DFCC Bank PLC | Annual Report 2025

GRI

3-1

DFCC Bank’s materiality approach is dynamic and grounded in double materiality assessing both our outward impacts on the economy, society, and the environment (impact materiality) and the way these topics affect our enterprise value, resilience, and long-term performance (financial materiality). Our assessment reflects the Bank’s strategic context, stakeholder priorities, and risk/opportunity outlook. It is aligned with Integrated Reporting principles, GRI topic families, and mandatory sustainability disclosure standards such as SLFRS S1 and S2.

Materiality Determination Process

During the year, the Bank carried out a refreshed materiality assessment to ensure our sustainability priorities continue to reflect stakeholder expectations, emerging regulatory requirements and the rapidly evolving operating environment. The process considered internal strategic priorities, sector-wide risks and opportunities, peer practices as well as local and global sustainability frameworks. Stakeholder insights were captured through sharing a structured questionnaire among stakeholders supported by direct engagements, customer interactions, and ongoing dialogue with regulators, employees, suppliers, and community.

This materiality assessment resulted in the identification and validation of five key material themes and a refined set of 11 material sub-topics which are most relevant to the DFCC Bank’s value creation over short, medium and long term. These material topics represent areas with the greatest significance from both an impact materiality perspective reflecting how it impacts on stakeholders and environment; and a financial materiality perspective reflecting its influence on the Bank’s resilience, risk profile, performance and ability to create value.

Following this materiality assessment, the Bank applied a structured five step, materiality determination process to ensure that each material topic is accurately prioritised, governed, and embedded into decision-making and reporting frameworks.

Potential sustainability topics were identified through regulatory developments, industry standards, peer benchmarking, DFCC’s strategic direction, internal policies, and continuous stakeholder engagement.

Each potential topic was assessed for:

Impact materiality: the scale, likelihood, and nature of DFCC’s actual or potential impacts on people, communities, and the environment.

Financial materiality: the influence on DFCC’s resilience, risk exposure, credit quality, operational continuity, and long‑term value creation.

Based on stakeholder significance and strategic relevance, the most material topics were prioritised and refined. The final list of themes and sub‑topics was validated by senior management and relevant Board‑level Committees to ensure alignment with risk appetite, strategy, and regulatory expectations.

Material topics were incorporated into the Bank’s strategic pillars, integrated risk management, sustainability initiatives, and performance scorecards. Progress is monitored throughout the year through management of dashboards, KPIs, KRIs, and periodic Board reporting.

The validated material themes and sub‑topics are disclosed in DFCC’s Integrated Annual Report, sustainability‑related reporting and corporate website.

GRI

3-2

Material theme		Sub-topics	Primary stakeholders	GRI aligned material topic addressed	Reference to management approach
1.	Resilient and responsible banking	Resilient business	Customers, Investors, Regulator	GRI 201 – Economic performance GRI 205 – Anti–corruption GRI 207 – Tax	Page 61
	Resilient and responsible banking	Brand and reputation	Customers, Investors, Community	GRI 417 – Marketing and labelling	Page 61
2.	Secure and Innovative digital transformation	Technological advancements	Customers, Employees, Fintech partnerships	GRI 418 – Customer privacy GRI 404 – Training and education	Page 62
		Data privacy and cybersecurity	Customers, Regulator	GRI 418 – Customer Privacy	Page 62
		Developing sustainable financial products and services	Customers, Investors, Community, Development partners	GRI 203 – Indirect economic impacts	Page 62
3.	Climate action and ecological enhancement	Climate action	Regulator, Investors, Community, Industry associations	GRI 201 – Economic Performance GRI 302 – Energy GRI 305 – Emissions	Page 63
	Climate action and ecological enhancement	Biodiversity	Regulator, Investors, Community, Industry, associations	GRI 201 – Economic Performance GRI 302 – Energy GRI 305 – Emissions	Page 63
4.	Ethical conduct and compliance	Ethical, transparent and accountable business	Regulator, Customers, Employees	GRI 205 – Anti–corruption GRI 207 – Tax	Page 64
		Risk Management and Compliance	Regulator, Board committees	GRI 205 – Anti–corruption GRI 207 – Tax	Page 64
		Sustainable procurement and resource efficiency	Suppliers and Service providers		Page 64
		ESG Integration into business operations	Employees, Customers, Regulator, Investors		Page 64
5.	Financial Inclusion and Socio–economic Stability	Inclusive economic growth	Community, Industry associations, Regulator, Customers	GRI 201 – Economic performance GRI 203 – Indirect economic impacts	Page 65
		Talent management	Employees	GRI 202 – Market presence GRI 401 – Employment GRI 404 – Training and Education GRI 405 – Diversity and Equal opportunity GRI 406 – Non–Discrimination	Page 65
		Women empowerment	Community, Customers
		Diversity, Equity and Inclusion (DEI)	Employees, Customers, Community
		Customer centricity	Customers	GRI 418 – Customer privacy	Page 65
		Resilient communities	Community, Industry associations	GRI 203 – Indirect economic impacts GRI 413 – Local communities	Page 65

Mapping to DFCC Bank's EESG Perspective

Economic

Environmental

Social

Governance

Inclusive Visual Materiality Matrix

This matrix illustrates the relative positioning of DFCC’s material themes across two lenses: (i) Influence on Stakeholder Decisions; and (ii) Significance of Bank’s Economic, Environmental, Social and Governance (EESG) impacts.

Changes to Materiality

During the year, DFCC Bank undertook a refreshed and more structured materiality assessment, which resulted in several refinements to our material topics. Changes in the external environment such as evolving economic conditions, heightened climate-related expectations, digital transformation trends, and stronger governance requirements prompted a reassessment of how issues interact and influence long term value creation. Through this enhanced double materiality lens, several related matters were consolidated, clarified, or repositioned to better reflect strategic relevance and stakeholder expectations. As a result, the Bank’s updated materiality table now presents five overarching material themes and seventeen streamlined sub topics, replacing a broader set of topics previously reported. This refinement ensures clearer alignment to DFCC’s strategic pillars, strengthens reporting transparency, and more accurately captures the sustainability issues that are most significant to DFCC’s performance, resilience, and stakeholder impact.

Embedding Material Themes into Our Management Approach

The following sections outline DFCC Bank’s Management Approach to each material theme detailing how the Bank governs, manages and monitors associated topics to ensure meaningful progress, informed decision-making and transparent reporting.

Resilient and
Responsible Banking

Resilient and Responsible Banking ensures that DFCC Bank maintains a strong financial fundamental, transparent conduct and stakeholder trust through its journey. It integrates robust risk culture, sound capital/liquidity management and proactive reputation stewardship across the Bank.

Resilient Business

Brand and Reputation

Management Approach

Safeguarding capital, liquidity, and portfolio quality to withstand shocks and support sustainable growth.

Strengthening stakeholder confidence through transparent disclosures, responsible conduct, and consistent service.

Why this is Material

Financial resilience and reputation are foundational to DFCC Bank's ability to serve customers, access funding, and support the real economy. In a dynamic environment, disciplined risk management and clear communications reduce volatility, protect enterprise value, and anchor long-term trust among customers, investors, regulators, and communities.

How it helps deliver our Strategy

Customer Centric Excellence:

Stable, trusted platform for consistent service and fair outcomes

Digital Innovation
and Transformation:

Confidence to invest in secure, modern systems

Empowered Talent and Culture:

Build a strong culture of accountability by ensuring employees understand and follow clear ethical standards

Strategic Growth and
Market Expansion:

Capital strength enables strategic growth

Operational Efficiency
and Agility:

Streamlined processes reduce turnaround and cost

Sustainable Impact
and Governance:

Transparent, ethical practices reinforce good governance

Associated Risks and Opportunities

Related Risks

Credit Risk
Market Risk
Liquidity Risk

Related Opportunities

Lower cost of capital
Stronger investor confidence
Strategic partnerships

Actions (Detailed management approach)

Reference to Capital Reports

Financial Capital (pages 87 to 93)

Manufactured Capital (pages 98 to 100)

Intellectual Capital (pages 101 to 104)

Human Capital (pages 105 to 119)

Social and Relationship Capital
(pages 120 to 136)

Alignment with SDGs

Secure and Innovative
Digital Transformation

Secure and Innovative Digital Transformation strengthens DFCC Bank's digital backbone, protects customer data, and scales inclusive, sustainable financial solutions through safe, user-centred innovation.

Technological Advancements

Data Privacy and Cybersecurity

Developing Sustainable Financial Products and Services

Management Approach

Modernising core platforms and channels for reliability, speed, and agility.

Protecting personal and transactional data through robust controls and response readiness.

Embedding sustainability attributes and access features into digital offerings.