk across the organisation.

We complete customer due diligence

proportionate to the ML/TF risk posed

by our customers. We seek to identify

unusual or suspicious transactions,

activities and/or behaviours through a

combination of transaction monitoring

and other methods of observation,

reporting suspicious activity to

appropriate authorities.

Australia’s AML/CTF laws are in the

process of being updated to modernise

and expand its oversight to additional

higher risk services. These reforms come

into effect on 31 March 2026 for existing

reporting entities, including ANZ. These

changes impact policies and processes

relating to AML/CTF Programs, risk

assessments, customer due diligence

and reporting obligations.

Sanctions compliance

Our sanctions compliance program

and Policy Summary

1

outline our Group's

approach to identifying and managing

sanctions risks globally.

Customer relationships and activities that

pose a higher sanctions risk are subject

to enhanced due diligence measures,

monitoring and approval. We continue

to enhance transaction monitoring and

strengthen customer due diligence to

ensure compliance and support business

within our risk appetite.

Anti-Bribery and Anti-

Corruption (ABAC)

Our ABAC Business Integrity Policy

2


outlines the standard of behaviour we

expect from our employees and third

parties in all countries that ANZ operates

in. The underlying principles and conduct

provisions include knowing who we are

doing business with, doing business with

integrity, and ensuring transparency in

our relationships.

This is supported by procedural standards

to identify and mitigate higher risk third

parties, conflicts arising from the

exchanges of gifts and entertainment,

and ensure our dealings with public

officials are appropriately managed. The

policy requirements are operationalised

through centralised technology platforms

to support the management of risks and

provide visibility of bribery and corruption

risk across ANZ.

Partnerships and programs

To help protect vulnerable communities

and reduce harm through strategic

private-public collaboration. For ANZBGL

3

,

this includes with the Australian

Transaction Reports and Analysis

Centre (AUSTRAC) Fintel Alliance and

strengthened engagement with the AFP,

including the Joint Policing Cybercrime

Coordination Centre (JPC3) and the

Australian Centre to Counter Child

Exploitation (ACCCE).

Through these programs we embed

intelligence specialists and deploy

security-cleared employees to law

enforcement and regulatory agencies,

directly supporting initiatives focused on

dismantling child sexual abuse networks,

identifying modern slavery, human

trafficking, dismantling groups seeking

to defraud and scam our customers and

developing financial intelligence tools and

algorithms that detect criminal patterns

targeting vulnerable individuals.

Suncorp Bank has continued to

maintain its own Anti-Money

Laundering and Counter Terrorism

Financing Policy. For a full list of

Suncorp Bank

4

policies, see page 2.

Suncorp Bank remains focused on

maturing its AML/CTF systems and

controls. To ensure a strategic and

holistic approach, Suncorp Bank

management established a Financial

Crime Compliance Program of Action

(FCCPoA). The FCCPoA incorporated

the actions arising from AUSTRAC’s

AML/CTF Compliance Assessment

Report findings in relation to the

Company’s AML/CTF Program as

well as findings and recommendations

from internal assurance and audit work.

The Program is now well advanced and

completion is expected during the

FY26 financial year.

Material ESG issue

38

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Social and environmental
risk management

Social and environmental risks arising from transactions,

projects and customer relationships can affect society,

human rights, environments and associated communities.

We have a responsibility to manage social and

environmental risks for the benefit of our people,

customers, communities, and shareholders.

1. Customers’ of ANZ’s Institutional division where ANZ has a credit exposure. 2. Summaries available here: anz.com/social-and-environmental-risk-management. 3. Suncorp Bank

maintains its own Responsible Banking Policy which outlines its approach to the management of ESG risks and opportunities across Suncorp Bank. The Responsible Banking Policy

applies to Suncorp Bank and all products and services provided by Suncorp Bank to its customers.

Our approach 

Social and Environmental Risk

ANZ Bank Group assesses and manages

potential social and environmental impacts

of our lending decisions to large business

customers

1

through the application of

our Social and Environmental Risk Policy

(S&E Risk Policy), Social and Environmental

Risk Standard (including specific

requirements for ‘sensitive sectors’), and

Climate Risk Standard.

2

The Policy and

Standards apply to ANZ Bank Group

excluding Suncorp Bank.

3

 

Our S&E Risk Policy outlines ANZ Bank

Group’s approach to the management

and mitigation of social and environmental

risks arising from large business customer

activities, including the impacts of climate

and nature risks. It is applied to other

customers where ANZ perceives that a

customer or their activities may have a

material impact and is otherwise used to

guide decision-making.

Our Social and Environmental Risk

Standard provides our bankers with more

detail on our internal requirements and

the expectations we have of our large

business customers, having regard to

ANZ’s more specific policy positions, as

applicable. It includes core requirements

such as consideration of human rights

and the protection of culturally or

environmentally sensitive areas. ANZ

will not tolerate land acquisition and

involuntary resettlement that we consider

improper. The core requirements apply

to decisions relating to large business

customers, in addition to the requirements

specific to certain ‘sensitive sectors’

(listed below).

Energy Industry

Extractives Industry

Land and Forest Management

Water Management

Military Equipment

More than one set of sensitive sector

requirements may apply to the same

customer/activity under consideration.

Our Climate Risk Standard is principles-

based and seeks to provide a consistent

approach to identifying, assessing, and

managing climate risk. This includes key

elements taken into consideration when

making decisions that may result in actual

or potential climate risks and impacts to

our customers or ANZ. The Standard

includes requirements relating to:

Acting in accordance with our

S&E Risk Policy, Climate and

Environment Strategy and

Climate Change Commitment,

Identifying, assessing and managing

climate risks in our lending portfolios

and capital markets activity, and

Monitoring and reporting of potential

climate risks and impacts to relevant

forums and committees see

pages 7-9.

For more information on our

approach to deforestation

see page 19 in the 2025

Climate Report available at

anz.com/esgreport

Material ESG issue

39

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

To o l sDescriptionCustomer Cohort
Social and

Environmental

Screening Tool 

A tool used to facilitate qualitative risk assessments of social and environmental

risks, including impacts of climate change, that may result in potential financial

and/or non-financial risks to ANZ Bank Group from our Institutional customers’

activities. It also assists bankers in the application of the S&E Risk Policy and the

S&E Risk Standard.

This assessment is ordinarily performed when conducting due diligence on

new to bank

1

customers, when reviewing existing customers (at least annually),

or prior to a material transaction, or when ANZ Bank Group becomes aware of:

• a material change to the customer’s activities, or

• a material impact occurring.

Customers within

ANZ's Institutional

division (our large

business customers) 

Enhanced

Human Rights

Due Diligence 

A process that seeks to identify and assess potential and actual adverse human

rights impacts associated with our large business customers and their activities,

to support engagement with our customers to understand their approach to

respecting human rights, and where necessary the steps taken to avoid or

mitigate adverse impacts. For further information on our approach to human

rights see page 52.

Large business customers

of ANZ’s Institutional

division, when identified

through our Social and

Environmental Risk

Screening Tool

Equator

Principles 

A risk management framework that determines, assesses, and manages social

and environmental risks when financing large infrastructure and industrial

projects. More information on the Equator Principles is available at anz.com/

about-us/esg/policies-practices/equator-principles

Project financing or

export finance provided

to ANZ’s Institutional

customers 

Tools and processes

The table below outlines examples of key tools and processes that are used within the credit process across different customer

cohorts to help identify, assess and manage environment and social risks.

Our 2025 Climate Report, available at anz.com/esgreport, sets out in more detail additional tools and process that are focused

on identifying, assessing, and managing climate risks.

Further information on the Equator Principles categories and this year’s Equator

Principles transactions is available in our 2025 ESG Data and Frameworks Pack

available at anz.com/esgreport

Equator Principles

Case studies

Affordable housing in

eastern Australia

ANZ acted as the sole Mandated Lead

Arranger, Underwriter and Bookrunner

in the provision of financing for the

construction, operation and maintenance

of affordable housing in eastern Australia.

The project will provide over 400

affordable dwellings across key growth

suburbs aimed at young families, as well

as key workers and senior citizens. An

EP Due Diligence (DD) assessment was

undertaken by an independent technical

advisor as part of the environmental

impact due diligence for the project. As

an affordable housing project based within

a high-income Organisation for Economic

Co-operation and Development (OECD)

country, it was classified as a Category C

project, with minimal negative impact on

the social, economic or ecological status

of the site and surrounding areas.

Public health facility in

eastern Australia

ANZ acted as a Mandated Lead Arranger,

and joint Sustainability Loan Co-ordinator

on a sustainability loan facility for the

construction, and operation, of a public

health facility in eastern Australia. This

health facility is designed to address

the lack of acute health services in the

catchment area. As part of our due

diligence process for the project, an EP

DD assessment was undertaken by an

independent technical advisor on behalf

of the lenders. The facility was classified

as a Category B project, with limited

adverse environmental and social risks.

Solar project in southern USA

ANZ acted as Joint Lead Arranger, and

Green Loan Co-Ordinator, for a 300MW

solar project in the USA. This project will

support the power grid in the region, as

well as commercial operations in the area.

As part of our due diligence process for

the project, an EP DD assessment was

undertaken by an independent technical

advisor on behalf of the lenders. The solar

project was classified as a Category B

project, with limited adverse environmental

and social risks. The project is sited on

agricultural land, however, the size of the

disturbance and change in land use and

mitigation are expected to have limited

adverse environmental and social impacts.

1. Customer where ANZ has had no meaningful lending relationship within the last 12 months. Entities or assets acquired from existing ANZ customers are not classified as new to

bank customers.

40

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Managing ESG risks
and opportunities in

our supply chain

1. Numbers on this page are presented on a cash expenditure basis and also include Suncorp Bank from 31 July 2024 to 30 September 2024. Suncorp Bank is included for

2025. 2. The framework provides the foundation and arrangements that will help embed the right behaviours, processes and practices for managing third-party risk at ANZ. It

provides a structured approach to managing third party risk in an effective and consistent manner to minimise the impact of adverse events and maximise the right outcome

for all stakeholders.

Our approach

Our Supplier Code of Practice (SCOP)

outlines minimum expectations for

suppliers on topics such as human

rights, ethical business practices and

environmental management.

In 2025, through our Third-Party Risk

Management (TPRM) program, ANZ

continued the implementation of a new

centralised solution, framework

2

and

policy.This is enabling a more integrated

and comprehensive approach to the way

we identify, assess and manage risks

associated with our third parties, including

ESG related risks. This also includes the

ongoing management and monitoring of

third-party risks, in line with our risk

management and compliance policies.

Outcomes

This year, ANZ spent $5.8 billion

1

($5.1

billion in 2024) with suppliers, with 90% of

this spent in Australia and New Zealand.

Supplier screening

Contracted suppliers are screened as

part of ongoing due diligence using a

thirdparty tool to assess performance

against 28 ESG themes. In 2025, 4,099

checks were conducted (2024: 5,311

checks), including our top 100 suppliers

by spend. The reduction in checks this

year is due to a change in methodology

and reduced supplier base. Checks

identified potential issues in six instances,

with ANZ working with these suppliers to

understand the issues and mitigation

actions taken.

Supplier Code of Practice

We include SCOP clauses in new and

renewed supplier contracts with 83% of all

live supply contracts including the SCOP

clauses. We expect suppliers conduct

their business in accordance with these

expectations.

More information on our Supplier

Code of Practice is available at

anz.com/sustainable-procurement

Supporting supplier diversity

In 2025, our engagement of certified

Indigenous businesses increased,

predominantly in our Property and

Technology business units. This year, we

spent $22.9 million (2024: $13.4 million)

with First Nations businesses and

$16.6 million (2024: $6.6 million) with

social enterprises in Australia. This

includes with one supplier which is

certified as both an Indigenous business

and a social enterprise.

In New Zealand, we became buyer

members of Amotai to support future

procurement opportunities with Māori

and Pasifika owned businesses.

Governance of international supply chains take a whole-of-

economy response to identify and mitigate potential social

and environmental risks. We acknowledge the critical role

that third parties play in delivering services to, or on behalf of,

ANZ as well as the evolving industry practices and regulatory

requirements concerning third-party risk management.

Material ESG issue

41

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Banking in the Pacific
With a legacy spanning over 140 years, ANZ’s presence in the

Pacific reflects our steadfast focus on advancing regional

prosperity. Today, we operate in eight markets across the Pacific:

Fiji, Samoa, Tonga, Vanuatu, the Solomon Islands, Kiribati, the

Cook Islands and Timor Leste and hold the most extensive

footprint of any bank in the region. We also have a substantial

presence in Papua New Guinea, which plays an important role

within our Institutional business.

Islands, Tonga, Solomon Islands and

Kiribati now use the ANZ Pacific App,

with 71% of customers using Internet

Banking (an increase from 65% in 2024).

This reflects more than technological

progress, it represents increased access,

empowerment and resilience. It shows

nations adopting digital solutions to pay

and receive money.

Financial literacy and community

empowerment

At ANZ, we believe that financial wellbeing

is foundational to thriving communities

and financial literacy remains central to

ANZ’s social impact in the Pacific and

Papua New Guinea. In 2025, our flagship

program, MoneyMinded, reached over

15,000 individuals across the region.

In 2025, we also expanded our matched

savings initiative, Saver Plus, through

pilot programs in Fiji, Vanuatu, and the

Solomon Islands. ANZ partnered with the

United Nations Development Programme

and United Nations Women’s Markets

for Change project to support market

vendors and farmers. The Fiji and Vanuatu

pilots have successfully concluded,

and the Solomon Islands pilot is due for

completion in late calendar year 2025.

While participants in the Fiji program

collectively saved FJ$36,981 and

participants in the Vanuatu program

collectively saved VT$1,572,529, with

ANZ matching FJ$29,039 and

VT$701,200, the impact extends beyond

the financial metrics. By the completion of

these programs, participants:

• had developed an ongoing savings

habit (90% in Fiji and 85% in Vanuatu);

• felt better equipped to plan their

financial future (87% in Fiji and 82%

in Vanuatu); and

• reported improved confidence in

managing their businesses and

supporting their families (90% in

Fiji and 80% in Vanuatu).

Following the success of the Saver Plus

pilot, ANZ has committed to continuing the

program in Fiji and Vanuatu, reinforcing the

focus on practical solutions that reduce

poverty and empower underserved

communities.

Our approach

In 2025, ANZ’s commitment to the region

was further reinforced through the signing

of an agreement with the Australian

Government, who will provide a limited

$2 billion guarantee to ANZ in connection

with its Pacific operations including Papua

New Guinea for 10 years.

This arrangement highlights our shared

commitment to providing access to safe,

trusted banking services in the Pacific. As

part of the arrangement, ANZ will invest a

further $50 million in our Pacific banking

systems to enhance our digital banking

offering and support ongoing operations

in the region.

Uplifting digital banking

Uplifting digital banking usage through

the ANZ Pacific App and our Internet

Banking platform, continues to be a key

pillar of ANZ’s financial accessibility

strategy in the Pacific.

Kiribati, the most remote location in

ANZ’s international network, alongside

Tonga, an economy with heavy

dependence on remittances from

members of the population who live

abroad, are leading examples of smaller

island nations embracing digital banking.

In 2025, both Kiribati and Tonga grew

their ANZ Pacific App adoption rates to

68% (an increase from 55% in 2024)

and 54% (an increase from 38% in 2024)

respectively.

The Cook Islands continue to lead the

Pacific in digital banking adoption, with

the proportion of customers using

Internet Banking rising to 81% in 2025,

(an increase from 76% in 2024).

More broadly across the region, digital

adoption continues to grow. 60% of

customers (an increase from 53% in

2024) across Fiji, Samoa, Vanuatu, Cook

For more information on MoneyMinded

and Saver Plus see pages 30-31

In a region where connectivity

remains a challenge, ANZ is

helping local businesses

overcome barriers to digital

participation through a strategic

partnership with the Market

Development Facility (MDF), an

Australian Government-funded

multi-country initiative,

implemented by Palladium, in

partnership with Swisscontact.

This initiative, which commenced

in 2025, supports entrepreneurs

in Tonga by helping them integrate

ANZ eGate, our international

payment gateway, into their

websites, enabling them to grow

their business and expand their

reach to global markets.

ANZ refers eligible participants

to Palladium, who connect

them with web development

experts, to provide website

integration and maintenance,

at little to no cost.

Key actions in 2025

Foundational ESG issue

42

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Our approach
ANZ has a Diversity and Inclusion

Policy

1

which sets out how we are

building a diverse workforce which

reflects the communities in which

we operate, harnesses the unique

capabilities and perspectives of our

people, and leverages this diversity

of thought through an inclusive

workplace which values every voice.

Diversity and inclusion

Our employee

networks: creating an

inclusive culture

Our employee networks continue

to play a significant role in shaping

our inclusive culture. The networks

represent our diverse workforce

including Abilities, Reconciliation,

Mental Health, Cultural Inclusion,

ForWARD (gender equality), Pride

and Wired Differently.

Representatives of our Abilities

and Reconciliation networks sit

on the governance groups of the

Accessibility and Inclusion Plan

and Reconciliation Action Plan

2


respectively, highlighting the

importance of their lived experience.

Employment programs

We also continued to run a range

of employment programs designed

to increase the diversity of our

workforce. These included

Indigenous traineeships, summer

internships, graduate programs,

the ANZ Spectrum Program, and

the Given the Chance program

which is run in collaboration with

the Brotherhood of St Laurence.

Equity, diversity and

inclusion in New Zealand

ANZ Bank New Zealand continued

to embed its refreshed Equity,

Diversity and Inclusion (EDI) Plan

during the year, developed to reflect

the evolving demographic landscape

of New Zealand. The plan reinforces our

commitment to cultivating a workplace

where everyone feels valued, respected

and empowered to thrive.

01. Inclusive leadership

Strengthening leadership capability

to embrace diverse perspectives,

foster inclusive decision-making and

model inclusive behaviours across

the organisation.

02. Inclusive culture

Shaping a workplace culture that

promotes belonging, psychological safety

and respect for all, ensuring EDI is woven

into the fabric of everyday experiences at

ANZ Bank New Zealand.

03. Inclusive careers

Driving equity in recruitment, development

and career progression to ensure fair and

inclusive opportunities for all employees.

Over the next two years, our focus

remains on increasing the representation

of women in leadership roles and, through

the Tākiri-Ā-Rangi Te Ao Māori Strategy,

enhancing the representation of Māori and

Pasifika peoples across our workforce and

leadership. For more on our Tākiri-Ā-Rangi

Te Ao Māori Strategy see page 47.

1. Includes Suncorp Bank. 2. We are currently developing

our sixth RAP, to be governed by Reconciliation Australia,

which we plan to launch in 2026 to support the delivery

of the First Nations Strategy.

Our five Diversity and Inclusion

strategic priorities are:

Create an inclusive culture and

improve the experience of our

employees who represent all

dimensions of diversity.

Build confidence and capability

of people leaders to lead diverse

and inclusive teams.

Improve the diversity of our

leadership population.

Strengthen and empower our

employee networks.

Improve accountability and

governance.

A diverse workforce and inclusive culture improve

the quality of decision making and drive innovation,

making us a better bank for our customers.

More information on these programs

is available at anz.com/about-us/esg/

workplace-participationdiversity

Refer to the 2025 ESG Frameworks

and Data Pack at anz.com/esgreport

for further information on the summer

internships and graduate program

participants

This year, we focused on creating opportunities for senior leaders to hear directly

from our employee network leads and members, including:

Sharing insights into the history and purpose of our networks with ANZ's

CEO Nuno Matos.

Holding a series of focus groups with senior executives to understand

opportunities to improve inclusion. All-gender change room facilities

were opened at our head office in Docklands following feedback from

these sessions.

A discussion was held between ANZ’s Board and employees in which

both groups shared their experiences and recommendations for

improvements.

Key actions in 2025

Foundational ESG issue

43

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Gender Pay Gap (WGEA – Australian
Workplace Gender Equality Agency)

The gender pay gap represents the

difference between the total pay

3

that

women and men

4

earn across all roles.

Outcomes

ANZ’s continued focus on gender pay

equality has led to a further narrowing of

our gender pay gap in 2025. At 17.2% we

have reduced the average total pay gap by

1.6 percentage points (ppt) year-on-year.

While we have more work to do, we are

encouraged that it remains below the

latest reported industry average

benchmark of 22.2% for financial and

insurance services.

We have also reduced our median

gender pay gap – now at 18.9%. We

are consistently reducing this gap and

remain below the latest reported industry

median benchmark also of 22.2% for

financial and insurance services.

As these reported gaps are based

on total pay, they are susceptible to

fluctuation due to several factors such

as variable pay pools and workforce

composition. We continue to supplement

these disclosures with the reporting of

fixed remuneration

5

gender pay gaps,

broken down by job category.

Under the Australian Workplace Gender

Equality Act 2012, ANZ is required to

make annual public filings with the

Workplace Gender Equality Agency

(WGEA), disclosing its ‘Gender Equality

Indicators’. These reports are filed annually

for the 12-month period ending 31 March.

A copy of the latest filing is available at

anz.com/gender.

There continues to be solid

progress towards reducing

ANZ’s gender pay gap.

Pay equity gap

(like-for-like roles):

The pay equity gap represents the

difference between the total pay of

women and men in the same or similar

roles based in Australia.

Outcomes

ANZ’s pay equity gap remains minimal at

less than 1% (currently in favour of men).

Year-on-year there has been a small

widening, attributable to outliers rather

than systemic issues. We remain confident

that the measures we have implemented

are effective.

For more detail on our gender pay

reporting and remuneration see our

2025 ESG Data and Frameworks

Pack available at anz.com/esgreport

More information on how we report

our gender pay gap is available at

anz.com.au/about-us/esg/

workplace-participation-diversity/

gender/equality-reporting

Gender pay equality

1. Includes CEO, Executive Committee, permanent, casual and temporary (fixed-term) employees, and trainees/interns. Excludes ANZ Non-Bank Group, Suncorp Bank and

independent contractors. Effective date 31 December 2024. Fixed remuneration data reflects actual earnings over 12-months (grossed up to 1 FTE and annualised). Variable pay

is based on FY24 outcomes. 2. Includes permanent employees. Excludes CEO, Executive Committee, casual employees, temporary (fixed-term) employees, trainees/interns,

ANZ Non-Bank Group and Suncorp Bank. Total pay includes fixed remuneration as at 20 September 2024 plus FY24 variable pay outcomes (grossed up to 1 FTE and annualised).

3. Includes both fixed and variable pay, such as bonuses. 4. Gender data reported using binary female and male categories to ensure confidentiality of our non-binary and gender

diverse employees. ANZ recognises and respects diverse gender identities and is focused on providing a safe, respectful and inclusive workplace. 5. Fixed remuneration, such as

base salary and superannuation.

AverageMedian

Reporting Year2025YoY c h a n g e2025YoY c h a n g e

Gender Pay Gap

1

1 7. 2 %


-1.6 p pt

18.9%


-2.2 ppt%

Pay Equity Gap

2

0.7%


0.4 ppt

0.4%


0.4 ppt%


Increase (in favour of men)


Decrease (in favour of women)

Average

Sum of pay divided by

Average Pay Gap is calculated by

dividing the average remuneration

for women by the average

remuneration for men

Sum of employees

Median

Median Pay Gap is calculated

by dividing the mid-point

remuneration for women by the

mid-point remuneration for men

Lowest

paid

Highest

paid

Foundational ESG issue

44

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

In 2025, there has been a strong
focus on building the WIL pipeline

particularly in our divisions with

large leadership populations and

higher proportions of men, such

as Institutional and Technology.

Our Markets Acceleration Program

(MAP) was launched in 2023 as

a strategic initiative to address the

under-representation of women

in front-line Markets roles such as

sales and trading. In 2025, the

program continued to include

participants from Australia and

Singapore. All eight participants

from the inaugural cohort

transitioned to roles in Markets.

More information on the program

and application process is

available at anz.com.au/

newsroom/news/2025/march/

markets-acceleration-program-

diversity-career.

Key actions in 2025

Maintaining the focus on achieving gender balance

remains a key priority across ANZ’s geographies and

businesses. We have continued to improve gender data

reporting to enable divisions to identify areas that require

focus and track progress.

Gender

balance

Outcomes

We have exceeded our Women in

Leadership (WIL) target this year

by 0.3 ppt to 40.5% – an annual

increase of 1.5 ppt.

3

Women in

revenue generating leadership roles

increased by 0.8 ppt to 33%. As at

30 September 2025, women as

Key Management Personnel (KMP)

decreased from four out of ten, to

three out of nine and is now below

target at 33%.

With the recent permanent

Executive Committee

4

appointments

of Stephen White, Pedro Rodeia,

Christine Palmer and Donald Patra

(who will commence from October

to December 2025) women as

KMP will increase back to 40%.

More information on the Executive

Committee

4

is available in the 2025

Annual Report available at

anz.com/annualreport.

1. Includes permanent employees of ANZ Bank New Zealand Limited, excluding the New Zealand CEO.

Percentages are based on full-time equivalent average Total Pay (salary and superannuation, where it forms

part of a fixed remuneration package, plus variable pay). Values are provided by ANZ on a voluntary basis and

are as at 30 September of the relevant year. 2. The number of permanent employees of ANZ Bank New Zealand

Limited who identify as Māori or Pasifika is 9.5% of the total permanent employee population, including

employees who have not declared an ethnicity. Employees who haven’t provided ethnicity data aren’t included

in the ethnicity pay gap calculation. We recognise that our ethnicity pay gap is based on less than half of our

workforce and does not provide a complete picture. Values are provided by ANZ Bank New Zealand Limited

employees on a voluntary basis and are as at 30 September 2024. 3. FY24 Women in Leadership result of

38.8% excluded Suncorp Bank, whereas FY24 Women in Leadership baseline for FY25 Women in Leadership

target is 39.0% including Suncorp Bank. 4. Executive Committee (ExCo) comprises ANZ’s most senior

executives. The members of ExCo are available at anz.com/exco.

For more information about

employee gender breakdowns

see our 2025 ESG Data and

Frameworks Pack available

at anz.com/esgreport

For more information on our

approach to gender equity see

anz.com/gender

Further detail on our gender diversity

targets (including at the Board level)

can be found in our Corporate

Governance Statement and our

Diversity and Inclusion Policy available

at anz.com/corporategovernance

Leadership: Increasing the

number of women in more

senior and higher paying roles.

Development: Addressing

the gender imbalance in junior

and lower paid roles, noting

they make up a significant

proportion of ANZ’s workforce.

Data and reporting: Continuing

to actively monitor and review

both our gender pay gap and

pay equity gap (including as

part of our annual Performance

and Remuneration Review

process) and taking positive

action to adjust where possible.

Regular reporting on pay equity

is provided to the Board and is

also made available to help

inform initiatives where

appropriate.

Key actions in 2025

New Zealand Pay Gaps

ANZ Bank New Zealand also continues

to publicly report its gender pay gap

(average of 18.7% favouring men in

2024)

1

and the Māori and Pasifika pay

gap – the difference between the

average pay for Māori and Pasifika and

for European/Pākehā (21.9% in 2024

favouring European/Pākehā employees).

2

More information on how we

are working towards closing pay

gaps in New Zealand is available

at anz.co.nz/about-us/corporate-

responsibility/equity-diversity-

and-inclusion/edi-news

Foundational ESG issue

45

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

As a result, by 2035 ANZ aims to advance First Nations aspirations for
economic self-determination by targeting three priorities:

1. Improving financial inclusion and wellbeing – including investing in the next

generation of First Nations people to be financially empowered and confident.

2. Banking and growing the First Nations economy – becoming a thought

leader, trusted adviser and bank of choice for the First Nations economy.

3. Building ANZ’s cultural intelligence – improving First Nations employment,

workforce cultural capability, and relevant policies.

Foundational ESG issue

1. Executive Committee (ExCo) comprises ANZ’s most senior executives. The members of ExCo are available at anz.com/exco.

Throughout 2025, ANZ made tangible progress in delivering this Strategy. This

included commissioning Deloitte Access Economics to create Australia’s first

forecast of the First Nations economy and releasing this publicly. The report found the

First Nations economy is one of Australia’s fastest growing sectors and could generate

$50 billion annually in revenue in the next decade, up from $16.1 billion in 2021.

ANZ also commenced its partnership with Jawun, seconding five employees

to work within First Nations organisations, totalling 1,200 hours of pro bono work.

We signed as a partner with First Nations Foundation to support financial

inclusion and wellbeing, procured $22.9 million from 51 First Nations businesses,

and surpassed $150 million in lending through our First Nations Guarantee

program. The Guarantee program is delivered in partnership with three of our

Institutional mining customers and has supported more than 30 First Nations

business customers since 2018.

We are currently developing our sixth RAP, to be governed by Reconciliation

Australia, which we plan to launch in 2026 to support the delivery of the Strategy.

ANZ’s final report on the 2021-2024 Stretch RAP is available at anz.com.au/

about-us/esg/workplace-participation-diversity/indigenous-australians.

Key actions in 2025

46

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

ANZ 2025 ESG Report

First Nations Strategy

First Nations roles have also been created across the bank, with 100% filled by Indigenous

people (First Nations and Māori), including two executive roles in our Commercial division,

and Talent and Culture business unit. Progress on the Strategy will be guided by First

Nations people and reported to the ANZ Board and Executive Committee

1

every six months.

Priorities and vision (what we will do)

Business outcomes

Reducing business risk

through a considered

approach to First Nations

Protecting and growing our

market share in the rapidly

growing First Nations economy

Learning and adapting to

better meet customer needs

Improving financial

inclusion and wellbeing

Banking and growing the

First Nations economy

Building ANZ’s cultural

intelligence

Principles (how we will do it)

Grounded in truth

and data

Create shared value and

mutual benefits

Aligned to First

Nations priorities

Our First Nations Strategy

To advance First Nations

aspirations for economic

self-determination

This year ANZ launched its inaugural

First Nations Strategy (Australia)

‘Fuelling the Fire’, in a first for the

Australian banking sector.

This ten-year Strategy focuses on the

common ground between ANZ’s purpose

and the aspirations of First Nations

peoples: economic self-determination.

ANZ’s First Nations Strategy (Australia) is

available at anz.com.au/about-us/esg/

first-nations-strategy.

This Strategy builds on ANZ’s ongoing

commitment to reconciliation, including the

completion of five Reconciliation Actions

Plans (RAPs), and our 20-year investments

in our Indigenous Traineeship program and

First Nations financial education program,

MoneyBusiness. For more information on

MoneyBusiness see page 31.

The Strategy was developed by listening

to the aspirations and priorities of First

Nations peoples, and ANZ employees.

Through this process, we identified

significant common ground and win-win

opportunities. This Strategy is not about

what ANZ can do ‘for’ First Nations

peoples, rather it focuses on recognising

shared aspirations and working together

towards a common goal.

To drive strategy execution, a First Nations

Strategy Office has been established, led

by executive Shelley Cable. Specialist

ANZ’s commitment to Māori
Key actions in 2025

Delivered Ko Tu Ko Rongo, Māori Housing Research Report, representing

our collective understanding of and lessons from Māori housing to inform

ANZ’s first steps in how as a bank, we can support more Māori in home

ownership.

Te Waka-Ā-Reo, ANZ’s internationally recognised reo Māori language

program, is designed to increase proficiency and confidence in the

language. It is now fully operational and accessible to all employees in

Aotearoa New Zealand. The number of wāhanga (tutorials) completed

continued to trend upwards during the year, with 12,423 tutorials

completed, a 104% increase compared to the same period last year.

Creating the role of Te Kaiwhiringa Whai Rawa, a Māori Business Specialist

spanning across two regions, has seen strong growth in connecting with

Māori business leaders and experts. Alongside the appointment of 28

Māori business champions across the Aotearoa New Zealand network, this

has seen ANZ grow our relationships with Māori businesses and leaders.

Our Te Kupenga Te Kokohi (a net to gather) employment strategy seeks

to increase Māori and Pasifika representation at ANZ Bank New Zealand

across Aotearoa New Zealand. Since its inception, Te Kupenga Te Kokohi

continues to be a cornerstone of our strategic approach. In 2025, ANZ

welcomed a further 28 Māori or Pasifika candidates into Customer Service

Consultant roles within the Contact Centre. Out of 76 total hires, this

represents 35%.

On 1 October 2024, ANZ Bank

New Zealand launched the second

two-year term of its strategy. It builds

on the first term, which focused on

building a culturally strong ANZ in

Aotearoa New Zealand

Launched in 2022, ANZ Bank

New Zealand’s Tākiri-ā-Rangi

Te Ao Maori Strategy is a 2040

roadmap for how ANZ Bank

New Zealand will reflect and

respond to the cultural diversity

of the workforce, customer

base, and country in Aotearoa

New Zealand. The strategy

also aims to deepen ANZ’s

understanding of the values

that are intrinsic to Māori and

support the growth of the

Māori economy.

Our approach

Tākiri-ā-Nuku, the core framework

that governs the strategy, is deeply

rooted in an ancestral wharenui

(large meeting house). Progress on

the strategy is regularly reported to

the New Zealand Leadership Team

and the New Zealand Board.

Develop stronger relationships

with hapori Māori, iwi (tribe)

and hapū (subtribe) across the

country, acknowledging the

growing contribution Māori

businesses make to the

economy.

Support Indigenous

financial inclusion to

improve Māori

financial wellbeing.

Conduct a program

to enhance ANZ Bank

New Zealand’s own

understanding of

Te Ao Māori (the

‘Māori world view’).

Foundational ESG issue

47

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Accessibility and inclusion
Our approach

The 2023 –2025 Plan includes

14 commitments designed to embed

accessibility and inclusion into key

aspects of our business in Australia

1


and New Zealand. We strive for greater

economic and social participation for all.

Inclusive design

• Monthly accessibility reporting

which identifies opportunities to

improve accessibility in our digital

channels, with uplift activities

prioritised for implementation.

• Marketing guidelines reviewed by

digital accessibility experts to uplift

to best practice and better support

inclusive customer communication.

Customer experience

• Expanded the accessibility of our

customer communications by

publishing an additional four Easy

Read documents. Easy Read uses

simplified language, large text,

and supportive visuals to make

information easier to understand,

particularly for people with cognitive

disabilities, individuals with low

literacy, or those who speak English

as an additional language. The new

topics aim to help customers to

more easily navigate banking

processes, bank online and use

our ANZ Classic banking app

along with understanding financial

vulnerability and accessing support

to manage debt.

• Uplifted training materials and

processes in our customer facing

channels, ensuring ongoing

alignment with the revised Banking

Code of Practice and providing

more accessible and inclusive

banking services for our customers.

Employee experience

• Launched a new mandatory training

program and supporting resources

on mental health for all employees

across the markets we operate in.

• Expanded our established Mental

Health First Aid program and training

in Australia and New Zealand to

Manila and India.

Community and partners

• Continued sponsorship of Dylan Alcott

Foundation’s Ability Fest in Melbourne

and Brisbane in October 2024. Ability

Fest is Australia’s leading accessible

music festival, designed to raise

awareness, help normalise disability

and celebrate inclusion.

• Continued the connection with

organisations such as the Brotherhood

of St Laurence and Inclusion Australia,

the national voice for Australians with

intellectual disability, to implement the

Chance for All disability employment

program.

• Announced our pilot program with

Berry Street Yooralla and Dylan Alcott

Foundation (DAF) to provide DAF grant

recipients the opportunity to strengthen

their financial capability using ANZ’s

MoneyMinded program. This program

helps empower people with disabilities

to take control of their financial future.

The commitments are

structured across four pillars:

Inclusive design By utilising inclusive

design principles, we ensure as many

people as possible can use our

products, services, and working

environments with dignity, convenience,

and independence.

Customer experience We identify and

address barriers to banking to promote

equitable access for everyone in the

community. We embrace and integrate

intuitive, innovative accessibility features

into our products and services.

Employee experience As a disability-

confident workforce, we create safe

and welcoming working environments

where people with disability can thrive.

We anticipate the needs of employees

with disability and make the necessary

adjustments to support high

engagement and performance.

Community and partners Through a

wide range of partnerships and ongoing

consultation with leading disability

organisations, changemakers, and

industry groups, we are a voice for

change, raising awareness and closing

social and economic gaps for people

with disability.

One in six Australians and one in four New Zealanders live with disability – these are our family members,

friends, neighbours and colleagues. We know that the world continues to present barriers to people

with disability, preventing them from fulfilling their human rights and potential. ANZ has a proud history

of supporting disability inclusion, with Accessibility and Inclusion Plans (Plan) being implemented since

2007. Each Plan has been registered with the Australian Human Rights Commission.

Key actions in 2025

ANZ also promotes inclusive

banking through accessibility

initiatives such as branch

modifications, interpreting

services, accessible card features

for visually impaired customers,

ATM enhancements (including

audio guidance and tactile

keypads), and ongoing

improvements to website and

mobile app accessibility.

ANZ’s Accessibility and Inclusion

Plan and information on our accessibility

and inclusion programs is available at

anz.com/accessible-workplace

Foundational ESG issue

1. Excludes Suncorp Bank.

48

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Suncorp Bank employees
In August 2025, Suncorp Bank employees voted in favour of the Suncorp Bank

Enterprise Agreement 2025 (EA). The Fair Work Commission subsequently

approved the Suncorp Bank EA, which came into effect on 21 October 2025.

This outcome brings Suncorp Bank and ANZ employment conditions into closer

alignment and is an important step towards becoming one bank. The approved

EA can be accessed on the Fair Work Commission website.

Suncorp Bank employee data has been included in the overall ANZ employee

data from 1 October 2024, unless otherwise noted. The 2025 ESG Data and

Frameworks Pack is available at anz.com/esgreport.

Simplifying the bank

In September 2025, ANZ announced changes

to simplify the bank, strengthen its focus on key

priorities and deliver for its customers.

Foundational ESG issue

By stopping work that doesn’t support

our priorities, we will be able to better

focus on delivering for our customers

and improving our non-financial risk

management. We will be a better bank for

our people as we deliver market-leading

services to our customers that our teams

can be proud of.

In addition, we are building a culture of

clarity, decisiveness, self-awareness,

execution and accountability. A culture

based on talent and performance that

focuses on customers’ needs, promotes

healthy and sustainable ambition,

external competitiveness and a desire to

outperform while ensuring compliance

with no short cuts.

As a result of these changes, ANZ expects

approximately 3,500 employees to depart

the Group by September 2026. As we

undertake these changes, we are

committed to working through impacts

quickly and safely, with both care and

respect for our people.

1. Australia and New Zealand employees only.

Support for employees

where their roles have been

impacted by organisational

change

ANZ recognises the importance of

supporting employees who are leaving

the bank due to organisational change.

ANZ provides a comprehensive Career

Transition Support program which

includes personalised coaching, career

advice, facilitated workshops and

on-demand career support content,

along with funding for career training.

1

These services aim to help employees

navigate their career transition effectively

and secure new opportunities, either

within ANZ or externally.

We also provide support for employees

to navigate change through wellbeing

resources (see page 50 for further

detail), access to our Employee

Assistance Program (discussed on page

50) and additional resources for our

people leaders to support their teams

through change.

49

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Engagement and wellbeing
Engagement

Our approach

My Voice is ANZ’s enterprise-wide

engagement survey that captures

employee sentiment across engagement,

wellbeing, inclusion, speak up culture and

leadership. The survey is run twice yearly

in March (a full survey) and August (a

shorter, pulse survey), complementing

our Risk Culture and Internal Audit surveys.

Dashboards track results from enterprise

to team level, enabling tailored solutions.

My Voice insights drive team

conversations and improvements, inform

people and culture plans and feed into

Divisional and Enterprise scorecards.

Outcomes

The August 2025 pulse survey

results indicated a decrease in overall

engagement across our key indices

compared to the March 2025 survey.

Engagement declined from 84% to

77%, a shift coinciding with significant

changes across ANZ.

While a decline in engagement during

periods of organisational change is

not unexpected, we do not take these

results lightly.

The results highlight the importance

of remaining actively engaged with our

teams, particularly through times of

change and staying focused on areas

where we can improve. We are committed

to addressing the areas identified for

improvement, including further

strengthening wellbeing, inclusion and

our speak up culture. These focus areas

have been integrated into our broader

planning and approach to non-financial

risk management.

At the same time, we will continue to

build on the trusting relationships and

the collaborative, supportive direct team

1


environments our people identified as key

positives in the survey. These strengths

will support our continued work to foster

a culture of excellence.

Wellbeing

Our approach

At ANZ, we’re focused on fostering

workplaces that support holistic wellbeing

by being inclusive, caring, and respectful.

More specifically, we are focused on

strengthening our organisational systems

and processes to help mitigate

psychosocial hazards, while also

enhancing individual level interventions

across all aspects of wellbeing including

mental, financial, social and physical.

Aligned with Australian Work Health

and Safety legislation for managing

psychosocial hazards in the workplace,

ANZ’s mental health roadmap continues

to progress with a range of initiatives

developed and implemented.

These include a psychosocial hazard

checklist for large change programs and a

redesign of the customer response plan

for all branches to help protect employees

from the impacts of inappropriate

customer behaviour. It also includes the

development of key psychosocial hazard

considerations when designing new roles

including ensuring accountability and

capability requirements are clear and that

there is a link between the role purpose

and the strategic objectives of the bank.

Outcomes

A range of wellbeing and safety metrics

are used to measure the success of the

roadmap including wellbeing and safety

incident reports, Employee Assistance

Program utilisation and presenting issue

trends, as well as relevant data points from

ANZ’s internal employee engagement

and risk culture surveys. The roadmap is

measured on an annual basis with the

next iteration of the roadmap to be

reviewed in late 2026.

1. Refers to a group of employees who work directly with

each other on a daily basis, typically employees reporting

to the same manager. 2. All results include employees

and contingent workers.

Another key roadmap initiative recently deployed was the Building Mentally

Healthy Workplaces mandatory online course which has been deployed to all

employees in 2025, with a three month period for completion. The course and

supporting resources are designed to proactively strengthen the awareness and

understanding of employees and people leaders in how to identify, respond and

manage psychosocial hazards in the workplace. Resources include:

• A checklist for people leaders to identify any emerging or existing psychosocial

hazards potentially impacting the mental health of their team.

• A range of tip sheets with practical tips and resources to help leaders and their

team/s identify, manage and mitigate these hazards.

Key actions in 2025

Employee engagement

77%

(March 2025: 85%)

Inclusion

76%

(March 2025: 80%)

Wellbeing

78%

(March 2025: 80%)

Speak Up

80%

(March 2025; 82%)

August 2025 My Voice Key Index survey results

2

Foundational ESG issue

50

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Developing our people
As customer expectations

evolve and technology

advances, our working

environment is constantly

changing.

Our approach

To support our people to continue to

deliver for our customers, strengthen

non-financial risk management and build

a culture of excellence, we offer a range of

learning and development options to build

the skills and capabilities needed today

and in the future.

We manage learning and development

through our Learning Council, Capability

teams and Community of Practice. These

groups align learning to strategy, share

initiatives and address workforce learning

and development needs. Training is

deployed via our Learning Management

System (LMS) and Our Way of Learning

(OWL) platforms, while compliance

training is overseen by a quarterly

governance forum. The ANZ Academy

also offers employees training in

professional skills, banking basics, data,

digital and leadership to build a future-

ready workforce.

Average training hours per employee

decreased by approximately 28% to 24.55

this year as mandatory learning courses

were optimised (and in many cases

shortened), and the range of discretionary

learning courses was rationalised and

reduced.

Further information on employee

training is available in our 2025 ESG

Data and Frameworks Pack available

at anz.com/esgreport.

Investing in our people via learning and

development is critical to enable delivery

of our ANZ 2030 strategy, as we build

a culture of clarity, decisiveness, self-

awareness, execution and accountability.

1. Feedback was sought from a representative sample

group who completed the program a minimum of six

months prior. 2. Persons holding roles within ANZ

designated as Group 3. 3. Group 3 roles and employees

below Group 3’s with direct reports. 4. The Net Promoter

Score is measured with a single-question survey and

reported with a number ranging from -100 to +100,

where a higher score is desirable. ‘Above 20’ is

favourable, ‘above 50’ is excellent, and ‘above 80’ is

world-class.

Foundational ESG issue

Key actions in 2025

We are launching targeted initiatives to increase senior leader decision

making confidence and support divisional leaders to own and prioritise

non-financial risk management. This is part of supporting the delivery of

our seven core workstreams under the Root Cause Remediation Plan, as

discussed on page 16.

Our LEAD@ANZ program focuses on enabling leaders with the right skills

and capabilities to be exceptional leaders. Since launch in 2023, 72.6%

of our people leaders have engaged with the program. To further unlock

organisational momentum, drive strategic outcomes and model the

behaviours needed for a high-performing culture, we continued our

Executive Leadership Series delivering a two-part program focused on

building a high productivity culture for self and teams, with 75% attendance

of Senior Managers

2

and below.

3

Since launch of the ANZ Academy in 2024, more than 19% of employees

have accessed ANZ Academy offerings, with an overall net promoter score

(NPS) of 66.

4

Enterprise masterclasses covered influencing and storytelling,

adaptability, data interpretation and planning and prioritisation.

In 2025, we began a targeted skills uplift program on strengthening

business analysis capability to meet evolving customer expectations and

enhance operational efficiency. Focused on building practical skills,

approximately 350 employees have commenced the 15-week program,

representing 35% of the target workforce. As a result, a positive capability

uplift has been evidenced.

Our Australian Commercial division launched Customer Centred

Conversations (CCC) to build and strengthen bankers’ capabilities to hold

proactive, value-driven, customer-focused conversations. CCC provides

frameworks and tools to help bankers identify deeper business priorities

and strategic needs through structured, customer-centric conversations.

Success is measured via program uptake, behavioural change and

commercial outcomes.

Building internal capability

We offer learning and development

opportunities on ESG risks and

opportunities through our ESG@ANZ

Mindset 2030 Learning Program. The

optional online program includes our

foundational and specialisation learning

programs, supplemented by webinars

and speaker events.

Since the 10-module foundational

learning program was launched in 2023,

over 6,400 employees have completed

the program. This included over 70% of

employees in our Institutional division,

which the learning program was initially

established to support, exceeding our

training and capability target of 65%.

The most recent feedback showed that

98%

1

of respondents believed the

program improved their knowledge of

ESG and how it relates to ANZ, with 79%

using their knowledge from the program

in their role.

An ESG Competency Framework is also

being developed to identify the skills,

knowledge, and behaviours needed for

specific roles across ANZ.

51

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Human rights
1. Suncorp Bank was acquired by ANZ on 31 July 2024. Following the acquisition, Suncorp Bank commenced a phased transition to adopt the policies and processes of ANZ. During

the transition period Suncorp Bank will be subject to a combination of ANZ and Suncorp Bank policies as outlined at page 2. Suncorp Bank is not yet integrated into ANZ’s Human Rights

Statement while work is undertaken to align Suncorp Bank where appropriate. 2. A set of guidelines for States and companies to prevent, address and remedy human rights abuses

committed in business operations. 3. Large business lending customers are current or former lending customers of ANZ’s Institutional division. 4. Executive Committee (ExCo)

comprises ANZ’s most senior executives. The members of ExCo are available at anz.com/exco. 5. Walk Free Global Slavery Index available at https://www.walkfree.org/global-

slavery-index/. 6. Excludes Suncorp Bank.

Human rights are essential to inclusive

development, poverty reduction and

social cohesion. It takes a whole-of-

society response to identify and

mitigate potential human rights risks.

ANZ respects human rights, including

the rights of our employees,

our customers and the people in our

communities. We expect the same

respect for human rights from everyone

who works for or with us.

Our approach

Our approach is outlined in our Human

Rights Statement (Statement)

1

and is

guided by our Code of Conduct, our

behaviours and values, and informed by

internationally recognised human rights

frameworks and standards including the

United Nations Guiding Principles on

Business and Human Rights

2

. We report

on our salient human issues in our 2025

ESG Data and Frameworks Pack, available

at anz.com/esgreport.

Our Human Rights Grievance Mechanism

(Mechanism) provides a channel for

people who consider their human rights

have been impacted by an ANZ large

business lending customer

3

to raise a

grievance with ANZ. This year, we received

two grievances: one has closed with a

response provided, and the other is under

assessment. Our Mechanism Framework

and our grievance reporting is available at

anz.com/human-rights.

We updated our Statement and

Mechanism Framework following a

review that included engaging with

external and internal stakeholders. The

review informed several refinements and

clarifications that improve the operational

effectiveness of the Mechanism. The

Mechanism Framework was endorsed

by ANZ’s Board with oversight from the

Executive Committee.

4

Modern slavery and

human trafficking

Modern slavery manifests in various

forms including human trafficking, forced

labour, debt bondage and involuntary

domestic servitude. It’s a global issue

affecting tens of millions

5

of people which,

despite international laws and regulations

Foundational ESG issue

Training

Delivered targeted training on

human rights to Institutional

employees, including modern

slavery training webinars for

relationship managers

Refreshed communications and

voluntary training modules on

human rights for all employees

Updated modern slavery training

for procurement managers

Piloted modern slavery training

for branch employees

6

in a

region identified as having a

higher risk of modern slavery

due to migrant workforce

Governance

 Incorporated additional

questions relating to modern

slavery and human trafficking

into our Social and Environmental

Risk Screening Tool used by

our bankers in the Commercial

Business, Corporate and

Agriculture customer segment

in New Zealand

Implemented a modern slavery

module into our Third-Party Risk

Management system

Key actions in 2025

Policies, processes and standards

embed our approach to human

rights, including:

Anti-Bribery and Anti-

Corruption Policy as discussed

on page 38

Accessibility and Inclusion

Plan as discussed on page 48

Climate Change Commitment

as discussed on p ag e s 27-28

Diversity and Inclusion Policy

as discussed on page 43

Equal Opportunity, Bullying

and Harassment Policy

available at anz.com/

corporate-governance 

Modern Slavery and Human

Trafficking Statement as

discussed on page 52

Social and Environmental Risk

Policy and Standard as

discussed on page 39

Supplier Code of Practice as

discussed on page 41

Complaints processes as

discussed on page 26

designed to combat it, persists in both

developing and developed nations.

ANZ takes a Group-wide approach to

managing modern slavery risks in our

operations and supply chain.

We work to build the awareness of

employees through targeted training

and our suppliers and customers through

engagement. We seek to continually

improve our policies, processes and due

diligence activities that aim to identify,

assess and manage modern slavery risk.

Our approach prioritises programs of work

through three key workstreams: supply

chain, customers, and investments.

Our annual Modern Slavery and Human

Trafficking Statement is prepared in

accordance with the Australian

Commonwealth’s Modern Slavery Act

2018 and the United Kingdom’s Modern

Slavery Act 2015. Our Modern Slavery

and Human Trafficking Statements are

available at anz.com/esgreport.

52

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

We have measured the dollar value of community investment in accordance
with the Business for Societal Impact Framework (B4SI).

In 2025, our community investment was over $132.2 million

1

. In addition,

we facilitated more than $31.0 million

1

in donations to community organisations

through our employees, customers, shareholders, other partners, and the public.

Our approach

Giving

Our workplace giving program enables employees in Australia to make contributions

to 28 charity partners through regular or once-off pre-tax payroll deductions.

Disaster relief and recovery

We support customers and communities to respond and recover from weather

related events. ANZ’s Disaster Relief and Recovery Policy and Suncorp Bank’s

approach guide an efficient, coordinated, and proportionate response to disasters.

They encompass a range of measures including hardship assistance and financial

support to assist with community rebuilding.

1. Includes Suncorp Bank except for foregone revenue. Refer to the 2025 ESG Data and Frameworks Pack for a detailed

breakdown of our 2025 community investment. 2. Excludes Suncorp Bank. 3. Charitable trusts that provide small grants.

Community investment

Community investment helps to strengthen local

economies and social infrastructure. During the year,

we invested in the communities in which we operate

and continued to work closely with our community

partners to provide support for them and their clients

in a respectful, fair, and appropriate way.

Community grants

2,3

$1,815,347

in community grants were

provided this year

N Z $ 9 3 7, 2 5 5

in ANZ Bank New Zealand

Staff Foundation grants

FJ $ 2 7, 3 6 3

in ANZ Fiji Staff

Foundation donations

$465,750

in ANZ Community

Foundation grants

$250,000

in ANZ Seeds of Renewal

community grants

 

This year, ANZ and our Australian employees donated over $1.3 million

2


to our charity partners through workplace giving. ANZ also matches

donations made by employees in New Zealand and Fiji through payroll

to their respective staff foundations

2

.

Throughout the year, ANZ and Suncorp Bank supported customers in

Queensland and New South Wales affected by cyclones and floods,

helping communities navigate recovery and build resilience. In addition,

Suncorp Bank donated $50,000 to OzHarvest this year to provide food

relief for communities impacted by ex-Tropical Cyclone Alfred.

In December 2024, ANZ activated a financial relief package for customers

in Vanuatu affected by a 7.3 magnitude earthquake. In addition, ANZ

donated $100,000 to Vanuatu Red Cross Society to help the people of

Vanuatu with recovery efforts. More information on how we invest in the

community is available at anz.com/community. A further breakdown of

ANZ’s community investment is available in our 2025 ESG Data and

Frameworks Pack available at anz.com/esgreport.

Key actions in 2025

Foundational ESG issue

53

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Appendix
ESG targets and related Sustainable Development Goals (SDG)

SDG cautionary statement on inclusion

ANZ supports the United Nations (UN) Sustainable Development Goals (SDGs), and we believe that business has an important role to

play in their achievement.

The SDGs are a collection of 17 non-legally binding, interlinked global goals produced by the UN for countries and governments.

The SDGs are included to show how our ESG approach supports the SDGs. ANZ makes no representation, warranty, or assurance of any

kind, express or implied, and takes no responsibility or liability as to whether ANZ’s strategy furthers the objective or achieves the purpose

of the indicated SDG. More information on the SDGs is available at un.org/sustainabledevelopment. The content of this publication has

not been approved by the UN and does not reflect the views of the UN or its officials or Member States.

Concluding targets

1

Related UN SDGs

Savings program pilots

Large Emitters Engagement

Program (LEEP)

Operational emissions and

non-emissions

• Scope 1 and Scope 2

emissions

• Renewable electricity

• Water

• Waste

• Paper

New Zealand retail lending

Continuing targets

1

Related UN SDGs

$10 billion social and

affordable housing

$100 billion social and

environmental activities

Sectoral pathways and

targets in place for 10 sectors

or sub-sectors, to transition

lending to net zero financed

emissions by 2050

2

Operational emissions

3


• Scope 1 and Scope 2

emissions

Gender equity targets

3

1. Targets exclude Suncorp Bank, unless otherwise stated. 2. Our 2025 Climate Report available at anz.com/esgreport details important information about the scope of our sectoral

pathways. Revised pathways and targets include customers of Suncorp Bank that meet our in-scope criteria for inclusion in our pathways. 3. Includes Suncorp Bank.

54

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Explanatory note for the target to fund and facilitate $10 billion
in affordable, secure and sustainable housing by 2030 across

Australia and New Zealand.

‘Affordable, secure and sustainable

housing’ is defined as the products and

services provided to our customers in

Australia to the extent they are related

to the defined activities below. The

$10 billion target is reported as at

30 September 2025 and is a twelve-year

Australia and New Zealand target, from

2018 to 2030.

It includes all financing either funded or

facilitated by ANZ through its products

and services, including, but not limited to,

loans, guarantees and bonds, markets

products and advisory services. It also

includes certain labelled sustainable

finance products such as social/

sustainability bonds and Sustainability-

Linked loans (SLLs).

Our approach to our $10 billion target:

• aligns to United Nations Sustainable

Development Goals (SDGs), specifically

SDG 9 Industry, Innovation and

Infrastructure and 11 Sustainable

Cities and Communities with support

of SDG 3 Good Health and Well-Being;

and

• commits to conducting an annual

review of activities and methodologies

used to guide activities that qualify for

the $10 billion target. This may result in

the inclusion of new activities and any

material changes will be transparently

disclosed. The inclusion of new activities

will not be applied retrospectively.

• The $10 billion target activities

specifically include the construction of,

or investment in, Australian and New

Zealand housing supply that supports

positive market change, including the

following aims:

– supporting social housing for

vulnerable communities;

– expanding the availability of

affordable housing for rental or

purchase;

– increasing the availability of

accessible housing that provides

better design to support disability

and aged persons;

– delivering security of tenure for

rental and/ or including the

opportunity to purchase; and

– improving housing sustainability

via design and features above

minimum standards.

The target includes products and services

that have been provided since 1 October

2018 above a threshold of $1 million.

Transactions that qualify for this target

(excluding deferred deals) contributed to

the $50 billion target from 1 October 2019

to 31 March 2023, and contribute to the

$100 billion target from 1 April 2023.

55

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Glossary of terms
Te r mDefinition

“ANZ” or “the Group” or

“our” or “we”

ANZ Group Holdings Limited and its subsidiaries, unless otherwise indicated.

ANZ Bank Group ANZ BH Pty Ltd and each of its subsidiaries, including ANZBGL and ANZ Bank New Zealand Limited.

ANZ Bank New Zealand ANZ Bank New Zealand Limited.

ANZ GroupANZGHL Group.

ANZ Non-Bank Group ANZ NBH Pty Ltd and each of its subsidiaries, including the Group’s beneficial interests in the 1835i

trusts and non-controlling interests in the ANZ Worldline Payment Solutions joint venture, and ANZ

Group Services Pty Ltd.

Board ANZGHL Board of Directors.

Climate Disclosure

Program

An internal program of work established to enable ANZ to meet the mandatory climate-related

disclosure requirements legislated by the Australian Government in 2024.

Climate riskThe financial and non-financial risks arising from climate change, including physical, transition and

liability risks.

Community investmentContributions from ANZ to address a social issue. Can be classified as time, in kind, cash, management

costs or foregone revenue.

Employee engagementThe levels of enthusiasm and connection our workforce has with ANZ.

Employees Persons employed by ANZ and paid directly through ANZ payroll. They can be permanent (full time or

part time), fixed term or casual.

Financed emissionsEmissions associated with financing through loans or other financial products that result in a credit

exposure. They are estimated based on an attributed proportion of the financial institution’s customers’

emissions. These financed emissions are part of the financial institution’s Scope 3, category 15

emissions. See our 2025 Climate Report Appendix 5 ANZ Financed and Facilitated Emissions

Methodology available at anz.com/esgreport for information about ANZ’s financed emissions.

Financial education

programs

Programs developed by ANZ in consultation with community partner organisations and government.

These programs aim to provide real social benefits to the community by improving financial inclusion

and capability of lower income individuals. Our programs include: MoneyBusiness, MoneyMinded and

Saver Plus.

Gender pay gapThe overall difference in pay between men and women in the workforce.

HardshipTypically refers to a situation where an individual is experiencing financial difficulty, making it challenging

for them to meet their financial obligations. This can include situations such as loss of income,

unexpected expenses, or other personal circumstances that impact one’s ability to repay debts or

manage financial commitments.

Labelled sustainable

finance

Existing banking products with a specific sustainability related label e.g. Green, Social, Sustainability or

Sustainability-Linked.

Large business customersThe customers of ANZ Institutional division where ANZ has a credit exposure.

Large Emitters Engagement

Program (LEEP)

Our signature customer engagement program which provides the framework for engaging with LEEP

customers on their transition plans.

MoneyBusinessAn adult financial education program designed to build the money management skills and confidence

of Indigenous Australians and develop a stronger savings culture.

MoneyMindedA flexible adult financial education program that builds knowledge, confidence and skills to help people

make informed decisions and manage their money. Developed in 2002, MoneyMinded is ANZ’s flagship

financial education program.

56

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Te r mDefinition
NatureThe Taskforce on Nature-related Financial Disclosures refers to ‘nature’ as the “natural world, with an

emphasis on the diversity of living organisms (including people) and their interactions among

themselves and with their environment.”

Net zeroThe state where greenhouse gas emissions are balanced by an equivalent amount of carbon removal

from the atmosphere, resulting in no net increase in global emissions.

Pay Equity GapSometimes called the ‘like-for-like gap’, is the difference in pay between men and women doing the

same or similar roles.

Saver PlusA matched savings and financial education program developed in 2003 by ANZ and the Brotherhood

of St Laurence. Eligible participants who complete the program have their savings matched (up to

$500) by ANZ for approved education-related expenses for themselves or their children.

Scope 1Direct greenhouse gas emissions from sources owned or controlled by a company.

Scope 2Indirect greenhouse gas emissions from consumption of purchased electricity, heat or steam.

Scope 3Other indirect greenhouse gas emissions not covered in Scope 1 or Scope 2 that occur in a company’s

value chain as described in table 5.3 of the Greenhouse Gas Protocol’s Corporate Value Chain (Scope

3) Accounting and Reporting Standard.

Sectoral pathways Industry-specific trajectories of emissions reductions.

Sensitive sectorsAn industry or business category that ANZ considers may present heightened environmental, social,

or governance risks, or significant potential negative impacts. These are: Energy, Extractive Industries,

Land and Forest Management, Water Management, and Military Equipment.

Sustainability-Linked A type of labelled sustainable finance where the economic characteristics (e.g. pricing outcomes) of the

financial instrument are linked to predetermined sustainability performance objectives.

Transition plan A climate-related transition plan is an aspect of an entity’s overall strategy that lays out the entity’s

targets, actions or resources for its transition towards a lower-carbon economy, including actions such

as reducing its emissions.

Women in leadershipMeasures proportion of women out of the entire Senior Manager, Executive, Senior Executive

and Group Executive Committee populations (roles within ANZ designated as Groups 3, 2 and 1

respectively). Includes all employees regardless of leave status but not contractors (which are

included in full-time equivalent).

57

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

Independent Assurance
Statement

Independent Limited Assurance Report to the Directors

of ANZ Group Holdings Limited

Basis for Conclusion

We conducted our work in accordance

with Australian Standard on Assurance

Engagements ASAE 3000 Assurance

Engagements Other than Audits or

Reviews of Historical Financial Information

(ASAE 3000). We believe that the

assurance evidence we have obtained

is sufficient and appropriate to provide a

basis for our conclusion.

In accordance with ASAE 3000 we have:

• used our professional judgement to plan

and perform the engagement to obtain

limited assurance that we are not aware

of any material misstatements in the

information subject to assurance,

whether due to fraud or error;

• considered relevant internal controls

when designing our assurance

procedures, however we do not express

a conclusion on their operating

effectiveness; and

• ensured that the engagement team

possess the appropriate knowledge,

skills and professional competencies.

Information Subject to Assurance and Criteria Used as the

Basis of Reporting

ANZ Group Holdings Limited (ANZ) engaged KPMG to perform a limited assurance

engagement for the year ended 30 September 2025. KPMG’s scope of work

comprised:

Information subject

to assuranceLocation

Criteria used as the Basis of

Reporting (the “Criteria”)

2025 ESG ReportPages

4-55

• GRI Universal Standards published

by the Global Reporting Initiative

(GRI) version dated 2021

• ANZ’s Social and Environmental

Sustainability Target Methodology

• ANZ’s explanatory note on page 55

2025 ESG Data and

Frameworks Pack

• All data sheets

• GRI Content Index

We assessed the information subject to assurance against the Criteria. The information

subject to assurance needs to be read and understood together with the Criteria

available at anz.com/esgreport.

KPMG, an Australian partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English

company limited by guarantee. All rights reserved. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organisation.

Liability limited by a scheme approved under Professional Standards Legislation.

Summary of Procedures

Performed

Our limited assurance conclusion is based

on the evidence obtained from performing

the following procedures:

• Enquiries with management to

understand ANZ’s process for

determining material ESG issues.

The material ESG issues inform the

risk-based limited assurance testing

performed on material data metrics and

narrative claims presented in the 2025

ESG Report and 2025 ESG Data and

Frameworks Pack;

• Interviews with relevant ANZ

management and staff concerning

ANZ’s ESG frameworks and policies for

material ESG issues, and the

implementation of these across the

business;

• Interviews with relevant management

responsible for developing the context

(text and data) within the 2025 ESG

Report and 2025 ANZ ESG Data and

Frameworks Pack to understand the

approach for monitoring, collecting and

reporting;

• Comparing text and data (on a sample

basis) presented in the 2025

ESG Report and 2025 ESG Data and

Frameworks Pack to underlying sources.

This includes assessing whether all

material matters are appropriately

included, whether any have been

omitted, and whether the reported text

and data accurately reflect the

underlying information;

• Testing over ESG targets presented in

the 2025 ESG Report and 2025 ESG

Data and Frameworks Pack and the

disclosed outcomes and performance

of the targets;

• Performing a consistency check of the

2025 ESG Report and 2025 ANZ ESG

Data and Frameworks Pack included

within the 2025 ANZ Climate Report

and 2025 Annual Report; and

• Reviewing ANZ’s assessment of the

disclosures in relation to the GRI; and

• Reviewing the 2025 ANZ ESG Report

and 2025 ANZ ESG Data and

Frameworks Pack (in their entirety) to

ensure it is consistent with KPMG’s

overall knowledge of, and experience

with, the ESG performance of ANZ.

Conclusion

Based on the procedures we have

performed and the evidence we

have obtained, nothing has come

to our attention that causes us to

believe that the ANZ 2025 ESG

Report and ANZ 2025 ESG Data

and Frameworks Pack, has not been

prepared by ANZ Group Holdings

Limited in all material respects, in

accordance with the Criteria for the

year ended 30 September 2025.

58

ANZ 2025 ESG Report

Overview and

governance

Our ESG targets

and performance

Non-financial risk

management

Ethics, conduct

and culture

Responsible customer

engagement

Environmental

sustainability

Financial

wellbeing

Housing

Inherent Limitations
Inherent limitations exist in all assurance

engagements due to the selective testing

of the information being examined. It is

therefore possible that fraud, error or

material misstatement in the information

subject to assurance may occur and not

be detected. Non-financial data may be

subject to more inherent limitations than

financial data, given both its nature and

the methods used for determining,

calculating, and estimating such data.

The precision of different measurement

techniques may also vary. The absence

of a significant body of established

practice on which to draw to evaluate and

measure non-financial information allows

for different, but acceptable, evaluation

and measurement techniques that can

affect comparability between entities and

over time.

The procedures performed in a limited

assurance engagement vary in nature

and timing from, and are less in extent

than for a reasonable assurance

engagement. Consequently, the level of

assurance obtained in a limited assurance

engagement is substantially lower than

the assurance that would have been

obtained had a reasonable assurance

engagement been performed.

Accordingly, we do not express a

reasonable assurance conclusion.

Misstatements, including omissions, are

considered material if, individually or in

the aggregate, they could reasonably be

expected to influence relevant decisions

of the Directors of ANZ.

Use of this Assurance Report

This report has been prepared solely for

the Directors of ANZ who have voluntarily

commissioned this independent

assurance over the information subject to

assurance to enhance transparency and

confidence in their oversight. This report

may not be suitable for another purpose.

We disclaim any assumption of

responsibility for any reliance on this

report, to any person other than the

Directors of ANZ, or for any other purpose

than that for which it was prepared.

Management’s Responsibility

Management are responsible for:

• determining appropriate reporting

topics and selecting or establishing

suitable criteria for measuring,

evaluating and preparing the

information subject to assurance;

• ensuring that those criteria are relevant

and appropriate to ANZ and the

intended users; and

• establishing and maintaining systems,

processes and internal controls that

enable the preparation and presentation

of the information subject to that is free

from material misstatement, whether

due to fraud or error.

Our Responsibility

Our responsibility is to perform a limited

assurance engagement in relation to the

information subject to assurance for the

year ended 30 September 2025, and to

issue an assurance report that includes

our conclusion based on the procedures

we have performed and evidence we have

obtained.

KPMG, an Australian partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English

company limited by guarantee. All rights reserved. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organisation.

Liability limited by a scheme approved under Professional Standards Legislation.

Our Independence and

Quality Management

We have complied with our independence

and other relevant ethical requirements of

the Code of Ethics for Professional

Accountants (including Independence

Standards) issued by the Accounting

Professional and Ethical Standards Board,

and complied with the applicable

requirements of Australian Standard on

Quality Management 1 to design,

implement and operate a system of quality

management.

Maria Trinci

Partner

Melbourne

7 November 2025

KPMG

KPMG

Sarah Newman

Partner

Melbourne

7 November 2025

59

Information

security

Regulation and

risk management

Digital banking

experience

Diversity and

inclusion

Employee

experience

Human

rights

Thriving

communities

Appendices and

Assurance

anz.com/esgreport
ANZ Group Holdings Limited (ANZ) ABN 16 659 510 791

---

ANZ Group Holdings Limited
9/833 Collins Street Docklands Victoria 3008 Australia

ABN 16 659 510 791

10 November 2025

Market Announcements Office

ASX Limited

Exchange Place

Level 27

39 Martin Place

SYDNEY NSW 2000

ANZ 2025 Climate Report

AN

Z Group Holdings Limited (ANZ) today released its 2025 Climate Report.

It has been approved for distribution by ANZ’s Board of Directors.

Yours faithfully

Simon Pordage

Company Secretary

ANZ Group Holdings Limited

2025
Climate Report

Approved for distribution by ANZ Group Holding Limited’s Board.


Acknowledgement

of Country and

Traditional Owners

ANZ acknowledges the

Traditional Custodians of

Country throughout Australia

and recognises their

continuing connection to

lands, skies and waterways.

We pay our respects to

Aboriginal and Torres Strait

Islander cultures, and to

Elders past and present.

Whakatauākī, ANZ

New Zealand’s Proverb

Tākiri-ā-Rangi

The expansive universe

above

Tākiri-ā-Nuku

The beauty of the

proceeding lands below

Tākiri te Awatea

A new dawn beckons

Kia Puāwai ki te Ao

A blossoming to the world

Te Kare ā-Roto e

With ripples of

compassion and

hope for all.

We are continually seeking

to improve our reporting suite

and welcome feedback on our

ESG and climate reporting.

Please address any questions,

comments, or suggestions to

esg@anz.com

We continue to be driven by our

purpose: to shape a world where

people and communities thrive.

Australia – Retail, Commercial, Institutional

New Zealand – Retail, Commercial, Institutional

International – Institutional, Retail & Commercial in Pacific

ANZ network presence

Risk management 22

Metrics and targets 30

TCFD-related metrics and industry

exposures 30

Funding, facilitating and direct

investments in social and

environmental activities through

our $100 billion target 31

Our approach to sectoral pathways 32

Energy 34

Transport 40

Industry 43

Buildings 46

Other metrics 48

Operational emissions 52

Appendices 54

Glossary of terms 82

Independent Assurance Statement 87

Contents

Overview

Disclaimer and important notices 1

Our 2025 reporting suite 2

CEO's message 3

About our business 4

Governance 5

Strategy 8

Our Climate and Environment

Strategy 8

Our Large Emitters Engagement

Program 12

Supporting our customers' transition

through financing 16

Understanding nature risks

and opportunities 18

Building our capability to help

customers understand climate

and nature risks 20

Collaborating with stakeholders

to support the transition 21

B

The material in this report contains
general background information

about the Group’s activities current as

at 7 November 2025. It is information

given in summary form and does

not purport to be complete. It has

a sustainability focus and does not

reflect the totality of the Group’s

business activities. For a more

complete overview of the Group’s

business, see the 2025 Annual Report

available at anz.com/annualreport.

It is not intended to be and should not

be relied upon as advice to investors

or potential investors, and does not

take into account the investment

objectives, financial situation or needs

of any particular investor. These

should be considered, with or without

professional advice, when deciding if

an investment is appropriate.

Forward-looking statements

This report may contain forward-

looking statements or opinions

including statements regarding our

intent, belief or current expectations

with respect to the Group’s business

operations, market conditions, results

of operations and financial condition,

sustainability objectives or targets

and risk management practices.

Those matters are subject to risks

and uncertainties that could cause the

actual results and financial position of

the Group to differ materially from the

information presented herein. When

used in the report, the words

‘forecast’, ‘estimate’, ‘goal’, ‘target’,

‘indicator ’, ‘plan’, ‘pathway ’, ‘ambition’,

‘modelling’, ‘project’, ‘intend’,

‘anticipate’, ‘believe’, ‘expect’, ‘may’,

‘probabilit y ’, ‘risk ’, ‘will’, ‘seek ’, ‘would’,

‘could’, ‘should’ and similar

expressions, as they relate to the

Group and its management, are

intended to identify forward-looking

statements or opinions.

Those statements are usually

predictive in character; or may be

affected by inaccurate assumptions

or unknown risks and uncertainties or

may differ materially from results

ultimately achieved. As such, these

statements should not be relied upon

when making investment decisions.

There can be no assurance that

actual outcomes will not differ

materially from any forward-looking

statements or opinions contained

herein. Also see the notice about

climate related information on this

page which may affect climate-related

forward-looking statements or opinions

and the information in Appendix 5 which

may affect forward-looking statements or

opinions relating to the Group’s financed

and facilitated emissions.

The forward-looking statements or

opinions only speak as at 7 November

2025 and no representation is made as to

their correctness on or after this date. No

member of the Group undertakes to

publicly release the result of any revisions

to these statements to reflect events or

circumstances after this date to reflect the

occurrence of unanticipated events.

Climate-related information

This report may contain climate-related

statements, including in relation to

climate-related risks and opportunities,

climate-related goals and ambitions,

climate scenarios, emissions reduction

pathways and climate projections. While

the statements were prepared in good

faith, climate-related statements are

subject to significant uncertainty,

challenges and risks that may affect

their usefulness, accuracy and

completeness, including:

1. Availability and reliability of data –

emissions and climate-related data may

be incomplete, inconsistent, unreliable

or unavailable (including information

from the Group’s customers), and it may

be necessary to rely on assumptions,

estimates or proxies where that is

the case.

2. Uncertain methodologies and modelling

– methodologies, frameworks and

standards used for calculations of

climate-related metrics, modelling and

climate data are not universally applied,

are rapidly evolving and subject to

change. This may impact the data

modelling, approaches, and targets

used in preparation of this report.

3. Scenario analysis limitations – analysis

of climate scenarios is limited by its

reliance on assumptions, estimates

and projections that are not exact.

4. Complexity of calculations and estimates

– estimating financed or facilitated

emissions (including allocating emissions

to banking activities) and emissions

reduction is complex and relies on

assumptions and judgments, often

made in respect of long periods of time.

5. Changes to climate-related governing

frameworks – changes to climate-

related policy, laws, regulations and

market practices, standards and

developments, including those

resulting from legal proceedings

and regulatory investigations.

6. Lack of consistency in definitions

and climate-science terminology

subject to changes – definitions and

standards for climate-related data

and assessment frameworks used

across industries and jurisdictions

may vary, and terminology and

concepts relating to climate science

and decarbonisation pathways may

evolve and change over time. These

inconsistencies and changes can

also make comparisons between

different organisations’ climate

targets and achievements difficult

or inappropriate.

7. Reliance on third parties for data or

involvement – the Group may need

to rely on assistance, data or other

information from external data and

methodology providers or other third

parties, which may also be subject

to change and uncertainty.

Additionally, action and continuing

participation of third parties, such

as stakeholders, may be required

(including financial institutions and

governmental and non-

governmental organisations).

Due to these uncertainties, challenges

and risks, statements, assumptions,

judgments, calculations, estimates or

proxies made or used by the Group

may turn out to be incorrect,

inaccurate or incomplete. Readers

should conduct their own independent

analysis and not rely on the information

for investment decision-making.

Disclaimer and important notices

The information in this notice should

be read with the qualifications,

limitations and guidance included

throughout this report and in:

Appendix 4 ANZ Climate Scenario

Analysis Methodology

Appendix 5 ANZ Financed and

Facilitated Emissions Methodology

Appendix 7 Scope 1, Scope 2 and

Scope 3 Operational Greenhouse

Gas Emissions Reporting

Methodology

ANZ Social and Environmental

Sustainability Target Methodology

available at anz.com/esgreport

2025 ESG Data and Frameworks

Pack available at anz.com/esgreport

1

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Our 2025 reporting suite
Where to find

Annual

Report

Full Year

Results

announce-

ments

Corporate

Governance

Statement

Climate

Report

ESG

Report

ESG Data

and

Frameworks

Pack

Modern Slavery

and Human

Trafficking

Statement

Voluntary Tax

Transparency

Report

Financial

Governance

Strategy

Risk

ESG disclosures

and performance

Climate disclosures

and performance

About this report

Our 2025 Climate Report outlines ANZ

Group Holdings Limited (ANZGHL) ABN 16

659 510 791 and its subsidiaries’ (referred

to as “ANZ” or “the Group” or “our” or “we”)

approach and progress towards our

Climate and Environment (C&E) Strategy

vision to finance a sustainable transition.

This year, the report is prepared in

accordance with the Task Force on

Climate-related Financial Disclosures

(TCFD). See Appendix 2 for our TCFD index.

Under the Corporations Act 2001 (Cth), the

Australian Sustainability Reporting Standard

AASB S2 – Climate-related Disclosures

(the Australian equivalent of International

Financial Reporting Standards (IFRS) S2)

will apply to ANZGHL for the financial year

commencing 1 October 2025.

This report is also informed by the

Taskforce on Nature-related Financial

Disclosures (TNFD) framework for nature

disclosures, Glasgow Financial Alliance

for Net Zero (GFANZ), and Transition Plan

Taskforce (TPT) guidance and framework

in our disclosures on transition planning.

The report also details our actions in

setting pathways and targets to reduce

our financed and facilitated emissions in

key sectors, informed by the UN Guidance

for Climate Target Setting for Banks and

the Partnership for Carbon Accounting

Financial (PCAF) guidance. See page 32.

KPMG has performed assurance over

the disclosures in this report. A copy

of KPMG’s independent assurance

statement can be found on pages 87-89.

Reporting boundaries and periods

The processes, approaches and policies

described in this report may vary in

application across ANZ’s operations to

reflect specific legal requirements of the

jurisdictions in which ANZ operates.

Data and information within this report

relates to the consolidated Group for the

financial year ending 30 September 2025,

referred to as “2025” or “this year”,

throughout the report, except for:

Yea r

DataAs atPage

2025Australian home loan

portfolio assessed

as vulnerable to

physical risks

30

June

Page

28

2024

and

2025

Financed emissions

and sector-level

progress

Facilitated emissions

from capital market

activities

1

30

June

Pages

32-47

For further information on specific

methodologies and definitions (including

boundaries), see Appendix 4 and 5.

1. Deals for facilitated emissions from capital market activities for 2024 was for a 9-month period of 1 October 2023 to 30 June 2024 as we transitioned to 30 June end

reporting of Exposure at default. 2. The Suncorp Bank Performance and Remuneration Policy forms part of, and should be read in conjunction with, the ANZ Group Performance

and Remuneration Policy.

Reading this report

Words underlined like ‘this’ are

explained in the Glossary of terms on

pages 82-86. Monetary amounts in

this document are reported in

Australian dollars (AUD), unless

otherwise stated. Throughout this

report, the sum of parts within charts

and commentary may not equal

totals due to rounding.

Suncorp Bank

On 31 July 2024, the Group acquired

100% of the shares in SBGH Limited, the

immediate holding company of Norfina

Limited ABN 66 010 831 722 (previously

called Suncorp-Metway Limited)

(“Suncorp Bank”).

Following the acquisition, Suncorp Bank

commenced a phased transition to adopt

the policies and processes of ANZ. During

this transition period Suncorp Bank will

be subject to a combination of ANZ and

Suncorp Bank policies. As part of the

ongoing transition, Suncorp Bank will

seek to align to ANZ policies and practices,

where appropriate. Where Suncorp Bank is

included or excluded in policies, standards

or metrics throughout the report, this is

denoted. Noting Suncorp Bank is excluded

from prior year metrics, in this report.

Suncorp Bank’s operations continue to be

supervised by key regulatory bodies and

seeks to meet all due diligence obligations

mandated by law.

The following ANZ policies and standard,

which embed our approach to climate,

currently apply to Suncorp Bank or

applied to Suncorp Bank during the

reporting period:

• Non-Financial Risk Policy

• Performance and Remuneration

Policy – Group

2

• Climate Risk Standard (approved

30 September 2025)

During the reporting year, Suncorp Bank

retained the following policies:

• Responsible Banking Policy

• Credit Risk Management Policy

• Operational Resilience Policy

2ANZ 2025 Climate Report

These include technological
advancements, diversification of the

energy mix, market demand for climate

solutions, evolving consumer preferences

and public policy developments.

Currently, a combination of these factors

has led to the pace of the economy-wide

transition being slower than envisaged.

These realities impact our approach to

transitioning our lending portfolio to net

zero financed emissions by 2050 in line

with the goals of the Paris Agreement.

We acknowledge the Australian

Government’s release in 2025 of its Net

Zero Plan, accompanying sector

pathways and consultation on transition

planning. We will also be monitoring the

outcomes of the 2026-27 review of the

Australian Safeguard Mechanism and the

implications for our customers. These will

help guide our customers with operations

in Australia on how their efforts may

contribute to supporting Australia to meet

these sector and economy-wide plans.

Within this context, we expect the

pathways to net zero will look different

for different sectors. Where our

customers have, or are in the process of

further developing robust and credible

transition plans, we will continue to

support their efforts. This aligns to our

objective to be a trusted partner for our

customers as part of our Climate &

Environment Strategy.

Our vision at ANZ is to

finance a sustainable

transition. In particular,

we aim to be a leading

bank in supporting an

effective and orderly

transition for our large

business customers.

Our focus is on encouraging and

supporting our Large Emitters

Engagement Program (LEEP) cohort of

customers to continually improve their

transition plans. This year our customers

have demonstrated improvement, with

more of our customers assessed in the

'Mature' phase of our transition plan

assessment framework.

The LEEP program sits alongside our suite

of financed emissions reduction targets

that track our progress in aligning our

lending to net zero financed emissions.

eight of our revised sectoral pathways are

on-track, two are close to on-track and

none are off-track this year.

ANZ and our customers are making

good progress, but there are

continuing challenges.

Climate change and the transition to

net zero is an enormous and complex

challenge. We acknowledge there are

factors, outside of our control, which

impact the pace of the transition.

This year, we have achieved more than

$84 billion towards our target to fund and

facilitate at least $100 billion by end 2030

in social and environmental activities

through customer transactions and direct

investments. We also achieved a record

year in labelled sustainable finance,

participating in 159 deals.

We have continued to integrate and

embed climate risk into our Risk

Management Framework. This includes

taking steps to enhance our climate risk

scenario analysis capability, and disclosing

outcomes on the identification and

assessment of potential physical risks

within the Australian home loan portfolio.

Understanding the complexities and

challenges our customers face – as the

global landscape continues to evolve –

enables us to better engage with them

and support them to transition.

With this foundation in place, we

continue our preparation for Australia's

mandatory climate reporting. This is

a transition year and our climate

disclosures will be integrated into

our Annual Report from 2026.

CEO’s

message

Nuno Matos

Chief Executive Officer

Nuno Matos

Chief Executive Officer

3

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

About our business
We have a combination of two scale markets in Australia and New Zealand, two market-

leading positions, in Institutional and New Zealand, and a well-diversified business model

which includes Asia.

To deliver our banking products and financial services, ANZ is supported by a broad ecosystem of stakeholders integrated

across our value chain. These include capital providers, suppliers, employees and customers.

Upstream value chainOur business modelDownstream value chain

Capital providers

Includes customer deposits,

wholesale funding, institutional

investors in ANZ’s debt

programs, equity investors,

retail and institutional

shareholders.

Our suppliers

Suppliers and service

providers, including

technology vendors,

infrastructure partners, and

professional services firms.

Australia Retail

Banking products and

services provided to Australian

consumers including home

loans, deposits, credit cards

and personal loans.

Institutional

Services to institutional and

corporate clients, including

governments, via Transaction

Banking, Corporate Finance

and Markets business units.

New Zealand

Banking products and

services provided to New

Zealand customers through

Personal, Business and

Agribusiness units.

Australia Commercial

Banking products and

services provided to small-

to-medium enterprises, large

commercial customers and

high-net-worth individuals

and family groups in Australia.

Suncorp Bank

Banking and related services

to retail, commercial, small

and medium enterprises

and agribusiness customers

in Australia.

Pacific

Banking products and

services provided to retail

and commercial customers,

and to governments located

in the Pacific region.

Our customers

Individuals and businesses

using ANZ’s banking products

and services.

Our employees

Includes permanent, fixed

term, contractors and casual

employees across all ANZ

locations.

Our investments

Capital deployed through

debt and equity investments,

including holdings in associate

entities.

Our other stakeholders

Includes partners, regulators,

community, industry

associations, governmental

and non-governmental

organisations.

Group centre

Supporting functions including technology, property,

risk management, financial management, treasury, human

resources, corporate affairs and shareholder functions.

It also includes minority investments in Asia and interests

in the ANZ Non-Bank Group.

1

For details on how our business

model and value chain informed

aspects of the identification and

assessment of our material climate

risks, refer to pages 25-27.

1. ANZ NBH Pty Ltd and each of its subsidiaries, including the Group’s beneficial interests in the 1835i trusts and non-controlling interests in the ANZ Worldline Payment Solutions joint

venture, and ANZ Group Services Pty Ltd.

4ANZ 2025 Climate Report

Our ESG governance framework
is evolving with our ESG approach

and the expectations of our

stakeholders. This year, the

following changes have occurred

relating to committees with

oversight of our ESG approach and

climate risks and opportunities:

The Board Ethics, Environment,

Social and Governance (EESG)

Committee was discontinued

and its responsibilities

reallocated, as appropriate,

to the Board and its sub-

committees.

The management Ethics

and Responsible Business

Committee (ERBC) was

discontinued and where

appropriate, matters previously

considered by the ERBC

are referred to the Executive

Committee (ExCo).

1

A new and more focused

management Climate and

Environment Committee (CEC)

was established in March

2025 reporting to ExCo.

Governance

ANZ Board and committees

ANZ Group Holdings Limited’s Board

(Board) is responsible for oversight of

the Group. The Board, with the support

of its committees, is also responsible for

overseeing ANZ’s governance framework.

The framework seeks to provide for

effective and responsible decision making,

assisting ANZ to deliver on its strategy

and purpose.


Our governance framework seeks to provide a structure for effective and responsible decision

making at ANZ, including the approach to our climate ambition, action and accountability.

Board skills and experience

The Board has the collective skills,

capabilities and experience needed to

allow the Board to perform its role and

discharge its responsibilities. The 2025

Corporate Governance Statement (refer

to anz.com/corporategovernance) details

the categories that the Board considers

relevant to assessing the collective skills

and experience of the Board and is what

the Board is looking for in its own

composition. One of the categories is

sustainability, including climate.

The Board and each Board

committee has its own charter

setting out its roles and

responsibilities available at

anz.com/corporategovernance

More information on ANZ’s

governance framework is provided

in the 2025 Corporate Governance

Statement available at anz.com/

corporategovernance

Principal Board


committees

Audit

Committee

Risk

Committee

People

and Culture

Committee

Digital Business

and Technology

Committee

Nomination and

Board Operations

Committee

Board of Directors

1. Executive Committee (ExCo) comprises ANZ's most senior executives. The members of ExCo are available at anz.com/exco.

5

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Board committees
Other management

committees and forums

Key management roles

Key management commitees

Credit and Market Risk

Committee

Primary Group management forum

responsible for the oversight and

control of credit, market and other

material financial risks across the

Group. This includes relevant

climate-related financial risks.

Chaired by the Chief Risk Officer.

Executive Committee

Comprises ANZ’s most senior

executives. A delegations of

authority framework outlines those

matters delegated to the Chief

Executive Officer (CEO) and other

members of senior management.

Chaired by the CEO.

Climate and Environment

Committee

A decision-making committee

that is responsible for the execution

of our Climate and Environment

Strategy (C&E Strategy). This

includes past, current and

emerging climate and environment

risks and opportunities and climate

and environment targets.

Chaired by the Group Executive,

Institutional.

(Established March 2025)

Climate and Environment Forum

Responsible for overseeing delivery of our C&E

Strategy, and provides recommendations and

escalations to the CEC, Board and other

management committees.

(Established February 2025)

Climate Disclosure Program Steering Committee

Responsible for overseeing delivery of the Group-

wide Climate Disclosure Program to meet Australian

mandatory climate-related disclosure requirements.

(Established October 2024)

Chief Risk Officer

Responsible for

the management

of the Group’s risk

function, including

policies, systems

and processes

for identifying,

assessing and

managing risk

(including climate

risks).

Group

Executive,

Institutional

Responsible

for overseeing

execution of our

C&E Strategy.

Group General

Manager, Climate

Leads the Group’s

policy response to

climate change,

including supporting

the implementation

of the Large Emitters

Engagement

Program (LEEP) and

setting sectoral

pathway targets.

Group Head,

Corporate Affairs

Responsible

for voluntary

climate and ESG

disclosures and

ESG governance.

Chief Financial

Officer

Executive Sponsor

for Group-wide

Climate Disclosure

Program and

accountable for

ensuring the

program delivers

on its objective of

meeting Australian

mandatory climate-

related disclosure

requirements

applicable to

ANZ from

1 October 2025.

Audit Committee

Oversees financial

reporting principles

and policies, controls

and procedures.

Risk Committee

Oversees the implementation

and operation of the Group’s

Risk Management Framework,

including climate risk.

Responsible for endorsing the

Risk Appetite Statement.

People and Culture

Committee

Oversees the effective

operation of the

Performance and

Remuneration Framework

and other Talent and

Culture matters.

Nomination and Board

Operations Committee

Oversees matters to

do with the proper

functioning of the Board,

including in relation to

ongoing composition and

overall Board operations.

ANZ Group Holdings Limited Board

The Board and management committee structure below outlines relevant committees that have oversight of climate

risks and opportunities across the Group. It reflects changes to our ESG governance structure this year with the Board

committee changes effective from 5 September 2025.

6

ANZ 2025 Climate Report

Climate-related focus
areas of Board

1

and

management committees

During 2025, we engaged on a range

of ESG topics with our Board, senior

executives, regulators, government

and non-government organisations.

Directors also received briefings to

build knowledge in areas such as

climate and nature.

Board EESG Committee and

Management ERBC and CEC

Climate-related topics were discussed

at four Board EESG Committee

meetings (two meetings of the full

Board)

2

and each management CEC

and ERBC

3

meeting. Some topics

included:

C&E Strategy;

Climate-related targets

including sectoral pathways;

Preparation for mandatory

climate-related disclosures in

Australia; and

Customer engagement

on climate and nature,

including LEEP.

Board Risk Committee (BRC)

and Group Management Risk

Committee (Credit and Market

Risk Committee (CMRC))

Climate risk content was considered

at every meeting of the BRC and the

CMRC, with papers on Climate Risk

(as a Material Risk) as required.

Sectoral Pathway Transaction Escalation Process (STEP)

For our material energy transactions, we apply an enhanced due diligence process,

requiring review of the proposed transaction by internal senior subject matter experts. Our

experts evaluate the customer’s transition plan using the LEEP assessment framework

(see page 12 for further details) and having regard to ANZ’s Climate Change Commitment.

5


In some instances, material energy transactions are escalated for consideration by our

Group Executive Institutional, Group Chief Risk Officer and Group General Manager,

Climate. Reasons for escalation vary and may include consideration of larger transactions,

more significant impacts to emissions reduction pathways, reputational risk, or where

ANZ has assessed a customer’s transition plan as not yet in the 'Mature' phase (refer to

page 13 for detail). Our approach extends beyond each lending decision to decisions

relating to non-lending transactions, for certain energy customers where we consider

certain capital markets activities as part of our transaction escalation processes.

In 2025, we expanded our escalation process to include material lending transactions

6


that impact our industry and transport sectoral pathways. Reflecting its expanded

coverage, the process was renamed the Sectoral Pathway Transaction Escalation

Process. In 2026, we intend to include certain capital markets activities for customers

in scope of our industry and transport sectoral pathways.

In 2025, a total of 6 transactions were escalated to the senior executives, as mentioned

above, with 1 declined and 5 approved.

Governance over ESG and sectoral pathway targets

The setting of climate targets, including sectoral pathways, is reviewed by CEC and

ExCo, and approved by the Board. Targets are also monitored by ExCo and the Board.

In 2025, we introduced an internal reporting mechanism for our sectoral pathways

to provide more regular updates to internal stakeholders to help monitor our

progress. Refer to page 32 for our sectoral pathways and Appendix 5 for the

Financed and Facilitated Emissions Methodology.

1. The number of Board and Board Committee

meetings held during the year is set out in the

ANZ 2025 Annual Report available at anz.com/

annualreport. 2. The Board EESG Committee had its

last meeting in May 2025. 3. ERBC was discontinued

in July 2025. 4. These are a subset of ANZ’s ESG

targets. Relevant targets that contribute to ANZ’s

Group Scorecard are set out in the 2025 ESG Report,

available at anz.com/esgreport. 5. The Climate

Change Commitment excludes Suncorp Bank and

ANZ Bank New Zealand. 6. Transactions that are

likely to have significant impact on the size or carbon

intensity of our sector portfolio, or which ANZ

considers to represent heightened reputational risk.

Executive remuneration

ANZ’s Remuneration Report within

our Annual Report, available at

anz.com/annualreport, details how

performance and remuneration

outcomes are determined for our

most senior leaders.

The CEO’s Short Term Variable

Remuneration (STVR) is assessed

against the ANZ Group Scorecard,

adjusted by the ‘How’ Modifier, which

takes into consideration the CEO’s

leadership of ANZ’s values and

behaviours and ANZ’s risk and

compliance standards.

Performance objectives are set

for Disclosed Executives through

Divisional Scorecards, aligned with the

ANZ Group Scorecard. For Disclosed

Executives, STVR is assessed on

‘What’ assessment (ANZ Group

Scorecard and Divisional Scorecard) x

‘How’ Modifier. The weighting to

Divisional Scorecards varies from 50% to

75% for Disclosed Executives.

ANZ’s Group Scorecard includes relevant

objectives and key performance indicators

(KPIs). For example, the 2025 Group

Scorecard includes delivery against

Environmental, Social and Governance

(ESG) objectives and KPIs, such as:

Strengthen our reputation; enhancing our

employee value proposition and our social

license to operate:

Deliver environmental ESG targets

as planned

4

Divisional Scorecards also include

objectives and KPIs as relevant to the

particular business. Group/Divisional

Scorecards are not designed to capture

all of our ESG targets – however our senior

leaders are accountable for ensuring we

focus on and seek to adhere to our

commitments and policies.

7

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Strategy
1. Our disclosures do not purport to be comprehensive or to satisfy all aspects of GFANZ or TPT’s framework. 2. The

Climate Change Commitment excludes Suncorp Bank and ANZ Bank New Zealand. 3. For further detail on ANZ’s

approach for assessing the eligibility of transactions for inclusion towards the target, refer to the ANZ Social and

Environmental Sustainability Target Methodology available at anz.com/esgreport. 4. Refer to the Metrics and Targets

section for further details and Appendix 7 for ANZ Scope 1, Scope 2 and Scope 3 Operational GHG emissions reporting

methodology. 5. Refer to the Metrics and Targets section for further details and Appendix 5 for Financed and Facilitated

Emissions Methodology. 6. Applying to ANZ Group for the financial year commencing 1 October 2025.

Our vision at ANZ is to finance a sustainable transition. Our Climate and Environment Strategy (C&E

Strategy) sets out our objective to be a trusted partner for our customers, supporting them to adapt

and become more resilient to a changing environment and economy. In particular, we aim to be a

leading bank in supporting an effective and orderly transition for our large business customers.

Our C&E Strategy

We have established three core ambitions, supported by four action pillars that bring together the themes of the steps we are

taking to deliver on our ambitions. These ambitions and action pillars are supported by having specific focus areas and prioritised

action plans for our Institutional, Australia Commercial, Australia Retail and New Zealand divisions that we commenced implementing

aspects of this year.

Our approach to

transition planning

In 2025, we took further steps to progress

our transition planning.

1

Our C&E Strategy

forms the basis for our approach,

including how we plan to support an

effective and orderly transition for our

large business customers. We also draw

on guidance from the Glasgow Financial

Alliance for Net Zero (GFANZ) and the

Transition Plan Taskforce (TPT) transition

planning frameworks to inform areas

of focus in our C&E Strategy. Refer to

Appendix 1 for relevant Indexes.

Our C&E Strategy ambition is supported

by our Climate Change Commitment of

transitioning our lending portfolio to

net zero financed emissions, reflecting

where we can have the most significant

impact. We estimate our lending to

Institutional customers contributes

approximately two-thirds of our total

financed emissions. The remaining

financed emissions arise from our lending

to our commercial and retail customers.

Our Climate Change Commitment will

be available prior to our Annual General

Meeting at anz.com/climate-change.

2

The actions under our C&E Strategy

demonstrate our progress towards

credible transition planning. We

acknowledge that ongoing work is

required to satisfy a robust and well-

developed transition plan.

In this report, we set out the actions we

have progressed and how we have been

supporting our customers’ transition.

Financing a sustainable transition

Vision

Building our capability to help

customers understand climate

and nature risks

Transitioning our lending

portfolio to net zero financed

emissions

Supporting our customers’

transition and resilience

Ambition

Understanding risks

and opportunities

Building capability

and capacity

Driving customer

engagement

and propositions

Collaborating with

stakeholders to support an

economy wide transition

Action

pillars

Our targets

Our climate and environment targets

support the delivery of our C&E Strategy.

We continue to make progress, including

funding and facilitating $84.72 billion

towards our $100 billion target in social and

environmental activities

3

by 2030. Separately,

eight of our revised sectoral pathways are

‘on-track’, two are ‘close to on track’, and

none are ‘off track’. We also recognise our

role in reducing the emissions from our

operations and have continued to reduce

our combined Scope 1 and Scope 2

emissions across our operations.

4


Refer to pages 10-11 for further details

on our 2025 climate and environment

targets and performance, including our

sectoral pathways.

5


Reflecting the upcoming mandatory

climate-related disclosures in Australia

6


and a changing internal and external

operating environment - we are reviewing

our climate and environment targets to

ensure they continue to be relevant and

aligned with our strategy.

8ANZ 2025 Climate Report

How we are driving our ambitions
The below initiatives and activities illustrate how our actions connect to our three

ambitions, supporting the progress of our C&E Strategy in 2025.

AmbitionsFor further information

Our Large Emitters Engagement Program



Page 12

Supporting our customers’ transition through financing



Page 16

Understanding nature risks and opportunities


Page 18

Building our capability to help our customers understand

climate and nature risks


Page 20

Collaborating with stakeholders to support

the transition

Page 21

Managing climate risk



Page 22

Progress on our targets and metrics


Page 10 and 30

Building our capability to

help customers understand

climate and nature risks

Improve our understanding of

how climate and nature risks

and opportunities affect

customers and our lending

portfolio by continuing to

focus on training, data and

tools used to support our

customer engagement.

Transitioning our lending

portfolio to net zero

financed emissions

Continue to engage with our

LEEP and certain sectoral

pathways customers to support

our commitment to transition our

lending portfolio to net zero.

Continue to integrate climate risk

and opportunities into policies,

financing and risk decision

making where relevant.

Supporting our

customers’ transition

and resilience

Enhance customer

propositions and

engagement to support

our customers’ transition

and improve their resilience.

Our future focus

We continue to evolve our approach to enable us to deliver

our C&E Strategy ambitions.

9

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Our targets and performance
Sectoral pathways

1


SectorValue chain coverage2030 interim target

Baseline

year

Performance

against PathwayPage #

Power

generation

Generation

54% reduction in

emissions intensity

2020

On-track

34

Oil and gas

Upstream

Midstream & downstream

(integrated companies only)

32% reduction in

absolute emissions

2020

On-track

36

Thermal coal

Mining100% reduction in

absolute emissions

2020

On-track

38

Auto

manufacturing

Light duty passenger

vehicle manufacturers

18-33% reduction in

emissions intensity

2022

On-track

40

Aviation

Commercial passenger

transport

16-26% reduction in

emissions intensity

2019

Close to on-track

41

Shipping

Shipping operators23-30% reduction in

emissions intensity

2022

Close to on-track

42

Aluminium

Alumina refining

and smelting

17-30% reduction in

emissions intensity

2021

On-track

43

Cement

Production13-25% reduction in

emissions intensity

2021

On-track

44

Steel

Production11-22% reduction in

emissions intensity

2021

On-track

45

Australian

large-scale

commercial

real estate

Owners 60% reduction in emissions

intensity (office buildings

and shopping centres)

2019

On-track

46

On-track – On or below pathway or range (<=0%)

Close to on-track – >0% to <=+10% above the pathway or range

Off track – >+10% above the pathway or range

1. Further information on the scope of coverage can be found in Appendix 5 Financed and Facilited Emissions Methodology.

Ambitions

10ANZ 2025 Climate Report

Ta rg etBaseline
Ta rg et

yearPerformancePage #

Operational

emissions and

non-emissions

• Reducing combined Scope 1 and Scope 2

emissions by 85%

• Reducing combined Scope 1 and Scope 2

emissions by 90%

• Being powered by the equivalent of 100%

renewable electricity

• Reducing waste to landfill by 40%

• Reducing water consumption by 40%

• Reducing paper consumption (office and

ANZ originated customer paper use) by 70%

2015


2015

N/A

2017

2017

2015

2025

2030

2025

2025

2025

2025

(96%)

(96%)

97%

(79%)

(61%)

(77%)

52

Revised operational

emissions

Reducing combined Scope 1 and Scope 2

emissions by 85%

2

20242030Performance

to be reported

in 2026

53

Agribusiness data

coverage cohort


Data coverage target to seek the disclosure of

Scope 1 and Scope 2 emissions at a standard

equivalent to the ‘Australian National Greenhouse

Account Factors’ by 100% of the Agribusiness

data coverage cohort.

N/A202761%49

Other metrics

MetricPage #

Australian residential

home loans

Tracking the emissions intensity of our Australian residential home loan portfolio.48

Operational

emissions

Scope 1, Scope 2 (location- and market-based) and Scope 3 upstream value

chain emissions.

52

$100b Social and Environmental Sustainability Target

Ta rg etBaseline

Ta rg et

yearPerformancePage #

$100 billionFund and facilitate at least $100 billion in social

and environmental activities through customer

transactions and direct investments.

1 April 2023

(commence-

ment)

2030$84.72 billion31

Large Emitters Engagement Program

Ta rg etBaseline

Ta rg et

yearPerformancePage #

Large Emitters

Engagement Program

(LEEP)

Enhance our management of climate risks and

opportunities by intensifying our engagement with

our largest emitting business customers. We will

expect and encourage them to strengthen their

low carbon transition plans, by focusing our

engagement and raised expectations on our 100

largest emitting business customers with the aim

that by end 2025, compared to their starting point

more customers are assessed as being in a 'Mature'

phase of their low carbon transition plans.

20242025Achieved,

45 customers

were assessed

as being in

a 'Mature'

phase of their

low carbon

transition plans,

up from 42

in 2024.1

12

Other targets

1. Between 2024 and 2025, four of our 100 largest emitting customers upgraded to ‘Mature’, and one customer who was assessed as ‘Mature’ in 2024 was removed from LEEP due to

acquisition. In 2025, we expanded LEEP to additional customers subject to the Safeguard Mechanism, certain customers in our sectoral pathways and other large emitters. Within this

expanded LEEP cohort, there are 77 customers assessed in the 'Mature' phase as at end 2025. For further detail, refer to page 12. 2. Having achieved our 2030 target of a 90%

reduction (against a 2015 baseline) earlier than expected, we have revised our combined Scope 1 and Scope 2 emissions reduction target with a more ambitious baseline year of 2024

and to also include Suncorp Bank commencing 1 October 2025.

11

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Supporting our customers
to transition

Customer transition plans – particularly

those in emissions-intensive sectors –

help us understand and support how our

customers are adapting to and responding

to a changing climate.

Under our C&E Strategy, our vision is to

finance a sustainable transition. A key

initiative supporting this is our signature

Large Emitters Engagement Program

(LEEP). Through discussion and

engagement focused on their transition

plans, LEEP enables us to gain a deeper

understanding of our customers’

strategies. This also helps identify potential

financing opportunities to support their

decarbonisation efforts and informs the

management of our climate-related

transition risks associated with lending

to higher-emitting customers.

How we select LEEP

customers

To be included in LEEP, each customer

must satisfy certain threshold

requirements.

1

We also have regard to the

following factors that help us determine

which customers are included in LEEP:

• The customer’s ability to influence the

transition plan (e.g., ANZ’s customer

may not be the entity that manages

the transition plan);

• The materiality of the customer’s

operational emissions or emissions

intensity, having regard to the

relevant industry;

• The nature of the customer’s activities;

and

• The strength of ANZ’s relationship with

the customer.

In applying these factors, ANZ exercises

judgement in considering the significance

of them in relation to the relevant

customer. As a guide, ANZ’s intention is to

maintain 140-160 customers within LEEP,

based on the principle that we want to

engage with customers where we can

have the greatest impact.

From time to time, we may change the

composition of the LEEP cohort. The

Central Review Team (CRT) approves

the LEEP cohort and any changes to its

composition, such as where a customer’s

activities change, where the customer’s

emissions are no longer material or where

there are other factors that ANZ considers

are relevant. For more information about

the CRT, please refer to ‘Governing

transition plan assessment and customer

engagement’ on page 15.

Assessing our LEEP

customers’ transition plans

We expect our customers’ transition plans

to set out four elements – Governance,

Targets, Risk Management and Disclosure.

Key criteria for each element are outlined

in the table on page 13.

The customer transition plan assessment

framework, leverages guidance

from credible third-parties such as the

Transition Pathway Initiative, Climate

Action 100+ and the Science Based

Target Initiative. Expectations for credible

climate transition plans are evolving. In

light of this, we will continue to review our

assessment framework regularly to reflect

relevant developments. We may update

our assessment framework and, if we

make material changes, we will explain

how they impact upon our assessment

outcomes in the relevant year.

We assess the trajectory of our LEEP

customers’ transition plans relative to our

criteria and then categorise those plans as

being ‘Mature’, ‘Progressing’ or ‘Emerging’,

as described on page 13. We expect

customers in the ‘Emerging’ phase to

demonstrate sufficient improvement in

their transition plans to at least the

‘Progressing’ phase, generally within

two years of our engagement.

1. We apply general threshold requirements applicable to all LEEP customers, as well as threshold requirements specific to particular cohorts of LEEP customers. For further detail, refer

to the LEEP customer selection definition in the Glossary. 2. In some cases, our 2025 assessment of LEEP customers took into account customers’ actions and/or information relevant

to our assessment criteria up to 22 October 2025 (i.e., after ANZ’s end of financial year).

How our LEEP customers

are placed in 2025

LEEP customers grouped by

transition phase (150 customers)


Our 2025 assessment

2

resulted in an

upgrade of ten customers: six moved

from ‘Emerging’ to ‘Progressing’, one from

‘Emerging’ to ‘Mature’, and three from

‘Progressing’ to ‘Mature’. Upgrades were

largely driven by customers establishing

or strengthening their quantitative and

timebound climate targets.

During the year, a number of customers

were no longer in LEEP mostly due to

material changes in banking relationships

such as customer exits. For this reason,

we added five new customers to the LEEP

cohort during the year.

For the 16 customers that have remained

in the ‘Emerging’ phase this year, we have

tailored account plans to guide our

engagement. The high-level outcomes for

most of these customers are either to cap

or reduce support (as measured by credit

limits). In many cases, we have also sought

to pivot our financing towards those

customers’ transition or lower carbon

initiatives, noting that some ‘Emerging’

customers are active in transition

investments, but do not meet our other

assessment criteria for ‘Progressing’ or

‘Mature’ (such as disclosures).

MatureProgressingEmerging

774924

Our Large Emitters

Engagement Program

Our customers are also impacted by regulatory expectations, investor scrutiny and

broader societal demands which are driving the need for greater accountability

and climate-related disclosures. While these drivers are global, we acknowledge

the Australian Government’s release in 2025 of its Net Zero Plan, accompanying

sector pathways and consultation on transition planning, which will help guide our

customers with operations in Australia on how their transition efforts might

contribute to achieving these sector and economy-wide plans.

Ambitions

12ANZ 2025 Climate Report

1. We acknowledge that the Task Force on Climate-related Financial Disclosures (TCFD) was disbanded in October 2023, with its recommendations fully integrated into the ISSB
Standards. However, our current assessment framework continues to evaluate customers’ disclosures against the TCFD recommendations. 2. International Sustainability Standards

Board (ISSB).

Summary

phase

description

Customers that generally do not

meet our expectations for the

‘Progressing’ phase. Some may

have internal plans, including

governance structures and

steps being taken to reduce

emissions that are not yet

disclosed. Others may have

disclosed plans but without

accompanying emissions

disclosures or targets to reduce

their emissions.

Customers that are

demonstrating sufficient

improvement of their plans.

These customers may have

targets that fall short of being

Paris-aligned intermediate

targets, e.g., due to challenges

in the sector or environment

they operate in.

Customers that have

disclosed a well-developed

or advanced transition plan.

This includes customers we

consider to be ‘sector

leaders’.

Governance

• Acknowledges the need to

develop a transition plan or at

least recognises that climate

change is a significant issue.

• At least adequate

governance to manage

climate risk.

• Strong governance in place

to manage climate risk.

• Acknowledges climate

is a material risk and

opportunity.

Ta rg e t s

• No public targets to reduce

emissions (although may

have other plans in place to

reduce their Scope 1, Scope

2 or Scope 3 emissions).

• May have a reasonably

ambitious Scope 1 and

Scope 2 target but not yet

Paris-aligned.

• Have a Paris-aligned Scope 1

and Scope 2 target but does

not have clear plans to

achieve the target.

• Have a Paris-aligned Scope 1

and Scope 2 target and clear

plans to achieve the target.

• Committed to net zero by

2050 covering at least Scope

1 and Scope 2 emissions.

• May have targets to reduce

their material Scope 3

emissions.

• Incorporates climate

performance into executive

remuneration.

Risk

management

• Acknowledgement of link

between climate risk and

financial risk.

• Steps being taken to

embed climate risks and

opportunities in company’s

strategy (in addition to

acknowledging link between

climate and financial risks).

• Have embedded climate

risks and opportunities

in company’s strategy.

• Publicly disclosed

scenario analysis.

Disclosures

1

• High level or no Task Force

on Climate-related Financial

Disclosures (TCFD) – aligned

reporting, or equivalent (e.g.,

ISSB)

2

• No or limited disclosure

of emissions.

• No independent assessment

or assurance of transition

plan, targets or emissions.

• Have high level TCFD-aligned

(or equivalent) reporting.

May be moving towards

comprehensive TCFD-aligned

reporting, or equivalent (e.g.,

ISSB).

• At least Scope 1 and Scope

2 emissions disclosed.

• Comprehensive TCFD-

aligned reporting, or

equivalent (e.g., ISSB).

• Scope 1, Scope 2 and

material Scope 3 emissions

disclosed.

• Clear plans to reduce

emissions towards their

targets and disclose their

progress.

• Ideally independent

assessment or assurance

of transition plan, including

targets and emissions.

ProgressingEmergingMature

13

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Energy customers
This year marked a milestone in our

ongoing engagement with our energy

customers and assessment of their

progress. We had set clear expectations

for existing energy customers to achieve

by the end of 2025 and stated that we

may decline or reduce support to

customers that did not meet, or had not

sufficiently improved, towards those

expectations. We are pleased that our

engagement has mostly been positive.

Through this engagement, we have

supported energy customers to

strengthen their transition plans and

report transparently on their climate risks

and opportunities. We have assessed the

majority of the energy customer cohort

as having met, or made sufficient

improvements towards, our expectations.

Our assessment of energy customers’

progress provided valuable insights into

how these customers are approaching the

transition to a lower-emissions economy

and highlighted areas where ANZ can offer

targeted support to accelerate their

progress.

As part of our analysis, we assessed

transition plans for customers

representing approximately 90% of

credit limits of our energy customers.

This represents the vast majority of the

customer relationships within the energy

customer cohort. Transition plans for

energy customers representing

approximately 10% of credit limits were

not reviewed on the basis that exposures

were not material (e.g., energy customers

with very low credit limits) or the energy

customer has materially ‘transitioned’ to

low emissions activities (e.g., renewable

electricity generation).

Some of our energy customers have not

made sufficient progress towards our

expectations and we have reassessed our

support for them based on this and other

factors, by capping or reducing limits – in

some cases this has occurred before

2025. In other instances, we have exited

the customer, partly on the basis of their

lack of progress in developing their plan

since we first set our energy customer

expectations in 2021.

Ongoing LEEP customer

engagement and monitoring

At this point, we have considered how we

can best support the different cohorts of

LEEP customers, recognising that many

will soon be subject to mandatory climate

reporting in Australia or other countries.

We believe the most effective next step is

to adopt a single, integrated approach for

engaging with relevant higher-emitting

customers, regardless of their sector,

while ensuring consistent governance for

how we assess and monitor customer

transition plans. We estimate that through

LEEP we have undertaken enhanced

customer engagement with customers

responsible for around 60% of our

Institutional credit customer portfolio

financed emissions.

1

See LEEP customers

and LEEP customer selection terms in

the glossary for further detail on how we

select LEEP customers.

From 2026 onwards, we intend to engage

with our LEEP customers and assess their

transition plans at least annually. The level

of engagement will vary depending on the

assessment outcomes. For example, we

may increase engagement with customers

we assess as ‘Emerging’ and may reduce

engagement with customers that we

consider to be progressing well.

At the same time, our monitoring of our

LEEP customers’ transition plans will be

ongoing. If we observe that a customer’s

transition plan approach is not progressing

or that they are not achieving their

objectives, we will engage with the

customer and may reduce our support.

In this respect, we recognise that there

may be industry specific or market

challenges beyond the customer’s control,

which we seek to understand and take

into account.

Our 2026 LEEP customer cohort by sector

representation is reflected in the chart

below. As explained below, the

composition of LEEP may change from

time to time.

How our transition plan

assessment affects our

decision making about

LEEP customers

The diagram on page 15 illustrates,

at a high level, how our transition plan

assessment for LEEP customers is

relevant for decisions regarding our LEEP

customers more broadly. Our approach

extends beyond each lending decision

to include non-lending transactions for

certain energy customers where we

consider certain capital markets activities

as part of our transaction escalation

processes. In 2026, we intend to include

certain capital markets activities for LEEP

customers in-scope of our industry and

transport sectoral pathways.

While we continue to refine our decision-

making process, consideration based on

our transition plan assessment represents

a meaningful step forward in our ability to

assess, monitor and engage with our LEEP

customers. This enables us to better

understand the challenges and

opportunities they face and to support

their transition.

1. Includes Scope 1 and Scope 2 (location-based) of

ANZ's large business customers that are ultimate group

parents (where possible) with a material credit limit (either

through group or subsidiary level). We excluded customers

within Project Finance, Financial Institutions, Public Sector,

and other customer segments such as services and

education, which typically have lower emissions.

Oil & Gas

Transport

Food, Beverage & Agribusiness

Power generation

Mining

Other

Property

Mining with material met coal exposure*

32

5

12

2

3

22

9

41

Met Coal*

18

2026 LEEP customers by sector

*This includes 5 of 6 material metallurgical coal

customers, representing ~72% of our exposure

at default (EAD) to this sector.

14ANZ 2025 Climate Report

1. ANZ’s support is subject to applicable policies including the S&E Risk Policy and credit policies, as well as climate
targets including ANZ’s sectoral pathways (see pages 32 for further information). Refer to page 7 for information on

ANZ’s transaction escalation process. 2. Certain activities typically refers to those that assist customers to reduce their

carbon emissions or improve environmental outcomes. 3. Decisions are subject to consideration of industry or market

specific challenges that may impact our customers. 4. For example, decline to participate in new credit or certain capital

markets opportunities, reduce limits available to the customer or selldown existing exposures.

High level representation of how transition plan assessments

relate to broader decision making

Level of

support

Transition

phase

category

Emerging

Progressing

Mature

Likely to

support

1

May reduce

support

3,4

Governing transition plan

assessment and customer

engagement

The CRT is the main decision-making

body for customer transition plan

assessment ratings. The CRT also

governs decisions regarding inclusions

or exclusions from LEEP and, for LEEP

customers in the ‘Emerging’ phase

that have account plans, monitors the

implementation of those plans.

The CRT is co-chaired by

representatives from our Climate Risk

and ESG Analytics and Advisory team,

and includes representatives from

the Institutional division, including

Sustainable Finance and relevant

Business Sectors.

The diagram below illustrates, at a

high level, how we are incorporating

our transition plan expectations into

decision-making processes for our

LEEP customers.

Discuss the preliminary review outcome with Relationship

Managers before recommending customer transition plan

ratings to the CRT for review.

Monitor the account plan implementation

from customers in ‘Emerging’ phase.

Complete the Climate Change Risk

Assessment (CCRA), utilising the

latest climate-related disclosures for

the customer and insights from

customer engagement.

Engage customers with support from

Sector Transition Specialists.

Conduct an independent preliminary

review of Relationship Managers’

responses.


Oversee LEEP customers’ transition

plan ratings and engagement.

Make decisions if the CRT escalates

individual customer ratings.

Review proposed customer assessment

ratings.

Approve ratings except those escalated to

the Senior Executives Group due to

consensus not being reached within the CRT.

Track actions taken from the customer

engagement and evaluate progress against

our customer transition plan assessment

framework.

Senior Executives

Group Executive,

Institutional, Group Chief

Risk Officer, Group General

Manager, Climate

CRT

ESG Analytics and

Advisory Team, Climate

Risk, Business Sectors

and Sustainable Finance

Refer to our Sectoral Pathway

Transaction Escalation Process

on page 7 for further detail.

For our large business customers, including

LEEP customers, decision-making is

subject to due diligence as required by

our Social and Environmental (S&E) Risk

Policy and, where applicable, assessment

via our transaction escalation processes

which considers:

• The customer’s transition plan maturity;

• ANZ’s customer account plan (if any); and

• Relevant reputational risks.

Relationship

Managers

ESG Analytics and

Advisory Team

May support

(support more likely for

certain activities)

1,2,3

15

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

1. The total amount of funds raised by a borrower/ issuer on a transaction or deal e.g., if a customer borrows $1 billion via a syndicated loan from 5 banks providing $200 million each,
then the deal size is $1 billion. 2. To preserve confidentiality, the exact size of the single Corporate transaction executed this year is not disclosed.

ANZ is financing a

sustainable transition by

strategically mobilising

and deploying capital to

support our customers

to transition.

Supporting our Institutional

customers to transition

ANZ’s Sustainable Finance team in our

Institutional division helps our customers

identify climate- and nature-related

risks and opportunities and link our

customers’ financing needs to their

sustainability strategies, through the use

of labelled loans, bonds and trade

products. We continue to observe

sustainability strategies being integrated

by customers into lines of business

which is driving ongoing demand for

these labelled products.

During 2025, we participated in 159

labelled sustainable finance deals with a

total deal size

1

of $165 billion, compared

to 145 deals with a total deal size

1

of

$184 billion in 2024. The amount

attributed to ANZ was $23.60 billion, of

which $17.34 billion was executed through

on-balance sheet loans and other credit

lines and $6.26 billion executed via our

distribution capability. In addition, ANZ

acted as Sustainability Coordinator on

30% of the labelled deals we participated

in (48 deals), demonstrating our leadership

in facilitating sustainable finance.

$66b (41 deals) from Resources,

Energy and Infrastructure

$49b (40 deals) from Financial

Institutions Group

$24b (45 deals) from Property

and Health

$21b (23 deals) from Diversified

Industries

$5b (9 deals) from Food,

Beverages and Agribusiness

Less than $1b (1 deal) from Corporate

2

Total deal size

$165b

Sustainable finance total deal size

ANZ share/hold

120

140

160

180

200

100

80

60

40

20

0

20212022

119

11

202320242025

155

17

144

16

184

19

165

24

Sustainable finance total deal

size

1

over time ($b)

(74 deals) from

International

(68 deals) from

Australia

(17 deals) from

New Zealand

$59b

$99b

$7b

Supporting our customers’

transition through financing

This year we supported

Intellihub with approximately

$3 billion in Green Loans to

continue its roll out of smart

meter, solar, battery, EV

charging and swimming pool

efficiency technology. Certified

by the Climate Bond Initiative,

this was the fourth syndicated

Green Loan for Intellihub since

2021. ANZ acted as Green

Loan Coordinator and Agent

for all four loans.

See page 31 for information

on our $100 billion social and

environmental target.

Nature-related financing

We expect the nature finance market to develop over the short to medium term, as

global sustainable finance taxonomies, nature impact and dependency frameworks,

guidance and standardised metrics evolve. This is demonstrated through the

release of the Australian Sustainable Finance Taxonomy this year which encourages

nature-positive investments.

This year, Endeavour Energy secured $2.07 billion in financing through a Sustainability-

Linked Loan (SLL), aligned with the Asia Pacific Loan Market Association's SLL

Principles. Key performance indicators include Scope 1 and Scope 2 emissions

reduction, operational waste diversion from landfill, and net habitat gain, with a new

Scope 3 emissions target also introduced. ANZ acted as Joint Sustainability

Coordinator, Lender, and Mandated Lead Arranger and Bookrunner.

Ambitions

16ANZ 2025 Climate Report

Business and Retail Products (New Zealand)
ANZ Bank New Zealand offers lending products that may support households and

businesses to transition to a lower-emissions economy.

In addition, ANZ Bank New Zealand continues to offer lending to support customers

impacted by weather related events.

ProductDescription of Product

Business

and Agri

customers

ANZ Agri Uplift

Finance

6

For customers focused on improving farming

practices and increasing business resilience.

Supported by external assurance programs or

best practice. Launched in October 2024.

Good Energy

Agri Loan

7

Supports eligible farm gate agriculture customers

to make energy-efficient upgrades to their

on-farm houses. Launched in March 2025.

Business

Green Loan

8

Allows business and farm gate agricultural

customers to finance (or refinance) eligible assets

or specific projects that demonstrate clear

environmental benefits.

HouseholdsGood Energy

Home Loan

9

For existing eligible home loan customers to

upgrade their homes, including for example: solar

panels, heating and insulation, electric and hybrid

vehicles and chargers.

Healthy Home

Loan Package

10

For eligible customers who are buying, building,

renovating or already own a home with a

6  Homestar rating or higher.

New Zealand retail lending target

Since October 2020 we have supported 23,397 households into healthier homes

and NZ$938.86 million lending through:

• Our Good Energy Home Loan Top Up

• Our Healthy Home Loan package

• Interest-free Insulation Loans

11

Exceeding our target to help New Zealand homeowners improve the sustainability

of their homes and/or reduce their transport emissions through discounted lending

of at least NZ$825 million in aggregate to at least 19,700 households by end 2025.

SDG Bond Program

ANZBGL’s

1

capital and funding

strategy includes issuances

of bonds under ANZBGL’s

Sustainable Development Goal

(SDG) Bond Framework

2

, which

help support our vision to finance

a sustainable transition. This also

assists ANZBGL in maintaining

access to a diverse investor base

across global capital markets.

Since the first ANZ SDG Bond

issued in February 2018, ANZBGL

has issued a total of six ANZ SDG

Bonds amounting to approximately

$8.5 billion, supported by a

$14.5 billion eligible asset pool.

3


Our most recent SDG Bond was

issued in January 2025, raising

EUR 1 billion of Tier 2 capital.

Supporting customers’

decarbonisation

We also support our customers’ transition

through unlabelled financing products

and services. These include relationship

lending, structured lending (such as

project finance or asset finance) and other

banking solutions to finance or facilitate

initiatives that contribute to customers’

decarbonisation.

In 2025, we provided project financing

to fund solar farms and onshore and

offshore wind farms. We also provided

loans to fund sustainable buildings which

meet industry recognised standards or

certifications and guarantee facilities

supporting the sale of energy storage

systems.

For example, we provided $252 million in

project financing and guarantee facilities

to Cubico Sustainable Investments for the

development, construction and operation

of the 252 megawatt Wambo Stage I

and 254 megawatt Wambo Stage II wind

farms in Queensland, Australia.

1. Australia and New Zealand Banking Group Limited.

2. Issuances are subject to market conditions. 3. Some

ANZ SDG Bonds are no longer outstanding. 4. Safeguard

Mechanism – DCCEEW. 5. Vehicle and Equipment

Finance. 6. ANZ Agri Uplift Finance. 7. ANZ Good Energy

Agri Loan. 8. ANZ Business Green Loan. 9. ANZ Good

Energy Home Loan. 10. ANZ Healthy Home Loan

Package. 11. Product discontinued in July 2022.

Environmental Markets

ANZ plays a role in supporting customers’ participation in carbon and environmental

markets. ANZ’s Environmental Markets team engages with Institutional customers on the

risks and opportunities presented by carbon and environmental markets. This includes

customers subject to compliance obligations under the Safeguard Mechanism

4

and

those seeking to participate in carbon and environmental markets on a voluntary basis.

The team provides insights to help build ANZ’s capability and to support our

customers in understanding climate and nature risks. The team also develops related

specialist financing and market-related solutions for customers on both the demand

and supply side.

Supporting Australian commercial customers’ decarbonisation

ANZ has been working with the Clean Energy Finance Corporation (CEFC) since

2017, supporting Australian businesses to invest in more energy efficient assets.

Under the current program, extended in November 2024, ANZ and CEFC each

contribute a 0.40% discount to the interest rate, providing a total discount of 0.80%,

(increased from the 0.50% discount that applied prior to the extension) to eligible

customers for loans up to $5 million.

Eligible customers are small-to-medium sized businesses investing in a broad range

of renewable energy and energy efficient technologies, industrial and agricultural

equipment, recycling technologies and electric vehicles.

5

During 2025, 257 contracts

were funded for a total of $46.64 million under the program.

17

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Understanding nature
risks and opportunities

Our Climate and Environment Strategy (C&E Strategy) reflects our acknowledgment

of the importance of, and links between, climate and nature. Our approach is

guided by our ambition to build our capability to help customers understand both

climate and nature risks.

1. Including chemicals, construction materials, containers & packaging, metals & mining and paper & forest products. 2. Locate, Evaluate, Assess and Prepare. 3. The ENCORE tool

previously referred to ‘impacts’ and ‘dependencies’, however the tool now refers to ‘pressures’ and ‘dependencies’. 4. TNFD – Sector Guidance (June 2024).

Customer engagement

Since 2021, we have engaged with

some of our largest emitting business

customers on nature-related issues.

This year, we ran a two-tiered approach,

building on a desktop analysis conducted

in 2024. This approach helps us better

understand nature-related impacts,

support broad customer engagement

opportunities and informs our nature risk

management approach.

High level analysis 2025 –

LEEP customers

We sought information through our

Climate Change Risk Assessment (CCRA)

about whether LEEP customers are

establishing or strengthening their

nature-related Board governance, metrics

and targets, and disclosures using

recognised indicators or metrics on nature.

Focused nature

engagement cohort

We also undertook a focused engagement

over a small cohort of customers across

sectors (see chart below). Our bankers

initiated discussions with each customer

Focused nature engagement cohort by sector (%)

in the cohort to understand their approach

to managing nature risks and opportunities.

Our engagement approach is informed by

third party frameworks such as Nature

Action 100, SPRING, Forest 500 and the

Taskforce on Nature-related Financial

Disclosures (TNFD).

Key themes arising from this

engagement include:

• Nature is a growing strategic priority.

However, most organisations remain

focused primarily on climate, driven by

mandatory climate reporting

requirements.

• Maturity in nature strategies varies

across sectors. For example, Australian

resource sector customers continue to

be more mature in terms of identifying/

disclosing nature-related risks and

opportunities, partly due to heightened

scrutiny on the activities of customers

operating in this sector.

• Some companies have piloted LEAP

2


or are using aspects of the TNFD, while

others have communicated plans for

inaugural disclosures drawing on the

TNFD.

• In terms of the TNFD reporting

framework, some companies are in

the early stages of adoption of TNFD

recommendations.

• Some companies are embedding

processes to consider nature-related

impacts and dependencies across

their business, while others are taking

a project-specific approach.

An overarching theme was the

challenge of data collection and

subsequent comparison of location-

specific data, arising from a lack of

standardised metrics. This leads to

difficulties in quantifying nature-related

impacts and dependencies of relevant

projects.

Portfolio analysis

Nature risks and opportunities

are inherently sector and location

specific. As a result, identifying and

applying a single portfolio-wide

metric or target is challenging.

The Exploring Natural Capital

Opportunities Risks and Exposure

(ENCORE)

3

tool identifies potential sector-

level nature pressures and dependencies.

Having regard to the TNFD’s additional

guidance for financial institutions

4

, we

have reported against one of the core

disclosure metrics for financial institutions

– ‘Exposure to sectors’. This metric

represents exposure to a defined set

of sectors considered to have material

nature-related pressures and

dependencies. The outcomes are

reflected on page 19.

The assessment highlighted the

materials, and food and beverage

sectors as those with higher potential

pressures and dependencies on nature.

Within the sectors assessed, water use

and terrestrial (land-based) ecosystem

use are categorised as having the most

material potential nature-related

pressures. This analysis helped inform

our approach to customer engagement.

Ambitions

32%

24%

12%

12%

8%

4%

4%

4%

Materials

1

Real Estate Development &

Real Estate Investment Trusts (REITs)

Consumer Staples Distribution &

Retail & Services (Restaurants)

Consumer Durables & Apperal

(excluding Home Building)

Transportation

Food & Beverage

Utilities and Environment &

Facilities Services

Other

Number of

customers engaged

25

32%

24%

12%

12%

8%

4%

4%

4%

Materials

1

Real Estate Development &

Real Estate Investment Trusts (REITs)

Consumer Staples Distribution &

Retail & Services (Restaurants)

Consumer Durables & Apperal

(excluding Home Building)

Transportation

Food & Beverage

Utilities and Environment &

Facilities Services

Other

Number of

customers engaged

25

18ANZ 2025 Climate Report

Our approach to deforestation
Our S&E Risk Policy requires

decision makers to assess material

large business customer impacts. In

financing activities of land and forest

customers

5

, decision makers are

expected to have awareness of the

impacts of the land and forest

customers’ proposed activities,

including in relation to deforestation.

ANZ seeks to support large business

customers’ land management

activities that avoid or reduce

negative impacts on land and

forests, restore and regenerate

ecosystems, including reforestation

and improving grazing, water and

soil management.

We expect land and forest customers

engaging in forest management,

palm oil or soy activities to have

public commitments to high

standards via certification or

independent verification. Information

about ANZ’s policy on land and

forest management is available at

anz.com/social-and-

environmental-risk-management.

As part of our focused nature

engagement cohort, in sectors with

potential heightened deforestation

risk, we have included a tailored

focus on deforestation. Where

relevant, we discussed European

Union Deforestation Regulation

preparedness and the impact of

deforestation targets within the

customers' value chains.

We continue to monitor responses

to deforestation from industry

bodies and other stakeholders.

We will also consider ways to

improve our disclosure of potential

exposure to deforestation, informed

by engagement with the

Accountability Framework Initiative

(AFI) or its delivery partners that we

are planning to undertake in 2026.

This engagement is intended to

supplement discussions with our

customers, industry bodies and

other stakeholders about their use

of the AFI and what benefits it may

have achieved.

1. Pressure and dependency ratings were sourced from ENCORE. A score was applied in order to convert ENCORE's

qualitative assessment to a quantitative analysis and scores were aggregated. 2. Including chemicals, construction

materials, containers & packaging, metals & mining and paper & forest products. 3. Suncorp Bank is excluded from the

Policy. Suncorp Bank maintains its own Responsible Banking Policy which outlines its approach to the management of

ESG risks and opportunities across Suncorp Bank. The Responsible Banking Policy applies to Suncorp Bank and all

products and services provided by Suncorp Bank to its customers. 4. We recognise that there may be preference for

descriptions other than Indigenous such as First Nations peoples or Tangata Whenua. We respect preferences as guided

by the United Nations’ Permanent Forum on Indigenous Issues. 5. Large business customers that we consider manage

or have the potential to significantly impact areas of land.

We continue to draw on the

TNFD framework to help inform

our disclosures in this report.

Refer to Appendix 3 for our TNFD

Index, outlining our response to

the recommendations.

ENCORE

1

potential pressures and dependencies by sector

Lower

The size of the bubble represents exposure at default ($b EAD) as at June 2025.

Potential dependencies

Potential pressures

Higher

Lower

Higher

Household & Personal Products

Automobiles & Components

Consumer Staples Distribution &

Retail & Services (Restaurants)

Consumer Durables & Apparel

(excluding Home Building)

Food & Beverage

52.9

13.7

22.2

0.5

5.1

5.0

15.2

14.9

2.5

1.4

12.3

99.1

Utilities and Environmental

& Facilities Services

Electronic Equipment (including

semiconductors)

Real Estate Development & REITs

Energy (excluding energy utilities)

MaterialsŒ

Transportation

Pharmaceuticals & Biotechology

Our approach to

managing nature risk

Nature loss is classified as an

emerging risk to ANZ under our

Risk Management Strategy.

We are seeking to improve our

understanding of the impacts and

dependencies – positive and negative –

nature and biodiversity can have on our

customers, including how customers are

managing and mitigating material risks

and impacts.

We consider that nature and biodiversity

risk can arise from lending to customers

that have material impacts or

dependencies on nature. These risks

can also arise from legal and regulatory

changes, which may impact ANZ directly

or indirectly through our customers.

Failure to manage these risks may lead

to financial and non-financial risks to ANZ.

We seek to understand nature-related

risks from lending to our large business

customers, including through the

application of our Social and Environmental

Risk Policy (S&E Risk Policy)

3

and related

tools and processes (refer to page 23 for

further information).

ANZ will take steps through the use of the

Social and Environmental Screening Tool,

to understand whether large business

customer activities significantly affect

culturally or environmentally sensitive

areas or issues, and will not knowingly

support those activities. Examples of

such activities include those which

threaten, significantly impact or breach,

as the case may be:

• UNESCO World Heritage sites;

• wetlands on the Ramsar list;

• designated national parks and

conservation areas;

• species listed in the Convention on

International Trade in Endangered

Species of Wild Fauna and Flora;

• species listed in the International Union

for Conservation of Nature (ICUN) Red

List of Threatened Species;

• places or objects of Indigenous

4

cultural

heritage without appropriate consent; or

• relevant international and domestic

treaties and agreements.

19

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

We continue to build the capability of our relevant employees, through programs
and training that develop understanding, knowledge and skills in climate and

nature to help them to engage with and support our customers - a core ambition

of our Climate and Environment Strategy (C&E Strategy).

Building internal capability

We offer learning and development on

ESG, including climate and nature risks

and opportunities, through our ESG@ANZ

Mindset 2030 Learning Program. The

optional online program includes our

foundational and specialisation learning

programs, supplemented by webinars

and speaker events.

Since the 10-module foundational

learning program was launched in 2023,

over 6,400 employees have completed

the program. This included over 70% of

employees in our Institutional division,

which the learning program was initially

established to support, exceeding our

training and capability target of 65%. The

most recent feedback showed that 98%

1


of respondents believed the program

improved their knowledge of ESG and how

it relates to ANZ, with 79% using their

knowledge from the program in their role.

An ESG Competency Framework is also

being developed to identify the skills,

knowledge and behaviours needed for

specific roles across ANZ.

Helping our bankers to support our customers

Education is important for the understanding and effective management

of climate and nature risks and opportunities for our large business

customers. This year, we continued to:

Educate relevant employees about our Social and Environmental Risk Policy

(S&E Risk Policy) and Standard, including specific requirements for sensitive

sectors and Climate Risk Standard.

2

Training related to the S&E Risk Policy is

mandatory for employees authorised to make credit decisions relating to large

business customers. Refer to page 22 for further details on our S&E Risk Policy.

Deliver training to uplift the skills and knowledge of relevant employees

to apply the Climate Change Risk Assessment (CCRA), including relationship

managers who are engaging with our LEEP customers. The training includes

how climate risks and opportunities may manifest for our large business

customers, with reference to our internal customer transition plan assessment

framework.

1. Feedback was sought from a representative sample group who completed the program a minimum of six months prior. 2. Excluded Suncorp Bank during the reporting period. The

Climate Risk Standard will include Suncorp Bank in 2026. 3. Farming for the Future is a not-for-profit research and change program that seeks to progress the Australian agricultural

industry’s understanding of on-farm natural capital and its management.

Building our capability to help

our customers understand

climate and nature risks

Refer to page 23 for further details on

the CCRA and page 12 on our LEEP.

Ambitions

Examples of additional training provided in 2025:

A Climate Risk Masterclass was delivered to employees within the

Group Risk function to provide a deeper understanding of ANZ’s approach to

managing climate risk, including how this is supported through our C&E Strategy.

As part of our collaboration with Farming for the Future (FftF)

3

, face-to-face

training was delivered to ANZ Agribusiness employees including bankers, credit

decision makers and support functions. The sessions covered the findings of

research undertaken by FftF and included upskilling employees on environmental

projects on farms, such as carbon, biodiversity and renewable energy projects.

20ANZ 2025 Climate Report

Collaborating with
stakeholders to support

the transition

We continued to engage with stakeholders and leverage partnerships to uplift

our climate and nature capability and contribute to industry guidance and thought

leadership. We periodically review our membership of industry associations,

bodies and partners we work with for alignment with strategy, ANZ’s position

on policy and advocacy, along with other relevant considerations.

Industry associations

and bodies

We are members of a number of industry

associations and bodies. Through these

memberships we contribute to

discussions on industry-wide economic,

social and environmental issues affecting

our customers, shareholders and the

broader community. This includes matters

impacting the sustainable finance market.

We also participate in industry working

groups, including to contribute towards

improving market standards and market

development.

Many of our memberships are connected

to our Institutional business, reflecting

where we believe we can have the most

significant impact as we estimate our

lending to Institutional customers

contribute approximately two-thirds of

our total financed emissions.

Examples of our memberships include:

• New Zealand Banking Association

• Asia Pacific Loan Market Association

(APLMA)

• International Capital Markets Association

(ICMA)

• Australian Sustainable Finance Institute

(ASFI)

• Climate Bonds Initiative

• Green Buildings Council of Australia.

Examples of working groups we

participated in include:

• APLMA Green and Sustainable

Lending Committee

• ICMA Climate Transition Finance

Working Group

• ASFI’s implementation pilot of the

Sustainable Finance Taxonomy

Partners and

thought leadership

We partner with groups and organisations

to support the delivery of our Climate and

Environment Strategy (C&E Strategy) and

play a role in sharing research and insights

that aim to support our customers.

Pollination

This year, we continued to work with

Pollination to support various aspects of

the implementation of the C&E Strategy.

In addition, we contributed to Pollination’s

second edition Nature Finance Focus

report which details some of the models

that are helping to unlock and scale nature

investment, including nature-related debt

finance.

The Aotearoa Circle

ANZ Bank New Zealand is a leading

partner of The Aotearoa Circle

1

, a

voluntary initiative to protect and restore

Aotearoa New Zealand’s natural resources.

During 2025, ANZ Bank New Zealand

contributed to Circle initiatives including

strategic planning.

Putting energy efficiency to work

The Forgotten Fuel series of reports is the

result of a collaboration between ANZ and

the Energy Efficiency Council.

2

In May 2025 the final report in the series,

Putting energy efficiency to work at home

was released. It details the practical steps

Australians can take to improve the energy

efficiency of their homes, and the climate

and financial benefits of making our

households more sustainable.

Government and regulators

We listen to, and seek to engage with,

government, public officials and

regulators including through participation

in government consultations and

parliamentary inquiries, either directly

or through our industry associations.

ANZ Bank New Zealand has participated

in various consultations with the External

Reporting Board on climate-related

disclosures.

Non-government

organisations

We engage with non-government

organisations (NGOs) on topics that relate

to climate and nature. This enables us to

understand perspectives from external

stakeholders and build our knowledge.

This year, we continued to engage

and meet with environmental NGOs in

Australia, and internationally, covering

our climate policies, climate risks and

opportunities and nature. We also

engaged with regulators, government

and NGOs to build the knowledge of

our senior executives across ESG topics.

1. For further information: The Aotearoa Circle. 2. The Energy Efficiency Council is a not-for-profit membership association and is the peak body for Australia’s energy

management sector.

Ambitions

21

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Risk management
ANZ recognises Climate Risk

as a Material Risk within the

Group Risk Management

Framework (RMF). Climate risk

is also considered to be a

driver of other Material Risks

within our RMF.

ANZ continues to integrate and embed

climate risk within our RMF, which is

overseen by a dedicated Climate Risk team.

This is a multi-year journey, acknowledging

the complexities and challenges that arise

from an evolving regulatory landscape;

limitations on the availability of, and access

to, reliable and consistent data; and the

need to uplift systems, tools, and

capability across the Group.

Refer to pages 5-7 for more information on

our governance structure for the oversight of

climate risks and opportunities.

1. Summaries available here: anz.com.au/social-and-environmental-risk-management. 2. The Climate Risk Standard

excluded Suncorp Bank during the reporting period. It will include Suncorp Bank in 2026. 3. Suncorp Bank has retained

their own Responsible Banking Policy which outlines its approach to the management of ESG risks and opportunities

across Suncorp Bank. The Responsible Banking Policy applies to Suncorp Bank and all products and services provided

by Suncorp Bank to its customers.

Our Risk Management

Framework

The RMF comprises three key pillars, the

Group Risk Management Strategy (RMS),

the Group Risk Appetite Statement (RAS)

and the Group Strategic Planning process,

supported by Risk Principles, which helps

guide risk management and foster an

appropriate risk culture across the Group.

Collectively the RMF helps ANZ identify,

measure, evaluate, monitor, report and

control or mitigate our material risks

including climate risk.

The RMS includes a description of climate

risk, how it is governed and our approach to

managing and overseeing it. The RMS also

sets out our Three Lines-of-Defence model,

with defined roles and responsibilities to

support the management of material risks,

including climate risk. Further details on our

RMF, including our Three Lines-of-Defence

Model, is available in the Risk Management

section of our 2025 Annual Report

available at anz.com/annual report.

The RAS includes climate risk and conveys

the maximum level of risk that the Group is

willing to accept. The RAS includes a

high-level qualitative statement as well as

quantitative metrics and tolerances that

align with our policies for lending to

large business customers within certain

sensitive sectors. We will seek to continue

to enhance our risk appetite metrics as we

evolve our work on climate risk or as the

external risk environment evolves.

Our Policy Framework

Social and Environmental

Risk Policy

ANZ Bank Group assesses and manages

potential social and environmental impacts

of our lending decisions to large business

customers through the application of our

Social and Environmental Risk Policy (S&E

Risk Policy), Social and Environmental Risk

Standard (including specific requirements

for sensitive sectors), and Climate Risk

Standard (Standards).

1,2

The Policy and

Standards apply to ANZ Bank Group,

excluding Suncorp Bank.

3

Our S&E Risk Policy outlines ANZ Bank

Group’s approach to the management

and mitigation of social and environmental

risks arising from large business customer

activities, including the impacts of climate

and nature risks. It is applied to other

customers where ANZ perceives that a

customer or their activities may have a

material impact and is otherwise used to

guide decision-making.

The Social and Environmental Risk Standard

provides bankers with more detail on internal

requirements and the expectations we have

of our large business customers, having

regard to ANZ’s more specific policy positions,

as applicable. It includes core requirements

such as consideration of human rights and

the protection of culturally or environmentally

sensitive areas. ANZ will not tolerate land

acquisition and involuntary resettlement that

we consider improper. The core requirements

apply to decisions relating to large business

customers, in addition to the requirements

specific to sensitive sectors (listed below).

Energy Industry

Extractives Industry

Land and Forest Management

Water Management

Military Equipment

More than one set of sensitive sector

requirements may apply to the same

customer/activity under consideration.

Our Climate Risk Standard is principles-

based and seeks to provide a consistent

approach to identifying, assessing and

managing climate risk. This includes key

elements taken into consideration when

making decisions that may result in actual

or potential climate risks and impacts to our

customers or ANZ. The Standard includes

requirements relating to:

Acting in accordance with our

S&E Risk Policy, C&E Strategy and

Climate Change Commitment;

Identifying, assessing and managing

climate risks in our lending portfolios

and capital markets activity; and

Monitoring and reporting of potential

climate risks and impacts to relevant

forums and committees.

This year we focused on:

Further enhancing and embedding

climate risk management

requirements across the Group

through our Climate Risk Standard

and Non-Financial Risk Framework.

Expanding the escalation process to

include material lending transactions

that impact our industry and transport

sectoral pathways (refer to page 7).

Enhancing our Climate Change Risk

Assessment (CCRA) through exploring

the use of generative artificial

intelligence (refer to page 23).

Enhancing our climate scenario

analysis capability, including through:

• the recruitment of specialist

resources;

• identifying and assessing our

material climate risks; and

• undertaking a physical risk

assessment of our Australian home

loan portfolio (refer to pages 28-29).

Delivery of a Group-wide capability

to undertake geospatial climate risk

assessment through ANZ’s Climate

Risks and Opportunities Platform

(CROP), initially focusing on our

Australian home loan portfolio

(refer to pages 28-29).

Ambitions

22ANZ 2025 Climate Report

Tools and processes
The table below outlines examples of key tools and processes that are used within the credit process across different customer cohorts

to help identify, assess and manage climate risks.

Information on ANZ Bank New Zealand tools will be available in the ANZ Bank New Zealand mandatory climate statement no later than

31 January 2026 on ANZ Bank New Zealand's website.

To o l sCustomer Cohort

Agri Viability ToolA screening tool used to assist bankers with their understanding of

agricultural transactions including certain ESG-related risks when

assessing certain agricultural loan application types.

Small to Medium Agricultural

customers within Australia

Commercial division.

Climate Change

Risk Assessment

(CCRA)

An online tool used to help guide customer engagement and assess

and manage climate risks. The CCRA includes an assessment of our

customers’ exposure to potential physical risks and transition risks and

the maturity of the customers’ transition plan, as aligned to our customer

transition plan assessment framework.

The assessment is ordinarily performed when conducting due diligence

on new to bank customers, when reviewing existing customers (annually),

or prior to a material transaction.

In 2025, we explored the development of a generative artificial intelligence

(AI) assistant to support relationship managers in completing the CCRA

assessment. We are seeking to commence using a generative AI assistant

in 2026, starting with LEEP customers with public disclosures.

Select higher emitting

customers of Institutional,

including Project Finance

1


and LEEP customers.

Climate Variability

Analysis

A form of due diligence to help identify the risk of seasonal variability and

the potential impact on customer performance.

We use Australian Bureau of Meteorology data to determine the short-

term (under 12 months) weather outlook, including examining variability

in annual rainfall against farm productivity results in recent years to

understand if rainfall variability may affect the suitability and volatility of

farming in selected regions. The analysis helps inform ANZ’s strategic

decision making and risk appetite. This analysis is ordinarily prepared for

new customers, existing customers buying additional property and any

customer in a region identified by ANZ as affected by serious rainfall

deficiency.

Agricultural customers within

Australia Commercial.

Social and

Environmental

Screening Tool

A tool used to facilitate qualitative risk assessments of social and

environmental risks, including impacts of climate change, that may result

in potential financial and/or non-financial risks to ANZ Bank Group from

our Institutional customers’ activities. It also assists bankers in the

application of the S&E Risk Policy and the S&E Risk Standard.

This assessment is ordinarily performed when conducting due diligence

on new to bank customers, when reviewing existing customers (at least

annually), prior to a material transaction, or when ANZ Bank Group

becomes aware of:

a) a material change to the customer’s activities, or

b) a material impact occurring.

Customers within Institutional

(our large business customers).

1. Project Finance refers to a business unit within our Institutional division.

23

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Climate Scenario Analysis
We recognise the importance of

climate scenario analysis in helping us

understand our material climate risks and

opportunities

1

, including the resilience

of our business model and strategy.

Scenario analysis also supports insights

into sector and portfolio vulnerabilities

and informs risk assessments, strategic

planning and decision-making across

different time-horizons.

In 2025, we used climate scenario

analysis to identify and assess the material

climate risks to our business model and

conducted a quantitative physical risk

assessment of our Australian home loan

portfolio refer to pages 28-29.

2

We

continue to invest in resources, data and

systems to mature our approach to

scenario analysis.

Identification and assessment

of our material climate risks

We used a combination of quantitative

and qualitative factors to identify and

assess the potential impacts of climate

risk drivers on ANZ’s business model to

identify our material climate risks,

including their interaction with the

ANZ’s material risk

3

categories. This

assessment was informed by external

expert advice, climate scenario analysis,

ANZ’s existing RMF and input from more

than 50 internal stakeholders across a

range of functions. Judgement and

assumptions were applied to support

the identification and assessment of

our material climate risks. These were

documented through each stage of the

process, where relevant, for input and

validation by relevant stakeholders.

To assist with maintaining an up-to-date

understanding of our climate risks, we

seek to update this assessment

periodically. The outcomes inform our

ongoing efforts to integrate and embed

climate risk into ANZ’s RMF and

decision-making processes. Details of

the process are outlined on page 25.

The assessment showed the Group is

exposed to climate risk either directly

through its operations, or indirectly

through lending to customers. Our

material climate risks arise from lending

to business and retail customers,

contributing to credit risk. Climate risk

was also identified as a driver of

non-financial risk. See Potential

impacts of climate risk drivers to the

Group’s material risk categories on

pages 26-27 for further details.

The impact of these climate risks may

be widespread, including through

second-order impacts. For example,

the economic impact of a drought may

extend beyond primary producers to

other customers and sectors, including

suppliers to the agricultural sector and

businesses operating within affected

communities. The sectors identified as

being most affected by climate risk

include agriculture, commercial and

residential property and emissions

intensive sectors.

ProcessesCustomer Cohort

Review and

assessment of our

LEEP customer

transition plans

LEEP is ANZ’s signature customer engagement program, which enables

us to gain a deeper understanding of our customers’ transition strategies.

Review and assessment of LEEP customer transition plans are completed

at least annually.

For further information on the LEEP assessment framework,

refer to page 12.

LEEP customers.

Sectoral Pathway

Transaction

Escalation

Process (STEP)

A process for material transactions for customers in ANZ’s energy,

industry and transport sectoral pathways.

Material transactions are referred to internal senior subject matter experts

for review of the proposed transactions. For further information on STEP,

refer to page 7.

Customers in ANZ’s energy,

industry and transport sectoral

pathways.

Equator PrinciplesA risk management framework that determines, assesses, and manages

social and environmental risks when financing large infrastructure and

industrial projects.

More information on the Equator Principles is available at

anz.com/about-us/esg/policies-practices/equator-principles.

Project financing or export

finance provided to ANZ’s

Institutional customers.

1. Our opportunities analysis is ongoing at the time of this report, and we expect to disclose the outcomes of this next year. 2. Intergovernmental Panel on Climate Change (IPCC)

Representative Concentration Pathway (RCP) scenarios were selected for the physical risk assessment of our Australian home loan portfolio for their detailed physical climate

projections appropriate to evaluating property-level risks. Refer to Appendix 4 for more details of the inputs and assumptions used in our physical risk assessments.

3. Further details on our risk types is available in the Risk Management section of our 2025 Annual Report available at anz.com/annualreport.

24ANZ 2025 Climate Report

Climate risk identification and assessment process
• Mapped ANZ’s business model and value chain (refer to page 4).

• Identified key financial drivers for each division within the business model.

• Assessed financial materiality for each division to determine the scope of the assessment.

• Selected the appropriate climate scenarios and time horizons.

• Identified key physical and transition risk drivers relevant to each division and mapped

these to corresponding financial drivers.

• Developed a methodology to assess:

i) the severity of climate risks across the selected climate scenarios and time horizons,

ranging from low to very high levels of change; and

ii) the potential financial materiality of these risks, classified as low, medium or high.

Risks identified with minimal variation or no direct climate impact were excluded from

the assessment.


• Assessed inherent financial risks to ANZ using the methodology developed in Step 2.

A risk was assessed as material if it was rated as having “high” or “very high” severity

and “high” potential financial materiality.

• Assessed inherent non-financial risks to ANZ using ANZ’s Non-Financial Risk Framework

(NFR) to evaluate the likelihood and impact of each risk. These were combined using

ANZ’s NFR risk matrix to determine an overall consequence rating. Risks rated with “very

high” consequence were considered material.

Step 1. Business

Model and Value

Chain Mapping

Step 2. Climate Risk

Assessment

Step 3. Financial

Impact and Materiality

Assessment

Scenario selection and time horizon

Our assessment focused on ANZ’s inherent risk, explored through two climate scenarios and multiple time horizons. The scenarios,

selected from the Network for Greening the Financial System (NGFS), represent divergent climate pathways to help identify where our

material climate risks may arise.

Two NGFS scenarios were chosen as they provide comprehensive coverage of both transition and physical climate risks across

economic sectors.

NGFS Net Zero 2050

(a 1.5°C future):

Represents an orderly and coordinated

global response to achieving net zero

emissions by 2050 and limiting warming

to 1.5°C in line with the Paris Agreement.

It is characterised by consistent and

stringent climate policy action and rapid

adoption of low emission technologies,

leading to a sharp rise in global carbon

prices and a transition from fossil fuels

to renewables and electrification. While

near-term transition costs are higher,

physical climate risks are moderate due

to avoided climate impacts. This scenario

was selected to assess ANZ’s business

model exposure to high transition risk.

NGFS Current Policies

Hot House World (a >3°C future):

Represents the continuation of today’s

climate policies without additional

ambition, resulting in substantial warming

above 3°C. Transition costs are lower but

physical damages increase due to more

frequent and severe extreme weather

events. This scenario was selected to

assess ANZ’s business model exposure

to high physical risks.

Time horizons

In defining our time horizons, we

considered existing internal decision-

making processes, including those

relating to credit risk assessment,

strategic and capital planning processes

and target setting.

Time Horizon Yea rs

Short-term 0-1 (2026)

Medium-term 1-5 (2030)

Long-term 5+ (2050)

25

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Potential impacts of climate risk drivers to the Group’s material risk categories
Climate risk driver

Examples of

potential impacts

ANZ

Material

Risk

Category

ANZ

Severity Rating

Division

1

Managing the risk

NGFS

Net Zero

2050

NGFS

Current

Policies

Economic transition

Impacts to customers

from the shift to a lower

emissions economy,

including in response to

the regulatory and policy

environment in which the

customer operates,

disruption from new

technology and changes

in demand to lower carbon

products and services.

This may affect the ability

of customers to repay debt,

which may result in an

increased probability of

default, or result in

‘stranded assets’,

particularly for customers

operating in

emissions

intensive sectors

.

Credit

Risk

S

M

L

S

M

L

We manage climate-related credit

risks to our customers through the

application of certain policies, tools

and processes within the credit

process. For further details, refer to

page 23.

Delivery of actions under our C&E

Strategy are also expected to help

support our customers’ transition.

Climate litigation

Increasing risk of climate-

related litigation or

enforcement action, which

may lead to potential fines

and reputational impacts.

Greenwashing, including

misrepresentation of

climate risks, business

credentials or strategies,

may expose ANZ to, for

example, legal proceedings,

financial penalties and

reputational damage.

These impacts could, in

turn, lead to a decline in

ANZ’s future earnings.

Non-

Financial

Risk:

Conduct

Risk

S

M

L

S

M

L

We seek to manage this through

transparent disclosure of our

climate-related financial risks, and

through risk management policies

and processes.

Further, we seek to manage the

potential conduct risk in this context

by monitoring our own legal risks

and claims brought against other

organisations to better understand

emerging trends.

Stakeholder perception

Risk of negative external

stakeholder perception

of ANZ’s management of

climate risk, including

through our external

commitments and ANZ’s

C&E Strategy, impacting

reputation.

If external stakeholders

perceive that ANZ is not

effectively managing

climate risk, this may result

in, for example, climate-

related litigation or

reputational impacts.

Non-

Financial

Risk:

Conduct

Risk

S

M

L

S

M

L

ANZ has a collaborative and

proactive approach to building

and maintaining relationships with

stakeholders, including customers

and shareholders.

We also seek to manage this

through transparent disclosure of

our climate-related financial risks,

and through risk management

policies and processes.

Regulatory change

Risk of failure to act in

accordance with laws,

regulations and regulatory

expectations, including

statutory reporting

requirements in the

jurisdictions in which we

operate, in response to

introduction of regulatory

climate requirements.

Non-compliance with

relevant climate and

environmental risk

regulations and legislation

could lead to penalties,

increased regulatory

oversight, capital overlays

and reputational impacts.

Non-

Financial

Risk:

Regulatory

Risk and

Statutory

Reporting

and Tax

Risk

S

M

L

S

M

L

Climate risk is integrated into ANZ’s

NFR framework. Our Climate Risk

team is working with teams in other

jurisdictions, in which we operate,

that are affected by emerging and

maturing climate-related regulations,

to oversee and support them in

developing their approach to

compliance.

ANZ has a Group-wide Climate

Disclosure Program in place to help

us meet our Australian mandatory

climate disclosure requirements.

Transition risk

1. Severity ratings reflect the assessment at the overall ANZ Group level and do not imply uniform impact across all divisions. For example, a 'High' rating does not

indicate high severity for any specific division.

Australia Retail Australia Commercial Institutional New Zealand Pacific Suncorp Bank Group Centre

Low or Moderate High Very high

S - Short M - Medium L - Long

26ANZ 2025 Climate Report

Limitations and uncertainties in our use of climate scenarios
Climate scenarios include assumptions,

estimates and projections that are not

exact. While scenarios describe a potential

future, these are not a prediction or signal

to future conditions or events, and events

may turn out very differently to the

scenarios considered.

The publicly available source scenarios and

data used to identify and assess material

climate risks and impacts could become

out of date and different methods and

assumptions in the source scenarios may

create inconsistency across results. Climate

risk drivers identified are also uncertain.

Climate risk driver

Examples of

potential impacts

ANZ

Material

Risk

Category

ANZ

Severity Rating

Division

1

Managing the risk

NGFS

Net Zero

2050

NGFS

Current

Policies

Insurability

Impacts to the affordability,

availability and adequacy

of insurance coverage for

customers with assets

exposed to climate-related

physical risks, including as

a result of direct impacts of

extreme weather events.

This may impact a

customer’s ability to repay

debt, increase probability

of default, lead to ‘stranded

assets’ or impact the

amount the Group could

recover due to the value

or liquidity of collateral

security being impaired.

Credit

Risk

S

M

L

S

M

L

This year, we undertook a physical

risk assessment of the Australian

home loan portfolio, including

insurability risk. For further details,

refer to page 28.

Asset damage

Impacts to the value of

assets held as security, as

a result of direct impacts of

extreme weather events.

This may result in damage

to a customer’s physical

assets, increasing the

probability of default or

reducing the Group’s

recovery prospects due

to the value or liquidity of

collateral of security being

impaired.

Credit

Risk

S

M

L

S

M

L

ANZ recognises the role it can play in

supporting affected customers and

acknowledges that this support can

assist ANZ in its management of

associated credit risk. For example,

ANZ supports customers via our

Disaster Relief Package and our

relevant risk policies and

frameworks. For further details, refer

to page 22.

Business disruption

Operational disruption,

including impacts to

customer productivity and

revenue as a result of the

occurrence of extreme

weather events.

Operational disruption may

impact a customer’s ability

to operate, increasing the

probability of default or

reducing the Group’s

recovery due to impaired

collateral value or liquidity.

Extreme weather events

may also result in damage

to the Group’s physical

assets or impact our ability

to serve our customers

and maintain operations.

Credit

Risk,

Non-

Financial

Risk:

Operational

Resilience

Risk and

Physical

Security

Risk

S

M

L

S

M

L

We manage this through the

application of certain policies, tools

and processes within the credit

process. For further details, refer to

page 23.

Physical risks to our operations are

identified, assessed, and managed

through ongoing application of our

NFR Framework. For example, the

Group’s Business Continuity and

Disaster Recovery Plans are in place

to support alternative banking

arrangements for potential

communities affected.

Physical risk

1. Severity ratings reflect the assessment at the overall ANZ Group level and do not imply uniform impact across all divisions. For example, a 'High' rating does not

indicate high severity for any specific division.

Australia Retail Australia Commercial Institutional New Zealand Pacific Suncorp Bank Group Centre

Low or Moderate High Very high

S - Short M - Medium L - Long

See Appendix 4 for further information

about our approach to climate scenario

analysis, as well as the Disclaimer and

Important Notices on page 1 for

information about forward-looking

statements, and the uncertainties,

challenges and risks associated with

climate-related information.

27

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

We used this capability to visualise
physical risks to the Australian home

loan portfolio for ANZ (including

Suncorp Bank). We also explored the

vulnerability of ANZ’s Australian home

loan assets to physical risks, using

external data to assess home

insurance affordability and exposure

to typically uninsurable perils. We will

continue to seek to better understand

physical risk and the potential impacts

to the Group, which may mean our

approach to understanding this risk

will evolve over time.

Understanding the results

The assessment identified that around

2.7% of ANZ’s portfolio (including

Suncorp Bank) is considered

vulnerable to physical climate perils.

This increases to 3.4% by 2050 under

the RCP2.6 (low emissions) scenario

and 4.5% under the RCP8.5 (high

emissions) scenario.

2


As shown in the table below, the Group’s

exposure is primarily associated with

insurable perils (2.4%), while exposure to

uninsurable perils remains relatively

limited (0.3%).

Proportion of Exposure At Default (EAD) within ANZ’s Australian home

loan portfolio that is assessed to be vulnerable to each climate peril

EAD ($b) as at 30

June 2025

7

% of total

Australian home loan portfolio

8

(including Suncorp

Bank) assessed for physical risk404.7

Home loans assessed as vulnerable to physical risks11.12.7

Physical risk driver – Flood 5.51.4

Physical risk driver – Cyclone2.10.5

Physical risk driver – Storm2.00.5

Physical risk driver – Bushfire0.10.0

Physical risk driver – Uninsurable perils1.40.3

1. Refer to ANZ’s Consumer Lending Terms and Conditions. For Suncorp Bank, the requirement to maintain property insurance is included in the credit contract issued to customers.

2. Refer to Appendix 4 for details on our climate scenario selection, including key inputs, assumptions, and limitations. 3. Refer to 2024 Home Insurance Affordability and Home Loans

at Risk report published by Actuaries Institute in August 2024. 4. Sourced from Finity proprietary method to model estimated annual insurance premiums. 5. Sourced from Australian

Bureau of Statistics (ABS) for Statistical Area Level 1 (SA1) regions – 2021. 6. Sourced from Finity proprietary method. Uninsurable perils are typically not covered by building insurance

in Australia, therefore properties exposed to these perils are considered vulnerable to physical climate risk. 7. Reported as at 30 June 2025, to allow additional time for processing and

review of our EAD and Australian home loan data due to the complex nature of the calculation. 8. The assessment was conducted on approximately 92% of Australian home loan

property portfolio, based on available data.

How ANZ is exposed

to physical risk

An increase in the frequency and

magnitude of extreme weather events,

including bushfires, cyclones, floods and

severe storms and longer-term changes

in climate patterns leading to rising sea

levels, may impact our customers' income,

asset values and the cost, availability and

adequacy of home insurance. This may

result in a financial impact on ANZ

(including Suncorp Bank), which potentially

increases if our customers are affected

by an extreme weather event and are

uninsured or underinsured.

In 2025, our analysis focused on our

Australian home loan portfolio (including

Suncorp Bank) given its size, exposure to

physical risks and availability of data to

conduct the assessment.

ANZ Bank New Zealand assesses

physical risk to its mortgage-secured

lending. For further information on

ANZ Bank New Zealand’s physical risk

assessment, refer to ANZ Bank New

Zealand’s Climate Statement for the year

ended 30 September 2025, which will be

available on ANZ Bank New Zealand's

website no later than 31 January 2026.

Identifying and assessing

potential physical risk –

Australian home loan portfolio

Home insurance plays an important role

in providing financial protection for

customers against a range of risks

including direct loss or damage to their

property following an extreme weather

event. Property insurance is a condition

of ANZ’s home loans (including Suncorp

Bank)

1

, given it also helps to preserve

the value of the property held as

security and reduces the risk of the

customer defaulting in the event of

property loss or damage including

following an extreme weather event.

In 2025, we focused on developing

Group-wide capabilities to undertake

geospatial physical risk assessments

through the development of a Climate

Risk & Opportunity Platform (CROP).

Criteria

The following criteria was used

to assess assets vulnerable to

physical risks:

• Insurable perils (bushfires,

cyclones, floods and storms) were

assessed using a Home Insurance

Affordability metric. The metric

aligns to the Actuaries Institute of

Australia Home Insurance

Affordability Index

3

definition of

'affordability stressed', where

estimated annual insurance

premiums

4

exceed four weeks of

estimated household income.

5


• Uninsurable perils

6

(coastal

erosion and coastal inundation)

were assessed using the

following criteria:

–Coastal erosion: Properties

located within 70 metres of

the coastline, with high

shoreline erodibility and low

elevation (less than 10 metres

above sea level).

–Coastal inundation: Properties

identified as being at high risk

due to sea level rise scenarios,

oceanography factors, shoreline

erodibility, property elevation

and distance from coastline

(within 500 metres).

28ANZ 2025 Climate Report

Geographic distribution of ANZ’s
properties across Australia identified

in the physical risk assessment

Our approach to supporting

customers impacted by

natural disasters

Through our Disaster Relief Package

1

,

ANZ supports customers by providing

a range of relief and measures which

may include:

Short-term payment relief on

home loans, credit cards, personal

loans and some business loans

(we may still charge interest during

that period).

Waiving fees for restructuring

business loans.

Waiving fees for early access to

term deposits.

Customers with ANZ Home

and Contents Insurance may be

eligible for emergency funds and

temporary accommodation.

Our relief measures seek to enable an

efficient, coordinated and proportionate

response to disasters. These

encompass a range of measures

including charitable donations, hardship

assistance, financial advice, and

employee volunteering to support

community rebuilding efforts.

States and

territories

Total number of ANZ’s properties (including Suncorp Bank)

vulnerable to climate perils (‘000)

Queensland15.3


New South Wales4.9


Victoria1.9


Western Australia1.8


Others1

To t a l24.9

Assumptions and

limitations

Forward-looking assessments

present challenges due to the

uncertainty of climate models

and inherent limitations in data

quality, coverage, and reliability.

This challenge is common to

many organisations seeking to

understand the potential impacts

of climate risk on their activities.

This is expected to persist until

greater maturity is achieved

within ANZ and across external

datasets that support climate

risk assessments.

The physical risk assessment was

conducted on approximately 92% of

Australian home loan accounts, based on

available data. This coverage reflects the

portion of our mortgage book with a valid

Geocoded National Address File (GNAF).

The Home Insurance Affordability

metric is considered a proxy for physical

climate risk, assessing exposure where

estimated annual premiums exceed four

weeks of household income. It is based

on estimates derived from external data

sources, including the Australian Bureau

of Statistics and does not reflect actual

income of ANZ home loan customers or

actual insurance premiums paid. We

recognise some customers may be

exposed to physical climate perils but

are not captured in this assessment due

to the affordability threshold applied.

We assess the physical risk to the

Group by assuming that the entire

lending exposure is vulnerable if at

least one associated property is

assessed as vulnerable to climate

perils. To avoid duplication, where a

property is exposed to multiple climate

perils, we apply a hierarchy of risk:

uninsurable perils, followed by

insurable perils with the highest Annual

Average Loss (AAL) contribution to the

estimated insurance premium.

The physical risk assessment only

considers inherent risk exposure and

does not account for potential residual

risk exposure to properties where

climate adaptation and/or mitigation

measures have been implemented.

A high proportion of properties identified in this assessment (around 60%) are

located in Queensland, followed by New South Wales (around 20%) with the rest

spread across other states and territories in Australia.

ANZ properties (including Suncorp Bank) vulnerable to climate perils

ACT

SA

NT

VIC

WA

QLD

NSW

TAS

1. Our Disaster Relief Package does not extend to Suncorp Bank. Suncorp Bank currently supports customers impacted by natural disasters through its own policies and processes.

Following the acquisition on 31 July 2024, Suncorp Bank commenced a phased transition to adopt the policies and processes of ANZ. During the transition period Suncorp Bank will be

subject to a combination of ANZ and Suncorp Bank policies, outlined on page 2.

29

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

1. EAD excludes amounts for the ‘Securitisation’
Basel class. Data provided is on a post Credit Risk

Mitigation (CRM) basis, net of credit risk mitigation

such as guarantees, credit derivatives, netting and

financial collateral.

EAD breakdown for carbon exposed sectors 2025 ($b/%)

EAD trends for climate exposed sectors ($b)Subsector trends in EAD ($b)

$80

$100

$120

$60

$40

$20

0

Agriculture

EnergyTransportationMaterials and buildings

202320242025

$12

$16

$20

$8

$4

0

CoalElectric

utilities

Oil and gas

202320242025




16% Carbon-exposed sector EAD

84% Other sector EAD

9% Materials and

buildings

4% Agriculture

2% Energy

1% Transportation

We continue to disclose our Exposure at Default (EAD)

1


against four of the key sectors identified by the TCFD to

highlight potential concentrations of carbon-related assets

most exposed to climate-related risks.

Our overall exposure to these four emissions intensive

sectors remains approximately 16% of the Group’s EAD.

This is consistent with 2024 and is down from

approximately 17% in 2023.

We are disclosing 2024 and 2025 EAD data as at 30 June,

with 2023 EAD data reflecting the position as at

30 September. The 2025 data includes Suncorp Bank

EAD for each sector.

These sectors are:

Energy

Transportation

Materials and Buildings

Agriculture, Food and

Forest Products

Metrics and targets

TCFD-related metrics and industry exposures

Refer to Appendix 6 for a breakdown

of climate exposed sub-industries.

30ANZ 2025 Climate Report

Funding, facilitating and direct
investments in social and environmental

activities through our $100 billion target

This year, we continued to make good

progress towards our target to fund

and facilitate at least $100 billion by

end 2030 in social and environmental

activities through customer transactions

and direct investments by ANZ.

As at 30 September 2025, we have contributed

$84.72 billion in total towards the target since

it commenced on 1 April 2023. The total

comprises funding and facilitating $81.05

billion across 412 customer transactions and

directly investing $3.67 billion through 61

labelled green, social and sustainability bond

purchases held on ANZ’s balance sheet.

1

This includes activities that aim to help lower

emissions, protect or restore nature, increase

access to affordable housing and promote

financial wellbeing.

This year, we exceeded our 2025 goal to

contribute at least $18.5 billion towards our

target, with $45.75 billion added across

186 customer transactions and 61 bond

purchases.

2

This comprised:

• $21.86 billion attributed to ANZ’s on-

balance sheet loans and other credit lines;

• $20.22 billion facilitated by ANZ; and

• $3.67 billion via direct investments

(labelled bond purchases) held on ANZ’s

balance sheet.

In order to count towards the $100 billion

target, customer transactions and direct

investments are assessed against the criteria

for eligible banking activities and eligible social

and/or environmental activities specified in the

methodology for the target. They may include:

• labelled sustainable finance;

• unlabelled banking activities; and

• ANZ’s direct investments.

Some labelled sustainable finance and

unlabelled transactions detailed on pages

16-17 may not meet the above criteria and,

if that is the case, are not eligible for

inclusion in the target.

1. This is the first year we have included direct investment contributions towards our target. To limit complexity,

we have not included those made prior to 8 November 2024 (publication of the latest version of the target

methodology) and those on or after 8 November 2024 where the overlapping facilitation amount in relation to the

relevant bond issuance was included towards the target under the version of the target methodology that applied

before 8 November 2024. 2. 2025 includes transactions validated as eligible for inclusion in the target from

21/09/2024 to 19/09/2025. 3. Funded $42.09 billion includes deals in “Waste” and “Water” which have deal values

less than $0.10 billion. 4. Note that for the purposes of this reporting, Sustainability-Linked transactions (i.e., where

the economic characteristics (e.g., pricing outcomes) of the financial instrument are linked to predetermined

sustainability performance objectives) are reported as a separate category. 5. Includes activities which cover both

environmental and social categories. 6. Includes renewable energy, energy efficiency, clean transportation, green

buildings, and other environmental activities. Other environmental activities include activities which cover multiple

environmental categories and/or activities such as waste, sustainable water and waste water management, and

climate change adaptation. 7. Includes construction or operation of buildings or portfolios of buildings that deliver

positive environmental outcomes, which meet, or renovation or retrofitting of buildings, so that they can meet

regional, national or internationally recognised standards or certifications (e.g., under the Australian NABERS rating

system). 8. Includes affordable housing and other social activities. Other social activities include activities which

cover multiple social categories and/or activities such as socioeconomic advancement and empowerment.

Progress towards our $100 billion social and environmental

sustainability target – 1 April 2023 to 30 September 2025

Funded

$42.09

billion

3

1.35

% Social and Environmental

$0.57b Other social and environmental

5

1.45

% Sustainability-Linked and Environmental

$0.61b Sustainability-Linked and Environmental

40.32% Sustainability-Linked

4

$16.97b Sustainability-Linked

8.51

% Social

8

$2.04b Aordable housing

$1.54b Other social

$1.93b Clean Transport

$8.83b Energy

$7.95b Green building

7

$1.55b Other environment

48.37% Environmental

6

Facilitated

$38.96

billion

Direct

investments

$3.67

billion

14.93% Social and Environmental

$5.82b Other social and environment

5

27.90% Sustainability-Linked

4

$10.87b Sustainability-Linked

51.22% Environmental

6

$1.49b Clean Transport

$

10.72b Energy

$

4.35b Other environment

$

3.40b Green building

7

5.94% Social

8

$0.20b Aordable housing

$

2.12b Other social

$0.73b Green

$0.47b Social

$2.47b Sustainability

For further detail on ANZ’s approach

for assessing the eligibility of customer

transactions and direct investments

for inclusion towards the target, refer

to the ANZ Social and Environmental

Sustainability Target Methodology

available at anz.com/esgreport

31

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Our approach to sectoral pathways
Decision useful metrics

For eight of our higher emitting sectors

(which includes three sub-sectors in

transport), we have identified relevant

metrics and set specific targets. These

targets help guide our businesses to

make financing decisions about

customers operating in these sectors.

These pathways are an important input

in our decision making.

In some instances, our choice of an

emissions intensity target recognises that

certain sectors are likely to be essential

for the economy, and that global activity

in other sectors is expected to increase.

For some sectors, we have disclosed

additional or complementary metrics.

The move in 2025 to a target range for our

non-energy sectoral pathways (excluding

Australian large-scale commercial real

estate) reflects that emissions in these

sectors are hard-to-abate or the sector

is subject to other transition challenges.

Other metrics and targets

ANZ has not committed to an emissions

reduction target for home loans or

Agribusiness. We are currently reporting

other metrics or targets relevant to those

sectors’ decarbonisation trajectory.

These are:

• measuring the emissions intensity of

ANZ’s Australian residential home loan

portfolio, and

• reporting progress against our data

coverage target for a cohort of

Agribusiness customers where the

availability and quality of emissions

data remains a challenge and impacts

our ability to estimate emissions.

Actions to achieve our targets

Achieving our targets will partly depend

on our success in engaging with our

customers to improve their transition

plans, including seeking Paris-aligned

targets. Our success will also depend on

whether our customers are on-track to

meet their existing targets.

We acknowledge that in some cases,

the emissions intensity of our portfolio

may increase for a period of time, in

part reflecting the non-linear nature of

transition plans of our customers. In these

circumstances, we consider this is

appropriate as part of supporting

emissions reduction over the longer term,

provided those customers have, or are in

the process of developing, robust and

credible transition plans.

Key elements of our approach

to sectoral pathways

Appendix 5 outlines our Financed and

Facilitated Emissions Methodology, which

sets out our approach to:

• establishing sectoral pathways or

metrics, including criteria for

determining in-scope customers;

• measuring the emissions profile of

relevant portfolios and certain activities

in capital markets; and

• setting 2030 sectoral pathway financed

and facilitated emissions reduction

targets, and the scenarios that we have

benchmarked these targets against.

For the purposes of our sectoral pathways

on pages 34-47:

• Reference to ‘in-scope’ customers

means those customers within the

cohort for the relevant pathway. In some

instances, references are to a subset

of in-scope customers (e.g., where the

statement relates to customers

in-scope in relation to financed

emissions only, excluding customers

in-scope regarding facilitated

emissions).

• Reference to ‘Exposure at Default’ (EAD)

relates to financing activities only (i.e.,

excludes facilitated emissions from

capital market activities).

This section explains

our progress towards

transitioning our lending

portfolio to net zero

financed emissions by

2050 in line with the goals

of the Paris Agreement.

2025 review

In 2025, we reviewed our sectoral

pathway targets, including aviation

which was suspended in 2024.

The review resulted in some material

changes being made to pathways,

including targets and our historical

performance.

The review was undertaken for the

following reasons:

• To include facilitated emissions

associated with syndicated loans

and bonds informed by the UN

Guidance for Climate Target Setting

for Banks and the Partnership for

Carbon Accounting Financial (PCAF)

guidance.

• To assess whether customers of

Suncorp Bank met our in-scope

criteria for inclusion in our pathways

and metrics.

• To use more recent reference

scenarios where we considered

appropriate, including the

consideration of a target range.

• To reflect the UN Guidance for

Climate Target Setting for Banks

recommendation that targets

are reviewed at a minimum every

5 years.

• To consider the opportunity to use

an emissions intensity metric for the

shipping pathway.

Among other changes, the review

resulted in changes to our baseline

year performance and 2030 interim

targets for some pathways.

32ANZ 2025 Climate Report

Boundaries
When calculating our financed and

facilitated emissions the following data

collection and calculation dates are used:

• EAD: 2019 to 2023 measured as at

30 September of the relevant year. 2024

and 2025 measured as at 30 June of

the relevant year.

• Capital markets activity: 2019 to 2023

deals occurring between 1 October and

30 September of the relevant year. 2024

deals occurring between 1 October and

30 June as we transitioned to a 30 June

year end reporting period in line with the

EAD change. 2025 deals occurring

between 1 July and 30 June.

• Customer emissions data: We typically

preference the use of the latest available

customer emissions data. We typically

apply the following data hierarchy when

sourcing customer emissions data:

i. public customer disclosures;

ii. regulatory disclosures;

iii. credible third-party vendors; and as

a last resort

iv. sector averages.

• We have applied a 30 September 2025

cut off for reporting by our customers of

their emissions data for 2025 reporting

purposes.

• Australian residential home loans

outstanding loan amount: 2023 and

2024 are measured as at 31 May for the

relevant year. 2025 is measured as at

30 June.

Use of EAD

When assessing which customers are

in-scope for our sectoral pathways, we

use an EAD threshold (see pages 62-70

for sector specific thresholds). It is

estimated that cumulative customer

EAD below this threshold represents an

immaterial part of our overall financing

activities in the respective sector, meaning

we consider that the threshold does not

materially affect the financed emissions

included in scope. We assess customers

against the EAD threshold each year to

determine if they are in-scope for the

relevant year.

ANZSIC Codes

ANZ aims to ensure in-scope customers

are representative of our exposure to

each sector. Refer to our Financed and

Facilitated Emissions Methodology in

Appendix 5 for more details.

Interpreting our sectoral pathways

Performance relative

to pathway

Performance relative

to baseline

ANZ baseline

Global averageGlobal average

ANZ current

performance

ANZ 2030

target range

ANZ 2030

target pathway

Year

Emissions

Performance relative

to pathway

Performance relative

to baseline

ANZ baseline

ANZ current

performance

Year

Emissions

2030 target reduction (target range)2030 target reduction (1.5°)

33

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Graph 1.1: Performance
Targeting a 54% reduction in emissions intensity by 2030

1

Power Generation

Energy

Global average emissions intensity

Actual performance against our target2030 target pathway (54% reduction)

20302021202220232024202620272028202920252020

GHG intensity (kg CO

2

-e

/MWh)

0

50

100

150

200

250

300

350

400

450

500

The emissions intensity of our in-scope

power generation customers has

decreased by 51% from our 2020 baseline

to 120 kgCO₂/-e MWh. This is below the

2023 global average of 458 kgCO₂/-e

MWh.

3

We are on-track to meet our 2030 target

of reducing the emissions intensity of our

pathway portfolio by 54%.

1

As at 30 June 2025, 84% of our in-scope

EAD to the power generation pathway

portfolio financed generation from

renewables and other lower-emissions

energy sources (Graph 1.4). This is a

16-percentage point increase since

2020 with $11.9 billion of our in-scope

EAD financing renewable and other

lower-emissions energy production,

which includes nuclear and waste-to-

energy projects.

The net $6.7 billion growth in our in-scope

power generation EAD since 2020 has

primarily financed customers that generate

electricity from renewable and other

lower-emission energy sources, while our

in-scope EAD to customers generating

electricity from fossil fuels reduced by

more than $167m over the same period.

ANZ exposure (EAD) ($b)

202320242025

0

2

4

6

8

16

14

10

12

Coal

Gas

Oil

Wind

Solar

Hydropower

Geothermal

Ocean power

Power storage

Fossil fuels

related

Renewables

Biomass

Renewables

Bioenergy

Nuclear power

Waste-to-energy

Fossil

fuels

Other low

emissionsRenewables

Graph 1.4: ANZ pathway EAD to electricity

generation fuel and technologies

ffififfittffififfiff

ft ft 

ffififfi

fi
ffi

ff




fi

ffi

ff



fi



ffi

 ­€

fiffifi



ffi

 ­€

‚fiffi

ffi

 ­€

ƒ„…†‡ˆ‡

ƒ„‰Š ‡‹‡ŒŽ

Graph 1.3: Breakdown of ANZ’s power

generation pathway EAD

1. In 2025, we completed a review of our Power Generation sectoral pathway emissions intensity target to, among other things, include facilitated emissions and to update the

reference scenario to use the latest science. This resulted in a change to the overall headline power generation target from 50% to 54% by 2030. Refer to our Financed and Facilitated

Emissions Methodology in Appendix 5 for further details. 2. IEA – World Energy Outlook 2024. Net Zero Emissions by 2050 (NZE) scenario. 3. IEA – World Energy Outlook 2024.

Graph 1.2: Emissions intensity

movements

GHG intensity (kgCO₂-e/MWh)

TotalDecreaseIncrease

ANZ

2024

156

Customers’

climate

performance

(2.7)

ANZ

2025

120

Portfolio

change

(32.8)

Ta rg e t

Baseline

2020

Emissions


Scope 1

Scenario

IEA WEO

NZE (2024)

2

EAD as at

30 June 2025

$14.1b

% Group

EAD

1.03%

Status

On-track

Performance

vs pathway

(33%)

Performance

vs baseline

(51%)

34ANZ 2025 Climate Report

Refer to page 1 for our disclaimer and important notices, pages 
50-51 for the power generation sectoral pathway performance

summary, page 32 for Our Approach to Sectoral Pathways, and

Appendix 5 for our Financed and Facilitated Emissions

Methodology.

1. For lending relating to project finance, we have considered the entity that has operational control over the project. In prior years we excluded project finance. 2. Relates to mines

with production or reserves greater than 35% thermal coal. 3. Applies to lending products only, i.e., excludes transaction banking, credit cards, and performance guarantees, meaning

that only lending products that will help customers ‘fund’ their activities would be excluded. 4. In 2024, we reduced this threshold from 50% to 35%. We will progressively reduce the

35% threshold so that by 30 September 2030 we will seek a diversification strategy from mining, transport and power generating Institutional customers with more than 25% thermal

coal exposures.

How is ANZ supporting the transition?

Customer engagement

via our LEEP

As at 30 June 2025, 18 customers contributing 21% of EAD and 84% of the debt-weighted

financed and facilitated emissions intensity of our power generation pathway were captured

within our LEEP. Refer to page 12 for more details on the program including how we select

LEEP customers.

Prioritisation of customers with

lower emissions assets, stronger

emissions reduction targets and/or

diversification strategies

ANZ’s project finance activities, where most of our power generation exposures are to

renewables and energy storage projects, increased by $5.0 billion since September 2020.

ANZ’s exposure to pathway customers producing power at an average emissions intensity

of less than 200 kgCO

2

-e/MWh increased $1.5 billion since September 2020 (Graph 1.3).

• % EAD of power generation customers in-scope for financed emissions that have set

interim emissions reduction targets

1

: 78%

• % EAD of power generation customers in-scope for financed emissions that have

publicly committed to net zero 2050

1

: 77%

Specific policies in place to steer

our lending decisions

We will:

• Not directly finance any new coal-fired power plants, expansions of existing coal-fired

power plants or extensions to operating life. Existing direct financing to coal-fired power

generation will run off by 30 September 2030.

2,3

• Continue to support existing diversified customers but will not provide lending to new

customers that derive more than 10% revenue, installed capacity or power generation

from thermal coal.

3

• Engage with existing large business customers who have more than 35%

4

thermal coal

exposure by revenue, installed capacity or power generation to support diversification

plans. Refer to page 12 for further detail on LEEP.

Potential options for our customers

to reduce their emissions

• Increase in renewable energy capacity.

• Investment in enabling infrastructure and technology, such as transmission/distribution

networks and energy storage.

• Energy efficiency improvements.

35

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Energy
The absolute emissions of our in-scope

oil  and gas customers has decreased

by 62% from our 2020 baseline to

5.24 MtCO₂-e.

We remain below our pathway reduction

target and are on-track to meet our 2030

target of reducing the absolute emissions

of our pathway portfolio by 32%.

1

Our EAD to oil and gas customers

in-scope for financed emissions declined

by $1.6 billion from the prior year and

$5.9 billion since September 2020.

5

This

reduction is partially due to actions we

have taken to reduce our exposure to

customers who have less mature

transition plans.

Around $2.3 billion of this decline since

2020 was associated with independent oil

and gas companies whose activities are

focused on the upstream segment of the

oil and gas value chain (Graph 2.3).

In 2023, we set an additional target to

reduce our Group EAD to oil and gas

extraction customers

3

by 40% by 30

September 2025 from a 2020 baseline.

4


We have successfully met this target,

having reduced our EAD by 56%

5

as at

30 September 2025.

6


1. In 2025, we completed a review of our oil and gas sectoral pathway absolute emissions target to, among other things, include facilitated emissions and to update the reference

scenario to use the latest science. This resulted in a change to the pathway overall headline oil and gas target from 26% to 32% by 2030. Refer to our Financed and Facilitated

Emissions Methodology in Appendix 5 for further details. 2. IEA - World Energy Outlook 2024. Net Zero Emissions by 2050 (NZE) scenario. 3. Oil and gas extraction includes exposure

to exploration and extraction only as the focus is on resources (mining) exposure in line with industry groupings. 4. On an FX adjusted basis. 5. Some of the reduction in EAD since

September 2020 is a result of the APRA Basel IV rule changes which came into effect 1 January 2023. The new rules altered the way EAD is calculated. When applied to ANZ’s oil and

gas EAD, the revised calculation resulted in a lower EAD amount compared with the original EAD calculation which was based on the old method. 6. A portion of our overall 56%

reduction against this target is attributed to the changes to our EAD calculation methodology brought on by the APRA Basel IV rule changes.

ANZ exposure (EAD) ($bn)

2025

0

2

4

6

8

10

12

MajorIndependent

NOC

INOCs

202420232022

Graph 2.3: Breakdown of ANZ’s oil

and gas pathway EAD

Graph 2.1: Performance

Targeting a 32% reduction in absolute financed and facilitated emissions by 2030

1

2030 target pathway (32% reduction)

20302022202420262028202120202023202520272029

ANZ financed and facilitated emissions (MtCO

2

-e)

0

2

4

6

8

10

12

16

14

Actual performance against our target

Oil and Gas

Graph 2.2: Absolute emissions

movements

GHG emissions (MtCO

2

-e)

TotalDecreaseIncrease

8.06

(0.06)

5.24

(2.77)

ANZ

2024

Customers’

climate

performance

ANZ

2025

Portfolio

change

Ta rg e t

Baseline

2020

Emissions

Scope 1, 2 and 3

(category 11 only)

Scenario

IEA WEO NZE

(2024)

2

EAD as at

30 June 2025

$4.3b

$% Group

EAD

0.32%

Status

On-track

Performance

vs pathway

(55%)

Performance

vs baseline

(62%)

36ANZ 2025 Climate Report

1. For lending relating to project finance, we have considered the entity that has operational control over the project. In prior years we excluded project finance. 2. ANZ defines
renewables as wind, solar photovoltaics (PV), concentrating solar power (CSP), hydropower, geothermal and marine (tide and wave) energy that is used for electricity and heat

generation. 3. IEA – World Energy Outlook 2023.

How is ANZ supporting the transition?

Customer engagement

via our LEEP

As at 30 June 2025, 13 customers contributing 88% of EAD and 89% of the absolute

financed and facilitated emissions of our oil and gas pathway were captured within our LEEP.

Refer to page 12 for more details on the program including how we select LEEP customers.

Prioritisation of customers with

lower emissions assets, stronger

emissions reduction targets and/or

diversification strategies

• % EAD of oil and gas customers in-scope for financed emissions that have set interim

emissions reduction targets

1

:

– Scope 1 and Scope 2: 93%

– Scope 3: 45%

• % EAD of oil and gas customers in-scope for financed emissions that have publicly

committed to net zero 2050

1

:

– Scope 1 and Scope 2: 88%

– Scope 3: 45%

Specific policies in place to steer

our lending decisions

Gas helps firm renewables

2

, assists the exit of thermal coal and is a critical feedstock for the

industrial, manufacturing and agricultural sectors.

We continue to assess the role of gas within the context of the broader energy market, public

policy developments, and stakeholder and shareholder expectations. We will:

• Not directly finance new or expansion upstream gas projects (including new liquefied

natural gas (LNG) liquefaction plants, floating production storage and dedicated offloading

infrastructure); and

• Not on board any new to bank upstream gas customers.

Should national energy security issues arise and our assistance is sought, we will consider

exceptions on a case-by-case basis.

Potential options for our customers

to reduce their emissions

Scope 1 and Scope 2 emissions

• Minimise methane leaks through leak detection and repair programs and upgrading

leaky equipment.

3

• Avoidance of non-emergency flaring and venting.

• Electrification of upstream operations.

• Carbon capture, utilisation and storage (CCUS).

Scope 3 emissions

• Reducing the amount of oil and gas sold.

• Reweighting overall production to natural gas.

• Supporting the use of CCUS by their customers.

Refer to page 1 for our disclaimer and important notices, pages

50-51 for the oil and gas sectoral pathway performance summary,

page 32 for Our Approach to Sectoral Pathways, and Appendix 5

for our Financed and Facilitated Emissions Methodology.

37

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Energy
The absolute emissions of our in-scope

thermal coal customers has decreased

by 96% from our 2020 baseline to 0.35

MtCO₂-e. We remain on-track to exit our

exposures (subject to limited exceptions

2

)

to thermal coal mining ahead of our

2030 target.

A small number of customers (less than

10) make up our exposures within this

pathway. The remaining direct exposures

are largely attributable to existing

customers with mining rehabilitation

bonds to enable them to fulfil their

responsibilities relating to rehabilitation

and exiting of mine sites.

3

Given the small

remaining exposure to in-scope thermal

coal mining customers, the financed

emissions of our thermal coal pathway

will be sensitive to minor customer

movements as we continue to wind

down support to thermal coal miners.

We continue to have other indirect

exposures to thermal coal, through

metallurgical coal miners and diversified

mining customers that produce thermal

coal. Some of these customers are

amongst the world’s largest producers

of transition metals and minerals. These

exposures are not within scope of the

pathway. Further, facilitated emissions

from capital markets activities for

customers outside of our thermal coal

pathway are not included. We will continue

to provide finance to and to facilitate,

through capital markets activities,

metallurgical coal miners and diversified

miners, subject to our policies.

In 2023, applying the same EAD criteria

and threshold as our pathway at that time,

we quantified the breakdown of our

financed emissions to each customer

type, shown in Table 3.3 on page 39.

1. IEA – World Energy Outlook 2024. Net Zero Emissions by 2050 (NZE) scenario. 2. We will continue to provide rehabilitation bonds for those existing customers with thermal coal

exposure to ensure their rehabilitation responsibilities at existing mine sites can be fulfilled. Transaction banking/markets 3-day settlement limits are excluded from this cap. 3. The

purpose of a rehabilitation bond is related to environmental remediation and not financing of the coal mining activity itself. As at 30 June 2025, rehabilitation bonds were $70.6m, which

equates to 41.6% of our exposure to thermal coal mining under ANZSIC code 1102 (from an ANZ perspective, customers allocated to this code are those which predominantly produce

coal for power generation).

Graph 3.1: Performance

Targeting a 100% reduction in absolute financed and facilitated emissions by 2030

Actual performance against our target

2030 target pathway (100% reduction)

20302022202420262028202120202023202520272029

Absolute financed and facilitated emissions (MtCO

2

-e)

0

2

1

4

3

6

8

7

5

9

10

Thermal Coal

Graph 3.2: Absolute emissions

movements

GHG emissions (MtCO

2

-e)

TotalDecreaseIncrease

0.26

(0.01)

0.35

0.10

ANZ

2024

Customers’

climate

performance

ANZ

2025

Portfolio

change

Ta rg e t

Baseline

2020

Emissions

Scope 1, 2 and 3

(category 11 only)

Scenario

IEA WEO

NZE (2024)

1

EAD as at

30 June 2025

$0.10b

% Group

EAD

0.01%

Status

On-track

Performance

vs pathway

(92%)

Performance

vs baseline

(96%)

38ANZ 2025 Climate Report

1. Applies to lending products only, i.e., excludes transaction banking, credit cards, performance guarantees, meaning that only lending products that will help customers ‘fund’ their
activities in a material way would be excluded. 2. A large business customer of ANZ involved in exploration, mining and/or primary mineral processing; oil or gas exploration and

production, development, extraction, processing, storage and transport; associated facilities including major infrastructure; mining contracting and haulage; or smelters and metals

refineries but excludes customers that only operate downstream secondary metals processing (other than in the case of smelters). 3. Any project or investment that would increase

the production capacity, geographic footprint, or operational lifespan of an existing thermal coal mine, or establish a new thermal coal mining operation. 4. We will continue to provide

rehabilitation bonds for those existing customers with thermal coal exposure to ensure their rehabilitation responsibilities at existing mine sites can be fulfilled. Transaction banking/

markets 3-day settlement limits are excluded from this cap. 5. In 2024, we reduced this threshold from 50% to 35%. We will progressively reduce the 35% threshold so that by

30 September 2030, we will seek a diversification strategy from mining, transport and power generating customers with more than 25% thermal coal exposures.

How is ANZ supporting the transition?

Customer engagement

via our LEEP

As at 30 June 2025, customers contributing 39% of EAD and 21% of the absolute financed

and facilitated emissions of our thermal coal pathway were captured within our LEEP. Refer to

page 12 for more details on the program including how we select LEEP customers.

Specific policies in place to steer

our lending decisions

We will:

• Not provide lending

1

to new to bank extractives customers

2

that derive more than

10% revenue from thermal coal mining.

• Not directly finance any new thermal coal mine, or expansions or extensions to the

operating life of existing mines.

3

In each case, this refers to mines with production or

reserves greater than 35% thermal coal. Existing lending will run off by 2030.

4

• Engage with existing large business customers that have more than 35%

5

thermal

coal exposure by revenue to support diversification plans.

Potential options for our customers

to reduce their emissions

While our emissions reduction target is to reduce our financed and facilitated emissions to

in-scope pathway customers by 100% by 2030 from a 2020 baseline, there are still actions

that mining companies that produce thermal coal can take to reduce their Scope 1 and

Scope 2 emissions, including:

• Reducing fugitive coal mine methane emissions.

• Use of biofuels and electric powered alternatives to replace diesel use in

mining equipment.

• Renewable energy investments.

Refer to page 1 for our disclaimer and important notices, pages 

50-51 for the thermal coal sectoral pathway performance

summary, page 32 for Our Approach to Sectoral Pathways, and

Appendix 5 for our Financed and Facilitated Emissions

Methodology.

Table 3.3: 2023 Total thermal coal financed emissions by customer type (MtCO₂-e)

Customer type2023Thermal coal target

Mining companies whose predominant activity is thermal coal production (ANZSIC code 1102)0.38Included

Metallurgical coal miners that produce thermal coal by-product*1.44Not included

Diversified miners that produce thermal coal*

1.44

Not included

* Contributing 5% revenue or more

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

39

The emissions intensity of our in-scope
light duty passenger auto manufacturing

customers has decreased by 33% from

our 2022 baseline to 94 gCO₂-e/vehicle

kilometre (vkm). This is below the 2024

global average of 202 gCO₂-e/vkm.

3


We are on-track to meet our 2030 target

of reducing the emissions intensity of our

pathway portfolio by 18-33%.

1

In 2023, we set a powertrain financed

emissions reduction target for our auto

manufacturing pathway cohort of 10%

hybrid and 15% electric vehicle (EV)

production by end of 2025. This target

was designed to show support for and to

monitor the strong progress our in-scope

customers were showing in their sales of

hybrid and electric vehicles. We have

achieved a combined hybrid/EV portfolio

mix of 41%. We exceeded the EV portion of

the target, as well as the combined target

outcome, notwithstanding that our

financing of hybrid production is

1-percentage point below the 10% target.

We do not intend to set a further powertrain

target, however we will continue to monitor

and disclose our powertrain financing mix.

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Graph 4.3: Auto manufacturing pathway

powertrain financing mix

1. In 2025, we completed a review of our auto manufacturing sectoral pathway emissions intensity target to, among

other things, include facilitated emissions, update the reference scenario to use the latest science, and to change from

a 1.5°C aligned target to a 1.5°C – 1.7°C aligned target range. The adoption of a target range recognises recent

challenges with EV adoption and market development, including trade disruptions and changes in government policies.

This resulted in a change to the pathway overall headline auto manufacturing target from 28% to a range of 18% to 33%

by 2030. Refer to our Financed and Facilitated Emissions Methodology in Appendix 5 for further details. 2. IEA – World

Energy Outlook 2024. Net Zero Emissions by 2050 (NZE) scenario and Announced Pledges Scenario (APS). 3. IEA

– World Energy Outlook 2024. 4. IEA – World Energy Outlook 2023. 5. IEA – Tracking Clean Energy Progress 2023.

Graph 4.1: Performance

Targeting a 18-33% reduction in emissions intensity by 2030

1

Actual performance against our target

Global average emissions intensity

2030 target pathway (18% to 33% reduction)

203020242026202820232022202520272029

GHG intensity (gCO

2

-e/vkm)

0

50

100

150

200

250

Auto manufacturing

Graph 4.2: Emissions

intensity movements

GHG intensity

(gCO₂-e/vkm)

Total

Decrease

Increase

107

0.6

94

(13.3)

ANZ

2024

ANZ

2025

Customers’

climate

performance

Portfolio

change

Ta rg e t

Baseline

2022

Emissions

Scope 3

(category 11 only)

Scenario

IEA WEO NZE

and APS (2024)

2

EAD as at

30 June 2025

$2.41b

% Group

EAD

0.18%

Status

On-track

Performance

vs pathway

(28%)

Performance

vs baseline

(33%)

How is ANZ supporting

the transition?

Customer engagement

via our LEEP

As at 30 June 2025, customers

contributing 92% of EAD and 90%

of the debt-weighted financed and

facilitated emissions intensity of our

auto manufacturing pathway were

captured within our LEEP. Refer to

page 12 for more details on the

program including how we select

LEEP customers.

Prioritisation of customers with

lower emissions assets, stronger

emissions reduction targets and/or

diversification strategies

• % EAD of auto manufacturing

customers in-scope for financed

emissions that have set interim

emissions reduction targets: 100%

• % EAD of auto manufacturing

customers in-scope for financed

emissions that have publicly

committed to net zero by 2050:

100%

Potential options for our customers

to reduce their emissions

• Electrification of light duty vehicles

through transition to battery electric

vehicles (BEVs) and fuel cell electric

vehicles (FCEVs).

4

• Electricity supply decarbonisation.

4

• Improving fuel efficiency.

5

• Exploring alternative fuels (biofuels,

synthetic fuels).

5

Refer to page 1 for our disclaimer and

important notices, pages 50-51 for the

auto manufacturing sectoral pathway

performance summary, page 32 for

Our Approach to Sectoral Pathways,

and Appendix 5 for our Financed and

Facilitated Emissions Methodology.

Transport

40ANZ 2025 Climate Report


We have set a new aviation target after the

suspension of our previous target in 2024.

Our customers in the aviation sector face

significant challenges in further reducing

their emissions intensity due to delays in

fleet renewal and limited Sustainable

Aviation Fuel (SAF) supply.

When setting our target range, we applied

the IEA reference pathways

3

for aviation.

As at 30 September, it is unclear whether

the IEA reference pathways for aviation

include freight emissions. We have

assumed that the IEA pathways do not

include freight emissions.

However, if the IEA reference pathways

for aviation do include freight emissions,

our aviation pathway may not align with

the IEA reference pathways’ 1.5°C – 1.7°C

trajectory.

The emissions intensity of our in-scope

aviation customers has decreased by

0.1% from our 2019 baseline to 870

gCO₂-e/ revenue tonne kilometre (RTK).

This is below the 2024 global average of

1,150 gCO₂-e/RTK.

4

Due in part to an increase in some

customers’ emissions intensity and

changes in portfolio composition, we are

close to on-track to meet our 2030 target

of reducing the emissions intensity of our

pathway portfolio by 16-26%.

1

Our pathway includes in-scope

customers’ emissions from passenger

and freight activity, noting that passenger

operations make up most of the activity

of our in-scope aviation customers.

1. In 2025, we set an aviation sectoral pathway emissions intensity target range, recognising the hard-to-abate nature

of the sector, which includes financed and facilitated emissions. Refer to our Financed and Facilitated Emissions

Methodology in Appendix 5 for further details. 2. A 2019 baseline was chosen to reflect a year that was not distorted by

COVID-19. Aviation activity did not return to pre-pandemic levels until February 2024. 3. IEA – World Energy Outlook

2024. Net Zero Emissions by 2050 (NZE) scenario and Announced Pledges Scenario (APS). 4. IEA – World Energy

Outlook 2024. 5. I ATA – Aircraft Technology Net Zero Roadmap (2023).

Graph 5.1: Performance

Actual performance against our target

Global average emissions intensity

2030 target pathway (16% to 26% reduction)

203020242026202820232022202120202019202520272029

GHG intensity (gCO

2

-e/RTK)

0

500

1000

1500

2000

2500

Graph 5.2: Emissions

intensity movements

GHG intensity

(gCO₂-e/RTK)

797

15.7

870

57.1

Total

Decrease

Increase

ANZ

2024

ANZ

2025

Customers’

climate

performance

Portfolio

change

How is ANZ supporting

the transition?

Customer engagement

via our LEEP

As at 30 June 2025, customers

contributing 100% of EAD and 100%

of the debt-weighted financed and

facilitated emissions intensity of our

aviation pathway were captured within

our LEEP. Refer to page 12 for more

details on the program including how

we select LEEP customers.

Prioritisation of customers with

lower emissions assets, stronger

emissions reduction targets and/or

diversification strategies

• % EAD of aviation customers

in-scope for financed emissions

that have set interim emissions

reduction targets: 33%

• % EAD of aviation customers

in-scope for financed emissions

that have publicly committed to

net zero by 2050: 78%

Potential options for our customers

to reduce their emissions

• Development and uptake of SAF

4

,

including through engagement with

industry and government.

• Fleet renewal to use new generation

aircraft which are more fuel efficient.

4


• Development of alternative

propulsion technology including

electric and hydrogen powered

aircraft.

5

Targeting a 16-26% reduction in emissions intensity by 2030

1

Aviation

Ta rg e t

Baseline

2019

2

Emissions

Scope 1

Scenario

See text

below

EAD as at

30 June 2025

$3.15b

% Group

EAD

0.23%

Status

Close to

On-track

Performance

vs pathway

9%

Performance

vs baseline

0%

Transport

Refer to page 1 for our disclaimer and

important notices, pages 50-51 for the

aviation sectoral pathway performance

summary, page 32 for Our Approach to

Sectoral Pathways, and Appendix 5 for

our Financed and Facilitated Emissions

Methodology.

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

41

The emissions intensity of our in-scope
shipping customers has decreased by 3%

from our 2022 baseline to 11.13 gCO₂-e/t

km. This is above the 2024 global average

of 6.62 gCO₂-e/t km.

3

We are close to on-track to meet our

2030 target of reducing the emissions

intensity of our pathway portfolio by

23-30%.

1

This is due to the hard-to-abate

nature of the sector and our highly

concentrated portfolio which includes

customers operating vessel types that are

more emissions intensive than the global

average (e.g., car carriers, small general

cargo vessels).

A small number of customers (less than

10) make up our exposure in this pathway.

In 2025, we updated our methodology

to replace our shipping absolute

emissions target with an emissions

intensity target range. This change to an

emissions intensity metric recognises that

global shipping activity is expected to

increase

4

and has been prompted by an

improvement in customer data availability

which has enabled us to adopt an

intensity metric.

1. In 2025, we completed a review of our shipping sectoral pathway target. In addition to moving from an absolute

emissions target to an emission intensity range, the review was undertaken to, among other things, include facilitated

emissions and to update the reference scenario to use the latest science. This resulted in a change to the pathway

overall headline Shipping target from 10% to a range of 23% to 30% by 2030. Refer to our Financed and Facilitated

Emissions Methodology in Appendix 5 for further details. 2. IEA – World Energy Outlook 2024. Net Zero Emissions by

2050 (NZE) scenario and Announced Pledges Scenario (APS). 3. IEA – World Energy Outlook 2024. 4. IEA – World

Energy Outlook 2024. Under the APS scenario shipping activity is expected to increase. Under the NZE scenario

shipping activity is expected to decrease by ~3% between 2023 and 2030. 5. IEA – International shipping.

Graph 6.1: Performance

Targeting a 23-30% reduction in emissions intensity by 2030

1

Shipping

Graph 6.2: Emissions

intensity movements

GHG intensity

(gCO₂-e/tkm)

12.35

(0.19)

11.13

(1.03)

Total

Decrease

Increase

ANZ

2024

ANZ

2025

Customers’

climate

performance

Portfolio

change

Ta rg e t

Baseline

2022

Emissions

Scope 1

Scenario

IEA WEO NZE

and APS (2024)

2

EAD as at

30 June 2025

$0.50b

% Group

EAD

0.04%

Status

Close to

On-track

Performance

vs pathway

6%

Performance

vs baseline

(3%)

How is ANZ supporting

the transition?

Customer engagement

via our LEEP

As at 30 June 2025, customers

contributing 67% of EAD and 89%

of the debt-weighted financed and

facilitated emissions intensity of our

shipping pathway were captured

within our LEEP. Refer to page 12 for

more details on the program including

how we select LEEP customers.

Prioritisation of customers with

lower emissions assets, stronger

emissions reduction targets and/or

diversification strategies

• % EAD of shipping customers

in-scope for financed emissions

that have set interim emissions

reduction targets: 77%

• % EAD of shipping customers

in-scope for financed emissions

that have publicly committed to

net zero by 2050: 100%

Potential options for our customers

to reduce their emissions

• Efficiency improvements including

slow steaming, voyage optimisation

and retrofitting vessels (e.g., with

wind-assistance technology).

5

• Development and uptake of lower

emissions fuels such as biofuels,

hydrogen and ammonia.

5

Refer to page 1 for our disclaimer

and important notices, pages 50-51

for the shipping sectoral pathway

performance summary, page 32 for

Our Approach to Sectoral Pathways,

and Appendix 5 for our Financed and

Facilitated Emissions Methodology.

Transport

Actual performance against our target

Global average emissions intensity

2030 target pathway (23% to 30% reduction)

203020242026202820232022202520272029

GHG intensity (gCO

2

-e/t km)

0

2

4

6

8

10

12

14

ANZ 2025 Climate Report42ANZ 2025 Climate Report

The emissions intensity of our in-scope
aluminium customers has decreased by

14% from our 2021 baseline to 5.88

tCO₂-e/t aluminium. This is below the

2024 global average of 9.47 tCO₂-e/t

aluminium (primary and secondary

production).

4,5

We are on-track to meet our 2030 target

of reducing the emissions intensity of our

pathway portfolio by 17-30%.

1

A small number of customers (fewer than

10) make up our exposure in this pathway.

Previously, we relied on company level

data where asset level data was

unavailable. We now use asset level third

party data. This change results in a

worsening of our data quality score

however it better reflects the emissions

intensity of our finance.

1. In 2025, we completed a review of our aluminium sectoral pathway emissions intensity target to, among other things,

include facilitated emissions and to change from a 1.5°C aligned target to a 1.5°C – 1.75°C aligned target range to

recognise the hard-to-abate nature of the sector. This resulted in a change to the pathway overall headline aluminium

target from 30% to a range of 17% to 30% by 2030. Refer to our Financed and Facilitated Emissions Methodology in

Appendix 5 for further details. 2. International Aluminium Institute – 1.5 Degrees Scenario and B2D Scenario (2021).

3. Reduction driven by structural changes (e.g., mergers, acquisitions and divestments of customers within the relevant

pathway). 4. International Aluminium Institute – Global Aluminium Industry Greenhouse Gas Emissions Intensity

Reduction Continues, with Total Emissions Below 2020 Peak. 5. Aluminium that is produced from recycled aluminium

originating from various forms of aluminium scrap. 6. A furnace used for scrap-based aluminium production, where the

metal is heated by means of an electric arc.

Graph 7.1: Performance

Graph 7.2: Emissions

intensity movements

GHG intensity

(tCO

2

-e/t aluminium)

8.31

(0.39)

5.88

(2.04)

Total

Decrease

Increase

ANZ

2024

ANZ

2025

Portfolio

change

3

Customers’

climate

performance

How is ANZ supporting

the transition?

Customer engagement

via our LEEP

As at 30 June 2025, customers

contributing 100% of EAD and 100%

of the debt-weighted financed and

facilitated emissions intensity of our

aluminium pathway were captured

within our LEEP. Refer to page 12 for

more details on the program including

how we select LEEP customers.

Prioritisation of customers with

lower emissions assets, stronger

emissions reduction targets and/or

diversification strategies

• % EAD of aluminium customers

in-scope for financed emissions

that have set interim emissions

reduction targets: 100%

• % EAD of aluminium customers

in-scope for financed emissions

that have publicly committed to

net zero by 2050: 91%

Potential options for our customers

to reduce their emissions

• Decarbonisation of electricity supply

used in aluminium production.

• Limiting the use of aluminium in final

products via ‘lightweighting’ and

efficiency in design.

• Investment in the commercialisation

of currently expensive technologies

such as carbon-free anodes.

• Increased secondary production

5

of

aluminium via electric arc furnace

6

,

noting this is limited by scrap

availability.

Targeting a 17-30% reduction in emissions intensity by 2030

1

Aluminium

Ta rg e t

Baseline

2021

Emissions

Scope 1 and 2

Scenario

IAI 1.5°C and

IAI B2DS

2

EAD as at

30 June 2025

$0.46b

% Group

EAD

0.03%

Status


On-track

Performance

vs pathway

(7%)

Performance

vs baseline

(14%)

Refer to page 1 for our disclaimer

and important notices, pages 50-51

for the aluminium sectoral pathway

performance summary, page 32 for

Our Approach to Sectoral Pathways,

and Appendix 5 for our Financed and

Facilitated Emissions Methodology.

Industry

Actual performance against our target

Global average emissions intensity

2030 target pathway (17% to 30% reduction)

2030202420262028202320212022202520272029

GHG intensity (tCO

2

-e/t aluminium)

0

2

4

6

8

10

12

43

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

1. In 2025, we completed a review of our cement sectoral pathway emissions intensity target to, among other things,
include facilitated emissions, update the reference scenario to use the latest science, and to change from a 1.5°C

aligned target to a 1.5°C – 1.7°C aligned target range to recognise the hard-to-abate nature of the sector. This resulted

in a change to the pathway overall headline cement target from 20% to a range of 13% to 25% by 2030. Refer to our

Financed and Facilitated Emissions Methodology in Appendix 5 for further details. 2. IEA – World Energy Outlook 2024.

Net Zero Emissions by 2050 (NZE) scenario and Announced Pledges Scenario (APS). 3. In line with SBTI - Cement

Science Based Target Setting Guidance (2022) and our understanding of industry practices, when we refer to our

intensity target in tCO₂-e/t cement, we have set an intensity target per tonne of ‘cementitious product’ rather than per

tonne of ‘cement’. 4. IEA – World Energy Outlook 2024. 5. Intermediary product in cement production, production of

which is emissions intensive. 6. Fly ash is a waste product from coal-fired power generation that can be used as a

supplementary cementitious material. 7. IEA – Net Zero Road Map (2023).

Graph 8.1: Performance

Graph 8.2: Emissions

intensity movements

GHG intensity

(tCO

2

-e/t cement)

0.62

(0.02)

0.620.02

Total

Decrease

Increase

ANZ

2024

ANZ

2025

Customers’

climate

performance

Portfolio

change

How is ANZ supporting

the transition?

Customer engagement

via our LEEP

As at 30 June 2025, customers

contributing 100% of EAD and 100%

of the debt-weighted financed and

facilitated emissions intensity of our

cement pathway were captured within

our LEEP. Refer to page 12 for more

details on the program including how

we select LEEP customers.

Prioritisation of customers with

lower emissions assets, stronger

emissions reduction targets and/or

diversification strategies

• % EAD of cement customers

in-scope for financed emissions

that have set interim emissions

reduction targets: 100%

• % EAD of cement customers

in-scope for financed emissions

that have publicly committed to

net zero by 2050: 45%

Potential options for our customers

to reduce their emissions

• Substituting clinker

5

for

supplementary cementitious

materials (e.g., fly ash

6

granulated

slag, limestone, and calcined clay).

• Alternate fuels for kilns (e.g.,

biomass instead of fossil fuels).

• Decarbonisation of electricity

supply.

• Plant and end-user efficiencies.

• CCUS technologies.

7

Targeting a 13-25% reduction in emissions intensity by 2030

1

Cement

Ta rg e t

Baseline

2021

Emissions

Scope 1 and 2

Scenario

IEA WEO NZE

and APS (2024)

2

EAD as at

30 June 2025

$0.18b

% Group

EAD

0.01%

Status


On-track

Performance

vs pathway

(1%)

Performance

vs baseline

(7%)

The emissions intensity of our in-scope

cement customers has decreased by 7%

from our 2021 baseline to 0.62 tCO₂-e/t

cement.

3

This is below the 2024 global

average of 0.66 tCO₂-e/t cement.

4

We are on-track to meet our 2030 target

of reducing the emissions intensity of our

pathway portfolio by between 13-25%.

1

A small number of customers (fewer than

10) make up our exposure in this pathway.

The limited availability of cost-effective

technologies to reduce hard-to-abate

emissions of cement production provides

greater uncertainty in the pathway

towards our target, relative to other

sectors. However, customer engagements

to date have been positive, indicating that

the sector is investing in research and

development of decarbonisation initiatives.

Refer to page 1 for our disclaimer and

important notices, pages 50-51 for the

cement sectoral pathway performance

summary, page 32 for Our Approach to

Sectoral Pathways, and Appendix 5 for

our Financed and Facilitated Emissions

Methodology.

Industry

Actual performance against our target

Global average emissions intensity

2030 target pathway (13% to 25% reduction)

2030202420262028202320212022202520272029

GHG intensity (tCO

2

-e/t cement)

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

44ANZ 2025 Climate Report

The emissions intensity of our in-scope
steel customers has decreased by 21%

from our 2021 baseline to 1.66 tCO₂-e/t

steel. This is below the 2024 global

average of 2.04 tCO₂-e/t steel.

3


We are on-track to meet our 2030 target

of reducing the emissions intensity of our

pathway portfolio by 11-22%.

1


A small number of customers (fewer than

10) make up our exposure in this pathway.

Given the significant technological

advances required to enable

commercialisation of lower emissions steel

making, the decarbonisation of the steel

sector will likely be slow moving. However,

we are seeing adoption of efficiency

measures and investment into research

and development in the steel sector,

including by some of our customers.

Metallurgical Coal

As at 30 June 2025, our EAD to

metallurgical (coking) coal mining

(ANZSIC code 1101) was $0.51 billion.

4


We acknowledge that there are no

readily available and commercially viable

substitutes for the use of metallurgical

coal in steel production at-scale. We

continue to support our metallurgical coal

mining customers. There are several

metallurgical coal customers included in

our LEEP, and we are engaging with those

LEEP customers to encourage them to

strengthen their low carbon transition plans.

1. In 2025, we completed a review of our Steel sectoral pathway emissions intensity target to, amongst other things,

include facilitated emissions, update the reference scenario to use the latest science, and to change from a 1.5°C

aligned target to a 1.5°C – 1.7°C aligned target range to recognize the hard-to-abate nature of the sector. This resulted

in a change to the pathway overall headline steel target from 28% to a range of 11% to 22% by 2030. Refer to our

Financed and Facilitated Emissions Methodology in Appendix 5 for further details. 2. IEA – World Energy Outlook 2024.

Net Zero Emissions by 2050 (NZE) scenario and Announced Pledges Scenario (APS). 3. IEA – World Energy Outlook

2024. 4. The EAD calculation for this metric differs to the sectoral pathway as it includes all ANZ EAD attributed to

ANZSIC code 1101, rather than in-scope steel sectoral pathway customers.

Graph 9.1: Performance

Graph 9.2: Emissions

intensity movements

GHG intensity

(tCO

2

-e/t steel)

1.93

(0.02)

1.66

(0.25)

Total

Decrease

Increase

ANZ

2024

ANZ

2025

Customers’

climate

performance

Portfolio

change

How is ANZ supporting

the transition?

Customer engagement

via our LEEP

As at 30 June 2025, customers

contributing 85% of EAD and 92%

of the debt-weighted financed and

facilitated emissions intensity of our

steel pathway were captured within

our LEEP. Refer to page 12 for more

details on the program including how

we select LEEP customers.

Prioritisation of customers with

lower emissions assets, stronger

emissions reduction targets and/or

diversification strategies

• % EAD of steel customers in-scope

for financed emissions that have set

interim emissions reduction targets:

87%

• % EAD of steel customers in-scope

for financed emissions that have

publicly committed to net zero by

2050: 100%

Potential options for our customers

to reduce their emissions

• Decarbonisation of electricity

supply, combined with Electric

Smelting Furnace and Electric Arc

Furnace technologies.

• Direct-reduced iron and utilisation

of low-grade ores.

• Plant and end-user efficiencies.

• CCUS technologies.

Targeting a 11-22% reduction in emissions intensity by 2030

1

Steel

Ta rg e t

Baseline

2021

Emissions

Scope 1 and 2

Scenario

IEA WEO NZE

and APS (2024)

2

EAD as at

30 June 2025

$0.67b

% Group

EAD

0.05%

Status


On-track

Performance

vs pathway

(17%)

Performance

vs baseline

(21%)

Refer to page 1 for our disclaimer and

important notices, pages 50-51 for the

steel sectoral pathway performance

summary, page 32 for Our Approach to

Sectoral Pathways, and Appendix 5 for

our Financed and Facilitated Emissions

Methodology.

Actual performance against our target

Global average emissions intensity

2030 target pathway (11% to 22% reduction)

2030202420262028202320212022202520272029

GHG intensity (tCO

2

-e/t steel)

0

0.5

1.0

1.5

2.0

2.5

Industry

45

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Buildings
The emissions intensity of our in-scope

Australian large-scale commercial real

estate (CRE) customers’ office buildings

has decreased by 73% from our 2019

baseline to 21.52 kgCO₂-e/m

2

NLA. This

is below the 2025 Australian average of

40.51 kgCO₂-e/m

2

NLA.

3

Similarly, the emissions intensity of our

in-scope CRE customers’ shopping

centres has decreased by 57% from our

2019 baseline to 38.43 kgCO₂-e/m

2

NLA.

This is below the 2025 Australian average

of 39.92 kgCO₂-e/m

2

NLA.

3

1. Target is specific to Australian large business customers. 2. The International Energy Agency Beyond 2°C scenario presented in the IEA – Energy Technology Perspectives (2017)

report puts service buildings on a pathway to achieve net zero emissions by 2050, with most of these savings to be achieved before 2030. The 2050 convergence to net zero emissions

for service buildings closely reflects the IEA – Net Zero Emissions by 2050 (2021). 3. Australian base building averages, NABERS Annual Report.

We are on-track to meet our 2030 target

of reducing the emissions intensity of our

pathway portfolio by 60%.

Our current CRE target does not directly

reflect ANZ’s financial exposures as they

relate to customers’ emissions. Rather, we

calculate emissions intensity using the

combined net lettable area (NLA) of all

office buildings and shopping centres that

are owned or operated by our in-scope

customers. Our target also excludes some

emissions arising from energy use in

building tenancies, or emissions

embodied in building materials.

Graph 10.1: Performance (Offices)Graph 10.2: Performance (Shopping centres)

Targeting a 60% reduction in emissions intensity by 2030 – office buildings and shopping centres

1

Australian large-scale commercial real estate

Ta rg e t

Baseline


2019

Emissions

Scope 1 and 2

from building operational

energy use

Scope 3

category 3 – fuel and

energy related emissions

Scenario

IEA B2D

2

Status

On-track

EAD as at

30 June 2025

Current metric is not

tied to our lending

Performance

vs pathway

Offices (60%)

Shopping

Centres (36%)

Performance

vs baseline

Offices (73%)

Shopping

Centres (57%)

Actual performance against our target

2030 target pathway (60% reduction)

203020242026202820232022201920202021202520272029

GHG intensity (kgCO

2

-e/m

2

NLA)

0

20

10

40

30

50

60

70

80

90

Actual performance against our target

2030 target pathway (60% reduction)

203020242026202820232022201920202021202520272029

GHG intensity (kg CO

2

-e/m

2

NLA)

0

20

10

40

30

50

60

70

80

90

100

Limitations on the availability of data in

the sector has impacted the review of our

CRE sectoral pathway approach, including

exploring the potential use of alternative

reference scenarios. We may consider

adjusting our approach as the availability

of data increases.

46ANZ 2025 Climate Report

How is ANZ supporting the transition?
Customer engagement

via our LEEP

As at 30 June 2025, 5 of our CRE pathway customers were captured within our LEEP.

Refer to page 12 for details on the program including how we select LEEP customers.

Specific policies in place to steer

our lending decisions

ANZ will only finance the construction of new large-scale office buildings

1

if they

achieve an ‘as designed’

2

NABERS energy rating of at least 5 stars

3

(or equivalent

international rating).

Potential options for our customers

to reduce their emissions

• Electrification and transition to lower emissions electricity sources.

• Implementing energy efficiency measures.

1. Large scale is an office building with a NLA > 10,000 sqm located within a major CBD. 2. ‘As designed’ refers to a rating that is calculated during the design phase of a building, before

it is actually constructed. 3. As of July 2025, the “as designed” NABERS rating requirement for the construction of new large-scale office buildings increased to 5.5 stars (or equivalent

international rating). This change impacts new lending post-July 2025.

Refer to page 1 for our disclaimer and important notices,

pages 50-51 for the Australian residential home loan

portfolio performance summary, page 32 for Our Approach

to Sectoral Pathways, and Appendix 5 for our Financed and

Facilitated Emissions Methodology.

47

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Other metrics
The emissions intensity of our Australian

residential home loan portfolio in 2025

was 4.10 tCO

2

-e per dwelling, 4% below

2024. This is slightly lower than the

Australian average emissions intensity of

4.64 tCO

2

-e per dwelling. Suncorp Bank

is included within scope. Our emissions

intensity calculation utilises an outstanding

loans balance that is not indicative of

ANZ's entire Australian Residential Home

Loan book. Refer to our Financed and

Facilitated Emissions Methodology in

Appendix 5 for further details on

applicable eligibility criteria.

ANZ has not committed to an emissions

target for its Australian residential home

loan portfolio.

We project that the emissions intensity

of ANZ’s Australian residential home loan

portfolio would need to reduce by at least

53% by 2030

3

(from 2023) to align with

the goal to limit global warming to 1.5°C

above pre-industrial levels. This reduction

to our portfolio emissions is unlikely to be

linear considering our customers’ Scope 2

emissions profile from home energy use is

significant.

In Australia, this is mostly influenced by

the electricity grid’s reliance on coal-fired

generation. However, as power stations

are gradually replaced by lower emitting

sources of generation, we expect that

there will be reductions in the emissions

Graph 11.1: Australian residential home loan portfolio emissions intensity

1


Australian residential home loans

Potential opportunities for

emissions reduction in the sector

ANZ

• Supporting the higher

penetration of renewable

and other lower emissions

sources of electricity in

Australia through our lending

and facilitation activities in

the debt capital markets.

• Continuing to provide

financing to build new homes

and explore potential

opportunities to support the

retrofitting of existing homes

to improve energy efficiency.

Governments and

regulatory bodies

• Facilitating the increased

penetration of renewables

into Australia’s electricity grids

and improving the energy

efficiency of homes through

policy developments.

Customers

• Improving the energy

efficiency of their homes.

• Electrification of home

equipment (e.g., hot water

systems, space heating and

gas appliances).

• Increasing the use of rooftop

solar supported by batteries.

Outstanding loans

2

at

30 June 2025

$371.58b

2025 emissions intensity

(tCO₂-e per dwelling)

4.10

Emissions included

Scope 1 and 2

Natural gas and liquified petroleum

gas (LPG) & electricity use sourced

from grid

intensity of electricity supplied to our

customers’ homes. See the power

generation section on page 34 for details

on ANZ’s role in financing renewable

electricity generation.

In 2025, we supported customers

through our participation in the Australian

Government’s trial of the Nationwide

House Energy Rating Scheme (NatHERS)

for existing homes. The trial provides

select ANZ customers the opportunity

to identify energy efficiencies and

cost-savings for their property through a

free physical evaluation and home energy

rating trial certificate.

4

We have also progressed customer

education programs through the Forgotten

Fuel series, created in partnership with

the Energy Efficiency Council. It presents

practical steps Australians can take to

improve the energy efficiency of their

homes and the financial benefits of

making households more sustainable.

5

1. The national average for Australia has been calculated using dwelling data from ABS – Total Value of Dwellings

(June 2025), energy data from DCCEEW – Australian Energy Update 2025 and emissions factors from DCCEEW

– Australian National Greenhouse Accounts Factors (2025). 2. This is not indicative of ANZ's entire Australian

Residential Home Loan book. Refer to our Financed and Facilitated Emissions Methodology in Appendix 5 for further

details on applicable eligibility criteria. 3. IEA – Net Zero Emissions by 2050 World Scenario (2023). 4. ANZ - ANZ joins

government trial to help homeowners save on energy bills (23 May 2025). 5. ANZ and Energy Efficiency Council

- Putting Energy Efficiency to Work at Home (May 2025).

Emissions per dwelling

(tCO

2

-e)

0

1

2

3

4

5

6

ElectricityGas

2024

2023

LPGNational average

2025

%

0

20

40

60

80

100

VicNSW

Qld

WA

SA

ACT

NT

Tas

% of financed

emissions

% of customer

homes

38%

23%

29%

25%

23%

23%

9%

12%

3%

2%

1%

1%1%

2%

2%

7%

Refer to page 1 for our disclaimer

and important notices, pages 50-51

for the Australian residential home loans

portfolio performance summary,

page 32 for Our Approach to Sectoral

Pathways, and Appendix 5 for our

Financed and Facilitated Emissions

Methodology.

48ANZ 2025 Climate Report

Agribusiness data
coverage cohort

Targeting 100% of the Agribusiness data coverage cohort

to disclose Scope 1 and Scope 2 emissions at a standard

equivalent to the ‘Australian National Greenhouse Account

Factors’

1

by the end of financial year 2027.

ANZ has not committed to an emissions

reduction target for our Institutional

Agribusiness sector or sub-sectors,

concluding that it remains premature to

set a target while the availability and

quality of emissions data remains

challenging. Data availability and quality

impacts our ability to accurately estimate

financed and facilitated emissions.

For this reason, we remain focused on

seeking enhanced disclosures from the

large Agribusiness customers in our data

coverage cohort. ANZ’s data coverage

target aims to encourage and support

the provision of high quality and

comparable emissions data by the

customers in our cohort.

The agribusiness data coverage cohort

comprises large Institutional Agribusiness

customers who either have significant

operations in Australia or are

headquartered in Australia

3

and own

assets or operate in one or more of the

following parts of the agribusiness

value chain:

• Farm input providers (e.g., fertiliser

manufacturers)

• Producers (e.g., of beef, lamb, grain,

poultry, and aquaculture products)

• Processors (e.g., bulk-handlers, meat

processors)

• Retailers (e.g., supermarkets)

• Quick-service restaurants (e.g., large

fast-food chains)

Currently, 61% of our agribusiness data

coverage cohort customers are disclosing

Scope 1 and Scope 2 emissions to an

Australian National Greenhouse Account

Factors (NGA) standard or equivalent, a

decrease of 2% compared with last year.

These customers disclosed their

emissions publicly or to the Australian

Clean Energy Regulator through the

National Greenhouse and Energy

Reporting Scheme.

4

The decrease was

due to some customers not seeking

assurance of their Scope 1 and Scope 2

emissions data in the current reporting

year (but having done so in the previous

reporting year).

Overall, the number of cohort customers

publicly reporting emissions increased

from 81% to 87% in 2025, however some

of these disclosures were not subject to

assurance and therefore did not meet our

data coverage target criteria. We will

continue to engage with the agribusiness

data coverage cohort customers who do

not report Scope 1 and Scope 2

emissions, or do not report in accordance

with the data coverage target criteria, to

understand and encourage their progress

towards disclosure and assurance.

1. DCCEEW – Australian National Greenhouse Accounts Factors. 2. To the Australian National Greenhouse Account Factors (NGA) standard or equivalent e.g., audited emissions

disclosure. 3. Cohort is made up of a selection of large Institutional Agribusiness customers as at October 2023. ANZ does not intend to add new customers to the cohort to replace

customers that are no longer in the cohort (e.g., because they no longer have the required nexus with Australia or are no longer an ANZ customer), but may do so if it considers it

appropriate in the circumstances. As a result, Suncorp Bank is not considered within scope of this metric cohort. 4. National Greenhouse and Energy Reporting (Measurement)

Determination 2008 (Cth). The National Greenhouse and Energy Reporting (NGER) Scheme is a national framework for reporting company information about greenhouse gas

emissions, energy production, and energy consumption.

EAD as at

30 June 2025

$5.62b

% Group

EAD

0.41%

% of Agribusiness data coverage

cohort disclosing their Scope 1 and

Scope 2 emissions

2

61%

49

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Sectoral pathway performance summary
Exposure at Default (EAD)

Baseline

year

EAD $b (% of Group EAD)

Sector

1,2

Baseline202320242025

Power generation20207. 4 69.35 (0.81%)9.36 (0.80%)14.14 (1.03%)

Oil and gas202010.207.35 (0.63%)5.93 (0.51%)4.34 (0.32%)

Thermal coal20200.430.09 (0.01%)0.08 (0.01%)0.10 (0.01%)

Auto manufacturing20222.132.03 (0.18%)1.73 (0.15%)2.41 (0.18%)

Aviation20193.292.79 (0.24%)2.51 (0.22%)3.15 (0.23%)

Shipping20220.840.72 (0.06%)0.64 (0.05%)0.50 (0.04%)

Aluminium20210.670.69 (0.06%)0.72 (0.06%)0.46 (0.03%)

Cement20210.390.28 (0.02%)0.21 (0.02%)0.18 (0.01%)

Steel

20211.021.15 (0.10%)1.01 (0.09%)0.67 (0.05%)

Australian residential

home loans

3

--280.17299.15371.58

Absolute financed emissions (MtCO₂-e)

Sector

1,2

Baseline yearScopeBaseline202320242025

Power generation20201Not Reported5.304.484.53

Oil and gas20201 and 21.431.010.870.67

311.227. 8 66.844.50

Thermal coal20201 and 20.240.010.010.01

38.600.370.250.34

Auto manufacturing202231.871.621.321.78

Aviation201912.541.011.281.86

Shipping202210.240.250.230.20

Aluminium20211 and 20.530.390.520.31

Cement20211 and 22.241.520.910.63

Steel20211 and 21.261.621.230.87

Australian residential

home loans

-1 and 2-1.691.651.87

1. Relates to customers identified as within-scope of our sectoral pathway portfolio cohorts as defined within our Financed and Facilitated Emissions Methodology. For further detail on

the emissions scope, inclusion and exclusion criteria, and any limitations, refer to the methodology located at Appendix 5. 2. The datapoints disclosed within these tables use varying

collection and calculation dates. Refer to page 33 and Appendix 5 for further details on the boundaries applied for our Financed and Facilitated Emissions. 3. The exposure figures

reflects the total loans outstanding for homes within ANZ’s Australian home loan book that are within scope for the financed emissions metric.

50ANZ 2025 Climate Report

Absolute facilitated emissions (MtCO₂-e)
Sector

1,2

Baseline yearScopeBaseline202320242025

Power generation20201Not Reported0.140.170.65

Oil and gas20201 and 20.150.060.050.01

31.130.400.300.07

Thermal coal20201 and 20.000.000.000.00

30.150.000.000.00

Auto manufacturing202230.05 0.05 0.04 0.03

Aviation201910.130.020.040.03

Shipping202210.010.010.000.00

Aluminium20211 and 20.040.020.040.06

Cement20211 and 20.000.000.000.07

Steel20211 and 20.040.000.000.00

Emissions intensity

Sector

1,2

Baseline yearUnitsBaseline202320242025

Power generation2020kgCO₂-e/MWh245171156120

Oil and gas2020kgCO₂-e/GJ produced71696870

Thermal coal2020kgCO

2

-e/t produced2.502.442.532.52

Auto manufacturing2022gCO₂-e/vkm140121 107 94

Aviation2019gCO₂-e/RTK871906797870

Shipping2022gCO₂-e/t km11.4912.2512.3511.13

Aluminium2021tCO₂-e/t aluminium6.818.698.315.88

Cement2021tCO₂-e/t cement0.660.650.620.62

Steel2021tCO₂-e/t steel2.102.001.931.66

Australian large-scale

commercial real

estate – offices

2019kgCO

2

-e/m

2

NLA80.2140.8624.4921.52

Australian large-scale

commercial real

estate – shopping

centres

2019kgCO

2

-e/m

2

NLA89.7560.3044.9838.43

Australian residential

home loans

-tCO₂-e/dwelling-4.444.294.10

1. Relates to customers identified as within-scope of our sectoral pathway portfolio cohorts as defined within our Financed and Facilitated Emissions Methodology. For further details

on the emissions scope, inclusion and exclusion criteria, and any limitations, refer to the methodology located at Appendix 5. 2. The datapoints disclosed within these tables use varying

collection and calculation dates. Refer to page 33 and Appendix 5 for further details on the boundaries applied for our Financed and Facilitated Emissions.

51

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Operational emissions
Operational emissions are greenhouse

gas (GHG) emissions associated with

operating our business. Scope 3 financed

emissions and facilitated emissions (see

page 32) and emissions associated with

ANZ’s investments are not included as

part of operational emissions.

In previous years, we reported our

operational emissions for the period

1 July to 30 June. In 2025, we updated

our operational emissions reporting period

to align with ANZ’s financial year end of

30 September in preparation for ANZ’s

first mandatory climate reporting period,

commencing 1 October 2025. In this

transition year, we have disclosed

operational emissions for both reporting

periods ending 30 June 2025 and

30 September 2025. Data in respect of

prior years remains reported for the period

1 July to 30 June. Both the operational

targets, detailed on page 53, and the

year-on-year comparisons made below

will also remain by reference to the periods

ending 30 June.

For further information on our

measurement approach, refer to ANZ’s

Scope 1, Scope 2 and Scope 3

Operational GHG emissions reporting

methodology at Appendix 7.

The decrease to combined Scope 1 and

Scope 2 (location-based) emissions in

2025 was primarily due to the reduction

in gas consumption in our Melbourne

headquarters and reduced electricity and

diesel consumption across our

international offices.

The decrease to combined Scope 1 and

Scope 2 (market-based) emissions in

2025 was primarily due to ANZ procuring

97% of our electricity needs from

renewable sources, up from 57% in 2024.

In 2025, ANZ signed a second Power

Purchase Agreement (PPA) with Mortlake

South Wind Farm, complementing the

Murra Warra Wind Farm PPA established in

2019. In addition, ANZ has deployed 16

rooftop solar systems through a retail solar

PPA program since its commencement in

2023.

Internationally, ANZ sources renewable

energy through a portfolio of measures

tailored to each region. In New Zealand,

100% renewable electricity was achieved

through the purchase and surrender of

New Zealand Energy Certificate’s (NZECs)

from our electricity supplier. For other

international operations, where energy

demand is comparatively lower, we source

renewable electricity through retail

products or unbundled renewable energy

certificates – tradable instruments that

represent renewable electricity but are

sold separately from the physical

electricity itself. The portfolio of measures

allows us to source renewable electricity

based on market availability and our

electricity needs.

Value chain emissions

In 2025, ANZ’s reported Scope 3

(location-based) operational emissions

were 80,146 tCO

2

-e, 16% higher than

2024. In 2025, we continued to work with

our suppliers to better understand our

impact and identify opportunities to

reduce emissions.

Emissions by Scope

2025

1

2024

Emissions (tCO

2

-e) Location-based

1 Oct to

30 Sep

1 Jul to

30 Jun

1 Jul to

30 Jun

Scope 1 emissions6,3146,2695,958

Scope 2 emissions74 , 5 5 674 , 9 5 576,020

Scope 3 measured operational emissions7 7, 1 7 380,14668,845

Total emissions (location-based)158,043161,370150,823

Emissions (tCO

2

-e) Market-based

Scope 1 emissions6,3146,2695,958

Scope 2 emissions2,1382,27236,076

Scope 3 measured operational emissions

70,41073,35866,992

Total emissions (market-based)

78,86281,899109,026

Emissions (tCO

2

-e) by region (Scope 1 and Scope 2 location-based)

Australia

61,83861,63360,638

New Zealand

3,6843,5673,351

Asia Pacific, Europe and America

15,34816,0231 7, 9 9 0

Total Scope 1 and Scope 2 (location-based)

80,87081,22481,978

Emissions (tCO

2

-e) by region (Scope 1 and Scope 2 market-based)

Australia

4,6754,59232,458

New Zealand

1,5241,5611,918

Asia Pacific, Europe and America

2,2532,3887, 6 5 8

Total Scope 1 and Scope 2 (market-based)

8,4528,54142,034

Emissions (tCO

2

-e) Scope 3

Category 1: Purchased goods and services9,2159,2886,489

Category 2: Capital goods7999083,118

Category 3: Fuel and energy related activities12,00812,2579,907

Category 4: Upstream transportation and

distribution

4,4094,4064,156

Category 5: Waste generated in operations686660834

Category 6: Business travel22,17924,90420,459

Category 7: Employee commuting27, 71627, 5 6 222,008

Category 8: Upstream leased assets1611611,873

1. Includes Suncorp Bank.

52ANZ 2025 Climate Report

Climate-related
operational targets

Since setting our current range of

operational targets in 2022, we have made

strong progress across the business to

support us in meeting our ambitions.

Several of our targets, detailed below,

expired as at 30 June this year. As a result,

this year we have chosen not to restate

the baseline years and performances

towards our targets from 30 June to a

30 September reporting period, to align

with our banking financial year-end.

Similarly, existing targets have not been

restated for the Suncorp Bank acquisition.

1


Future targets including our revised target

below aligned with our financial reporting

year of 1 October to 30 September and

Suncorp Bank will be included in scope as

relevant to the target.

Refer to our Scope 1, Scope 2 and Scope

3 Operational GHG emissions reporting

methodology in Appendix 7 for further

details.

Reducing waste to landfill

4

by

40% by 2025 (against 2017

baseline)

ANZ exceeded its 2025 waste reduction

target, achieving a 79% decrease in waste

to landfill against its 2017 baseline year.

This result was driven by the continuation

of zero waste principles in new retail

branch fit outs across New Zealand,

recycling of e-waste and office furniture,

and employee engagement through

internal campaigns and audits.

1. Although the Suncorp Bank acquisition represented

a notable structural change, it did not meet the 5%

materiality threshold for our baseline to be restated.

There is also an absence of available of Suncorp Bank

data for the 2015 baseline year. 2. Self-generated

renewable electricity, direct procurement from offsite

grid connected generators e.g. Power Purchase

Agreement (PPA), retail products, unbundled renewable

energy certificates and default delivered renewable

electricity from the grid. 3. Total potable water consumed

from ANZ’s global properties. 4. Total waste to landfill

generated from ANZ’s global properties.

Non-emissions targets

Reducing water consumption

3

by

40% by 2025 (against 2017

baseline)

ANZ exceeded its 2025 water reduction

target, achieving a 61% decrease in

consumption against its 2017 baseline

year. This was largely achieved by

rightsizing the property portfolio; achieving

a 3.5-star NABERS water rating at the

Melbourne headquarters; and ongoing

monitoring to maintain usage even as

employee attendance increased.

tCO

2

-e

20152016201720182019202020212022202320242025

200

150

100

50

0

2025 target

Scope 1 and Scope 2 operational

emissions: Performance against target

Revised target: Reducing combined

Scope 1 and Scope 2 emissions by

85% by 2030 against a 2024 baseline

Having achieved our 2030 target of a 90%

reduction (against a 2015 baseline) earlier

than expected, we have revised our

combined Scope 1 and Scope 2

emissions reduction target with a more

ambitious baseline year of 2024. Our

target has been revised to an 85%

reduction in combined Scope 1 and

Scope 2 emissions against a 2024

baseline and to also include Suncorp Bank

commencing 1 October 2025.

Reducing paper consumption (both

office and ANZ originated customer

paper use) by 70% by 2025 (against

2015 baseline)

ANZ exceeded its 2025 paper reduction

target, achieving a 77% decrease in

consumption against its 2015 baseline

year. This result was driven by the

expansion of eSign usage which saved

over 500,000 printed documents, the

digitisation of brochures and customer

statements across the branch network

and the streamlining of internal workflows

to reduce reliance on printed materials.

Reducing combined Scope 1 and

Scope 2 emissions by 85% by

2025 and 90% by 2030 against

2015 baseline

Objective

Scope 1 and Scope 2

emissions reduction

(market-based)

ScopeANZ’s global footprint

under operational control

Ta rg e t Ty p eAbsolute quantitative

target

AlignmentInformed by the Paris

agreement

(1.5

0

C degree alignment)

Performance

ANZ exceeded its 2025 target to reduce

combined Scope 1 and Scope 2 (market-

based) emissions by achieving a 96%

reduction, driven principally from an

increase in renewable electricity. A reduction

of diesel cars from the New Zealand fleet

and the reduction of natural gas use at the

Sydney and Melbourne commercial offices

also contributed to the reduction.

Being powered by the

equivalent of 100% renewable

electricity by 2025

2

ObjectiveRenewable energy

procurement

ScopeANZ global footprint under

operational control

Ta rg e t Ty p e% of renewable energy

purchased

Alignment

Not applicable

Performance

As of 30 June 2025, 97% of ANZ’s

electricity needs were from renewable

sources, just falling short of our target of

100% renewable electricity by 2025. This

was principally due to the absence of

recognised schemes or renewable

electricity infrastructure in Papua New

Guinea and Pacific countries.

53

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

1. Glasgow Financial Alliance for Net Zero (GFANZ) Financial Institution Net zero Transition Plans – Fundamentals, Recommendations, and Guidance (2022).
2. Transition Plan Task Force Disclosure Framework (2023).

TPT ElementsPage referenceGFANZ ComponentPage reference

FoundationsFoundations

1.1 Strategic ambition8 -11Objectives and priorities8-11, ESG Targets – see our

2025 ESG Report located at

anz.com/esgreport

1.2 Business model and

value chain

Not met - see details of our business

model and value chain on page 4

1.3 Key assumptions and

external factors

Not met - see details of our C&E

strategy and approach to transition

planning on pages 8-11

Implementation StrategyImplementation Strategy

2.1 Business operations12-15, 26-27, 52-53Products and services12-21, 31

2.2 Products and services16-17, 21, 31Activities and decision-making22-24

2.3 Policies and conditions19, 22-24, 32-51Policies and conditions19, 22, 32-51

2.4 Financial planningNot met

Engagement StrategyEngagement Strategy

3.1 Engagement with value chain12-18, 31, 52Clients and portfolio

companies

12-18, 31, 52

3.2 Engagement with industry21Industry21

3.3 Engagement with

government, public sector,

communities and civil society

21Government and public sector21, ESG Targets – see our

2025 ESG Report located

at anz.com/esgreport

Metrics and TargetsMetrics and Targets

4.1 Governance, engagement,

business, and operational

metrics and targets

12-15, 30 - 53Metrics and targets10-11, 30-53, ESG Targets

and Performances – see our

2025 ESG Report located at

anz.com/esgreport

4.2 Financial metrics and targets31

4.3 GHG metrics and targets32-53

4.4 Carbon credits77

GovernanceGovernance

5.1 Board oversight and reporting5 -7Roles, responsibilities and

remuneration

5 -7

5.2 Management roles,

responsibilities and accountabilities

5 -7

5.3 Culture5, 20Skills and culture5, 20

5.4 Incentives and remunerationPartially met - see page 7

5.5 Skills, competencies and training5, 20

The index below provides section references of this report to the relevant GFANZ and TPT transition planning guidance framework.

1,2

Our disclosures do not purport to be comprehensive or to satisfy all aspects of GFANZ or TPT’s framework.

Appendix 1: GFANZ and TPT index

54ANZ 2025 Climate Report

Appendix 2: Task Force on Climate-related
Financial Disclosures (TCFD) Index

TCFD categoryTCFD disclosure recommendationANZ response – page

Governance

Disclose the organisation’s governance

around climate-related risks and

opportunities.

a.Describe the board’s oversight of climate-related risks

and opportunities.

5 -7

b.Describe management’s role in assessing and managing

climate-related risks and opportunities.

6 -7

Strategy

Disclose the actual and potential impacts

of climate-related risks and opportunities

on the organisation’s businesses, strategy,

and financial planning where such

information is material.

a.Describe the climate-related risks and opportunities the

organisation has identified over the short, medium, and

long term.

24-27

b.Describe the impact of climate-related risks and

opportunities on the organisation’s businesses, strategy,

and financial planning.

26-29

c.Describe the resilience of the organisation’s strategy,

taking into consideration different climate-related

scenarios, including a 2°C or lower scenario.

28-29

Risk Management

Disclose how the organisation identifies,

assesses, and manages climate-related

risks.

a.Describe the organisation’s processes for identifying

and assessing climate-related risks.

22-27

b.Describe the organisation’s processes for managing

climate-related risks.

22-27

c.Describe how processes for identifying, assessing, and

managing climate-related risks are integrated into the

organisation’s overall risk management.

22-27

Metrics and Targets

Disclose the metrics and targets used

to assess and manage relevant climate-

related risks and opportunities where

such information is material.

a.Disclose the metrics used by the organisation to assess

climate-related risks and opportunities in line with its

strategy and risk management process.

12-15, 28-29, 30-52, 76

b.

Disclose Scope 1, Scope 2 and, if appropriate, Scope 3

greenhouse gas (GHG) emissions and the related risks.

32-52

c.Describe the targets used by the organisation to manage

climate-related risks and opportunities and performance

against targets.

10 -11, 31- 53

55

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Appendix 3: Task Force on Nature-related
Financial Disclosures (TNFD) Index

TNFD categoryTNFD disclosure recommendationANZ response – page

Governance

Disclose the organisation’s

governance

of nature-related dependencies,

impacts, risks and opportunities.

a.Describe the board’s oversight of nature-related dependencies,

impacts, risks and opportunities.

7

b.Describe management’s role in assessing and managing nature-

related dependencies, impacts, risks and opportunities.

7, 18-19, 22

c.Describe the organisation’s human rights policies and engagement

activities, and oversight by the board and management, with respect

to Indigenous Peoples, Local Communities, affected and other

stakeholders, in the organisation’s assessment of, and response to,

nature-related dependencies, impacts, risks and opportunities.

Partially met – see

our Climate Change

Commitment, available

here prior to our AGM

Strategy

Disclose the effects of nature-

related dependencies, impacts,

risks and opportunities on the

organisation’s business model,

strategy and financial planning

where such information is

material.

a.Describe the nature-related dependencies, impacts, risks and

opportunities the organisation has identified over the short,

medium and long term.

Partially met –

see pages 18-19

b.

Describe the effect nature-related dependencies, impacts, risks

and opportunities have had on the organisation’s business model,

value chain, strategy and financial planning, as well as any

transition plans or analysis in place.

18 -19

c.Describe the resilience of the organisation’s strategy to nature-

related risks and opportunities, taking into consideration different

scenarios.

Partially met – see initial

steps we are taking

utilising the ENCORE

tool on pages 18-19

d.Disclose the locations of assets and/or activities in the

organisation’s direct operations and, where possible, upstream

and downstream value chain(s) that meet the criteria for priority

locations.

Not met

Risk Management

Describe the processes used

by the organisation to identify,

assess, prioritise and monitor

nature-related dependencies,

impacts, risks and opportunities.

a.(i) Describe the organisation’s processes for identifying, assessing

and prioritising nature-related dependencies, impacts, risks and

opportunities in its direct operations.

Not met

a.(ii) Describe the organisation’s processes for identifying, assessing

and prioritising nature-related dependencies, impacts, risks and

opportunities in its upstream and downstream value chain(s)

22-24

b.Describe the organisation’s processes for managing nature-

related dependencies, impacts, risks and opportunities.

18 -19, 22

c.Describe how processes for identifying, assessing, prioritising and

monitoring nature-related risks are integrated into and inform the

organisation’s overall risk management processes.

18 -19, 22

Metrics and Targets

Disclose the metrics and targets

used to assess and manage

material nature-related

dependencies, impacts, risks

and opportunities.

a.Disclose the metrics used by the organisation to assess and

manage material nature-related risks and opportunities in line with

its strategy and risk management process.

Not met

b.Disclose the metrics used by the organisation to assess and

manage dependencies and impacts on nature.

Not met

c.Describe the targets and goals used by the organisation to manage

nature-related dependencies, impacts, risks and opportunities and

its performance against these.

Not met

56ANZ 2025 Climate Report

Appendix 4: Climate Scenario
Analysis Methodology

Disclaimer and important notices

The information in this methodology should be read together with Disclaimer and Important Notices on page 1 which contains information

about forward-looking statements, and the uncertainties, challenges and risks associated with climate-related information.

The purpose of this section is to outline our approach to climate scenario analysis.

Further to scenario descriptions set out on pages 24-29 of this report, this section provides additional detail on the scenario-based

assumptions that supported our assessment.

Time horizons

The table below details the considerations that we took into determining the time horizons.

Summary of our scenario time horizons

Short-term

0-1 year (2026)

Medium-term

1-5 years (2030)

Long-term

5+ years (2050)

• Aligns with our annual business cycle• Aligns with our stress testing horizons,

group-level strategy cycle and our Internal

Capital Adequacy Assessment Process

(ICAAP)

• Aligns with our Climate-related

intermediate targets

• Aligns with the transition of our

lending portfolio to net zero financed

emissions by 2050

• Maximum 30-year tenor of home

loans

Inputs and assumptions

Network for Greening the Financial System (NGFS) Scenarios

ANZ selected two scenarios from the NGFS that represent divergent climate pathways to identify material climate risk. NGFS scenarios

were chosen as they provide comprehensive coverage of both transition and physical climate risks across economic sectors.

NGFS scenario architectures

1

Net Zero 2050 – Orderly TransitionCurrent Policies – Hot House World

SourceBoth scenarios are sourced from the NGFS Climate Scenarios

(November 2024 Phase V release).

Diversity of range of climate-related

scenario used

The two scenarios selected represent divergent climate pathways to support the

assessment of ANZ’s business model in response to low

physical risk and moderate

transition risks (Net Zero 2050) and high physical risks (Current Policies). These are

plausible scenarios that help us to understand where our most material climate risks

may arise.

Climate-related transition risk or

climate-related physical risks

Low physical and moderate transition risk

w i t h ~1 . 5

o

C warming by 2100.

High and escalating physical risk with >3

o

C

warming by 2100.

Minimal transition risk.

Alignment with the latest international

agreement on climate change

Aligned to the goals of the Paris

Agreement, which include:

• limiting the global temperature increase

to well below 2

o

C above pre-industrial

levels, with efforts to limit it to 1.5

o

C; and

• achieving global net zero

greenhouse

gas emissions by the second half of the

century.

N/A

Scope of operations used in the analysisThe assessment considered the potential impact of climate risks to ANZ’s business

model, including the interaction with our Material Risk categories.

Value chain considered in the analysisUpstream: capital providers and suppliers.

Downstream: investments, customers, employees, and other stakeholders.

1. Sourced from NGFS Climate Scenarios Technical Documentation and NGFS long-term scenarios for central banks and supervisors.

57

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Net Zero 2050 – Orderly TransitionCurrent Policies – Hot House World
Climate-related policies in the

jurisdictions in which ANZ operates

• Policy action such as carbon pricing,

subsidies for renewable energy are

introduced early and become gradually

more stringent.

• Only currently implemented climate

policies are preserved with no

strengthening of policy ambition.

• No additional climate measures

introduced.

Macroeconomic trends• Immediate transition costs with rising

carbon pricing create short-term

economic headwinds.

• Australian and New Zealand Gross

Domestic Product (GDP) impacts peak

by 2030 and then stabilise over time.

• Modest interest rate increases support

orderly adjustment.

• Lower transition costs but accelerating

physical climate damages cause severe,

worsening economic deterioration.

• GDP decline intensifies over time

without policy intervention.

• Mounting productivity losses and

reduced economic resilience.

National- or regional- level variables Macroeconomic variables were derived from the NGFS NiGEM

1

dataset which includes

Australia-specific variables. We selected the Global Change Analysis Model (GCAM) as

our primary integrated assessment model due to its higher granularity in modelling

Australia and New Zealand as a single distinct entity.

Energy usage and mix• Rapid decarbonisation of energy

systems with accelerated deployment

of renewables.

• Significant carbon pricing incentivising

clean energy transition.

• Continued reliance on fossil fuels.

• Energy mix evolution continues through

market-driven optimization and existing

policy frameworks.

Developments in technology• Rapid technological advancement and

innovation drive the transition.

• Fast deployment of renewable energy

technologies.

• Slow technological change with existing

climate policies maintained.

• Technology development constrained

by current policy frameworks.

• Continued reliance on existing energy

mix.

Reporting period

Scenario analysis was carried out in the 2025 reporting period

Intergovernmental Panel on Climate Change (IPCC) Scenarios

ANZ utilised IPCC Representative Concentration Pathway (RCP) scenarios for assessing climate risks to our Australian home loan residential

mortgage portfolio (refer to pages 28-29). IPCC RCP scenarios were selected for their detailed physical climate projections essential for

evaluating property-level risks such as flooding and extreme weather events.

IPCC scenario architectures

2


RCP 2.6 – Strong MitigationRCP 8.5 – High Emissions

Global temperature increase by 21000.9°C – 2.3°C above pre-industrial levels3.2°C – 5.4°C above pre-industrial levels

Sea level rise by 21000.3 – 0.6 metres0.5 – 0.8 metres

Extreme weather eventsModerate increase in frequency and

intensity

Significant increase in frequency and

intensity

Precipitation patternsRegional variability with some areas

experiencing increased drought and flooding

Substantial changes with more frequent

droughts and intense precipitation events

Coastal flooding riskElevated risk in low-lying areasSevere and widespread coastal flooding

Bushfire/wildfire riskModerately increased fire weather

conditions

Substantially increased fire weather and

extended fire seasons

Reporting periodScenario analysis was carried out in the 2025 reporting period

1. A global econometric model used by NGFS for economic forecasting, scenario analysis and stress testing. 2. Sourced from IPCC AR5 Reports.

58ANZ 2025 Climate Report

Limitations
Limitation Description

Scenario Data and Modelling

Climate scenario analysis relies on external data sets and models that have several

limitations. These may include:

• Limited Detail by Region and Sector:

Scenarios often lack the granular detail needed to assess risks specific to certain

industries and/or locations.

• Simplified Physical Risk Modelling:

The models distinguish between acute risks, which are short-term, high-impact

events (e.g., cyclones, bushfires), and chronic risks, which are longer-term, gradual

changes (e.g., rising temperatures, sea level rise). However, they may not fully reflect

the severity or frequency of acute risks, particularly when multiple events occur

close together or interact in complex ways.

• Idealised Transition Pathways:

Transition scenarios often assume smooth policy implementation and cooperation,

which may not reflect real-world political and/or economic challenges.

• Linear Assumptions on Technology and Behaviour:

Models typically assume gradual changes in technology and consumer behaviour,

limiting the ability to explore disruptive shifts and/or innovations.

• Lag in Scenario Updates:

Scenarios are updated periodically and may not reflect the latest science or policy

changes, especially in fast-moving environments.

• Framework-Specific Limitations:

– NGFS Scenarios focus on macroeconomic and transition risks but may

underrepresent physical climate impacts and tail risks.

– IPCC Scenarios model physical climate outcomes based on emissions pathways

but exclude socio-economic and policy assumptions.

Aggregating and Cascading Risks

Climate risks often occur together or in sequence, but current models assess risks

in isolation. This makes it difficult to understand the full impact when multiple risks

interact or cascade through systems such as how a flood might disrupt supply chains

and then affect financial markets.

Identifying Capital Risk Capital risk, that is, where ANZ might not hold enough capital to meet regulatory

requirements, is challenging to assess using current climate risk assessment

methodology. This is because capital adequacy depends on the combined impact of

many financial and non-financial risks, which are not fully captured in scenario analysis.

Identifying Tail Risk Current models focus on certain scenarios which are useful for exploring plausible

futures but may miss rare, high-impact events (“tail risks” or “black swans”) that fall

outside the scope of these scenarios.

59

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Appendix 5: Financed and Facilitated
Emissions Methodology

Disclaimer and important notices

The information in this methodology should

be read together with our Disclaimer and

Important Notices on page 1 which

contains information about forward-looking

statements, and the uncertainties,

challenges and risks associated with

climate-related information.

The purpose of this appendix is to

outline the methodologies that ANZGHL

has used to establish targets for the

reduction of financed and facilitated

emissions and to measure the emissions

profile of the relevant portfolios and

capital markets activities.

In some instances, ANZ has not set an

emissions reduction target for a sector but

has established a metric. Where that is the

case, this methodology explains how the

metric has been designed.

Our approach to sectoral

pathway targets

ANZ has set sectoral pathway targets

with the ambition to transition our

lending portfolio to net zero financed

emissions by 2050 in line with the goals

of the Paris Agreement.

2025 review

In 2025, we reviewed our sectoral pathway

targets, including aviation which was

suspended in 2024. The review has

resulted in some material changes being

made to pathways, including targets and

our historical performance.

The review was undertaken for the

following reasons:

• To include facilitated emissions

associated with syndicated loans and

bonds informed by UN Guidance for

Climate Target Setting for Banks and

the Partnership for Carbon Accounting

Financial (PCAF) guidance

• To assess whether customers of

Suncorp Bank met our in-scope criteria

for inclusion in our pathways and

metrics

• To update to use more recent reference

scenarios where we considered

appropriate, including the consideration

of a target range

• To reflect the UN Guidance for

Climate Target Setting for Banks

recommendation that targets are

reviewed at a minimum every 5 years

• To consider the opportunity to use

an intensity metric for the shipping

pathway

Amongst other changes, the review

resulted in changes to our baseline

year performance and 2030 targets for

some pathways.

See Sectoral pathway targets detailed

method on pages 62-73 which outlines

key changes from 2024 for each sector.

As part of the development of our

financed and facilitated emissions sectoral

pathways, we engaged a third-party to

undertake a limited-scope technical

review of some of our sectoral pathway

targets. The review assessed the

consistency of power generation and

oil and gas target pathways with the IEA

World Energy Outlook 2024 Net Zero

Emissions by 2050 reference scenario,

and the aviation target pathway with the

IEA World Energy Outlook 2024 Net Zero

Emissions by 2050 and Announced

Pledges scenarios.

Restatement approach

ANZ’s general approach is to restate

climate-related data where we identify

that a restatement is appropriate. For

example, to correct for errors in prior

reporting periods (such as calculation

mistakes, misinterpretations and errors in

applying the methodology) that we assess

as having a material impact on the

reported data or to adjust climate-related

data for any of the following events when

it results in a material impact:

• Changes in calculation methodology;

• Structural changes (e.g., mergers,

acquisitions and divestments of

customers within the relevant pathway);

and

• Changes in data availability (e.g.,

replacing estimates with actuals).

Materiality is assessed based on both

qualitative and quantitative factors,

including the impact of the change on

users of the data and our ability to track

and accurately report on performance

against our targets. Where undertaken, a

5% materiality threshold is used as a guide

for the quantitative assessment, but

where the threshold is not met, ANZ may

still make a restatement based on

qualitative factors. In some circumstances,

a restatement may have a consequential

impact on related information. If that is the

case, we may make other adjustments to

the related information to reflect the

restated position.

The materiality threshold for financed and

facilitated emissions metrics reflects the

complexity and significant uncertainty in

calculating Scope 3 emissions. When a

restatement results in a change to a

sectoral pathway baseline, we will

consider the impact on the

appropriateness of our target.

As a result of the 2025 review described

above, we have made changes to the oil

and gas, power generation, thermal coal,

auto manufacturing, shipping, aluminium,

cement and steel sectoral pathways this

year. In some instances, changes from the

2025 review may result in a consequential

change that meets the restatement

criteria, e.g., to reflect updated customer

emissions data, correct for errors (such as

calculation mistakes, misinterpretations

and errors in applying the methodology),

and to improve data granularity. Where

that is the case, we have not separately

identified the restatement.

60ANZ 2025 Climate Report

ANZSIC codes
ANZ aims to ensure in-scope customers

are representative of our exposure to

each sector. However, the approach is

somewhat manual in nature and

constrained by certain limitations.

The first step in assessing whether a

customer is in-scope for our sectoral

pathway targets is reviewing its assigned

Australia and New Zealand Standard

Industrial Classification (ANZSIC) code.

ANZ applies the 1993 ANZSIC codes,

which ANZ may adapt where it considers

appropriate, to allocate customers to

industry sectors. The ANZSIC codes are

allocated in ANZ’s system by customer-

facing employees or customer on-

boarding back-office functions. The

allocation is intended to reflect the

primary business activity of the customer

in terms of revenue. Where a customer

operates in more than one industry, ANZ

uses the ANZSIC code of the industry

that generates most of the revenue.

Where the customer is a parent

company of subsidiaries operating in

more than one industry, ANZ uses the

ANZSIC code of the industry that

generates most of their revenue. If the

customer is a subsidiary, ANZ uses the

ANZSIC code of the industry that

generates most of the revenue of the

subsidiary. Due to the manual nature of

code application there is a possibility of

error in assigning ANZSIC codes at the

time of customer onboarding or other

discrepancies due to changes in

customer activities over time. Each

customer allocated to the ANZSIC code

relevant to the scope of the sectoral

pathways is considered for the purpose

of determining whether the customer is

in-scope of that sectoral pathway.

Through this process, a customer may

not be included in the pathway, if they

otherwise do not meet the pathway

criteria. See pages 62-73 for sector

specific inclusion and exclusion criteria.

Boundaries

When calculating our financed and

facilitated emissions the following data

collection and calculation dates are used:

Exposure

at default

2019 to 2023 as at

30 September of the

relevant year. 2024 and

2025 as at 30 June of

the relevant year.

Capital

markets

activity

2019 to 2023 deals

occurring between

1 October and 30

September of the

relevant year.

2024 deals occurring

between 1 October and

30 June as we

transitioned to June end

to the reporting period

in line with the EAD

change. 2025 deals

occurring between

1 July and 30 June

Customer

emissions

data

We typically preference the

use of the latest available

customer emissions data.

We typically apply the

following data hierarchy

when sourcing customer

emissions data: public

customer disclosures,

regulatory disclosures,

credible third-party

vendors and as a last

resort, sector averages.

We have applied a 30

September 2025 cut off for

reporting by our customers

of their emissions data for

2025 reporting purposes.

Australian

residential

home loans

outstanding

loan amount

2023 and 2024 as at

31 May of the relevant year.

2025 as at 30 June.

Exposure at Default

We have taken a more conservative

approach in calculating our financed

emissions by using Exposure At Default

(EAD) rather than the outstanding amount

of loans and investments. EAD represents

the exposure to the sector based on

APRA’s calculation formula which includes

total committed loans (drawn plus a

proportion of off-balance sheet exposures

as specified by APRA). This is a departure

from the PCAF approach, which

recommends including the outstanding

amount of loans and investments i.e.

excluding undrawn amounts. While our

approach means that we are attributing

a higher proportion of our customers’

emissions to ANZ, we consider this

provides a more accurate representation

of our support to our customers and the

transition risks that we are potentially

exposed to. Our choice to also include

a proportion of undrawn loan amounts,

rather than just the outstanding amount,

also helps reduce the risk of volatility in

customer drawdowns that may impact

the achievement of our targets.

When assessing which customers are

in-scope for our sectoral pathways we

use an EAD threshold (see pages 62-70

for sector specific thresholds). We assess

customers against the EAD threshold

each year to determine if they are

in-scope for the relevant year. It is

estimated that cumulative customer

EAD below this threshold represents an

immaterial part of our overall financing

activities in the respective sector meaning

we consider that the threshold does not

materially affect the financed emissions

included in-scope.

Use of offsets

Our sectoral pathways targets and

reported financed and facilitated

emissions are prepared on a gross basis

and therefore do not currently consider

the use of any offsets our customers

use or may use to reduce their emissions.

We recognise that many customers are

proposing to use offsets to achieve their

own emissions reduction targets. Given

the ‘hard-to-abate’ nature of some

emissions sources within some of these

sectors, there may be residual and

unavoidable emissions in 2050, if

technology to eliminate those emissions

does not exist, is in early stages of

development or is not financially viable.

We will look to further develop our position

on customers’ use of offsets in the coming

years, however we apply a general

principle that emissions should first be

avoided by our customers, with offsetting

used only to compensate for residual and

unavoidable emissions.

61

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Sectoral pathway targets detailed method
Power generation – targeting a 54% reduction in emissions intensity by 2030, from a 2020 baseline

Key changes

from 2024

• Update of reference scenario to use the 2024 IEA World Energy Outlook

• Inclusion of facilitated emissions

Target baseline 245 gCO₂-e/ MWh Target in 2030114 gCO₂-e/MWh

Target metric

Portfolio weighted emissions intensity was chosen as the demand for electricity is expected to remain steady

or increase under a 1.5°C aligned scenario.

Reference pathwayThe Net Zero Emissions by 2050 (NZE) Scenario presented in the IEA’s World Energy Outlook (2024) was

chosen as a credible and well-recognised decarbonisation scenario.

Target setting methodSectoral decarbonisation approach aligned with a 1.5°C transition pathway.

In-scope customers (subject to meeting the criteria for In-scope lending or capital markets activity)

Institutional, Commercial and Suncorp Bank customers allocated to or meeting the criteria for ANZ industry code 3611 – electricity

generation. For ANZ’s purposes, ANZ industry code 3611 is an adaptation of 1993 ANZSIC code 3610 (electricity supply) to capture

customers engaged in the generation of electricity as their predominant activity. ANZ’s industry code 3611 does not include

customers whose predominant activity by revenue is the transmission or distribution of electricity.

Customer in-scope emissions

• Scope 1 emissions from electricity generation activities.

• We prioritise use of CO₂-e data inclusive of all relevant GHGs, where not available we use CO

2

emissions.

• We prioritise the use of customer data based on the operational control approach, where not available we use the equity

accounting approach.

In-scope lending and capital markets activity

Financed Where our lending to the customer could be used for the development and/or operation of power generation

asset(s) and the EAD is greater than $1m.

Facilitated

Where ANZ is a lead bookrunner for a syndicated loan to the customer or bond issued by the customer. No

financial threshold is applied. Note that financed emissions of the customer are not included in the pathway

unless the ‘financed’ requirement above is met.

Sector specific method

• A 2020 baseline was chosen to align the baselines across our energy sector pathways. 2020 predominantly relies on company

emissions and production data from the 2019 calendar year (which wasn’t impacted by COVID-19).

• Unless reported differently by our customers, assets that were based on nuclear, bioenergy, hydro or renewables technologies

were all assumed to have an emissions intensity of zero.

• Unless reported differently by our customers, for greenfield projects that ANZ directly finances and that are still in the construction

phase, ANZ applies the estimated emissions intensity of the asset from its expected operational date.

• We exclude emissions relating to electricity that our power generation customers may purchase from third-party generators either

as part of a power purchase agreement or on the spot market unless they have operational control of the same asset(s).

Data sourcesCustomer disclosures, Australian Clean Energy Regulator, Asset Impact, International Energy Agency

Supporting metrics reported

• Absolute financed emissions and absolute facilitated emissions in-scope of the pathway (see page 75).

• ANZ EAD to electricity generation fuel types and technologies: for each power generation customer in-scope for financed

emissions, ANZ has apportioned our total EAD to that customer across different generation types based on the same proportion of

generation last reported by the customer. ANZ then aggregates these generation weighted exposures across the power generation

customers in-scope for financed emissions to determine our pathway generation weighted exposure.

• Breakdown of ANZ’s power generation pathway: ANZ has reported a breakdown of our EAD to power generation customers

in-scope for financed emissions across five categories. For the corporate finance categories ANZ has assessed each customer

based on their reported emissions intensity, which is calculated by dividing their total emissions from generation (kgCO

2

-e) by their

total electricity generation (MWh).

62ANZ 2025 Climate Report

Oil and gas – targeting a 32% reduction in absolute financed and facilitated emissions by 2030,
from a 2020 baseline

Key changes

from 2024

• Update of reference scenario to use the 2024 IEA World Energy Outlook

• Inclusion of facilitated emissions

Target baseline 13.9 MtCO₂-e Target in 2030 9.4 MtCO₂-e

Target metric

The choice of an absolute emissions reduction target recognises that 1.5°C aligned scenarios – such as those

published by the IEA – show the need for an absolute reduction in the production and use of fossil fuels.

Reference pathwayThe Net Zero Emissions by 2050 (NZE) Scenario presented in the IEA’s World Energy Outlook (2024) was

chosen as a credible and well-recognised decarbonisation scenario.

Target setting methodAbsolute contraction approach aligned with a 1.5°C transition pathway.

In-scope customers (subject to meeting the criteria for In-scope lending or capital markets activity)

Institutional customers allocated to ANZSIC code 1200 - oil and gas extraction.

We exclude customers that do not otherwise have an equity share in upstream producing assets or LNG production including dedicated

refinery operators, fuel wholesale and distribution companies (including pipelines), fuel retailers and petrochemical producers.

Customer in-scope emissions

• Scope 1 and Scope 2 (market-based) emissions associated with oil and gas production and Scope 3 Category 11 use of sold

products emissions.

• We prioritise the use of CO₂-e data inclusive of all relevant GHGs, where not available we use CO₂ emissions.

• We prioritise the use of customer data based on the equity accounting approach, where not available we use the operational control

approach.

In-scope lending and capital markets activity

FinancedWhere our cumulative EAD to entities within a corporate group exceeds $10M and includes EAD to ANZSIC

code 1200 – oil and gas extraction. For the purpose of calculating cumulative EAD, in addition to ANZSIC code

1200, we consider ANZSIC codes 1511 – petroleum exploration; 1512 – petroleum exploration service; 2510

– petroleum refining; and 4521 – petroleum product wholesaling.

Facilitated

Where ANZ is a lead bookrunner for a syndicated loan to the customer or bond issued by the customer. No

financial threshold is applied. Note that financed emissions of the customer are not included in the pathway

unless the ‘financed’ requirement above is met.

Sector specific method

• A 2020 baseline was chosen to align the baselines across our energy sector pathways. 2020 predominantly relies on company

emissions and production data from the 2019 calendar year (which wasn’t impacted by COVID-19).

• Although many of our customers now report Scope 3 emissions from the use of their sold energy products, boundaries are applied

inconsistently by customers. Therefore, ANZ calculates the downstream Scope 3 emissions associated with the use of sold products

for all customers on a consistent basis, using their publicly reported net production data (production available for sale where available)

and which reflects their working interest or equity share in the producing asset. We acknowledge that this may present an over-

estimation of our customers’ emissions where a proportion of their production is used for non-energy purposes.

• For calculated financed emissions in 2020, 2021 and 2022 we have applied an adjustment factor to account for the estimated

average reduction in financed emissions associated with the APRA Capital reforms that took effect on 1 January 2023. The

introduction of the APRA Basel IV rules altered the way EAD is calculated. For our oil and gas portfolio, the aggregate impact of this

change was a material reduction in EAD, which means a lower proportion of our customers’ Scope 1, Scope 2 and Scope 3 emissions

is attributed to us. Therefore, we apply the adjustment factor to improve comparability of emissions pre and post APRA reform.

Data sourcesCustomer disclosures, Wood Mackenzie, Rystad Energy, International Energy Agency, American Petroleum

Institute, 2006 IPCC Guidelines for National Greenhouse Gas Inventories

Supporting metrics reported

• Absolute financed emissions and absolute facilitated emissions in-scope of the pathway (see page 75)

• Breakdown of ANZ’s Oil and Gas Pathway: ANZ has reported a breakdown of our EAD to oil and gas customers in-scope for financed

emissions across the following four categories:

1. Majors – large companies listed on stock markets in the United States and Europe

2. Independents – smaller fully integrated companies or independent upstream operators. Also includes some diversified international

conglomerates with upstream activities

3. National Oil Companies (NOCs) – companies that have been given legal mandates to exploit national oil and gas resources, with

most of their assets located in their home country’s upstream operations

4. International National Oil Companies (INOCs) – similar to NOCs in their ownership and governance, but have substantial upstream

investments outside their home country.

Some of the reduction in EAD since September 2020 is a result of the APRA Basel IV rule changes which came into effect 1 January

2023. The new rules altered the way EAD is calculated. When applied to ANZ’s oil and gas EAD, the revised calculation resulted in a

lower EAD amount compared with the original EAD calculation which was based on the old method.

63

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Thermal coal – targeting a 100% reduction in absolute financed and facilitated emissions by 2030,
from a 2020 baseline

Key changes

from 2024

• Inclusion of facilitated emissions

Target baseline 9.00 MtCO₂-e Target in 20300 MtCO₂-e

Target metric

The choice of an absolute emissions reduction target recognises that 1.5°C aligned scenarios – such as those

published by the IEA – show the need for an absolute reduction in the production and use of fossil fuels.

Reference pathwayThe Net Zero Emissions by 2050 (NZE) Scenario presented in the IEA’s World Energy Outlook (2024) was

chosen as a credible and well-recognised decarbonisation scenario.

Target setting methodAbsolute contraction approach aligned with a 1.5°C transition pathway.

In-scope customers (subject to meeting the criteria for In-scope lending or capital markets activity)

Institutional customers allocated to ANZSIC code 1102 - Brown coal mining. ANZ considers the end-use of coal when allocating an

ANZSIC code. If a customer’s predominant activity is producing coal used for power generation, they are assigned to ANZSIC code

1102. This includes customers that predominantly produce black coal, when it is apparent to ANZ that the end use of the black coal is

for power generation. ANZ excludes metallurgical coal miners and diversified miners that produce thermal coal from ANZSIC 1102 and

therefore they are not included in our pathway.

Customer in-scope emissions

• Scope 1 and Scope 2 (market-based) emissions from thermal coal mining and Scope 3 category 11 – use of sold products (thermal

coal only).

• We prioritise the use of CO

2

-e data inclusive of all relevant GHGs, where not available, we use CO

2

emissions.

• We prioritise the use of customer data based on the equity accounting approach, where not available, we use the operational control

approach.

In-scope lending and capital markets activity

Financed Where our EAD (excluding rehabilitation bonds and transaction banking/markets 3-day settlement limits) to

the customer is greater than $1m.

Facilitated

Where ANZ is a lead bookrunner for a syndicated loan to the customer or bond issued by the customer. No

financial threshold is applied. Note that financed emissions of the customer are not included in the pathway

unless the ‘financed’ requirement above is met.

Sector specific method

• A 2020 baseline was chosen to align the baselines across our energy sector pathways. 2020 predominantly relies on company

emissions and production data from the 2019 calendar year (which wasn’t impacted by COVID-19).

• The UN Guidance for Climate Target Setting for Banks states that any client with more than 5% of their revenues coming directly from

thermal coal mining and coal-powered electricity generation activities should be included in the scope of targets (including dominant

metallurgical coal mines that produce a thermal coal product). ANZ’s thermal coal target includes customers that ANZ allocates to

ANZSIC code 1102, (i.e., those customers for whom thermal coal mining is their predominant activity.) The target does not include

diversified miners or metallurgical coal miners that produce thermal coal (i.e., customers that ANZ does not classify as ANZSIC code

1102). Analysis of this 5% revenue threshold found that diversified miners and metallurgical coal miners that produce thermal coal

may fall in or out of the target boundary in any given year because of fluctuations in commodity prices. This creates challenges in

both reporting and setting a target. For this reason, we have elected not to follow the Guidance in applying the 5% revenue threshold.

• Although many of our customers now report Scope 3 emissions from the use of their sold energy products, we found that boundaries

are applied inconsistently by customers. Therefore, ANZ calculates the Scope 3 emissions associated with the use of sold products

for all customers on a consistent basis, using their publicly reported net production data (production available for sale where

available). We acknowledge that this may present an over-estimation of our customers’ emissions where a proportion of their

production is used for non-energy purposes.

Data sourcesCustomer disclosures, Wood Mackenzie, AME, 2006 IPCC Guidelines for National Greenhouse Gas

Inventories, Australian Clean Energy Regulator, International Energy Agency

Supporting metrics reported

• Absolute financed emissions and absolute facilitated emissions in scope of the pathway (see page 75)

• Thermal coal financed emissions by customer: a breakdown of estimated financed emissions of three different customer types based

on 2023 data. Includes emissions from customers included in our thermal coal target i.e. ANZSIC code 1102 (the predominant activity

is producing coal for power generation), and certain customers not included in our thermal coal target i.e. metallurgical coal miners

and diversified miners, in each case, where more than 5% of revenue comes directly from thermal coal mining.

64ANZ 2025 Climate Report

Auto manufacturing – targeting a 18-33% reduction in emissions intensity by 2030, from a 2022 baseline
Key changes

from 2024

• Update of reference scenario to use the 2024 IEA World Energy Outlook

• Inclusion of facilitated emissions

• Change from 1.5°C aligned target to 1.5°C – 1.7°C aligned target range recognising recent challenges with

EV adoption and market development, including trade disruptions and changes in government policies.

Target baseline 140 gCO₂-e/

vehicle kilometre (vkm)

Target in 2030 94-115 gCO₂-e/vkm

Target metric

Portfolio weighted emissions intensity was chosen as the demand for the output of the sector is expected to

remain steady or increase under a 1.5°C aligned scenario.

Reference pathwayThe Net Zero Emissions by 2050 (NZE) Scenario and Announced Pledges Scenario (APS) presented in the

IEA’s World Energy Outlook (2024) were selected as credible and well-recognised decarbonisation scenarios.

Target setting methodSectoral decarbonisation approach aligned with 1.5°C to 1.7°C transition pathways.

In-scope customers (subject to meeting the criteria for In-scope lending or capital markets activity)

Institutional customers allocated to ANZSIC code 2811 – Motor vehicle manufacturing. ANZ’s pathway cohort only includes

customers that undertake light duty vehicle manufacturing (passenger cars).

Customer in-scope emissions

• Scope 3 category 11 emissions from the use of sold products, the estimated lifetime emissions associated with newly manufactured

passenger vehicles on a tank-to-wheel basis (excluding electricity related emissions from EV charging).

• We prioritise the use of CO

2

-e data inclusive of all relevant GHGs, where not available, we use CO

2

emissions.

• We prioritise the use of customer data based on the operational control accounting approach, where not available, we use the equity

accounting approach.

In-scope lending and capital markets activity

Financed Where our EAD to the customer is greater than $10m. ANZ excludes exposures not related to light vehicle

manufacturing, e.g., manufacturing of trucks or customer leasing activities.

Facilitated

Where ANZ is a lead bookrunner for a syndicated loan to the customer or bond issued by the customer. No

financial threshold is applied. Note that financed emissions of the customer are not included in the pathway

unless the ‘financed’ requirement above is met.

Sector specific method

• A 2022 baseline was chosen as it was the most recent year prior to the first reported year (2023).

• When calculating customers’ Scope 3 category 11 emissions from the use of sold products (tank-to-wheel, which excludes

electricity related emissions from EV charging) intensity associated with the lifetime use of new vehicle sales, we assume that a

passenger vehicle will travel 200,000 kms during its lifetime.

• For auto manufacturing entities’ assets that ANZ directly finances and that are still in the construction phase (i.e. have not

commenced vehicle production), ANZ applies an estimated emissions intensity based on the vehicles to be produced at the asset.

Data sourcesCustomer disclosures, Transition Pathways Initiative

Supporting metrics reported

• Absolute financed emissions and absolute facilitated emissions in-scope of the pathway (see page 75)

• Powertrain mix indicator: tracks the powertrain mix of our auto manufacturing customers’ in-scope for financed emissions new

vehicle sales broken down by technology type, namely internal combustion engines, hybrid (including plug in hybrid) and battery

electric vehicles (or hydrogen fuel cell) (represented in % of vehicles produced).

65

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Aviation – targeting a 16-26% reduction in emissions intensity by 2030, from a 2019 baseline
Key changes

from 2024

• New target range in 2025 which includes facilitated emissions.

Target baseline 871 gCO₂-e/

revenue tonne kilometre (RTK)

Target in 2030 642-732 gCO₂-e/RTK

Target metric

Portfolio weighted emissions intensity was chosen as the demand for the output of the sector is expected to

remain steady or increase under a 1.5°C aligned scenario.

Reference pathwayThe Net Zero Emissions by 2050 (NZE) Scenario and Announced Pledges Scenario (APS) presented in the IEA’s

World Energy Outlook (2024) were selected as credible and well-recognised decarbonisation scenarios. When

setting our target range we applied the IEA WEO 2024 reference pathways for aviation. It is unclear whether

the IEA WEO 2024 reference pathways for aviation include freight emissions. We have assumed that the IEA

WEO 2024 reference pathways for aviation do not include freight emissions but as at 30 September, the

position is unclear. However, if the IEA WEO 2024 reference pathways for aviation do include freight emissions,

our aviation pathway may not align with the IEA WEO 2024 reference pathways’ 1.5°C – 1.7°C trajectory.

Target setting methodSectoral decarbonisation approach

In-scope customers (subject to meeting the criteria for In-scope lending or capital markets activity)

Institutional customers allocated to ANZSIC codes 6401 - scheduled international air transport, 6402 – scheduled domestic air

transport, or 6403 – non-scheduled air and space transport, that undertake commercial passenger air transport.

We exclude customers who only undertake freight air transport, aircraft owners and lessors who don’t operate aircraft, other aircraft

operation (e.g., helicopters, search and rescue, military, scenic flights).

Customer in-scope emissions

• Scope 1 emissions from aircraft operation.

• We prioritise the use of CO₂-e data inclusive of all relevant GHGs, where not available we use CO₂ emissions.

• We prioritise the use of company reported emissions on an operational control basis, where not available we use the equity

accounting approach.

In-scope lending and capital markets activity

Financed Where our EAD to the customer is greater than $10m.

Facilitated

Where ANZ is a lead bookrunner for a syndicated loan to the customer or bond issued by the customer. No

financial threshold is applied. Note that financed emissions of the customer are not included in the pathway

unless the ‘financed’ requirement above is met.

Sector specific method

• A 2019 baseline was chosen to reflect a year that was not distorted by COVID-19. Aviation activity did not return to pre-pandemic

levels until February 2024.

1

• We include emissions and activity data from passenger and freight operations undertaken by our in-scope customers. Passenger

operations make up most of the activity of our in-scope customers. However, some customers also undertake freight operations.

Data limitations mean we are currently unable to allocate emissions between our customers’ passenger and freight activities,

noting that a significant portion of freight is carried as belly cargo on passenger flights.

• A conversion factor of 100kg per passenger is used to convert from revenue passenger kilometres to revenue tonne kilometres.

Data sourcesCustomer disclosures, Cirium

Supporting metrics reported

• Absolute financed emissions and absolute facilitated emissions in scope of the pathway (see page 75).

1. I ATA - Global Outlook for Air Transport (2024)

66ANZ 2025 Climate Report

Shipping – targeting a 23-30% reduction in emissions intensity by 2030, from a 2022 baseline
Key changes

from 2024

• Move from absolute to emissions intensity reduction target

• Inclusion of facilitated emissions

• Update of reference scenario to use the 2024 IEA World Energy Outlook

• Change from 1.5°C aligned target to 1.5°C – 1.7°C aligned target range to reflect the hard-to-abate

nature of the sector.

Target baseline 11.49 gCO₂-e/ tonne kilometre (t km) Target in 20308.08-8.79 gCO₂-e/t km

Target metric

Portfolio weighted emissions intensity was chosen as the demand for the output of the sector is expected to

remain steady or increase under a 1.5°C aligned scenario.

Reference pathwayThe Net Zero Emissions by 2050 (NZE) Scenario and Announced Pledges Scenario (APS) presented in the

IEA’s World Energy Outlook (2024) were selected as credible and well-recognised decarbonisation scenarios.

Target setting methodSectoral decarbonisation approach aligned with 1.5°C to 1.7°C transition pathways.

In-scope customers (subject to meeting the criteria for In-scope lending or capital markets activity)

ANZ Division

Institutional customers allocated to ANZSIC codes 6301 - international sea transport, 6302 – coastal water

transport, or 6303 – inland water transport.

We exclude customers that predominately operate passenger vessels, vessel owners and lessors that don’t

operate vessels, companies in respect of which the predominant activity isn’t shipping (e.g., manufacturing

customers with a small number of vessels for moving their own products).

Customer in-scope emissions

• Scope 1 emissions from operation of vessels.

• We prioritise the use of CO

2

-e data inclusive of all relevant GHGs, where not available we use CO

2

emissions.

• We prioritise the use of company reported emissions on an operational control basis, where not available we use the equity

accounting approach.

In-scope lending and capital markets activity

Financed Where our EAD to the customer is greater than $10m.

FacilitatedWhere ANZ is a lead bookrunner for a syndicated loan to the customer or bond issued by the customer. No

financial threshold is applied. Note that financed emissions of the customer are not included in the pathway

unless the ‘financed’ requirement above is met.

Sector specific method

• Our original shipping absolute emissions reduction target had a 2022 baseline, as it was the most recent year prior to the first

reported year. We have maintained this baseline year for our new intensity target.

• For some customers to which our exposure is low and their emissions intensity data is not available we have used emission

intensity estimates based on the UK Department for Energy Security and Net Zero - Greenhouse gas reporting: conversion factors.

Data sourcesCustomer disclosures, Transition Pathways Initiative, UK Department for Energy Security and Net Zero -

Greenhouse gas reporting: conversion factors

Supporting metrics reported

• Absolute financed emissions and absolute facilitated emissions in-scope of the pathway (see page 75).

67

OverviewGovernanceStrategyRisk managementMetrics and targetsAppendices

Independent Assurance

Statement

Aluminium – targeting a 17-30% reduction in emissions intensity by 2030, from a 2021 baseline
Key changes

from 2024

• Inclusion of facilitated emissions

• Change from 1.5°C aligned target to 1.5°C – 1.75°C aligned target range to reflect the hard-to-abate

nature of the sector.

Target baseline 6.81 tCO₂-e/ t aluminium producedTarget in 2030 4.77-5.65 tCO₂-e/ t aluminium produced

Target metric

Portfolio weighted emissions intensity was chosen as the demand for the output of the sector is expected to

remain steady or increase under a 1.5°C aligned scenario.

Reference pathwayInternational Aluminium Institute (IAI) 1.5°C and International Aluminium Institute (IAI) B2Ds-Aligned (1.75°C)

scenarios were selected as credible and sector specific decarbonisation scenarios.

Target setting methodSectoral decarbonisation approach aligned with 1.5°C to 1.75°C transition pathways.

In-scope customers (subject to meeting the criteria for In-scope lending or capital markets activity)

Institutional customers allocated to ANZSIC codes 2721 – alumina production, or 2722 – aluminium smelting. ANZ also includes other

customers for which alumina production or aluminium smelting is a material part of their business (assessed using the customer’s

reported revenue). In some cases this includes customers not identified in ANZSIC codes 2721 and 2722 due to the diversified nature

of their business.

Customer in-scope emissions

• Scope 1 and Scope 2 (market-based) emissions from alumina production and aluminium smelting.

• We prioritise the use of CO₂-e data inclusive of all relevant GHGs, where not available we use CO₂ emissions.

• We prioritise the use of customer data based on the equity accounting approach, where not available we use the operational

control approach.

In-scope lending and capital markets activity

Financed

Where our EAD to the customer is greater than $1m. In calculating the EAD, ANZ excludes exposure related to

the trade and mining of raw inputs, e.g., bauxite.

For diversified customers included in the pathway which do not undertake alumina production or aluminium

smelting as a predominant activity, we adjust our general corporate financing EAD to the customer based on

the percentage revenue they derive from these activities for use in our calculations.

Facilitated

Where ANZ is a lead bookrunner for a syndicated loan to the customer or bond issued by the customer. No

financial threshold is applied. Note that financed emissions of the customer are not included in the pathway

unless the ‘financed’ requirement above is met.

Sector specific method

• A 2021 baseline was chosen due to data availability.

• Where customers purchase semi-finished products such as alumina, emissions associated with the production of this alumina are

not included within our emissions intensity target as these are considered our customers’ Scope 3 emissions.

• In line with aluminium industry practice, the total emissions intensity represents the combination of refining and smelting operations

indexed to metric tons of primary aluminium production. This is applied at a ratio of approximately 2.0 metric tons of alumina to 1.0

metric tons of smelted aluminium.

Data sourcesCustomer disclosures, Wood Mackenzie, Transition Pathways Initiative, International Aluminium Institute

Supporting metrics reported

• Absolute financed emissions and absolute facilitated emissions in-scope of the pathway (see page 75)

68ANZ 2025 Climate Report

Cement – targeting a 13-25% reduction in emissions intensity by 2030, from a 2021 baseline
Key changes

from 2024

• Update of reference scenario to use the 2024 World Energy Outlook

• Inclusion of facilitated emissions

• Change from 1.5°C aligned target to 1.5°C – 1.7°C aligned target range to reflect the hard-to-abate

nature of the sector.

Target baseline 0.66 tCO₂-e/ t cement produced

1

Target in 20300.50-0.58 tCO₂-e/ t cement produced

Target metric

Portfolio weighted emissions intensity was chosen as the demand for the output of the sector is expected to

remain steady or increase under a 1.5°C aligned scenario.

Reference pathwayThe Net Zero Emissions by 2050 (NZE) Scenario and Announced Pledges Scenario (APS) presented in the

IEA’s World Energy Outlook (2024) were selected as credible and well-recognised decarbonisation scenarios.

Target setting methodSectoral decarbonisation approach aligned with 1.5°C to 1.7°C transition pathways.

In-scope customers (subject to meeting the criteria for In-scope lending or capital markets activity)

Institutional customers allocated to ANZSIC code 2631 – cement and lime manufacturing. ANZ also includes other customers for

which cement and lime production from raw materials is a material part of their business (assessed using the customer’s reported

revenue). In some cases, this includes customers not allocated to ANZSIC code 2631 due to the diversified or vertically integrated

nature of their business. We exclude customers that do not produce cement from raw materials as their predominant activity, eg,

customers that import or purchase clinker.

Customer in-scope emissions

• Scope 1 and Scope 2 (market-based) emissions from cement manufacturing.

• We prioritise use of CO₂-e data inclusive of all relevant GHGs, where not available we use CO₂ emissions.

• We prioritise the use of customer data based on the equity accounting approach, where not available we use the operational

control approach.

In-scope lending and capital markets activity

Financed

Where our EAD to the customer is greater than $1m. In calculating the EAD, ANZ excludes exposures related

to trade or mining of raw inputs, (e.g., limestone).

For diversified customers included in the pathway that do not undertake cement or lime production as a

predominant activity, we adjust our general corporate financing EAD to the customer based on the

percentage revenue they derive from these activities for use in our calculations.

Facilitated

Where ANZ is a lead bookrunner for a syndicated loan to the customer or bond issued by the customer. No

financial threshold is applied. Note that financed emissions of the customer are not included in the pathway

unless the ‘financed’ requirement above is met.

Sector specific method

• A 2021 baseline was chosen due to data availability.

• Our cement emissions include emissions from combustion of waste derived fuels, considered ‘gross’ emissions by the industry.

Data sourcesCustomer disclosures, Asset Impact, I

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Data sourced from publicly available filings. Our datasets may not be complete. Automated analysis can produce errors. If you believe any data on this page is incorrect, please contact us at hello@nzxplorer.co.nz. For informational purposes only. Not investment advice.