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SRS 102-44 SRS 102-46 SRS 102-47 SRS 102-49 SRS 103-1 SRS 103-2 SRS 103-3

SRS 102-14 SRS 102-15 SRS 102-19 SRS 102-20 SRS 102-21 SRS 102-27 SRS 102-29 SRS 102-30 SRS 102-44 SRS 102-46 SRS 102-47 SRS 102-49 SRS 103-1 SRS 103-2 SRS 103-3

Sustainable management

At GFNorte we believe that as a financial institution we play a key role in the development of a prosperous Mexico. For this reason, we integrate sustainability into our operations as a guiding principle to maximize profitability and growth, protecting at all times our financial, social and environmental capital.

Our objective is to generate value for all stakeholders, so we focus our sustainability strategy on four fundamentals:

• Promotion of sustainable finance
• Transparency and accountability
• Minimization of our environmental footprint
• Implementation of actions for the community

The area responsible for implementing this strategy is Sustainability and Responsible Investment depending on the Executive Management of Investor Relations, Sustainabillity and Financial Intelligence who, in turn, depends on the department of Finance.

Sustainability and Responsible Investment is comprised of the Environmental Risk Management area in credit and investment activities and of Social Value. Environmental initiatives are administered in conjunction with the Directorate of Material Resources, with the objective of achieving a strong integration between operational processes and sustainability.

Sustainability model

We continually strive to improve the Group’s performance, so in 2017 we updated our sustainability model in order to provide a clearer representation of our strategic pillars as well as our works areas. In this way we express the commitments and actions we have defined to meet the Objectives of Sustainable Development (ODS) proposed by the United Nations.

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Priorities

In addition, we believe that as engines of economic development we have the responsibility of promoting attention in topics whose characteristics represent unprecedented challenges on a global scale and for Mexico. Thus, we have determined that human rights, climate change and biodiversity are priorities within our processes.

Human rights

Mexico is one of the countries with more human rights observers’ visits due to the number of cases involving serious and systemic violations of vulnerable peoples and communities. Aware of this situation, we diagnose, assess and ensure respect for human rights within our activities, in line with the guidelines of the UN’s Universal Declaration of Human Rights.

Climate change

Climate change is one of the 21^st century’s major problems. According to the World Bank, Mexico is one of the most vulnerable countries, so our territory, population and economy are exposed to adverse consequences. Therefore we consider essential to get involved in initiatives that identify opportunities and provide consistent and efficient solutions to the risks of climate change. Promoting interest in the transition to a low-carbon economy, market resilience, mitigation of the impact of natural disasters among other issues, is paramount to GFNorte.

Biodiversity

Mexico is the fourth most megadiverse country in the world; home to between 10% - 12% of all plant and animal species on the planet. However, more than half is under some category of risk due to anthropogenic causes. Therefore, it is essential that the activities and projects in which we intervene seek to protect animal and plant species, their habitats and ecosystems in order to preserve the balance and the natural wealth of our country.

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Stakeholders

Our stakeholders are a key factor in achieving our business objectives. We believe that it is essential to maintain a constant, open and transparent communication to fulfill our commitments and strengthen the ties that unite us.

The frequency of interactions depends on the channel established with each group; however, our approach focuses on satisfying their requirements.

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Materiality

In GFNorte we are interested to know our stakeholders’ concerns about sustainability. For this reason, we developed a matrix of materiality with internal and external feedback, that allows us to see the relevance of the different issues that we address in our activities.

From the results of this exercise, we prioritize the topics that are most relevant for all, in order to define and implement actions that contribute to improving our performance.

Sustainable development goals

We are working on various initiatives to align them to the objectives established in the 17 Sustainable Development Goals (SDG), of the United Nations Development Program (UNDP) 2030 Agenda.

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Social and environmental risk management

Recognizing the importance of respecting human rights, the care of natural resources and the mitigation of climate change, GFNorte is committed to prevent, minimize, restore and compensate for adverse impacts. For this reason, a vital aspect within our investment and financing operations is the management of social and environmental risks.

Responsible investment

Following our new model of sustainability we seek to implement different strategies to handle the potential environmental, social and governance (ESG) risks of our business. In this regard, in March 2017 we became the first financial group in Mexico to form part of the Principles for Responsible Investment (PRI). As signatories of this initiative, we are committed to integrating ESG criteria in our investment process to support decision-making and the transition to a low-carbon economy covering the needs of the current economic model, and in addition, generate a positive financial impact on our investment portfolio.

The PRI derive from the United Nations Environment Program Finance Initiative (UNEP-FI) and the Global Compact, in order to improve the ability of investors to fulfill commitments with beneficiaries, as well as to align investment activities with the broader interests of the society, following six principles:

• Incorporating ESG issues into our analysis and decision making processes in regard to investments.
• Be pioneers in incorporating ESG issues to our practices and property policies.
• Seek transparent reporting of ESG issues by the entities in which we invest.
• Promote the acceptance and implementation of the principles in the investment sector.
• Work together to improve our effectiveness in implementing the principles.
• Report our activity and progress in the implementation of the principles.

In this first year of adherence, we focused efforts on the fourth principle, and promoted the acceptance and the implementation of all the principles.

Additionally, in July 2017, GFNorte joined the group of 390 global investors representing $22 billion dollars in assets, so that the G20 leaders honor their commitments to the Paris Agreement.

The investors called on global leaders to:

• Continue to support and implement the Paris Agreement, as did the G7 leaders last June.
• Direct investments towards a low-carbon economy.
• Implement financial reporting that explicitly considers climatic aspects.

In October of the same year, in conjunction with the PRI, Ecovalores, Moody’s Investors Services and WBCSD, we held the Introduction to Responsible Investment and Roundtable events for the purpose of disseminating practices of responsible investment in Mexico, exploring the international scene and promoting adherence of more financial institutions to the PRI. We received the support and participation of 44 representatives from different financial institutions, private sector companies and CSOs.

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Social and Environmental Risk Analysis Process

Since 2012, we have used our own Social and Environmental Risk Management System (SEMS) to analyze social and environmental risks and impacts arising from activities that we fund.

The SEMS is based on the most important global risk management standards, such as the Performance Standards of the International Finance Corporation (IFC) and the Equator Principles.

In this way, we encourage that projects from our loan portfolio have the least possible impact, and are developed in a socially responsible manner and apply rigorous environmental practices.

The SEMS complies to a process of identification, categorization, evaluation and risk management that operates in parallel to credit procedures and which currently includes Corporate Banking, Business Banking and Structured Financing portfolios.

Throughout our analysis process we detect potential environmental and social risks of loans by using our exclusion list, classifying them according to their degree of impact and selecting those that meet the criteria to be evaluated. Thus, financing of more than $1 million dollars are examined under performance standards, and transactions whose amounts exceed $10 million dollars are analyzed under the Equator Principles.

During the evaluation of projects, we check that they comply with national legislation and international guidelines. In addition, we follow-up on higher risk projects with annual reviews of customers’ plans of action, provide periodic advice, monitor reputation and make field visits.

The area responsible for the SEMS is Socio-Environmental Risk (ARSA), that pertains to Sustainability and Responsible Investment and is comprised of a team of four people with training and experience in environmental and social issues such as:

• Social and environmental impacts
• Control and prevention of pollution
• Biodiversity
• Rural and indigenous communities
• Safety and health in the workplace
• Regulatory compliance
• Training

In addition, the SEMS is supported by the Sustainability Champions, a group of employees from the credit and business area who serve as a link between the ARSA and the bank’s business areas to promote the proper management of risks and impacts at a national level.

The following email address is at the disposition of stakeholders: sems@banorte.com

ANALYSIS PROCESS OF SOCIO-ENVIRONMENTAL RISKS, SEMS

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Analysis process

In 2017, we conducted a thorough review of the social and environmental risk analysis process to redefine operation procedures and criteria to increase efficiency.

• We internally updated the SEMS manual and its regulated process in 2015.
• We extended SEMS coverage for financings under $1 million dollars with high potential impact through the SEMS assessment.
• We updated our catalogue of Sectoral Activity Codes with 86 new codes for sustainable economic activities.

2017 SEMS Results 2017

Pursuant to our testing criteria, we produced 32 rigorous due diligences for projects classified as Category A and B. All Category C projects were managed through IFC recommendations to customers, based on sectoral environmental, health and safety guidelines. We issued a total of 361 recommendations, mostly for the construction, agribusiness and infrastructure sectors.

Similarly, in 2017 we consolidated 15 on-site visits of projects, in conjunction with the credit and business areas, which reflects the interest of our decision makers in risk management, as well as the ever more noticeable participation of the ARSA in business processes. The dominant sectors in project financing were construction, agribusiness and tourism.

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Training

The Credit and Business area plays a key role in environmental and social risk management for GFNorte. Therefore, raising awareness and developing expertise in these areas is essential. Addressing this need, Banorte’s own ARSA provided face-to-face training for analysts, executives and directors in person, online and by telephone. And for the second consecutive year, we have published the monthly informative newsletter SEMS in Brief, reaching 15,278 employees.

We trained 375 employees investing more than 571.75 hours in reviewing issues with:

• Sustainability in the financial sector
• Management of social and environmental risks and impacts
• Sustainable and responsible customers
• Reputational risk
• Sensitive sectors
• Functioning of SEMS
• Relevant environmental and social risk cases

Interaction with business areas

The Credit and Business area, as well as having a crucial participation in the social and environmental risk analysis process, is one of the major stakeholders concerns. Credit committees are responsible for the decision-making for financing, so effective communication of findings from the proceedings carried out is important.

With the support of our principal ally, the area of Selective Credit, we incorporated a section called Socio-Environmental risk within the Study of Credit for Financing, in order to report the results of this analysis, as well as the recommendations and conditions established by ARSA. With this, we improve interaction with decision-makers and guarantee the adequate and opportune flow of information.

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Financing of clean energies

GFNorte is actively involved in the financing of the generation of electrical energy from renewable sources since 2012. We have funded 11 projects with a capacity to generate 1,190 MW, of which 647 come from wind energy, 433 from photovoltaic energy and 110 from natural gas open cycle cogeneration plant. These projects represent a total investment of $1,087 million dollars, of which GFNorte has funded $479 million dollars, equivalent to 44% of the investment. Our strategy is to seize the opportunities that the energy reform has generated for the electricity market, for which we have consolidated our relationship with investors, the federal government and banking institutions, with a firm commitment to extend financing and investment in clean energies.

Green bonds

In 2017 Banobras placed the first Sustainable Bond in Latin America in the Mexican Stock Exchange (BMV) for Ps 10 billion, for projects that benefit the environment and society. Banorte, through the Investment Bank Casa de Bolsa Banorte Ixe, served as one of three intermediary underwriters, providing consultancy and distributing the instrument on the market with investors in general.

Without a doubt, this initiative demonstrates the joint commitment of the financial system to boost mitigation of climate change and improve the social wellbeing of Mexico.

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Participation in initiatives

As leaders in sustainability, at GFNorte we want to promote good practices for the financial sector, supporting projects and keep updated on issues of national and international relevance; therefore we are actively involved in various initiatives.

National initiatives

• Mexican Bank Association, (MBA)
  Since 2015 we form a part of the Social Responsibility, Financial Education and Sustainability committees, and are signatories to the Sustainability Protocol of the ABM. In 2017 we attended meetings on financial education, risk management systems and green bonds, among others.
• Mexican Alliance for Biodiversity and Business, AMEBIN
  AMEBIN is an initiative created in 2016 within the COP 13 Convention on Biological Diversity framework, in which large companies, financial institutions, civil society organizations and agencies of international cooperation promote action towards the conservation, sustainable use and restoration of biodiversity. Since then, we form a part of the private sector companies which include biodiversity in their objectives, forming part of the work groups of the Alliance and regularly attending the events that have been held.
• Mexico GHG Program (2013)
  For the fifth consecutive year, we have participated in the Mexico GHG program of SEMARNAT.
• Biodiversity and Business Agreement (2016)
  An initiative of the Convention on Biological Diversity and the Government of Mexico to draw attention of companies and financial institutions with regard to the importance of biodiversity, ecosystem services and the urgency of taking action to prevent losses and promote conservation. This initiative is aligned with Strategic Plan 2011-2020 and the Aichi Targets for biodiversity.

International initiatives

• Global Reporting Initiative, GRI (2009)
  The international tool to standardize reporting and communicate a company’s actions of sustainability according to economic, environmental and social issues.
• United Nations Global Compact (2011)
  The international initiative that encourages implementation of 10 universally accepted principles to promote corporate social responsibility.
• CDP (2011)
  The Carbon Disclosure Project promotes awareness of climate change in Mexico and Latin America. At GFNorte we report our performance relative to emissions, testifying to our actions against climate change in the areas of disclosure, transparency, management and leadership.
• Natural Capital Declaration (2012)
  The financial sector’s voluntary initiative created at the Rio Earth Summit + 20 which recognizes the role of natural resources in the economy through their integration into financial products and services.
• Equator Principles (2012)
  Standards within the financial sector to determine, assess and manage the environmental and social risks of financing. In October 2017, we attended the annual meeting of the Equator Principles, an event that unites all signatory members of the world in order to share experiences and promote the implementation of best risk management practices. The annual meeting took place in São Paulo, Brazil and also included the participation of the IFC’s Global Learning Community, created to provide advice and training in the application of Performance Standards.
• United Nations Environment Program – Finance Initiative UNEP FI (2013)
  An initiative that aims to identify, promote and encourage the adoption of best practices for sustainability at all levels of financial institution operations. We participated in the Regional Roundtable of Sustainable Finance for Latin America and the Caribbean organized by the UNEP FI, which took place in September 2017. We had the privilege to present our experience on the criteria that should be considered by a financial institution to integrate sustainability into its processes.
• Objectives of Sustainable Development, ODS (2015)
  A global initiative proposed by the United Nations and with a 2030 objective, comprising a set of 17 goals to eliminate the problems facing humanity in environmental, social and governance matters, seeking to ensure prosperity by developing sustainable.
• Principles of Responsible Investment, PRI (2017)
  An initiative that has six principles that seek to improve the capacity to meet commitments with beneficiaries and align investment activities with ESG topics.

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Adherence to national and international indexes

The depth and scope of the implementation and disclosure of our practices has positioned us as a leader in sustainability in Latin America, which is why we have been honored with multiple awards that have placed us in different national and international indexes.

• IPC Sustentable (2011),
  Mexican Stock Exchange (BMV): Comprised of 30 leading Mexican companies.
• Dow Jones Sustainability Emerging Markets Index (2013),
  New York Stock Exchange: Comprised of 80 companies (12 Mexican), 20 emerging markets based on long-term economic, environmental and social criteria.
• Euronext Vigeo-Eiris Emerging Markets Indexes (2016),
  The leading European stock market operator: recognizes 70 companies from emerging countries (four Mexican) with the most advanced practices in sustainability.
• FTSE4Good Emerging Markets Indexes (2016),
  London Stock Exchange: Comprised of 508 companies (24 Mexican), evaluates actions on issues of climate change, labor standards, and risk management, among others.
• Dow Jones Sustainability MILA Pacific Alliance Index (2017),
  New York Stock Exchange: Comprised of 42 companies from Chile, Colombia, Mexico and Peru (eight Mexican), with the highest scores in environmental, social and corporate governance practices.
• Bloomberg Financial Services Gender-Equality Index (2017), New York Stock Exchange: Comprised of 54 companies of America (two Mexican), providing analysis of their commitment to gender equality in the workplace.
• Index Americas (2017)
  The first sustainability index created by a multilateral development bank (Inter-American Development Bank - BID and BID Invest): formed by 100 companies operating in Latin America and the Caribbean.

Acknowledgements

We obtained the following awards in 2017:

• Leading Company in Sustainability in Mexico, Sustainable Leaders Agenda 2020 ALAS20.
• 2^nd Place in Leading Company in Corporate Governance, ALAS20.
• Best Corporate Governance, Ethical Boardroom magazine.
• Award for Carlos Hank Gonzalez, Chairman of the Board of Directors, as Director of a Leading Institution in Responsible Investment for integrating sustainability into the Group’s business and the principles of responsible investment into the operations of the Afore XXI Banorte, ALAS20.
• Socially Responsible Company, Mexican Philanthropy Center (CEMEFI).
• GEI2 Award
  Recognizing our commitment to the evaluation, accounting and reporting of emissions, awarded by the Mexico GHG program of SEMARNAT.
• Award for Leadership in the CDP Latin America Climate Change Program
  For the third consecutive year, we were distinguished by CDP, obtaining rating of A- in the 2017 CDP Climate Change questionnaire.