Allied Irish Banks (AIB) Group

Governance roles

Reference: pages 93-95. Composition, diversity and employee-representation datapoints are incorporated by reference to the Governance Report (pages 122-131, 148-151) and GOV-1 paragraph 22(c) to Risk Management (page 178), per the Appendix 1 index (page 107).

As at 31 December 2025 the Board comprised the Chair (deemed independent on appointment), ten Independent Non-Executive Directors and two Executive Directors - the CEO and the CFO (page 93).

Allocation of responsibility (pages 93-95):

• The Board "promotes the Group's long-term sustainable performance by approving strategy, financial, and investment plans, including sustainability factors", approves sustainability targets within strategic planning, and receives sustainability updates twice yearly.
• Board and Advisory Committees: BAC (financial and non-financial disclosures, internal controls, whistleblowing), BRC (risk governance including ESG risks), SBAC (sustainability matters and oversight of the DMA), TDAC (technology, data and cyber), NomCo, RemCo. "The DMA outcomes are reported to SBAC and approved at BAC" (page 94).
• Senior management committees: Group Sustainability Committee, chaired by the Chief Strategy and Sustainability Officer, plus GRC, GDC, GCCC and DATC.

Board skills are regularly evaluated "including Climate & Environmental (Sustainability) and Customer & Conduct (including business conduct) areas" (page 95).

Information provided to and matters addressed by the bodies

Reference: page 95, with the due diligence mapping on page 108.

"Our Board Committees are regularly informed by senior management, supporting their oversight and management of material IROs." Progress against Board-approved sustainability targets "is tracked quarterly on the Sustainability Dashboard, reported to the GSC and SBAC" (page 95).

Matters the Board, ELT and their Committees discussed in 2025 include sustainability transformation and targets, "Double Materiality Assessment - Outputs and performance measures", Pillar 3 ESG Disclosures, the Modern Slavery Statement, social strategy and customer vulnerability updates, Inclusion & Diversity, "AIB's environmental footprint", whistleblowing and the Code of Conduct, Climate & Environmental Risk, conduct and culture risk, cyber risk updates, variable remuneration, Data & AI, and supply chain management updates (page 95).

Material impacts and risks are also monitored "through enhanced due diligence processes", including "extensive due diligence assessments of clients and business partners" - for example an ESG Questionnaire used as part of the credit assessment process, subject to criteria, for borrowers in sectors with increased ESG risks (page 95).

Sustainability performance in incentive schemes

Reference: page 95, with further detail incorporated by reference to the Governance Report from page 152.

AIB operates a short-term Variable Remuneration Scheme, which "all employees who participate in the Scheme do so on the same basis". Measures and performance targets "are agreed by the Remuneration Committee and align with the Group's ongoing strategy" (page 95).

Structure of the scheme (page 95):

• Six measures in total: three financial, carrying 60% of the award, and three non-financial, carrying 40%.
• The three non-financial measures cover gender balance, customer satisfaction and green finance, each weighted equally.
• A Group Profit underpin requires a minimum level of profit to trigger an award. "The underpin was achieved for the 2025 performance year."

A clear limitation is disclosed: "The scheme does not currently assess performance against GHG emission reduction targets" (page 95). The ESRS 2 GOV-3 requirement is also cross-referenced under ESRS E1 in the Appendix 1 index (page 107).

Statement on due diligence

Reference: pages 95 and 108.

The Appendix 1 due diligence table (page 108) maps each of the five elements of the due diligence process to the section and page where it is described:

• (a) embedding due diligence in governance, strategy and business model - Our Material Impacts, Risks, and Opportunities; Our Sustainability Governance (pages 51-54, 95)
• (b) engaging with affected stakeholders in all key steps - Our Stakeholder Engagement; Our Approach to the DMA; Channels for Stakeholders to Raise Concerns; Our policies; Our Sustainability Governance (pages 48, 49-50, 89-90, 95)
• (c) identifying and assessing adverse impacts - pages 49-50, 51-54, 89-90
• (d) taking actions to address those adverse impacts - Material Topic: Climate Change; Material Topic: Cyber Security & Data Protection (pages 56-73, 103-106)
• (e) tracking the effectiveness of these efforts and communicating - pages 56-73, 103-106

The statement is explicit about the limits of the requirement: "The ESRS do not impose any conduct requirements in relation to due diligence or require any modification to our governance" (page 95). Appendix 2 records GOV-4 paragraph 30 as an SFDR-derived datapoint located in Sustainability Reporting at page 108 (page 109).

Risk management and internal controls over sustainability reporting

Reference: page 95, with GOV-5 paragraph 36(d)-(e) incorporated by reference to the Governance Report and 36(b)-(c) to Risk Management (page 107 index).

"Our governance for sustainability reporting aligns with financial reporting, is part of our internal controls and is governed by the Sustainability Disclosure Policy for all material Group and in-scope entities' sustainability disclosures" (page 95).

The approval chain is set out in full: annually the Chief Strategy and Sustainability Officer recommends the disclosures for review by the GSC, after which they are reviewed by the GDC, then the SBAC, and approved by BAC (page 95). The Group Disclosure Committee "reviews key judgements and estimates applied to sustainability disclosures" (page 94).

Risks are identified "using risk assessment methodologies and internal controls in line with the 3LOD approach". Key risks named are regulatory compliance, inaccurate disclosures and lack of regulatory awareness, mitigated by the Sustainability Disclosure Policy and the internal control framework. The statement adds a candid forward note: controls are "expected to further strengthen over time as processes and systems continue to mature". Findings from the assessment of the reporting process "are reported to BAC and tracked until closure by First Line Assurance teams" (page 95).

Strategy, business model and value chain

Reference: pages 44-45, 46 and 47, with SBM-1 paragraph 40(a) incorporated by reference to the Annual Review (pages 4-5). Phase-in is applied for SBM-1 40(b) and 40(c) (page 107).

AIB operated three business lines in 2025 - Retail Banking, Capital Markets and Climate & Infrastructure Capital (C&IC) - predominantly in the ROI, the UK and the USA. In July 2025 "the Group announced the simplification of its management structure and the integration of the UK into Retail Banking" (page 44).

Strategy rests on three priorities - Customer first, Greening our business, Operational efficiency and resilience - with "Greening our business" one of the three, and three ESG pillars: Climate & Environmental Action, Societal & Workforce Progress, Governance & Responsible Business (pages 44-45).

Key inputs and outputs disclosed (page 47): €117bn customer deposits; 10,207 actual FTE; 170 AIB branches and 66 EBS offices in ROI; €8.2bn green and social bonds issued since 2020; 92% of own electrical energy needs sourced through the renewable VPPA. Outputs: €14.7bn new lending; €22.9bn cumulative new green and transition lending since 2019; 2.35m digitally active customers; €4.5bn total operating income.

The value chain spans upstream (investors, suppliers, regulators), own operations (own workforce) and downstream (business and personal customers, society and community, and clients and suppliers of clients) (page 46).

Interests and views of stakeholders

Reference: page 48, with SBM-2 paragraphs 45(a) and (c) incorporated by reference to the Governance Report (page 136).

"Stakeholders' views, interests and expectations are integral to our strategy and business model, and are considered by the Board in all its deliberations." Board engagement "ranges from direct engagement to receiving management reports and updates on relevant stakeholders matters" (page 48).

Stakeholders are grouped per the ESRS into affected stakeholders (employees and customers directly, community and society indirectly) and users of the Sustainability Statement (investors and regulators) (page 46).

For the DMA, "affected stakeholders provided input from an impact materiality perspective, while users of the Sustainability Statement provided input from both impact and financial materiality perspectives" (page 49). External engagement used "an online survey and focus group discussions through a sample population of customers, investors and suppliers", plus working sessions with the Climate Change Advisory Council, Open Doors Initiative, International Financial Services Centre of Excellence, IBEC, BPFI and Sustainability Works, who "were also involved in validating the DMA results" (page 49).

Memberships include BPFI, Business in the Community Ireland, the European Banking Federation, the Financial Services Union, IBEC, the Irish Banking Culture Board, the Cyber Defence Alliance and UNEP-FI (page 48).

Material impacts, risks and opportunities

Reference: pages 51-54, with climate content also at pages 69-70. Phase-in is applied for SBM-3 48(e) (page 107).

The DMA identified seven material topics mapped to five topical standards (page 42): Climate Change (E1); Own Workforce - Equal Treatment & Opportunities for All (S1); Housing (S3, S4); Financial Wellbeing (S4); Corporate Governance, Ethics & Accountability (G1); Culture & Reputation (G1); Cyber Security & Data Protection (S1, S4).

Materiality perspective by topic (page 50): Climate Change and Own Workforce are material from both impact and financial perspectives; Cyber Security & Data Protection from impact and risk; Culture & Reputation from a financial (risk) perspective only; Financial Wellbeing, Housing and Corporate Governance, Ethics & Accountability from an impact perspective only.

The tables on pages 52-54 set out 25 individually typed IRO rows, each with a positive/negative marker, an actual/potential marker and a value-chain position. Current financial effects are summarised for the two financially material topics: for Climate Change, €6.3bn new green and transition lending in 2025, and "we have not identified a material impact on the Group's financial reporting judgements and estimates" (page 52); for Cyber, risk "remained a material and emerging risk for AIB in 2025" (page 54).

Process to identify and assess material IROs

Reference: pages 49-50, with climate and environmental risk identification at pages 69-70.

"The DMA process was first carried out in 2023. We conducted an annual review in 2024 for FY2024 CSRD reporting and, in 2025, our second annual review concluded that the foundational work from 2023 continues to provide a reliable basis for our sustainability reporting" (page 49). The Group "continues to use the most up-to-date ESRS (July 2023)" and EFRAG guidance.

Five-step process (page 50): business context; identification of sustainability matters from five input categories, producing "a list of 24 preliminary material sustainability topics"; assessing impact materiality (scale, scope, irremediable character, likelihood) and financial materiality (magnitude, likelihood) "on a scale of 0 - 5, ranging from not material to critical"; consolidation; and validation via the GSC and GDC, discussed at SBAC and approved by BAC.

"We set our materiality threshold to include topics ranked from the high-end of important up to critical" (page 49). Disaggregation "was not deemed necessary". For human rights, "the severity of the impact takes precedence over its likelihood... their severity scored below our materiality threshold" (page 50). One change is recorded: analysis of the Material Risk Assessment "concluded with the identification of an additional risk regarding AI" (page 49).

Disclosure requirements covered by the statement

Reference: pages 107-109 (Appendix 1 list of Disclosure Requirements, Appendix 2 list of datapoints deriving from other EU legislation).

AIB publishes a genuine ESRS content index. "Following the completion of the DMA process, we conducted a materiality of information assessment for each ESRS to determine material DR and data points (DPs)... The following table lists all of the DRs in ESRS 2 and the topical standards, both mandatory and material to AIB" (page 107).

Scope of omission is stated expressly: "We have omitted all the DRs 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 our materiality thresholds, except for the DRs related to IRO-1 in ESRS 2" (page 107).

The index marks each remaining DR either with page references, "Not material" (NM) or "Phase-in". Phase-in is applied to SBM-1 40(b) and 40(c), SBM-3 48(e), E1-9, S1-7 and S1-12; NM is recorded for E1-7, E1-8, S1-8, S1-10, S1-11 and S1-14.

"For six of our material topics, with the exception of 'Own Workforce (Equal Treatment & Opportunities for All)', entity-specific disclosures in relation to metrics have been included to support disclosure of material information" (page 107). Appendix 2 (page 109) lists every EU-legislation-derived datapoint with its location or an NM/phase-in/n-a marker.

Transition plan for climate change mitigation

Reference: page 56, supported by actions on pages 58 and 60-62 and targets on pages 59 and 62-68.

"For FY2025, this chapter provides enhanced disclosures on AIB Group's standalone CTP [Climate Transition Plan], available in full on our website... complemented by the EBA Prudential Transition Plan, effective January 2026" (page 56). It was "Developed in line with the Transition Plan Taskforce (TPT) Disclosure Framework, and approved in the context of our 'Greening our business' strategic priority... as overseen by the Board".

Ambitions: decarbonise own operations by 2030 and the customer lending portfolio by 2050. SBTi-validated targets for Residential Mortgages, CRE and Electricity Generation, with the Corporate Portfolio Coverage target, "cover... 75% of our loan book" at the 2021 baseline.

Four levers: reducing direct Scope 1 and 2 emissions; green and transition financing; green products and propositions; reducing Scope 3 financed emissions. Four enablers: policies and frameworks; educating customers and colleagues; collaboration; engaging with the value chain.

"AIB has <1% lending to non-financial corporates excluded from EU Paris-aligned benchmarks." The plan "is reviewed annually and overseen by GSC". The company states plainly: "we recognise the need to strengthen transition planning and further integrate sustainable practices throughout the business".

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3 and the Climate & Environmental Risk section (pages 51-53, 69-70). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (page 69). The 2025 Transmission Channel Analysis "considered nine drivers over the short (1 - 3 years), medium (4 - 10 years) and long term (>10 years)", in four categories: Climate (Physical) - "climate change patterns and extreme weather events"; Environmental (Physical) - "biodiversity loss and degradation, water stress and management, raw material shortage as well as air pollution"; Climate (Transition) - "consumer and investor sentiment, climate policy and regulation as well as technological change"; and Environmental (Transition).

Methodology (pages 69-70). Annual Transmission Channel Analysis; the Business Environment Scan; "three heatmaps, covering physical, transition and environmental risks", developed in 2025; sector 'house view' deep dives; and a flood model "first introduced in 2023". Flooding "is the Group's most material physical risk".

Scenarios (page 70). Physical risk uses IPCC RCP 2.6, 4.5, 6.0 and 8.5 at five-year intervals to 2100. ICAAP stress testing uses Tipping Points (physical), Paris-aligned and Sudden Realisation (transition). No temperature projection is stated per scenario.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the Climate & Environmental Risk section (pages 51, 56, 63, 70). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

AIB presents no climate resilience analysis as a named ESRS disclosure. What it discloses is resilience assessed through capital stress testing: "we use scenario analysis and stress testing to assess the resilience of our strategy across each of our Principal Risks, including C&E Risk. The scenarios we use... form part of the Internal Capital Adequacy Assessment Process (ICAAP) and the assessment of our three-year financial plan" (page 51).

Result (page 70). The stress tests "were included in the ICAAP process, which provided assurance that the Group had adequate capital to withstand these risks", and "The impacts of climate risk under various climate scenarios are not expected to manifest in the short term and therefore there is no requirement to make any related adjustments to the financial statements".

Uncertainty. "The world, however, is not on track to limit global warming to 1.5°C... This trajectory gap... is also visible in AIB's year-on-year performance against certain targets" (page 63). The flood model "cannot calculate joint probabilities across multiple properties" (page 70), and "we recognise the need to strengthen transition planning" (page 56).

Policies related to climate change mitigation and adaptation

Reference: pages 58 and 60.

Own operations (page 58). The Group Energy Policy "outlines how we conduct our business and operations as energy efficiently as possible" and is "managed and controlled through the implementation of Energy Management Standard ISO 50001". The Group Environmental Policy "commits us to supporting initiatives aimed at mitigating, adapting or responding to climate change" and takes account of ISO 14001. "The Chief Operating Officer (COO) is accountable for their implementation."

Loan book (page 60). The Sustainable Lending Framework (SLF) provides "transparent eligibility criteria for classifying and reporting loans as Green, Transition or Social lending" and is approved by the GSC. The Green Bond Framework is based on the ICMA Green Bond Principles of 2021. The C&E Risk Framework and C&E Risk Policy set out how the Group "define[s], manage[s], mitigate[s] and measures C&E Risk (physical and transition)"; the framework is approved by the BRC, the policy by the GRC.

The SLF carries an excluded activities list in place since 2020; for 2025 these include "the exploration, extraction and upgrading of oil sand projects, fracking, deforestation, illegal logging and trading, nuclear waste transportation, unreported or unregulated fishing, and the decommissioning and/or final disposal of high-level nuclear waste".

Actions and resources in relation to climate change policies

Reference: pages 58 and 60-62.

Own operations (page 58). Under the Greener Branches Refurbishment Programme, "35 branches have been upgraded to date (26 of which were completed in 2025), with €22.4m invested to date". In 2025 AIB "Replaced 13 fossil fuel boilers (oil and gas) with energy efficient electrical based alternatives", enhanced efficiency "across 26 properties through improved insulation", and installed LED lighting. Under the 2022 VPPA with NTR plc for two County Wexford solar farms, "In 2025, 92% of AIB's own electrical energy needs were produced from these solar farms"; the agreement fixes price for 15 years.

Loan book (pages 60-62). "All actions relate to our lending portfolio and, therefore, our downstream value chain." Green mortgages across AIB, EBS and Haven for BER A1-B3 homes, with "62% of new mortgage lending in ROI" to energy efficient homes in 2025; continued participation in the Home Energy Upgrade Loan Scheme; the Business Sustainability Loan launched in 2025 (up to €100k/£100k); and the Growth and Sustainability Loan Scheme, where "In Q4 2025, we reached our full allocation under this scheme and applications are now closed".

Enablers include the €20m sustainability education and research investment (AIB Trinity Climate Hub, Innovate for Ireland's 'Decarb-AI' centre) and the 9th Sustainability Conference with 14,239 attendees (page 62).

Targets related to climate change mitigation and adaptation

Reference: pages 59 and 62-66.

Own operations (page 59). An SBTi-validated interim target "to reduce absolute Scope 1 GHG emissions by 34% by 2027", measured "against a baseline of 4,800 tCO2e in 2019". "By the end of 2025, AIB's emissions were 2,168 tCO2e (2,885 tCO2e in 2024). This represents a cumulative reduction of 55% in 2025 (compared to a 40% reduction noted for 2024)." A second SBTi-validated target increases "annual sourcing of renewable electricity needs to 100% by 2030 from a 2019 baseline of 1%"; 92% was reached in 2025 (89% in 2024).

Lending (pages 62, 64). A green and transition lending fund of €30bn by 2030 (€22.9bn drawn at end-2025), and 70% of new lending green and transition by 2030 - "43% of total lending in 2025... (from a 2019 baseline of 10%)".

SBTi financed emissions targets, 2021 baseline (page 64): Residential Mortgages -58% intensity per m2 by 2030; CRE -67% per m2 by 2030; Electricity Generation "To maintain at or below 21 gCO2e/kWh"; Corporate Portfolio Coverage from 12% to 54% by 2030.

AIB notes the own-operations targets "used assumptions around the changes within our estate over the period" and that, at the midpoint, "we will take the opportunity to consider future developments and how these will impact on our target by 2030" (page 59).

Energy consumption and mix

Reference: page 59, with supporting notes on pages 72-73.

FY2025 totals (page 59), 2024 comparatives in brackets:

• Total energy consumption 29,381 MWh (33,691), and 28,497 MWh (32,553) reported on net calorific value
• Total fossil energy consumption 11,039 MWh, a 38% share (15,209 MWh, 45%)
• Total renewable energy consumption 18,342 MWh, a 62% share (18,482 MWh, 55%)
• Nuclear consumption 0 MWh, 0% share
• Fuel from natural gas 7,175 MWh (9,032); from crude oil and petroleum products 3,372 MWh (4,712); from coal and other fossil sources 0
• Purchased electricity, heat, steam and cooling from renewable sources 18,246 MWh (18,350), of which direct procurement under the VPPA 17,151 MWh and contracts with electricity suppliers 1,095 MWh
• Self-generated non-fuel renewable energy 0 MWh

"AIB does not operate within a high climate impact sector, as defined by ESRS 1, and, as such, this has not affected our energy intensity calculations" (page 59) - the Appendix 2 entries for E1-5 paragraphs 38 and 40-43 are correspondingly marked Not material (page 109).

A measurement limitation is disclosed: "FY2025 data includes nine months of actual data from January to September, while Key Performance Indicators (KPIs) are then used to estimate the final three months" (page 72). FY2024 figures have been restated to 12 months of actual data; the previously reported FY2024 estimate was 33,028 MWh total (page 73).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 66-68, with supporting notes on pages 72-73.

FY2025 (page 66), with 2024 and the 2019 Scope 1/2 baseline in brackets:

• Scope 1 2,201 tCO2e (2,945; 4,784), -25%
• Scope 2 location-based 3,078 tCO2e (4,440; 10,025), -31%; market-based 157 tCO2e (511; 64), -69%
• Total Scope 1 and 2 location-based 5,279 tCO2e; market-based 2,358 tCO2e
• Scope 3 category 15, SBTi-validated portfolios 962,476 tCO2e (1,067,519), -10% against a 2021 baseline of 2,570,000
• Other in-scope customer loan book 6,543,900 tCO2e (5,852,380), +12%
• Total Scope 3 7,506,376 tCO2e (6,919,899), +8%; total Scope 1-3 location-based 7,511,654 tCO2e

Intensity per net revenue rose to 1,665.2 tCO2e per €m location-based (2024: 1,405.7), +18%, on total operating income of €4,511m.

FY2025 is the first year AIB presents "absolute emissions associated with our full in-scope customer loan book", disaggregated by PCAF Asset Class across Project finance, Commercial real estate, Mortgages and Business loans and other classified lending, on €68.52bn exposure (page 68).

"No other Scope 3 categories are deemed to be significant under CSRD for FY 2025... account for less than 1% of our total Scope 3 emissions" (page 72). A phase-in provision applies "for Scope 3 category 15 absolute value emissions".

Policies related to own workforce

Reference: pages 82-83, 85, 88 and 103-104, with S1-1 paragraph 19 incorporated by reference to the Governance Report (page 107).

"While 'Own Workforce' spans a variety of sub-topics as per ESRS S1, we identified two through our DMA process... creating a culture of Inclusion & Diversity (I&D), and creating a culture of learning and development" (page 82).

Policies disclosed:

• I&D Code (page 82), covering discrimination on grounds of "race... religion or belief, age, disability, gender and gender identity, sexual orientation, marriage or civil partnership, pregnancy or maternity, family status and membership of the Travelling Community". AIB states: "We do not have specific monitoring in place, but our Raising Other Concerns portal option and our Grievance procedures allow colleagues to report behaviours contrary to the Code."
• Family Leave Handbook and Carer's Policy (page 83).
• Anti-bullying and Harassment Policy (page 83), on the grounds defined in the Irish and UK Equality Acts.
• Education Policy and People Risk Policy (page 85).
• The Human Rights Commitment, shaped by the UN Guiding Principles, introduced 2021 and updated 2023 (page 88).

The CPO is ultimately responsible for the I&D Code and family policies. Scope is limited to those directly employed in ROI and the UK; "Goodbody and Payzone are governed by their own subsidiary policies".

Processes for engaging with own workforce

Reference: pages 89-90.

"We listen to our people through several initiatives. Twice a year, we conduct short online AIB Engage surveys with employees and contractors to gather feedback, overseen by the CPO" (page 89).

FY2025 engagement data (page 89), 2024 in brackets:

• The surveys "focused on Leadership, Customer, and Culture, receiving a total of 13,693 employee responses" (16,023)
• They "yielded 25,302 comments (2024: 30,598) and suggestions received from colleagues on how we can make improvements"
• "The resulting insights and suggestions from the surveys have formed the basis of action plans and areas of focus as we move into 2026"
• Response rates for the two surveys were 73% and 58% (page 102)

"We also have ERGs, known as Inclusion Networks, that support colleagues who may be at risk of marginalisation, meeting quarterly and led by employees with senior management sponsorship" (page 89). The Women's+, Origins+, Pride+, Abilities+ and Life & Family+ Networks are named (page 83).

Workplace safety appears in the same section: "To protect our colleagues, we maintain workplace accident prevention policies; these are our Safety Statement for the ROI and our Safety Policy for the UK" (page 89).

The Irish Banking Culture Board 'éist Staff Culture' survey "is conducted every two to three years, with the latest survey conducted in February 2026" (page 102).

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 89-90, with policy detail at page 96.

"A new Whistleblowing Policy, introduced in January 2025, allows colleagues to report suspected or actual wrongdoing in the workplace in line with Protected Disclosures legislation" (page 90). Disclosures "can be made via the externally hosted Whistleblowing Portal (with an anonymity option), mailbox, or phoneline" and are "triaged to ensure that they are promptly, objectively, and independently investigated by HR, business representatives, or Group Internal Audit" (page 96). "The Chair of BAC, who acts as our Group Whistleblowers' Champion, oversees its integrity and effectiveness."

Staff may also raise non-protected concerns "directly with their People Leader, senior management, or via the 'Raise Other Concerns' portal option" (page 90).

Grievance mechanisms (page 90). The CPO oversees the Grievance Policy, which "is available on AIB's website". Three steps support effectiveness: grievances "are recorded on a personal case register"; "A dedicated Grievance & Disciplinary decision-maker panel facilitates the independence and effectiveness of the channel, and appeals are heard by either the CEO or an appointed nominee"; and "The investigator is assigned a dedicated case manager, who oversees fairness and correct procedure".

Taking action on material impacts on own workforce

Reference: pages 83, 85 and 104.

Inclusion and diversity (page 83). "We successfully retained our Gold Investors in Diversity accreditation, the highest standard awarded by Irish Centre for Diversity... AIB was the first bank in Ireland to achieve the Gold standard and is one of only 14 organisations in Ireland to have achieved reaccreditation as of 31 December 2025." The fourth annual Universal Inclusion Campaign included "a NeuroInclusion Team Talk which more than 2,000 of our colleagues took part in". The I&D Council "welcomed the CRO as our new Council Chair", and "In 2025, we have launched a long-term Women in Leadership project and working group to tackle career progression challenges facing women in the workplace." The Mentor Her programme "featured 186 mentors and mentees (2024: 194)".

Family leave (page 83). "Our policies became Day 1 entitlements... We also introduced foster leave allowing up to 10 days paid leave", and AIB topped up the new UK neonatal leave payment "while also extending this fully to colleagues in ROI", up to 12 weeks.

Training and skills (page 85). Support for post-graduate and role-specific qualifications (APA/QFA, Chartered Banker Institute, ACCA, CIMA); IOB-accredited CPD including 'Understanding ESG for Business Customers'; the AIB Sustainability Academy; and an updated Career Structure with the 'Invest in You' initiative.

Targets related to own workforce

Reference: pages 84, 85 and 106.

Gender diversity targets (page 84). "Having been an early signatory of Ireland's first Women in Finance Charter, we aim to have a gender-balanced ELT, management and the Board each year. Specifically, we target between 40% and 60% female representation in ELT and management", underpinned by the Equileap definition. "AIB has an ongoing target for the Board of a minimum of 40% female representation."

A miss is reported, not buried: "We have maintained a gender-balanced ELT and management in 2025. However, female representation on the Board decreased to 38% as at 31 December 2025, falling below the stated target. The Board remains committed to this gender diversity target, and the selection process for future appointments will take it into consideration." ELT and management stood at 42% (2024: 43%).

Training target (page 85). "a completion rate of 90% is required each year for the mandatory 'Sustainability and AIB' training. The figure of 90% is derived from and aligned with the limit included in the RAS". Completion was 94% in 2025.

Two absences are stated: "we do not have specific targets in place for employee retention, but our related performance measure 'employee turnover rate' shows progress" (page 86), and "We do not have specific targets related to the number of personal data breaches" (page 106).

Characteristics of the undertaking's employees

Reference: page 86, with supporting notes on page 87.

Headcount is reported on an FTE basis at year end, "defined as staff in payment only, excluding tied agents, and AIB staff on career break or other unpaid long-term leave", and "The total year end FTE figure is the same as that noted in the financial statements on page 330" (page 86).

FY2025 (2024 in brackets), page 86:

• Employees 10,207 FTE (10,469); headcount 10,467 (10,721), split 5,686 female, 4,772 male, 9 not reported
• By country on headcount: 9,670 ROI, 763 UK, 34 USA (9,918 / 768 / 35)
• Permanent 9,883 (10,078); temporary 324 (390); non-guaranteed-hours 0 (1)
• Full-time 9,641 (9,915); part-time 566 (554)
• Turnover: 1,111 leavers (1,265), a rate of 11.2% (12.6%)

Turnover "is calculated based on the total number of leavers, divided by the number of FTE staff at the start of the year... and excludes Goodbody and Payzone employees" (page 87).

A reporting gap is disclosed rather than hidden: "As of FY2025, AIB is reporting employee gender for each group of 'Male', 'Female' and 'Not Reported', but not for 'Other'. Work is ongoing to HR systems to include voluntary anonymised reporting options on gender diversity" (page 87).

Diversity metrics

Reference: page 84, with supporting notes on page 87.

"AIB's ELT is its 'Top Management' level (for the purposes of addressing S1-9 requirements)" (page 84).

ELT gender diversity (page 84), 2024 in brackets:

• Number of females 5 (6); number of males 7 (8)
• 42% female (43%); 58% male (57%)

Age diversity, all employees (page 84):

• Under 30 years old 16% (18%)
• 30-50 years old 62% (61%)
• Over 50 years old 22% (21%)

Women as a percentage of ELT and management was 42% (2024: 43%) against the 40-60% gender balance target, and women on the Board 38% (2024: 40%) against a minimum 40% target (page 84).

Scope is disclosed carefully. "Women as % of ELT and Management includes Goodbody in FY25. It was not included in the prior year figure and has not been restated because the differing career structures in AIB and Goodbody did not allow for a consolidated Group-level metric. Within AIB's career structure, management is defined as those in Level 4-6 positions including the Executive Leadership Team (ELT) & Goodbody." By contrast, "The gender and age diversity performance measures in the tables on page 84, which relate to S1-9 requirements, are taken at the year end and do not include Goodbody and Payzone" (page 87). The gender diversity figures also exclude employees recorded as Other/Not reported.

Training and skills development metrics

Reference: page 85, with supporting notes on page 87.

FY2025 metrics (page 85), 2024 in brackets:

• Average training hours per employee: female 35 (32), male 35 (29), all 35 (31)
• Employees participating in regular performance and career development reviews: female 95% (95%), male 95% (94%), all 95% (95%)
• 'Sustainability and AIB' mandatory training completion 94% (94%), against a required 90% each year

Average training hours "includes virtual instructor-led training (virtual classroom), instructor-led training (classroom), web-based training, Session Management Training (AIB internal training), video, and material provided via iLearn LMS. The figure excludes Goodbody, Payzone, and AIB staff on long-term leave" (page 87).

Two limitations are stated on the performance review metric: "The metric reported here uses 2025 interim data because the final year end reviews are completed post year end, and validated completion rates are not available until after the publication of the Annual Report", and the data "excludes Goodbody, Payzone, and a senior cohort of AIB ROI and UK employees who currently have different measurement criteria" (page 87).

Completion rates are "generated from Cornerstone, our external learning management system provider", and "A reduction in completion rate would lead to discussions on what improvements are required" (page 87).

Work-life balance metrics

Reference: page 84, with supporting notes on page 87.

"In 2025, 100% of AIB employees are entitled to take family-related leave, with 21% doing so (26% of females and 15% of males). In 2024, 19% took this leave (23% of females and 13% of males)" (page 84).

The metric is presented alongside the family leave policies it measures: the Family Leave Handbook covers "our maternity, adoptive, surrogacy and paternity leave policies, our paid and unpaid parent's leave policies, our UK shared parental leave policy, our fertility and neonatal leave policy, and our foster leave policy", and the Carer's Policy covers Critical Caring Leave, Leave for Significant Care/Medical Support, and Carer's Leave for ROI employees (page 83). In 2025 these "became Day 1 entitlements meaning that all colleagues can avail of benefits from the first day of employment", with foster leave of up to 10 days paid leave introduced and neonatal leave topped up and extended to ROI (page 83).

A counting convention and its effect are both disclosed: "Employees who took multiple types of family-related leave during 2025 were only counted once. This avoids double-counting but means that the figures are a conservative view of how much family-related leave our employees took during 2025. These figures exclude Goodbody and Payzone" (page 87).

Compensation metrics (pay gap and total compensation)

Reference: page 84, with supporting notes on page 87.

Gender pay gap (page 84), prior years in brackets:

• ROI mean gender pay gap 17.5% (2024: 17.8%; 2023: 18.9%), snapshot date 30 June 2025 - "there has been a 0.3 percentage point improvement"
• UK mean gender pay gap 21.3% (2024: 27.0%; 2023: 28.3%), legislative snapshot date 5 April 2025 - "there has been a 5.7 percentage point improvement"

Total compensation ratio (page 84). "The highest paid individual in our organisation is our CEO. The median annual total compensation for all employees (excluding the CEO) for 2025 was €62,391 (2024: €60,406) and, the ratio of the annual total compensation of our CEO to the median annual total compensation of all employees (excluding the CEO) was 12.69 (2024: 10.66)."

AIB explains the driver: "the primary reason for our pay gap remains our organisational shape, with a significantly larger number of females in lower-level roles, and higher numbers of males in more senior roles".

Two limitations: "Estimates are used for variable remuneration that relate to 2025 but are not paid until Q2 2026"; and the calculations "exclude Goodbody, Payzone and any employees who do not meet the eligibility criteria" under the Irish 2022 and UK 2017 regulations (page 87). FY2023 comparatives are not subject to limited assurance.

Incidents, complaints and severe human rights impacts

Reference: pages 86 and 88.

FY2025 metrics (page 86):

• "In FY2025, a total of one incident of discrimination, including harassment, was reported."
• "No complaints were filed through the Group's channels for its own workforce to raise concerns, in relation to the social, including human rights, factors or matters as outlined in paragraph 2 of ESRS S1."
• "No complaints were made to the National Contact Points for Organisation for Economic Co-operation and Development (OECD) Multinational Enterprises."
• "The Bank faced no fines, penalties or compensation for damages as a result of the incident disclosed in the period."
• "AIB confirms that no severe human rights issues and incidents were reported with respect to our colleagues in 2025 (2024: 0)."

The Human Rights Commitment extends the nil return across stakeholder groups: "As part of the DMA process, we did not identify any severe human rights impacts. We confirm that no severe human rights issues or incidents were reported with respect to our colleagues, customers and communities in 2025 (2024: 0)" (page 88). AIB also states it "has not identified any significant risk of incidents of forced, compulsory labour or child labour" and reports annually in a Modern Slavery Statement that "explicitly references trafficking in human beings, forced labour and child labour" (page 88).

Policies related to affected communities

Reference: pages 80 and 88.

AIB's S3 materiality derives from one material topic, Housing, whose material IRO is the positive potential impact that "We contribute to the greater availability of housing stock, including social and affordable housing - stimulating economic growth, improving access to housing, and enhancing quality of life for residents" (page 80).

Policies disclosed (page 80):

• ROI and UK Residential Mortgage policies, which "set out rules for all residential mortgage-related lending we perform in both our key markets, including lending to first-time home buyers"
• Group Residential Development Policy, covering "the development phase of BTR, PRS and residential developments, and the development phase of social housing"
• Group Commercial Investment Policy
• Group Social Housing Policy, supporting "lending for the purpose of acquiring and refurbishing units for social housing, or debt funding for social housing providers and approved housing bodies"
• Social Bond Framework, based on the ICMA Social Bond Principles 2023, covering Approved Housing Bodies, MTR providers and First Home Scheme and LAAPS borrowers

"The Chief Credit Officer owns these internal policies"; they exclude Goodbody and Payzone. The Human Rights Commitment applies to communities (page 88).

Processes for engaging with affected communities

Reference: page 89.

"We engage monthly and quarterly with affected communities through partners such as FoodCloud, GOAL, Junior Achievement Ireland, AsIAm, Innovate for Ireland and the AIB Trinity Climate Hub. These discussions inform our Community Framework in Sustainability, Education & Opportunities, and Digital, Innovation & Financial Inclusion. The Director of Corporate Affairs, supported by the Communities and Partnerships team, oversees this engagement" (page 89).

A second channel is the community fund nomination process: "Our customers, employees and the public were able to nominate charities for our fourth annual AIB Community €1 Million Fund on our website, and in addition our employees were able to nominate on an internal online survey. In 2025, the €1 Million was distributed among 66 charitable organisations across Ireland and Great Britain" (page 89). The fund sits within a €12 million Community Investment in 2025 (FY2024: €11.3 million) (page 45).

Community and NGO representatives also fed the DMA: AIB "engaged through working sessions with representatives of industry associations and non-governmental organisations in relation to the interests and views of the wider community and the environment", naming the Climate Change Advisory Council, Open Doors Initiative, IBEC, BPFI and Sustainability Works, which "were also involved in validating the DMA results" (page 49).

Processes to remediate negative impacts and channels for communities to raise concerns

Reference: pages 89-90.

Communities share the external complaints channel with customers: "Customers and the community can raise concerns through our robust complaints management process to ensure customers are heard and issues addressed. Any dissatisfaction can be logged as a complaint through multiple channels - branches, phone, post or online. If the complaint cannot be resolved at the first point of contact, it goes to our dedicated complaints team for independent investigation and resolution" (page 89).

"We apply root cause analysis to complaints and errors to improve customer experience and prevent future issues. In line with regulatory obligations, we review complaint and error patterns to identify isolated cases or systemic concerns. To strengthen this, we created a Group Complaints & Errors Committee for greater focus and governance" (page 89).

Governance is stated: "Analysis and monitoring of complaints is governed by our Complaints Management Policy and applies to all staff and contractors in Ireland and the UK. It is owned by the Head of Customer Care & Outcomes" (page 89).

A 2025 remediation action is given as an example: roll-out of "our new cloud-based complaints and errors management system across the Group, which is now live in AIB ROI, EBS, and Haven", plus 'Understanding Errors' e-training covering "the full error lifecycle" (page 90).

Taking action on material impacts on affected communities

Reference: pages 81 and 88.

National housing agenda (page 81). "In 2025, we continued to participate in the Irish Government's FHS [First Home Scheme] and LAAPS [Local Authority Affordable Purchase Scheme]. The FHS supports middle- to lower-income buyers by bridging the gap between the home price, their deposit and their mortgage... The LAAPS enables customers to buy a home at a discounted market price." AIB "reduced mortgage interest rates in 2025, in AIB, EBS and Haven".

Increasing housing stock. "In Ireland, our Real Estate Finance team within our Capital Markets segment is a specialist lending unit. In 2025, the Real Estate Finance team provided funding for large corporates who build houses, small regional developers, homes for rent and for sale and social and affordable housing." AIB notes "The supply of homes has consistently fallen short of rising demand."

Customers in vulnerable circumstances. "In 2025, AIB continued to support customers affected by the Defective Concrete Blocks (DCB) issue through a dedicated team." Forbearance options include "interest-only periods, fixed repayments, term extensions and arrears capitalisations". AIB "introduced AIB mobile app push notifications alerting customers when funds are insufficient for their mortgage direct debit", and "In 2025, we funded iCare's purchase of MTR properties".

Targets related to affected communities

Reference: page 81.

First-time buyers - the one quantified target. "We have made a commitment to deliver more than €6bn of cumulative new lending to first-time buyers in ROI by 2026. Our Housing target is guided by our internal target-setting process. Our management teams consider results from scenario analysis models, which are approved by senior leadership." Performance: €2.61bn in 2025 (FY2024: €2.79bn), "Cumulative €5.4bn as of end-2025, against >€6bn target for 2026".

Other measures, tracked without targets:

• Funding for new residential developments €959m (FY2024: €978m)
• Funding for social and affordable housing in ROI €139m (FY2024: €147m)
• Funding for social housing in the UK £174m (FY2024: £112m)

A metric change is explained: the FY2024 measure 'New lending to fund residential developments' (€366m) "under-represented the total level of funding advanced to developers" because such funding "is often drawn down through a combination of term loans and revolving credit facilities (RCFs) over multiple phases"; the FY2025 measure "captures all term and cumulative revolving lending drawdowns during the year".

"While we do not have specific targets related to funding social and affordable housing in ROI, or funding social housing in the UK, we use the performance measures as noted here to track the effectiveness of our actions".

Policies related to consumers and end-users

Reference: pages 77, 80, 88 and 103-104.

Two material topics drive S4 - Financial Wellbeing and Housing - with Cyber Security & Data Protection also disclosed under S4 (page 42).

Financial Wellbeing policies (page 77). The Product and Propositions Risk Policy "ensures products are designed with a target market in mind and that customers' needs are considered throughout the product development and management stages". The Group Conduct Risk Policy holds that "all forms of customer communications, including our advertising, should be clear, fair, accurate, and not misleading", is owned by the Group Chief Compliance Officer, and makes "each ELT member... responsible for the effective implementation of Customer Vulnerability processes in their business". The Customer Vulnerability Guidelines define a customer in vulnerable circumstances as one who "require[s] additional care or support to prevent poor or unfair customer outcomes".

A gap is acknowledged: "Going forward, we will consider developing a specific policy to manage our impact in relation to financial literacy".

Housing policies are at page 80; data protection policies - aligned to the GDPR and the Irish and UK Data Protection Acts 2018 - at page 104, where "safeguarding their right to privacy is a key part of our Human Rights Commitment".

Processes for engaging with consumers and end-users

Reference: pages 89-90.

"We engage with customers daily across branches, by phone and online, with 41,636 customers visiting branches each day and 56 easy banking workshops held this year" (page 89).

"Our 'Voice of the Customer' programme collects feedback through our digital channels, and via email and phone, overseen by the Customer Experience Transformation team and Chief Customer Officer (CCO). After campaigns, we conduct quantitative review and annual research on consumers' understanding of our communications" (page 89).

The programme feeds product design: "Our design improvements in 2025 were influenced by external market research, 'Voice of the Customer' programme, app store ratings and the analysis of customer calls" (page 78). AIB also "undertake[s] substantial customer research with the design of new products and propositions" and tracks effectiveness "with our Customer Experience surveys" (page 77).

Customers were among the external groups engaged in the DMA, through "an online survey and focus group discussions through a sample population of customers, investors and suppliers" (page 49).

For data protection, "Our DPOs are responsible for engaging with customers and the DPC when a query is raised regarding our use of personal data" (page 103), and Data Protection Notices "provide contact details for queries on personal data processing" (page 90).

Processes to remediate negative impacts and channels for consumers to raise concerns

Reference: pages 89-90.

"Any dissatisfaction can be logged as a complaint through multiple channels - branches, phone, post or online. If the complaint cannot be resolved at the first point of contact, it goes to our dedicated complaints team for independent investigation and resolution" (page 89). Root cause analysis is applied, pattern review identifies "isolated cases or systemic concerns", and a Group Complaints & Errors Committee was created "for greater focus and governance". The Complaints Management Policy is owned by the Head of Customer Care & Outcomes.

Remediation actions in 2025 (page 90): roll-out of "our new cloud-based complaints and errors management system across the Group, which is now live in AIB ROI, EBS, and Haven"; and 'Understanding Errors' e-training "embedding obligations under the Consumer Protection Code and AIB's Errors and Management Policy".

Data protection channels (page 90). Local DPOs "serve as contacts for staff and customer data queries or complaints", and "Customers are directed to our website's Complaints section for data protection-related complaints." A "personal data breach assessment matrix determines when to notify the Data Protection Commission (DPC) and affected individuals". All breaches are recorded in SHIELD, which "provides the real-time monitoring and centralisation of information on breaches".

Taking action on material impacts on consumers and end-users

Reference: pages 78-79, 81, 88 and 104-105.

Tailored products (page 78). AIB life protection, investment and pension solutions with a financial planning service; "Sustainability is embedded in our Investment Fund Range, which includes Article 8 and Article 9 funds under the Sustainable Finance Disclosure Regulation"; a first National Savings Week in May 2025; new digital investment advice in the mobile app; the AIB Mentoring Access Initiative for Women in SMEs, "offering 20 places in a year-long mentoring programme"; and a new Standard Care Account for 16- and 17-year-olds who need a carer's support.

Innovative solutions. The Customer Credit Transformation Programme extended to business customers; SEPA instant payments "enabling Euro transfers within ten seconds, 24/7"; and Abi, a new digital assistant.

Customers in vulnerable circumstances (page 79). A dedicated helpline that "supported customers and carers via 18,096 (2024: 10,331) calls"; "66,028 hours of training completed (2024: 42,334)"; voice-guided ATMs; braille and large print statements; "A language translation and interpretation service... in over 120 languages"; Safe Spaces for domestic abuse in all NI branches; and partnership with AsIAm "becoming the first Irish Bank to receive Autism Friendly Accreditation for all its branches and EBS offices".

Targets related to consumers and end-users

Reference: pages 79, 81 and 106.

Financial Wellbeing (page 79). "In 2025, qualified advisers carried out 34,100 financial planning consultations (FY2024: 31,808), and this is measured against an internal target. All financial planning consultations are recorded on a dashboard, with a four-eye review performed. No judgements or estimates are applied." AIB adds it is "exploring ways to better measure our impact on customers' financial wellbeing, especially for those needing extra support".

Housing measures (page 81): €2.61bn new lending to first-time buyers in ROI against a cumulative target above €6bn by 2026 (€5.4bn at end-2025); €959m for new residential developments; €139m for social and affordable housing in ROI; £174m for social housing in the UK.

Cyber Security & Data Protection (page 106): IT service availability 99.99% (FY2024: 99.98%); total personal data breaches 1,385 (1,747), of which 267 were reported to the data protection authorities (488); substantiated complaints from outside parties 135 (164) and regulatory bodies 5 (6); 493,173 data subjects impacted (18,816), the increase "primarily attributable to two incidents in AIB ROI, affecting 471,658 customers".

Two candid notes: "We do not have specific targets related to the number of personal data breaches", and the FY2024 'Cyber security spending' measure "will no longer be reported externally from FY2025 onwards".

Business conduct policies and corporate culture

Reference: pages 96-97 and 101-103.

Corporate Governance, Ethics & Accountability (pages 96-97). The Conflicts of Interest Policy requires prior approval for gifts or hospitality "valued at more than €200/£165/$205, either individually or cumulatively", recorded on the CoI register, with a Business Coordinator in each area reviewing it "to identify any actual, potential or perceived conflicts or corruption risks". The Financial Crime Policy (incorporating ABC) covers "anti-money laundering, countering the financing of terrorism, anti-bribery and corruption (ABC), and sanctions"; "Any material updates require Board approval". The Whistleblowing Policy operates under the Protected Disclosures Act 2014 (ROI) and Public Interest Disclosures Act 1998 (UK). Tax Principles, approved by BAC, commit AIB to "complying with the letter and the spirit of applicable tax laws".

Culture & Reputation (pages 101-102). The Culture Risk and Conduct Risk Framework, approved by the BRC. The Code of Conduct, whose five standards include acting "in the best interests of our customers, at all times"; all employees declare compliance "as part of the annual Aspire performance management process", and it is "aligned to the Central Bank of Ireland's Individual Accountability Framework and the UK Financial Conduct Authority's Senior Managers and Certification Regime".

Management of relationships with suppliers

Reference: pages 99-100.

"Managing our supplier relationships is a key aspect of our material topic Corporate Governance, Ethics & Accountability", positioned upstream, with the material IRO that "The integration of sustainability criteria into our risk management processes, policies, and procedures supports responsible and sustainable business practices, supply chain and investments" (page 99).

Supplier base (page 99). "3,924 (2024: 4,003) active suppliers on our database, and we transacted with 2,478 (2024: 2,528) of them in 2025." By location, "67% (2024: 66%)" in Ireland, "25%" in the UK and "8%" elsewhere. Suppliers are segmented "into five tiers, based on the risk and criticality of the service they provide".

Responsible Supplier Code. It "sets out the minimum standards we expect" on "human rights, health and safety, supply chains, I&D, and responsible and sustainable business". "Specific suppliers must attest annually that they have complied with our policies."

ESG Questionnaire (page 100). Used in selection, it requires evidence on decarbonisation targets, "scope 1, 2 and 3 GHG emissions", physical climate risks, and policies "on discrimination, I&D, health & safety, modern slavery, vulnerable persons, greenwashing, and speaking up". CDP participation rose to 106 suppliers (2024: 65), "52% (2024: 50%) of the AIB suppliers invited".

Prevention and detection of corruption and bribery

Reference: pages 97 and 98.

Investigation function (page 97). "The Special Investigations Unit (SIU) independently investigates allegations of serious wrongdoing by our employees, including bribery and corruption, and those raised through our whistleblowing channels. The unit is part of GIA, and derives its authority from the Board, through BAC. The SIU is independent and separated from any chain of management involved in a matter that is being investigated... Each quarter, or as requested, GIA submit a status report of all investigations to both BAC and GRC."

Training (page 97). Annual bespoke Financial Crime (AML & Sanctions) and CoI training "to all employees and Directors... tailored to the financial crime risks relevant to specific roles" - "one hour of computer-based training" covering "the definition of corruption, details of our Financial Crime Policy, the procedures regarding suspicion/detection, and the key laws and regulations". The MLRO "also delivered in-person Financial Crime training (incorporating ABC) to our Board".

Completion rates (page 98): financial crime 96% (2024: 98%); CoI 94% (94%); whistleblowing 95% (95%). "AIB does not assess workers as being at risk of bribery or otherwise for the purposes of assigning this training; it is mandatory for all employees." "We did not identify any significant risks related to corruption in the risk assessment during 2025".

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

AIB discloses no outcome-oriented business conduct target, and says so. On supplier management: "We are considering developing a target to measure the results of our supplier management policies and actions to integrate sustainability and ESG criteria into our procedures, to support responsible business practices, including a more sustainable supply chain" (page 100).

Consistent with MDR-T's second limb, effectiveness is tracked in the absence of targets:

• "Conduct Risk and Culture Risk continues to be a primary focus for the Group... We measure our effectiveness through three Key Risk Indicators (KRIs), which are internally reported: Completion of mandatory training courses; Critical & high customer impacting conduct issues; Culture metric (composite of three culture risk measures)" (page 102).
• A quantified threshold operates across mandatory training: "a completion rate of 90% is required each year", derived from the Risk Appetite Statement limit (page 85). Against it, financial crime training reached 96%, CoI 94%, whistleblowing 95% and Code of Conduct 95% in 2025 (pages 98, 102).

Incidents of corruption or bribery

Reference: page 98.

A complete nil return is given for FY2025:

• "There were 0 confirmed incidents in which we dismissed or disciplined our own workers for corruption or bribery incidents and 0 confirmed incidents of corruption or bribery violations where we terminated or did not renew contracts with business partners."
• "There were no incidents in our value chain where AIB or our employees were directly involved. Accordingly, no actions have been necessary to address breaches in our procedures and standards."
• The headline measure reads "0 Incidents of corruption or bribery", with a 2024 comparative of 0.

Data provenance and the absence of judgement are both stated: "The incidents of corruption or bribery data are sourced from our risk management system, SHIELD. The report is a point-in-time snapshot and is constantly updated. There are no validation, judgements or estimations applied, as SHIELD is fully automated."

The nil return sits alongside the annual corruption risk assessment, where AIB "did not identify any significant risks related to corruption in the risk assessment during 2025". Appendix 2 records the paragraph 24(a) datapoint on fines for violation of anti-corruption and anti-bribery laws as located at page 98 (page 109).

Political influence and lobbying activities

Reference: page 98.

"Our CoI Policy prohibits us from making political donations. We also have a Lobbying Policy, which is approved annually by the RCCR and reviewed annually by the Group Chief Compliance Officer. Lobbying activity in Ireland is recorded on a lobbying register, where AIB is registered as a Lobbyist. Lobbyists must submit returns to the register detailing their activities every four months."

The content of the 2025 returns is disclosed specifically: "In 2025, our lobbying returns focused on seeking clarification that the obligations imposed under the State's Financial Guarantee Legislation were no longer applicable to AIB and a proposed amendment to the Companies Act to allow directors' names to be listed on a company's website rather than on letterheads."

A limitation is disclosed rather than glossed: "We are a member of multiple trade associations; however, we do not currently have a process in place to determine which of these are engaged in political activity. We will consider the feasibility of putting a process in place."

On the revolving-door datapoint: "No members of our Board or ELT 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 and its registration number is 885308748162-21".

Payment practices

Reference: page 100.

"Our standard payment terms apply equally for SMEs and non-SMEs, and are the same across our geographies. These terms include payment on receipt of invoices that have been flagged as approved to pay, which account for approximately 81% (2024: 78%) of the invoices received during 2025. The remaining 19% (2024: 22%) of annual invoices are paid once any outstanding elements of the invoice have been settled and flagged as approved to pay." The headline measure is "Payments aligned with standard payment terms of 30 days": FY2025 81%, FY2024 78%.

"The average time that AIB takes to pay an invoice, from the date when the contractual or statutory term of payment starts to be calculated, is 26 days (2024: 28 days)... This calculation is based on all invoices received and paid up to 31 December 2025."

"There are no legal proceedings currently outstanding for late payments (2024: 0). All Group employees have an obligation to notify the Litigation and Enforcement legal team of any legal proceedings that are received in their area."

Method and scope: the calculation "is facilitated through the central collection of invoice data containing all relevant information, and excludes Payzone. This is reviewed and signed off by management. No judgements or estimations are applied".