Commerzbank AG (2 Apr 2025 – 31 Dec 2025)

Equator Principles at Commerzbank AG

In April 2025, Commerzbank officially adopted the Equator Principles to address environmental and social impacts in its project-related financing activities. The Equator Principles is part of Commerzbank’s well-established sustainability strategy and underscores the Bank’s commitment to responsible financing practices.
By adopting the Equator Principles, Commerzbank commits to conducting all project-related financing activities falling within the scope of the Equator Principles, in line with these ten principles and in a socially responsible and environmentally sustainable manner.

Roles and Responsibilities

In 2025 Commerzbank established an Equator Principles Office responsible for implementation of the Equator Principles across the bank, working in close cooperation with Commerzbank’s Global Sustainability and Risk teams.

The Equator Principles Office comprises a team of Sustainability Experts and centralises the necessary technical expertise for Equator Principles implementation. Day-to-day activities are also integrated into the responsibilities of front-office and transaction management staff in Commerzbank’s Corporate Clients business segment. The Equator Principles Office provides the necessary ongoing training and capacity-building on environmental and social risk management for relevant staff within the bank.

The governance and organizational setup are designed to ensure a coherent, expert-driven ap-proach to Equator Principles implementation. The EP Office responsibilities for Equator Principles relevant transactions include confirming E&S categorisation, undertaking due diligence and support for ongoing monitoring of implementation of Equator Principles commitments.

Equator Principles Embedded into Commerzbank Policies and Procedures

To ensure consistent implementation across Commerzbank, a binding and instructive Equator Principles Procedure is in place. This procedure describes the actions required throughout the lifecycle of a transaction to ensure implementation of the Equator Principles.

Each new transaction is screened to determine its relevance under the EP and, if within scope, as-signed a category (A, B, B* or C) based on potential environmental and social impacts. A detailed due diligence and a positive EP Vote from the EP office confirming alignment with EP is required for all but Category C transactions prior to signing of the financing agreement. EP-related covenants are integrated into financing agreement and monitored through the lifetime of the loan.

To support the relevant business units, implementation guidance, tools and training are integrated into established internal processes.

Reporting of Equator Principles Transactions

This implementation report represents the first qualitative report on EP implementation for the period April-December 2025. In line with Equator Principle Signatory requirements for full signatories, Commerzbank will in future submit an annual, institution-level report detailing its project financing activities under the Equator Principles.