Allied Irish Banks (AIB) Group

Reference: pages 51-53

AIB's sustainability governance framework provides Board and Executive oversight of the Group's sustainability strategy and the management of impacts, risks and opportunities. The AIB Group Board is responsible for promoting long-term sustainable performance and approves the Group's strategy, sustainability targets and Code of Conduct; at 31 December 2024 it comprised the Chair (deemed independent on appointment), twelve Independent Non-Executive Directors and two Executive Directors, being the Chief Executive Officer and the Chief Financial Officer. The Board is supported by several committees, including the Board Audit Committee, Board Risk Committee, Sustainable Business Advisory Committee, Technology and Data Advisory Committee, Nomination and Corporate Governance Committee and Remuneration Committee. The AIB Group Executive Committee (ExCo) is led by the CEO and includes the managing directors of the four core operating segments, and it operates through subcommittees such as the Group Sustainability Committee (chaired by the Chief Sustainability Officer), Group Conduct Committee, Group Risk Committee, Group Disclosure Committee and the Data, Analytics and Technology Committee. Board and ExCo members hold specialised sustainability knowledge, and each Board member's skills are evaluated against core skills including Climate & Environmental (Sustainability) and Customer & Conduct, which covers business conduct. Throughout 2024 several ESG related training events were delivered by internal and external subject matter experts on topics including emerging practices, data quality for climate related disclosures and CSRD.

Reference: page 52

AIB's Board Committees are regularly informed by Management and ExCo subcommittees to support their oversight and management responsibilities for the Group's material impacts, risks and opportunities. Sustainability disclosures are shared with the Sustainable Business Advisory Committee for information and feedback, and the Group monitors progress towards Board approved sustainability targets through a Climate & Environment Dashboard reported quarterly to the Group Sustainability Committee and SBAC. During 2024 the Board, ExCo and their Committees discussed a broad range of sustainability matters, including sustainability transformation and targets, mobilisation of CSRD and readiness for implementation, a refresh of the Double Materiality Assessment, development of the Social Agenda including vulnerable customers, ESG propositions, diversity and inclusion, and AIB's environmental footprints. Further matters covered included regulatory engagement and expectations, sustainability reporting, Board succession planning and composition, stakeholder engagement, whistleblowing and the Code of Conduct, climate and environmental risk, conduct and culture risk, cyber risk, corporate governance and variable remuneration. Opportunities are considered as part of strategic planning, and SBAC ensures that the DMA results frame the approach to developing the sustainability strategy.

Reference: page 53

AIB operates a short-term variable remuneration scheme that focuses on delivery against Group performance measures and applies to all employees. The scheme comprises three financial measures, accounting for 60% of the award calculation, and three non financial measures accounting for the remaining 40%. The non financial measures relate to gender balance, customer satisfaction and green finance, each carrying an equal weighting of 13.33%, underlining the importance placed on the ESG and customer agendas. Currently, performance is not assessed against GHG emission reduction targets. The scheme has a Group Profit underpin, a minimum level of profit that must be achieved to trigger an award, and this underpin was achieved for the 2024 performance year. The variable remuneration scheme is a component of the Remuneration Policy and its terms are approved by the Remuneration Committee.

Reference: pages 52, 114

In addition to policies, actions, metrics and targets, AIB manages and monitors its material impacts and risks through enhanced due diligence processes, demonstrating its commitment to identifying, preventing, mitigating and accounting for the ESG related impacts of its business on people and the environment. Controls include extensive due diligence assessments of clients and other business partners; for example, as part of its Climate & Environmental Risk due diligence, an ESG Questionnaire continues to be used in credit applications for borrowers identified as carrying increased transitional, environmental, social or governance related risk. AIB notes that the ESRS do not impose any conduct requirements in relation to due diligence or require any modification to its governance. The due diligence table in Appendix 1 on page 114 maps where the main elements and steps of the process are reflected in the sustainability statement, covering embedding due diligence in governance, strategy and business model; engaging with affected stakeholders in all key steps; identifying and assessing adverse impacts; taking action to address those adverse impacts; and tracking the effectiveness of these efforts and communicating.

Reference: page 53

AIB's governance approach to sustainability reporting is aligned with financial reporting and is integrated within its internal control system. It is governed by the Sustainability Disclosure Policy, which applies to all material sustainability disclosures of the Group and all in scope entities. On an annual basis the Chief Strategy and Sustainability Officer, as sponsor of the policy, recommends the sustainability disclosures for review by the Group Sustainability Committee, after which they are reviewed by the Group Disclosure Committee and the Board Audit Committee, with the Board having final approval authority and SBAC kept informed. Risks are identified through a combination of risk assessment methodologies and internal controls in line with the Three Lines of Defence model; the key risk identified relates to regulatory compliance, while other risks relate to inaccurate disclosures, lack of awareness of reporting regulatory requirements, green washing, regulatory censure and reputational damage. These risks are mitigated by the Sustainability Disclosure Policy together with the internal control framework and minimum control standard. Any findings or issues identified during the assessment of the reporting process are captured and reported to the BAC and are tracked and monitored until closure by the relevant First Line Assurance teams.

Reference: pages 46-50

AIB's sustainability strategy is integrated with its overall Group strategy, with Sustainable Communities as a core pillar, and aligns with three strategic areas of focus: serving customers, greening the business, and operational efficiency and resilience. As a financial institution, AIB's ambition is for its own operations to be Net Zero by 2030 and for its lending portfolio to be Net Zero by 2050, supported by an ambition to source 100% of electricity from certified renewable energy by 2030 and a target for 70% of all new lending to be green and transition by 2030. The Group operates predominantly in Ireland and the UK through four operating segments: Retail Banking, Capital Markets, Climate Capital and AIB UK, and has established a €30bn Climate Action Fund to support strategy implementation. AIB's value chain encompasses upstream, own operations and downstream activities and relationships, with key stakeholder groups including investors, suppliers, regulators, its own workforce, customers and the wider community, grouped in line with the ESRS as affected stakeholders and users of the sustainability statement. Its value creation model relies on inputs such as €110bn of customer accounts, 10,469 full time equivalent employees and key intangible resources including brand reputation, employee expertise and technology innovation. AIB applied the phase-in provisions for SBM-1 paragraphs 40 b and 40 c.

Reference: page 49

Effective, systematic and continuous stakeholder engagement is a key focus of AIB's approach to sustainability, and stakeholders' views, interests and expectations are integral to its strategy and business model and are considered by the Board in all its deliberations. Throughout 2024 the Board continued engaging directly with key stakeholders, including colleagues, customers, suppliers, investors, regulators and the wider society and community, and received management reports and updates on stakeholder matters. The Group promotes a culture of accountability and inclusivity, conducts appropriate checks as part of due diligence and onboarding, and ensures channels for all stakeholders to raise concerns, including whistleblowing channels; a new Whistleblowing Policy was approved by the Group Board Audit Committee in November 2024 and became effective from January 2025, replacing the retired Speak Up Policy. AIB's respect for human rights is embedded in its Human Rights Commitment, shaped by the UN Guiding Principles on Business and Human Rights and operating alongside the Code of Conduct and Responsible Supplier Code. In 2023, as part of the DMA process, AIB engaged with its key stakeholders and the outcome was communicated to the respective ExCo and Board Committees. Information on key engagement outcomes and how they informed the Group's strategic decisions is included in the Section 172 Statement and Stakeholder Engagement in the Governance Report.

Reference: pages 58-61

AIB's Double Materiality Assessment identified seven material topics and their corresponding impacts, risks and opportunities, and this section explains how they relate to its strategy and business model. From the perspective of its own operations, AIB's most material impacts relate to its own workforce, while through its business model the most significant impacts relate to retail and corporate lending activities, influencing customers' financial wellbeing and, through financed emissions, contributing to climate change. The Group's Material Risk Assessment process has identified Climate & Environmental Risk as a principal risk, and AIB has also identified social and governance related risks, including those linked to cyber security and data protection and to attracting and retaining talent. AIB's material opportunities are mainly linked to financing the transition to a sustainable future, including the full mobilisation in 2024 of its Climate Capital segment, which lends to large scale renewable and infrastructure projects across Ireland, the UK, Europe and North America. Impacts are assessed across short, medium and long-term time horizons, with actual impacts generally occurring during the reporting period. For the climate change topic, which was deemed material from a financial materiality perspective, new green and transition lending in 2024 was €5.1bn, bringing the total drawdown of the Climate Action Fund to €16.6bn. AIB applied the phase-in provision for SBM-3 paragraph 48 e.

Reference: pages 54-57

The Double Materiality Assessment is the starting point for preparing AIB's sustainability statement, assessing material sustainability matters from both an impact materiality and a financial materiality perspective. AIB carried out its DMA in 2023 and reviewed it in 2024, concluding that the foundational work continues to provide a reliable basis; the 2024 review added 'Own workforce (Equal treatment & opportunities for all)' as a material topic and merged certain environmental and social topics. In line with the ESRS, AIB designed a five step process: business context; identification of the list of sustainability matters; assessing impact materiality; assessing financial materiality; and validation and sign off. Step 2 examined inputs such as peers and competitors, ESG focused regulations, ESG frameworks, media, industry publications and company documents, resulting in a list of 24 preliminary material sustainability topics. Impacts were assessed on scale, scope, irremediable character and likelihood, while risks and opportunities were assessed on the magnitude of their financial effect and likelihood, using a scoring scale of 0 to 5 ranging from not material to critical, with the materiality threshold set to include topics ranked from the high end of important up to critical. Stakeholder engagement involved internal parties including the Board and ExCo and external parties through surveys and focus groups, with 1,201 customers responding to the survey, and the results were consolidated using weighted averages across stakeholder groups. The DMA connects to AIB's annual Material Risk Assessment and Risk and Control Assessment, and the results were validated and ultimately noted by SBAC, BAC and the Board.

Reference: pages 113-115

Appendix 1 of AIB's sustainability statement lists all of the Disclosure Requirements in ESRS 2 and in the topical standards, both mandatory and material to AIB, and indicates through index tables where each DR can be found, including information incorporated by reference to other sections of the management's report and where phase-in provisions or a not material determination have been applied. Following completion of the DMA, AIB conducted a materiality of information assessment for each ESRS to determine the material DR and data points. AIB's material topics map to five ESRS: Climate Change (E1), Own Workforce (S1), Affected Communities (S3), Consumers and end-users (S4) and Business Conduct (G1). AIB omitted all Disclosure Requirements in the topical standards E2 (Pollution), E3 (Water and marine resources), E4 (Biodiversity and ecosystems), E5 (Resource use and circular economy) and S2 (Workers in the value chain), as these topics were below its materiality thresholds, except for the DR related to IRO-1 in ESRS 2. For six of its material topics, with the exception of 'Own workforce (Equal treatment and opportunities for all)', entity-specific disclosures in relation to metrics were included to support disclosure of material information.

Reference: pages 66-67

AIB does not currently have a standalone Transition Plan published, but states it is mapping and maturing one in line with industry best practice, regulatory guidance and national plans, and expects to publish it within 12 months. The plan supports AIB's decarbonisation ambition to be Net Zero in its own operations by 2030 and Net Zero in its customer lending portfolio by 2050, aligned with the Paris Agreement aim of limiting global warming to 1.5C. To steer the business, AIB has SBTi-validated financed emissions targets covering 75% of the 2021 loan book and was the first bank in the world to receive an SBTi-approved maintenance target for electricity generation in 2023. Own operations emissions are measured and reported according to the Greenhouse Gas Protocol for Scope 1 and Scope 2. The transition is supported by two primary frameworks, the Sustainable Lending Framework and the Green Bond Framework, along with the C&E Risk Policy, Group Energy Policy and Group Environmental Policy, and an excluded activities list in place since 2020. The €30bn Climate Action Fund and the Climate Capital segment channel finance towards renewable power generation and sustainable infrastructure. AIB states it does not currently use GHG removals or carbon credits, or any form of internal carbon pricing.

Reference: pages 70, 75

For loan book decarbonisation, AIB has three Board-approved policies and frameworks: the C&E Risk Policy, the Sustainable Lending Framework (SLF) and the Green Bond Framework (GBF). The C&E Risk Policy is approved by the GRC and defines how AIB identifies, manages, mitigates and measures physical and transition C&E risk, while the SLF and GBF are approved by the GSC with regular reporting to ExCo, SBAC and the Board. The SLF was developed and implemented in July 2021 to comply with the EBA guidelines on Loan Origination and Monitoring and aims to align to the greatest extent possible with the technical criteria of the EU Taxonomy, supporting the ambition that 70% of new lending should be green or transition by 2030. The GBF is based on the ICMA Green Bond Principles of 2021, including the updated Appendix I of June 2022, and is publicly available on AIB's website. For its own operations, AIB relies on two primary policies: the Group Energy Policy, implemented through the ISO 50001 Energy Management Standard, and the Group Environmental Policy, which takes environmental action in accordance with ISO 14001. The Chief Operating Officer is accountable for implementation of these operational policies, which are publicly available on AIB's website.

Reference: pages 70-72, 75

To achieve its green and transition lending targets, AIB offers a suite of green products including Green Mortgages across AIB, EBS and Haven for homes with a BER between A1 and B3, the AIB Green Personal Loan, participation in the Government and SBCI Home Energy Upgrade Loan Scheme, and the SBCI Growth and Sustainability Loan Scheme for businesses and agriculture. In 2024 AIB launched new Transition Finance Guidance to support corporate customers, and its Climate Capital segment became fully operational, centralising green energy activities and helping deploy the €30bn Climate Action Fund towards renewable energy assets across Ireland, the UK, the EU and North America. AIB provided €11.6bn of green lending between 2019 and 2023 and a further €5.1bn in 2024. On education and collaboration, AIB established a Sustainability Academy, developed the 'SME Steps to Sustainability' resource, announced a €20m investment in sustainability education and research (€10m for an AIB Trinity Climate Hub and €10m as a founding partner of Innovate for Ireland), and joined voluntary organisations including CDP, SBTi, the Net Zero Banking Alliance, UN Global Compact and WBCSD. For its own operations, AIB entered a VPPA with NTR plc to build two new solar farms in Co. Wexford, the first of which began energisation in February 2024, and in 2024 84% of AIB's own electrical energy needs was produced from these solar farms. AIB also runs a Greener Branches Refurbishment programme to improve the energy efficiency of its branch and office buildings.

Reference: pages 72-75

AIB's headline targets are to reach Net Zero across its own operations by 2030 and in its customer lending portfolio by 2050, with an ambition for 70% of new customer lending to be green or transition by 2030 (35% achieved in 2024 from a 2019 baseline of 10%). Using the SBTi Sectoral Decarbonisation Approach (SDA) and Portfolio Coverage Approach (PCA), AIB set financed emissions targets from a 2021 baseline for its three most material sectors and a Corporate Portfolio Coverage target, all validated by the SBTi in 2023 and covering 75% of the loan book. These sector targets are a 58% reduction in Residential Mortgages emissions intensity by 2030, a 67% reduction in Commercial Real Estate emissions intensity by 2030, maintaining Electricity Generation at or below 21 gCO2e/kWh, and increasing Corporate Portfolio Coverage from 12% to 54% by 2030 (27% reached in 2024). In 2024 the physical emissions intensity of the Residential Mortgages portfolio decreased by approximately 5.6% versus the 2021 baseline, the CRE portfolio reduced by approximately 8% against a restated baseline, and Electricity Generation stood at 0.97 gCO2e/kWh. Targets and baseline emissions were set using Partnership for Carbon Accounting Financials (PCAF) GHG guidance, and under the SDA methodology AIB aims to roughly halve absolute emissions by 2030. For its own operations, AIB has an SBTi-validated interim target to reduce absolute Scope 1 GHG emissions by 34% by 2027 from a 2019 base year of 4,784 tCO2e, with a cumulative reduction of 40% achieved by 2024, and a Scope 2 target to increase annual sourcing of renewable electricity to 100% by 2030 from a 2019 baseline of 1%.

Reference: pages 76, 79

AIB's total energy consumption was 33,028 MWh in 2024, down from 37,323 MWh in 2023 (reported on a Net Calorific Value basis, consumption was 32,209 MWh in 2024). The mix was split roughly evenly between fossil and renewable sources: total fossil energy consumption was 16,491 MWh (a 50% share) and total renewable energy consumption was 16,537 MWh (a 50% share), with no consumption from nuclear sources. Within fossil sources, natural gas accounted for 8,408 MWh and crude oil and petroleum products for 5,034 MWh. On the renewable side, direct procurement via the VPPA supplied 16,360 MWh in 2024, up from zero in 2023, reflecting the activation of the two Co. Wexford solar farms. AIB states it does not operate within a high-climate-impact sector as defined by ESRS, so this has not affected its energy intensity calculations. FY2024 data includes nine months of actual data from January to September, with KPIs used to estimate the final three months, whereas FY2023 data represents full-year actuals.

Reference: pages 77-79

AIB reports GHG emissions under the Greenhouse Gas Protocol, with a 2019 base year for Scope 1 and Scope 2 and a 2021 base year for Scope 3 financed emissions. Gross Scope 1 GHG emissions were 2,875 tCO2e in 2024 (2,886 in 2023, against a 2019 baseline of 4,784 tCO2e). Gross location-based Scope 2 emissions were 4,391 tCO2e in 2024 (4,948 in 2023, baseline 10,025), while gross market-based Scope 2 emissions were 813 tCO2e in 2024 (536 in 2023). Scope 3 Category 15 (financed emissions) were 1,067,519 tCO2e in 2024, up 31% from 813,528 in 2023, against a 2021 baseline of 2,570,000 tCO2e, and account for the majority of total emissions. Total GHG emissions were 1,074,786 tCO2e on a location basis and 1,071,207 tCO2e on a market basis in 2024. Financed emissions are accounted for using the Partnership for Carbon Accounting Financials (PCAF) Part A Standard and cover the three most material sectors (Residential Mortgages, Commercial Real Estate and Electricity Generation), with other Scope 3 categories accounting for less than 1% of total Scope 3 emissions and deemed not significant. AIB applies a phase-in provision for Scope 3 Category 15 absolute value emissions while adopting transitional measures for value chain information.

Reference: pages 90, 93, 95

AIB's own workforce policies apply to everyone directly employed by AIB, with Payzone and Goodbody generally governed by their own subsidiary policies. The Inclusion and Diversity (I&D) Code promotes equal treatment and opportunities for all and sets out the grounds of discrimination it covers, including race, religion or belief, age, disability, gender and gender reassignment, sexual orientation, marriage or civil partnership, pregnancy or maternity, family status and membership of the Travelling Community. Related policies include the Family Leave Handbook and Carer's Policy, which cover maternity, adoptive, surrogacy, paternity, parent's and fertility leave, and the Anti-Bullying and Harassment Policy, for which the Chief People Officer (CPO) is ultimately responsible. On training and skills, AIB maintains an Education Policy sponsored at ExCo level by the CPO and a People Risk Policy for which the CPO is the 1LOD sponsor and the CRO the 2LOD sponsor. AIB's approach to human rights is underpinned by its Human Rights Commitment, which is available on its website, was shaped by the United Nations Guiding Principles on Business and Human Rights, and was introduced in 2021 when it was approved by ExCo and reviewed by SBAC and the Board. The Code of Conduct is supported by the Whistleblowing Policy and Grievance Policy, and most policies are published on the intranet or website.

Reference: pages 96, 97

AIB has several initiatives for listening to its people and engaging them on material impacts. It checks in with both employees and contractors twice a year through AIB Engage surveys, which are short, focused online surveys open to employees and contractors at all levels, with the CPO overseeing implementation. In 2024 the key issues explored were innovation and creating the time and space to connect with each other and with the Group's purpose and strategy. The surveys received a total of 16,023 employee responses and 30,598 comments and suggestions from the own workforce, and the resulting insights form the basis of action plans implemented in the following months. AIB also operates several Employee Resource Groups (ERGs), known as Inclusion Networks, which represent colleagues who may be at risk of marginalisation or bias, meet at least quarterly, and offer support devised and deployed by employees with senior management sponsorship. Engagement on data protection impacts is supported by local Data Protection Officers in Ireland and the UK, and an Employee Data Protection Notice is shared with employees during onboarding.

Reference: page 97

AIB provides several channels for its internal stakeholders to raise concerns. Under the Whistleblowing Policy, colleagues are encouraged to Speak Up about actual or suspected wrongdoing, either with their People Leader in the first instance or through confidential channels such as the AIB Integrity Line, a secure web-based system hosted by an independent third party, and the policy applies to all those working in or for AIB Group in any jurisdiction. The effectiveness of the whistleblowing policy and processes is monitored and reviewed by BAC. Directly employed colleagues can also raise personal grievances, employment-related concerns and bullying and harassment complaints through the Grievance Policy and the Anti-Bullying and Harassment Policy, with the CPO ultimately responsible for the Grievance Policy and the Workforce Performance Team responsible for monitoring and tracking formal grievance complaints. To support effectiveness, formal grievances are recorded on a personal case register, a dedicated Grievance and Disciplinary decision-maker panel supports independence, all appeals are heard by the CEO or an appointed nominee, and a dedicated case manager oversees that fair procedures are followed. All issues raised are treated promptly, confidentially and with professionalism.

Reference: pages 90-91, 93

AIB took a range of actions on material impacts affecting its own workforce in 2024, organised around inclusion and diversity and around learning and development. To cultivate universal inclusion it delivered mandatory online I&D training for all employees, provided specialist I&D training for ExCo and their senior management teams supported by coaching, and held its third annual Universal Inclusion Campaign, overseen by an Inclusion and Diversity Council chaired by an ExCo member. Its leadership programme had 53% female participation in 2024 and includes an inclusive leadership module, and AIB conducted a Women in Leadership diagnostic that produced a roadmap of short, medium and long-term actions. A range of employee inclusion networks, including the Women's+, Origins+, Pride+, Abilities+ and Life and Family+ Networks, supported colleagues, and the 2024 Mentor Her programme featured 194 mentors and mentees. On family leave, when the Irish Government increased statutory parent's leave from seven to nine weeks per parent in August 2024, AIB topped this up to full pay for employees in both ROI and the UK. On training and skills development, AIB supports further education by covering eligible fees and study leave, offers CPD Certificates accredited by the Institute of Bankers, provides an AIB Sustainability Academy, and expanded its Invest in You career development celebration from once a year to three times a year.

Reference: pages 91, 93

AIB has set diversity and training targets related to its own workforce. As an early signatory of Ireland's first Women in Finance Charter, it targets between 40% and 60% female representation in ExCo and management, and it maintained a gender-balanced ExCo and management in 2024 at 43% women against a 40% target. It also has an ongoing target of a minimum of 40% female representation on the Board, and reported 40% women on the Board against the 40% target, with the Company Secretary monitoring Board performance against the target on an ongoing basis. On learning and development, a completion rate of 90% is required each year for the mandatory 'Sustainability and AIB' training, a figure derived from and aligned with the limit in the Risk Appetite Statement, and the course achieved a 94% completion rate in 2024. AIB states that it does not have specific targets in place for employee retention, and it uses its employee turnover rate as a performance measure to show progress towards retaining its workforce. AIB is applying phase-in provisions for certain metrics, including the metric on people with disabilities for 2024.

Reference: page 94

AIB reports the characteristics of its employees using both headcount and full-time equivalent (FTE) figures as at year end, with FTE defined as staff in payment only, excluding tied agents and staff on career break or other unpaid long-term leave. The total number of employees at year end using headcount is 10,721, split into 5,886 female, 4,832 male and 3 not reported, and broken down by country into 9,918 in the Republic of Ireland, 768 in the United Kingdom and 35 in the USA. Using the FTE-based contract tables the total is 10,469 employees, comprising 10,078 permanent, 390 temporary and 1 non-guaranteed-hours employee, and 9,915 full-time and 554 part-time employees. By gender the FTE table shows 5,647 female, 4,818 male and 3 not reported. On turnover, 1,265 employees left during 2024, giving an employee turnover rate of 12.6%, calculated as total leavers divided by the number of FTE staff at the start of the year, and excluding Goodbody and Payzone employees. AIB notes there are no significant variances in employee numbers during 2024 and that it currently reports gender as male, female and not reported, with work ongoing to add a voluntary anonymised option for other.

Reference: page 91

AIB reports gender and age diversity metrics for its workforce, taken at year end and excluding Goodbody and Payzone. Women represented 43% of ExCo and management combined against a 40% target, and 40% of the Board against a 40% target. Within ExCo specifically there were 6 females and 8 males, giving 43% female and 57% male representation. AIB notes that women as a percentage of management includes ExCo, and that its ExCo is treated as its 'Top Management' level for the purposes of the S1-9 requirements, with the Board figure referring to the AIB Group Board. On age diversity, 18% of employees were under 30 years old, 61% were between 30 and 50 years old, and 21% were over 50 years old. The gender diversity figures exclude employees noted as Other or Not reported.

Reference: page 93

AIB reports training and skills development metrics for its employees. In 2024, 95% of all employees participated in regular performance and career development reviews, comprising 95% of female employees and 94% of male employees, based on 2024 interim data because final year-end reviews are completed after year end. The average number of training hours per employee was 31, made up of 32 hours for female employees and 29 hours for male employees. The average training hours figure includes virtual instructor-led training, classroom instructor-led training, web-based training, Session Management Training, video and material provided via the iLearn learning management system. Both the performance review and training hours figures exclude Payzone, Goodbody and AIB staff on long-term leave, and the performance review data also excludes a senior cohort of AIB ROI and UK employees who currently have different measurement criteria.

Reference: page 92

AIB reports work-life balance metrics relating to family-related leave. In 2024, 100% of AIB employees were entitled to take family-related leave, and 19% did so, comprising 23% of female employees and 13% of male employees. Employees who took multiple types of family-related leave during 2024 were counted only once, which avoids double-counting but means the figures are a conservative view of how much family-related leave employees took. These figures exclude Payzone and Goodbody. AIB supports work-life balance through its Family Leave Handbook and Carer's Policy, which cover maternity, adoptive, surrogacy, paternity, parent's, fertility and shared parental leave as well as caring-related leave.

Reference: page 92

AIB reports gender pay gap and total compensation metrics. Its annual Gender Pay Gap report for AIB ROI, based on a snapshot date of 30 June 2024, shows a mean gender pay gap of 17.8%, a 1.1 percentage point improvement since the previous report in December 2023, while the AIB UK report, based on a legislative snapshot date of 5 April 2024, shows a mean gender pay gap of 27%, a 1.3 percentage point improvement since the 2023 report. The ROI mean gap was 18.9% in 2023 and 18.4% in 2022, and the UK mean gap was 28.3% in 2023 and 28.6% in 2022. AIB states the primary reason for its gender pay gap remains its organisational shape, with a significantly larger number of females in lower level roles and higher numbers of males in more senior roles. On total compensation, the highest paid individual is the CEO, the median annual total compensation for all employees excluding the CEO in 2024 was 60,406 euro, and the ratio of the CEO's annual total compensation to that median was 10.66. The compensation calculations exclude Payzone, Goodbody and non-active employees, and use estimates for variable remuneration relating to FY24 that is not paid until Q2 FY2025.

Reference: pages 94, 95

AIB reports on incidents, complaints and severe human rights impacts affecting its own workforce, noting that the Bank has several channels for its workforce to raise concerns and that all concerns are treated seriously and confidentially and investigated professionally. There were no incidents of discrimination, including harassment, as defined in paragraph 2 of ESRS S1, reported in 2024, and no complaints of discrimination, including harassment, were filed through the channels available to the own workforce in 2024. AIB also confirms that no severe human rights issues or incidents were reported with respect to its colleagues in 2024, and that as part of the DMA process it did not identify any severe human rights impacts. These confirmations are based on input from AIB's internal legal function, its Speak Up (Whistleblowing) team and its Workforce Performance team regarding grievance processes, with certain entities such as Goodbody and Payzone excluded from some of these inputs. Given the nature of its industry and markets, AIB has not identified any significant risk of incidents of forced, compulsory or child labour.

Reference: pages 88, 95

AIB addresses affected communities primarily through its Housing material topic, where policies govern the provision of finance for residential mortgages and residential developments, including Build-to-Rent, Private Rented Sector and social housing developments. The main policies are the ROI and UK Residential Mortgage and Group Development Policies, the Commercial Investment Policy, and the Social Housing Policy, which sets out lending rules for social housing in both ROI and the UK and covers acquiring and refurbishing units, debt funding for social housing providers, Mortgage to Rent, affordable housing, sheltered housing and housing for the elderly. Funding to Approved Housing Bodies and to borrowers under schemes such as the First Home Scheme and the Local Authority Affordable Purchase Scheme is included in AIB's social bond pool, subject to the voluntary transparency requirements of the Social Bond Framework, which is based on the ICMA Social Bond Principles 2021 and is available on the website. The CRO is accountable for implementing these internal policies, which are available to colleagues on the Intranet. Underpinning its approach to communities, AIB's Human Rights Commitment, shaped by the United Nations Guiding Principles on Business and Human Rights and available on its website, sets out policy commitments in relation to colleagues, customers and the wider society and community. The commitment operates alongside AIB's Code of Conduct and Responsible Supplier Code and was introduced in 2021, when it was approved by ExCo and reviewed by SBAC and the Board. AIB confirms that no severe human rights issues or incidents were reported with respect to its colleagues, customers and communities in 2024.

Reference: page 96

AIB engages with certain affected communities through its community partners on a monthly and quarterly basis, to discuss the impact and progress of the activities it supports. The results are reflected in its Community Framework, under the areas of Sustainability, Education & Opportunities and Digital, Innovation & Financial Inclusion. Long-term partners include FoodCloud, GOAL, Junior Achievement Ireland and AsIAm, alongside key educational partnerships. The Director of Corporate Affairs is ultimately responsible for this engagement, which is overseen by the Communities and Partnerships Team. Customers, employees and the public can submit nominations for their chosen charity via the AIB Community €1 Million Fund, with customers nominating through the Community pages of the website and employees through an internal online survey. In 2024, 70 charitable organisations received funding from the fund across Ireland, Northern Ireland and Great Britain. When engaging with stakeholders, AIB states that it pays attention to respecting their human rights, as outlined in its Stakeholder Engagement disclosures.

Reference: page 96

Customers and the wider community can engage with AIB through its complaint management process, where grievances are treated with confidentiality and respect. If negative impacts arise, AIB has a process in place and channels available online, by post or by phone to remediate negative impacts via the complaint management system, resolving complaints quickly at a local level where possible, and otherwise forwarding them to the Centralised Complaints Management team. AIB uses root cause analysis to examine, track and monitor complaints, and regularly analyses patterns of consumer complaints and errors, including investigating whether complaints indicate an isolated or more widespread issue. These processes and channels are governed by the Complaints Management Policy, which sets out roles and responsibilities, governance requirements and minimum standards, applies to all staff, contractors and third parties in Ireland and the UK, and is owned by the Head of Customer Care & Outcomes. In 2024, AIB rolled out a new complaints and errors management system to capture, manage, resolve and report on complaints and errors. Staff also completed training courses, including a voluntary course on phone skills and the 'Customer Island' course, covering skills such as talking to customers with empathy and dealing with difficult situations to achieve the best outcome for the customer.

Reference: pages 89, 95

AIB takes action on affected communities mainly by supporting the national housing agenda, financing social and affordable housing directly through various government-led initiatives and support for social housing through Approved Housing Bodies in Ireland and registered providers of social housing in the UK. In 2024, AIB provided €135m of new lending to fund social and affordable housing in ROI and £112m of new lending to fund social housing in the UK. It continued to support residential property development, providing total facilities of €366m to support the development of new homes in Ireland and the UK, and offered discounted loans to residential developers who adhere to an Irish Green Building Council benchmark that sets higher green building standards than current building regulations. AIB participates in the First Home Scheme and the Local Authority Affordable Purchase Scheme, and is an active supporter of the Mortgage to Rent scheme, in 2024 funding the acquisition of Mortgage to Rent properties by Home for Life and iCare. It continues to support customers impacted by the MICA/Defective Concrete Blocks issue through a dedicated team that liaises with customers and external advocacy groups, including BPFI and the Redress Focus Group. AIB notes it does not have specific targets related to lending to fund social and affordable housing in the ROI or social housing in the UK, and uses its performance measures to track the effectiveness of these actions. Underpinning these actions, its Human Rights Commitment guides its approach towards customers and the communities where it does business, and AIB confirms that no severe human rights issues or incidents were reported with respect to communities in 2024.

Reference: page 89

AIB tracks performance measures related to housing and affected communities, and notes it will also consider developing other metrics over time to measure performance within the housing value chain in Ireland. Its main commitment is to deliver more than €6bn of cumulative new lending to first-time buyers in ROI by 2026, guided by its internal target-setting process, with management teams considering results from scenario analysis models approved by senior leadership. In 2024, AIB made substantial progress by providing €2.79bn in new lending to first-time buyers in ROI. For social and affordable housing, AIB states that it does not have specific targets related to lending to fund social and affordable housing in the ROI, or lending to fund social housing in the UK, and instead uses performance measures to track the effectiveness of its actions. These tracked measures include €135m of new lending to fund social and affordable housing in ROI, £112m of new lending to fund social housing in the UK, and €366m of new lending to fund residential developments in 2024.

Reference: pages 85, 88, 95

AIB's consumer-related policies apply to all employees, contractors, consultants, agents and third parties across the Group who have direct or indirect access to its information or systems, and to all legal entities and subsidiaries including Goodbody, with Payzone maintaining its own suite of policies. Under the Financial Wellbeing topic, the Product and Propositions Risk Policy sets out the approach for managing and mitigating risks in the development of products, propositions, services and customer solutions, ensures customers' needs are considered throughout product development, and is owned by the Head of Operational Risk and sponsored by the CRO. The Customer Vulnerability Guidelines, owned by the Head of Customer Vulnerability, support the management of conduct risk relating to customers in vulnerable circumstances and are a key supporting document to the Group Conduct Risk Policy. The Conduct Risk Policy, owned by the Group Chief Compliance Officer and sponsored by the CRO, covers all customers, including those in vulnerable circumstances, and supports clear, fair and accurate communication; AIB notes it will consider developing a specific policy to manage its impact in relation to financial literacy. Under the Housing topic, policies including the ROI and UK Residential Mortgage and Group Development Policies, the Commercial Investment Policy and the Social Housing Policy cover all customers in Ireland and the UK and are reviewed periodically, with the CRO accountable for their implementation. Underpinning these, AIB's Human Rights Commitment sets out policy commitments in relation to customers and is available on its website, and safeguarding customers' right to privacy is described as a key part of that commitment.

Reference: pages 96, 97

AIB's customers engage with it every time they interact with its services, in person, by phone and online; across its branches AIB engages with 44,000 of its customers daily (branch footfall per day) and in 2024 held 24 easy banking workshops. AIB engages customers directly on the key issues that affect them through its 'Voice of the Customer' survey, capturing experiences in near-real time using digital surveys when customers interact through digital channels and via email and phone for other journeys. The Customer Experience team, headed by the Chief Customer Officer, is responsible for implementing the survey. AIB also carries out a quantitative review after launching campaigns to assess customers' response, building on annual research into consumers' understanding of communications such as brochures, branch screens and emails. Through its partnership with AsIAm, Ireland's autism charity, AIB engages on how its branches can become more autism-friendly. On data protection, the Group has appointed local Data Protection Officers in Ireland and the UK who are the point of contact for both staff and customers who have queries or complaints about how their data is processed, and its Data Protection Notice directs customers to the Complaints section of the website if they wish to raise a complaint about how their information is collected, used, kept or shared.

Reference: pages 96, 97

While AIB strives to provide the most positive experience for customers, it acknowledges it will not always get it right and believes in accountability when this happens. Customers can engage with AIB through its complaint management process, where grievances are treated with confidentiality and respect, and channels are available online, by post or by phone to remediate negative impacts via the complaint management system. Where possible, complaints are resolved quickly at a local level, and otherwise forwarded to the Centralised Complaints Management team, with root cause analysis used to examine, track and monitor complaints. These processes and channels are governed by the Complaints Management Policy, owned by the Head of Customer Care & Outcomes and applicable to all staff, contractors and third parties in Ireland and the UK. In 2024, AIB rolled out a new complaints and errors management system to capture, manage, resolve and report on complaints and errors, and continued to apply root cause analysis to help prevent complaints recurring. On data protection, AIB has channels for stakeholders to raise concerns, with Data Protection Notices including contact details for data subjects, and the Data Protection Notice directing customers to the Complaints section of the website; the personal data breach assessment matrix specifies when AIB must notify the Data Protection Commission and affected individuals.

Reference: pages 86-89

AIB takes wide-ranging action to support the financial wellbeing of its consumers. It improves tailored financial products and the customer experience through its Customer Credit Transformation Programme, an automated drawdown process with DocuSign, the AIB Business (iBB) app, and a redesigned AIB Mobile offering that includes a biometrics feature enabling customers to make payments of up to €10,000 in the app without a card reader. For customers in vulnerable circumstances, support includes a dedicated additional support helpline that handled 10,331 calls in 2024, an additional support flag system, a dedicated internal vulnerable customer support team, ATM accessibility with voice-guided functionality, sign language interpretation services, statements in braille and large print, a language translation and interpretation service covering over 120 languages, gambling blocks introduced in 2024, and a full annual colleague training programme with 42,334 hours completed. AIB supports customers in financial difficulty through early warning indicators, its Arrears Support Unit, regularly reviewed forbearance solutions and the 'Worried about Payments' section of its websites, and in 2024 upgraded and simplified its household expenditure guidelines to reflect cost-of-living increases. It promotes financial literacy through initiatives such as the AIB Future Sparks Programme for secondary schools, the 'Banking How To' Guide and clear, plain-language communication. To protect consumers from fraud, AIB ran a Fraud Awareness campaign, 'Wait a Sec, Double Check', a separate SME Fraud Awareness campaign on LinkedIn, and a campaign about the dangers of fraud around Black Friday and Cyber Monday. Under the Housing topic, AIB supports customers through a dedicated team of mortgage advisors, extended the validity of an Approval in Principle from six months to 12 months, participates in the First Home Scheme and Local Authority Affordable Purchase Scheme, and provided €2.79bn in new lending to first-time buyers in ROI in 2024.

Reference: pages 87, 89, 110

For tailored financial products under Financial Wellbeing, AIB reports that 31,808 Financial Planning consultations were carried out by its qualified advisors, recorded on a dashboard with a four-eye review of all figures and no judgements or estimations applied. With the appointment of a Chief Customer Officer in 2024, AIB states it will continue to track progress in customer service and the volume of finance provided through its tailored financial products, and will consider further developing how it measures its impact on other aspects of financial wellbeing, including for the most vulnerable customers. Under the Housing topic, AIB has committed to deliver more than €6bn of cumulative new lending to first-time buyers in ROI by 2026, and in 2024 provided €2.79bn of such new lending. For cyber security and data protection, which applies ESRS S4 to consumers and end-users, AIB has a Cyber Security spending target of at least 7% of overall annual IT spend, against which it achieved 10.33% in 2024. AIB states that it does not have specific targets related to the number of personal data breaches; instead it works to reduce them and support customers and business areas if they occur, tracking effectiveness through the total number of personal data breaches, which was 1,747 for the Group and its subsidiaries including Goodbody in 2024.

Reference: pages 101, 104-105

AIB's corporate governance, ethics and accountability policies apply to everyone directly employed by AIB as well as agency staff, contractors and Board members, covering AIB Mortgage Bank, EBS d.a.c. (including Haven), AIB UK and Goodbody, while Payzone maintains its own aligned suite of policies. The Conflicts of Interest Policy sets out how to evaluate, report and manage actual, potential or perceived conflicts, was approved by the Group Risk Committee, and requires prior approval for gifts, benefits or hospitality valued above the equivalent of 200 euro, 200 pounds or 260 dollars, which must be recorded on the CoI register. The Group's culture is expressed through six values and behaviours (Be one team, Own the outcome, Drive progress, Show respect, Eliminate complexity, and Put Customers First) and is governed by the Group Culture Risk and Conduct Risk Framework, which the Board Risk Committee approves. The Code of Conduct sets out clear expectations of behaviour, is aligned to the Central Bank of Ireland's Individual Accountability Framework and the UK FCA's Senior Managers and Certification Regime, is published on AIB's website, and is reviewed annually by the Group Conduct Committee and the Board Audit Committee. All employees must complete a declaration of compliance with the Code as part of the annual Aspire performance management process, and breaches are managed through a disciplinary process that can result in sanctions including dismissal. The Whistleblowing Policy provides a confidential route for reporting actual or suspected wrongdoing through multiple channels, including local management, a confidential internal telephone line and a Speak Up email address, an external facility operated by the specialist charity Protect, and a 24/7 external digital portal, without fear of retaliation. The Board receives an annual report on issues raised through the Whistleblowing process, which is sponsored by the Chief People Officer and approved by the Board Audit Committee.

Reference: pages 111-112

Managing supplier relationships is a key aspect of AIB's Corporate governance, ethics and accountability material topic, and suppliers are defined as any third party organisation that provides goods or services to or on behalf of AIB Group, excluding individual contractors, agents or intermediaries. AIB has 4,003 active suppliers on its database and transacted with 2,528 of them in 2024, with the largest cohort based in Ireland (66%), a further 26% in the UK, and the remaining 8% in other locations, mostly other European countries, the USA and India. The supplier base is segmented into five tiers based on the risk and criticality of the service provided, with the closest management given to Tier 1 suppliers who provide critical services and Tier 5 suppliers typically providing low value transactional goods and services. The Responsible Supplier Code sets out AIB's expectations and the minimum standards suppliers must meet regarding human rights, health and safety, supply chains, inclusion and diversity, and responsible and sustainable business, and AIB will only do business with suppliers that adhere to the Code. AIB requires evidence that suppliers have an ESG plan or are working on putting one in place, requires all successful suppliers to join a Supplier Financial Qualification System, and encourages suppliers to report their carbon emissions through the CDP, with 65 suppliers participating in CDP reporting in 2024, representing 50% of the AIB suppliers invited. Key suppliers must attest annually that they have complied with AIB's policies, including the Code of Conduct, CoI Policy, ABC Policy, Data Protection Policy, Whistleblowing Policy and Human Rights Commitment, and suppliers are informed of the Code at onboarding and at each transaction through Purchase Order communications. AIB also operates a Supplier Relationship Management Standard and uses an ESG Questionnaire during supplier selection, and in November 2024 it hosted a Supplier Summit for its top 100 suppliers.

Reference: pages 102, 103

AIB has a series of measures to prevent and mitigate financial crime and to ensure it effectively implements its Financial Crime and Conflicts of Interest Policies. The Special Investigations Unit (SIU) independently investigates allegations of serious wrongdoing by employees, including bribery and corruption and matters raised through whistleblowing channels; it is part of Group Internal Audit, derives its authority from the Board through the Board Audit Committee, and is independent of the Group's business management. Material bribery and corruption matters are escalated to the Board on a case by case basis through Executive Management reporting. All employees, contractors and suppliers are required to complete Financial Crime (Anti-Money Laundering and Sanctions) and CoI training annually, with bespoke training tailored to the financial crime risks relevant to specific roles, and the Money Laundering Reporting Officer provides comprehensive annual training to the Board. During 2024, AIB provided one hour of computer-based training on Financial Crime (AML, Sanctions and ABC) to employees, managers, ExCo and contractors, covering the definition of corruption, the Financial Crime Policy, the procedures on suspicion and detection, and the key laws and regulations, and this training was completed by 98% of managers and employees. The MLRO also delivered in-person Financial Crime training incorporating ABC to the Board in 2024. All employees and business partners, including advisory partners and contractors, are also required to complete CoI training annually, which had a 94% completion rate in 2024.

Reference: page 103

AIB assesses its operations across the Group annually for risks related to corruption in order to identify vulnerable areas and take preventative actions, and it did not identify any significant risks related to corruption in the risk assessment during 2024. There were 0 confirmed incidents in which AIB dismissed or disciplined its own workers for corruption or bribery, and 0 confirmed incidents where it terminated or did not renew contracts with business partners due to corruption or bribery violations. There were no incidents in AIB's value chain where AIB or its employees were directly involved. Accordingly, no actions were necessary to address breaches in AIB's Anti-Bribery and Corruption procedures and standards. The incidents of corruption and bribery data are sourced from AIB's risk management system SHIELD, which is fully automated, and the report is a point in time snapshot that is constantly updated, with no validation, judgements or estimations applied.

Reference: page 102

AIB's Conflicts of Interest Policy covers its approach to lobbying and prohibits the making of political donations, and AIB also has a Lobbying Policy that is approved by the Group Risk Committee. Lobbying activity in Ireland is recorded on a lobbying register, on which AIB is registered as a Lobbyist, and lobbyists must submit returns detailing their activities. AIB's returns focused on executive pay, promoting gender balance in financial services, and highlighting the challenges facing the Irish Stock Exchange, including ensuring the Minister is fully informed of concerns about Government limits on executive pay and bringing potential green financing solutions to the Minister's attention. AIB did not financially support any political parties in 2024. AIB is a member of multiple trade associations but does not currently have a process in place to determine which of these are engaged in political activity, and it plans to put such a process in place. No members of AIB's Board or ExCo held a comparable position in public administration in the two years preceding their appointment at AIB. AIB is registered on the European Union Transparency Register, with registration number 885308748162-21.

Reference: page 112

Payment practices are addressed as an ESRS requirement connected to business conduct and supplier management, particularly in relation to SMEs. AIB's standard payment terms apply equally for SMEs and non-SMEs and are the same across its geographies. These terms include payment on receipt of invoices that have been flagged as approved to pay, which account for approximately 78% of AIB's annual value, while the remaining 22% of annual invoices are paid once any outstanding elements have been settled and flagged as approved to pay. The average time AIB takes to pay an invoice, measured from the date when the contractual or statutory term of payment starts to be calculated, is 28 days, calculated as the average number of days between the invoice date and the clearing date of the payment based on all invoices received and paid up to 16 January 2025. AIB attempts to prevent late payments by aiming to pay immediately on receipt of invoices, by the ongoing training and education of users, and by monitoring outstanding invoices, and there are no legal proceedings currently outstanding for late payments. The calculation is facilitated through the central collection of invoice data, is reviewed and signed off by management, and no judgements or estimations are applied.