FinecoBank

Remuneration Information • Mar 27, 2025

ANNEX I

DISCLOSURE ON REMUNERATION PURSUANT TO ARTICLE 450 OF THE REGULATION (EU) NO. 575/2013 AND THE REGULATION (EU) NO. 637/2021

3

1.DISCLOSURE ON THE COMPENSATION POLICY

This document provides information on the remuneration policy and practices for the categories of personnel whose professional activities have a significant impact on the risk profile of the institution pursuant to article 450 of EU Regulation no. 575/2013.

The data will be displayed in a table format in application of the provisions of the Implementing Regulation (EU) no. 637/2021 as represented below.

1.1 QUALITATIVE DISCLOSURE

The EU REMA Qualitative Table, in line with article 450 of EU Regulation no. 575/2013, describes the main elements of the remuneration policy, providing information on the decision-making process underlying the definition of the remuneration policy, including the role of the Remuneration Committee, which is the body responsible for overseeing remuneration.

Furthermore, the table describes characteristics and structure of the remuneration system for Identified Staff, with particular reference to the link between remuneration and performance and the ex-ante and ex-post risk correction mechanisms.

In addition, disclosure is provided with regard to the ratio between variable and fixed remuneration, the criteria used to determine the balance between the cash and share component, the deferral scheme, the payments in financial instruments, the applicable retention periods and the vesting of the variable remuneration.

1.2 QUANTITATIVE DISCLOSURE

Table EU REM1 includes the amounts of remuneration awarded to Identified Staff for the performance year 2024, both fixed and variable remuneration. A breakdown of the cash and share component, as well as the upfront and deferred portion of the variable remuneration is also provided.

The special payments for Identified Staff awarded or made in 2024, with specific reference to severance indemnities (both paid in advance and deferred) are shown in Table EU REM2.

Table EU REM3 indicates the amounts of deferred remuneration linked to previous performance years.

Table EU REM4 reports the number of identified staff members who were awarded a remuneration equal to or higher than EUR 1 million for the performance year 2024.

Finally, aggregated quantitative data is provided on the remuneration of personnel whose professional activities have a significant impact on the risk profile of the institution (Table EU REM5).

1.1 QUALITATIVE DISCLOSURE

Table EU REMA – Remuneration Policy
a) Information relating to the bodies that oversee remuneration.	Name, composition and mandate of the main body (management body or remuneration committee as applicable) overseeing the remuneration policy and the number of meetings held by that main body during the financial year.
	The body that oversees the application of the Remuneration Policy and the design of the compensation systems is the Remuneration Committee.
	The Committee is composed by 3 non-executive Directors: Mr. Gianmarco Montanari, Ms. Giancarla Branda and Mr. Marin Gueorguiev, which are independent pursuant to art. 148 TUF and art. 2 of the Corporate Governance Code. As required by the "Corporate Governance Rules" internal regulation, the Committee has the role of presenting proposals and issuing opinions to the Board of Directors in relation to the Group's remuneration strategy, including, by way of example, the criteria for determining remuneration, performance targets, equity incentive plans etc., also supervising the overall consistency and application of the approved Remuneration Policy (for more details on the role of the Remuneration Committee, refer to Section II, p. 2.1 of the 2025 Remuneration Policy). The Remuneration Committee held 14 meetings in 2024.
	External consultants whose advice has been sought, the body by which they were commissioned, and in which areas of the remuneration framework.
	As provided for by the applicable legislation, in 2024 the Committee, in performing its duties, was supported by an external consultant (Willis Towers Watson – from January 1st, 2024 to June 30, 2024 – and Deloitte for the remaining months of 2024), specialized in advisory services, (providing, for example, market practices analysis on remuneration, updates on the reference regulatory framework, proposals for the definition of the peer group, etc.). The external advisor, whose independence had been previously verified, was appointed by the Remuneration Committee following a selection process, within the budget assigned by the Board of Directors.
	A description of the scope of the institution's remuneration policy (e.g. by regions, business lines), including the extent to which it is applicable to subsidiaries and branches located in third countries.
	The remuneration policy of the FinecoBank Group applies to the company FinecoBank S.p.A, the parent company of the Group, with reference to the employees, taking into account the specifics of their roles and duties, and to the Financial Advisors in line with the specific remuneration of the latter. Specific provisions contained in the Remuneration Policy apply exclusively to the Group's Identified Staff, as identified
	according to the criteria established by the relevant legislation. FinecoBank, in its capacity as parent company, ensures that the remuneration in the group companies, with specific reference to the subsidiary Fineco Asset Management DAC, is compliant with the principles and rules established by the Group Remuneration Policy and with the specific industry and local regulatory framework.
	A description of the staff or categories of staff whose professional activities have a material impact on institutions' risk profile.
	As a result of the analysis, conducted in line with the provisions of the Circular no. 285 of 2013 of the Bank of Italy and the EU Delegated Regulation 923/2021, the following categories of employees of staff whose professional activities have a material impact on institutions' risk profile have been defined for 2024: non-Executive Directors member of the Board, Chief Executive Officer and General Manager, Executives with strategic responsibility, executive positions with managerial responsibility on Company Control Functions (Compliance, Risk Management, Internal Audit, Anti Money Laundering), legal affairs, human resources, the soundness of accounting policies and procedures, information technology and other positions that are responsible for strategic decisions which may have a relevant impact on the Group's risk profile.
	In any case, all employees with Global band title equal to or greater than Senior Vice President are included among the Identified Staff. The Financial Advisors belonging to the Identified Staff are those who have an overall annual remuneration equal to
	or greater than 750,000 Euro and who fall within the 0.3% of PFAs in the Network with the highest total compensation, as well as those who coordinate Financial Advisors with total assets equal to or greater than 5% of the total assets attributable to the Network. For more details, refer to Section I paragraph 4.1 of the 2024 Remuneration Policy.

b) Information relating to	An overview of the key features and objectives of remuneration policy, and information about the decision-making
the design and structure	process used for determining the remuneration policy and the role of the relevant stakeholders.
of the remuneration
system for identified staff	The principles established by the Remuneration Policy are the pillars used to define the remuneration systems. Fineco's approach to remuneration, consistent with the legislation and best market practices, ensures the link to performance, external context and market practices, business strategies and long-term interests of shareholders. Notably, the Remuneration Policy aims to define incentive systems consistent with corporate values and objectives (including those that take into account environmental, social and governance factors), with company results and with an
	effective risk management in line with the reference framework for determining the risk appetite and with capital and liquidity levels. Appropriate remuneration and incentive mechanisms strive to support the creation of a working environment that is inclusive of any form of diversity and capable of encouraging the expression of individual potential, attracting, retaining
	and motivating highly qualified resources. In line with our remuneration governance model characterized by clarity, reliability and transparency in the decision making processes, the Remuneration Policy is drawn up by the Human Resources function, with the involvement of the other company functions based on the area of expertise and evaluated by the Compliance and Risk Management function before being submitted to the Remuneration Committee. The Remuneration Policy, upon proposal of the Remuneration Committee, is submitted annually to the Board of Directors
	and subsequently to the Shareholders' Meeting for approval, in line with regulatory requirements.
	Information on the criteria used for performance measurement and ex ante and ex post risk adjustment.
	The link between profitability, risk and remuneration is guaranteed by directly linking the bonus pool with company results and relevant risk profiles as defined in the reference framework for determining the risk appetite. Notably, specific entry conditions are defined, which act as ex-ante risk adjustment mechanisms and assess the Group's performance in terms of profitability, capital and liquidity. Only if all entry conditions are met, the bonus pool is confirmed with the possibility of applying further adjustments based on the overall assessment of the risk factors included in the risk-weighting mechanism "CRO dashboard". The CRO dashboard includes specific risk indicators of the Risk Appetite Framework (this process also applies to the definition of
	the bonus pool for Financial Advisors ). Once the bonus pool is defined, individual bonuses are determined within the annual performance appraisal process, based on the principles of transparency and clarity to ensure a direct link between variable remuneration and performance. The variable remuneration awarded or paid is subject to ex-post risk adjustment mechanisms (malus and claw back
	respectively) that take into account, among others, individual behavior. Notably, these measures make it possible to reduce, cancel or request the return of any form of variable remuneration. For more details, please refer to the Focus on "Compliance breach, individual malus and claw back" in Section I paragraph 2.5.3 of the 2024 Remuneration Policy.
	Whether the management body or the remuneration committee where established reviewed the institution's remuneration policy during the past year, and if so, an overview of any changes that were made, the reasons for those changes and their impact on remuneration.
	In 2024, the Remuneration Committee reviewed the 2023 Remuneration Policy making appropriate changes to further align with market practices and the expectations and indications of investors and proxy advisors. The following are the main changes introduced compared to 2023:
	• With the aim to incentivize, motivate and retain selected employees and to align the interests of the Group's management with the long-term value creation for shareholders, a share-based Long Term Incentive Plan has been introduced for the three-year performance period 2024-2026. The Plan sets financial and sustainability performance goals linked to the 2024-2026 MYP and provides for the payment of a bonus in shares over a multi-year period for the three-year performance period 2024-2026.
	• With regard to the 2024 Short-Term Incentive System for Employees, new sustainability parameters have been set out in the scorecard of the Chief Executive Officer and General Manager and other Identified Staff, within the "Stakeholder Value" macro-category, in line with the KPIs and targets of the 2024-2026 ESG MYP. In addition, starting in 2024, the "Tone from the top" goal has been integrated with reference to the contribution to the promotion of sustainability initiatives and behaviors within the organization. Furthermore, in the 2024 Incentive System for Financial Advisors, specific sustainability targets have been introduced relating to the percentage of assets held in funds and sicavs pursuant to Articles 8 and 9 of Regulation (EU) 2019/2088 (SFDR) and to the recruitment of financial advisors of the
	least represented gender. • As part of the Group's commitment to ensuring the Remuneration Policy is gender neutral, specific objectives relating to the improvement of the Gender Equity Pay Gap and Gender Balance in line with the 2024-2026 ESG MYP have been included in the 2024-2026 Long-Term Incentive Plan. • The weight of each financial and non-financial objective in relation to the overall performance appraisal is reported in the 2024 Chief Executive Officer and General Manager Scorecard. It's worth mentioning the new sustainability
	objectives, in alignment with the 2024-2026 ESG MYP, for which measurable targets have been set ex-ante in order to ensure an objective and transparent evaluation.

	Information of how the institution ensures that staff in internal control functions are remunerated independently of the businesses they oversee.
	In order to guarantee the independence of the corporate control functions (Internal Audit, Compliance, Risk Management, Anti-Money Laundering) from the results of the areas they monitor and to minimize potential conflicts of interest, no economic objectives or objectives linked to the economic results of the monitored areas are assigned. The individual objectives for the employees of these functions primarily reflect the performance of their own function. Additionally, the variable remuneration of Identified Staff of the Company Control Functions cannot exceed 1/3 of the fixed remuneration in line with the applicable regulatory framework and the incentive systems reflect the nature of their responsibilities and consistent with market practices. In order to adequately remunerate qualified and expert personnel in these functions, ensuring competitiveness in terms of total compensation, the Identified staff belonging to the corporate control functions benefit from a specific "Role based allowance" on the basis of the global band title. Role-Based Allowances (RBA) are considered fixed remuneration, in line with regulatory provisions and market practices. From a governance point of view, the Remuneration Committee directly supervises the remuneration of all Identified Staff belonging to the corporate control functions, regardless of their global band title. In addition, the Corporate Bodies Regulation provides that the Risk and Related Parties Committee is involved in setting and evaluating performance goals and in defining the overall remuneration of the Heads of corporate control functions. Goals linked to economic results are also avoided for the Head of Human Resources and the Manager in charge of financial statements, whose remuneration is predominantly fixed. For the Identified Staff belonging to the Control Functions, Human Resources and Manager in Charge, any implications on the annual bonus of the application of the Zero Factor clause, which is activated in the event of failure to achieve at
	least one of the access conditions, are assessed by the Board of Directors, considering their independence from the economic results of the areas under their control.
	Policies and criteria applied for the award of guaranteed variable remuneration and severance payments.
	The other forms of remuneration are subject to an-hoc decision-making process through the involvement of the relevant functions and, where required, the corporate bodies. Welcome bonus and retention bonus are considered variable remuneration and are limited only to exceptional situations or related to hiring, the need to attract the best competencies from the market, the launch of special projects, high risk of leaving for critical/strategic employees/roles, in line with the market practices. Bonuses linked to the hiring of new staff cannot be paid more than once to the same person, neither by the bank nor by any other company of the banking group and contribute to the determination of the limit to the ratio between fixed and variable remuneration of the first year, unless it is paid as a lump sum upon hiring. Retention bonuses, in accordance with Bank of Italy Circular No. 285 of 2013, may be paid to staff by reason of their remaining in service for a predetermined period of time or until a specified event, and are paid not earlier than the end of the retention period or the occurrence of the event. These forms of remuneration, awarded in compliance with regulations in force and the governance processes of the Group, are not a common practice for Identified Staff. The other forms of remuneration are granted in compliance with the regulations in force and are defined in line with the governance processes of FinecoBank S.p.A. and FinecoBank Group. All remuneration classified as variable remuneration is subject to the applicable rules (e.g. cap on the ratio between variable and fix remuneration, deferral) as well as to malus conditions and claw-back actions, as legally enforceable. These components are taken into account as retention measures in the Resolution Plan adopted by the Group in line with the Single Resolution Board's Operational Guidance for Operational Continuity in Resolution. With reference to severance pay, the Shareholders' Meeting of 10 April 2019 approved the Termination Payments Policy (so-called "Severance"), incorporating the regulatory provisions of the Circular no. 285/ 2013 of the Bank of Italy, and in particular the provisions regarding the amounts agreed in view of or on the occasion of the early termination of the employment relationship.
c) Description of the ways in which current and future risks are taken into account in the remuneration processes.	For more details, refer to Section I paragraph 3.2.4 of the 2024 Remuneration Policy. As described in point b), the link between risk and remuneration is guaranteed by directly linking the bonus pool with the relevant risk profiles as defined in the reference framework for determining the risk appetite. The entry conditions for 2024 are the following: Net Operating Profit adjusted >0, Net Profit >0, CET1 Ratio >10.7%, Liquidity Coverage Ratio >150%, Net Stable Funding Ratio >125%. Notably, only if all entry conditions are met, the bonus pool is confirmed with the possibility of applying further adjustments (as a multiplier) based on the overall assessment of the risk factors included in the "CRO dashboard". The CRO dashboard is risk-adjustment mechanism that includes specific risk indicators taken from the Risk Appetite Framework connected to capital, liquidity, risk & return, Credit, Interest Rate Risk on Banking Book, Operational risk, such as LCR, EL stock, EV Sensitivity, ROAC etc. The Risk Management function performs the CRO Dashboard evaluation, on the basis of a specific methodology approved by the Board of Directors, resulting in a multiplier of the bonus pool according to a negative (50% and 75%), neutral (100%) or positive (110% and 120%) range (the risk-adjustment mechanism applies also to the bonus pool for financial advisors with a correction range from 50% to 125%). The opportunity to award an extra performance in the bonus pool can only be granted in case of positive EVA at the end of the financial year. For more details, refer to Section I paragraph 4.2 and 4.3 of the 2024 Remuneration Policy.
d) The ratios between fixed and variable remuneration set in accordance with point (g) of Article 94(1) CRD.	In compliance with the applicable regulatory provisions, the Ordinary Shareholders' Meeting of FinecoBank established a maximum ratio between the variable and fixed component of the remuneration equal to 2:1 for employees belonging to the business functions. For the rest of the employees, a maximum ratio equal to 1:1 is usually adopted (the variable component, if present, is limited for all the personnel of the corporate control functions and of the human resources function). The variable remuneration of Identified Staff in company control functions cannot exceed 1/3 of the fixed remuneration. The remuneration is predominantly fixed for the Head of Human Resources and the Manager in charge of financial statements. In line with the applicable regulations, for Financial Advisors belonging to Identified Staff, a 2:1 ratio is applied between the non-recurring and the recurring component of the remuneration. The adoption of a ratio of 2:1 between variable and fixed compensation does not have any implication on the Bank's capacity to continue to respect all prudential rules, in particular capital requirements.

e) Description of the ways in which the insti	An overview of main performance criteria and metrics for institution, business lines and individuals.
tution seeks to link per formance during a per formance measurement	The link between profitability and remuneration is guaranteed by directly linking the bonus pool with company results. Notably, specific entry conditions are defined, which assess the Group's performance in terms of profitability, capital and liquidity.
period with levels of re muneration.	Entry conditions for 2024 take into consideration, in fact, the following corporate performance indicators: Net Operating Profit adjusted, Net Profit, CET1 Ratio, Liquidity Coverage Ratio, Net Stable Funding Ratio (for the definitions, refer to Section I, paragraph 4.2 of the 2024 Remuneration Policy).
	The achievement of all entry conditions allows to confirm the bonus pool defined in the budget phase by applying the "funding rate", a percentage of the Net Operating Profit (net of Provisions for Risk and Charges, corresponding to Profit Before Tax), and taking into consideration historical data analysis, expected profitability, business strategy and previous year pool.
	Further adjustments to the bonus pool can be applied on the basis of the overall assessment of the risk factors included in the so-called "CRO dashboard (as described in point c). For the subsidiary Fineco Asset Management DAC, additional entry conditions are envisaged at local level, which reflect
	the specific nature of the business, as well as other performance and risk adjustment parameters.
	With regard to employees, individual bonuses are defined within the annual performance appraisal process, based on the principles of transparency and clarity to ensure a direct link between variable remuneration and performance, taking into consideration the internal benchmarking analysis based on the role and in compliance with the maximum ratio between variable and fixed remuneration approved by the Shareholder's Meeting.
	The annual performance appraisal process requires a goal-setting phase at the beginning of the year for all Identified Staff. The individual goals are assigned through the Scorecard, which adequately balances economic-financial and non-economic factors. Specifically, the 2024 Scorecard for Identified Staff provides for a minimum of 4 and maximum 6
	goals that reflect the Bank and FinecoBank Group's strategy. The Scorecard includes 4-6 goals linked to the Multi-Year Plan, to business objectives and/or to the role, with an overall weight of 80% on the Scorecard, and up to 2 sustainable goals, defined as the ability to generate and sustain value for all stakeholders over the medium to long term, with a 20% weight on the Scorecard.
	For Company Control Functions, Human Resources department and the Manager in charge of financial statements, no goals linked to economic results are assigned, in order to minimize potential conflicts of interest and be independent from the results of the respective areas.
	For the purposes of performance appraisal, the reference target and the level of achievement, according to predefined evaluation scale, are defined for each quantitative objective. Qualitative objectives are evaluated based on specific parameters determined ex-ante. Each quantitative and qualitative objective is evaluated on the basis of a 5-point rating scale with a descriptive outcome (from "Below Expectations" to "Greatly Exceeds Expectations"), which drives the definition of the individual bonus amount. Therefore, the overall performance is assessed from 'Below' to 'Greatly
	Exceeds' on the basis of the weighted average of the values assigned to each goal, also taking into account additional external context and/or market factors. In line with the principle of "pay for performance", the individual bonus is allocated to beneficiaries based on the performance appraisal.
	Additionally, individual behaviors (compliance with internal and external rules and regulations, absence of disciplinary actions and completion of mandatory training) are also considered in order to award bonuses. With regard to Financial Advisor Identified Staff, the performance assessment, is based on specific parameters (by way of example, total net sales goal and total net sales under management goal, development activities, value generated by
	the requalification of assets in liquidity and asset under custody in Guided Products etc.). In order to award incentives individual behaviors (compliance with internal and external rules, Compliance rules and Group's integrity values and regulations and absence of disciplinary actions) are also considered (compliance assessment). In addition, to further strengthen compliance, a "Scoring" system is in place, consisting of an adjustment mechanism resulting from the assessment of compliance indicators and quality of operations, relating to specific areas
	such as MIFID, transparency, mandatory training, AML etc. This system is applied during the incentive period and can lead to the revision of the amount of the accrued bonus.
	An overview of how amounts of individual variable remuneration are linked to institution-wide and individual performance.
	Variable remuneration is linked to company performance, as described in the previous point related to the bonus pool, the amount of which is directly proportional to the results achieved by the Bank.
	Individual bonus amounts are defined within the annual performance appraisal process, based on the principles of transparency and clarity to ensure a direct link between variable remuneration and performance.
	Information on the criteria used to determine the balance between different types of instruments awarded including shares, equivalent ownership interest, options and other instruments.
	Bonus is delivered for Identified Staff through immediate (upfront) and deferred installments - in cash or in FinecoBank ordinary shares - over a maximum 6-year period. No other financial instruments are currently envisaged. In line with Circular no. 285/2013 of the Bank of Italy, at least 50% of the overall variable remuneration of Identified Staff
	is paid in FinecoBank ordinary shares. 56% of the bonus for the Chief Executive Officer and General Manager and for other roles provided for by the law (such as Deputy General Managers etc.) with significant variable remuneration is paid in shares. The share quota is equal to
	55% for the roles provided by law with no significant variable remuneration. Finally, for the other identified staff with no significant amount of total variable remuneration, the share component of the variable remuneration is equal to 50%. With reference to Financial Advisors, a balanced structure of payments in cash (50%) and shares (50%) was defined in
	2024.

	Information of the measures the institution will implement to adjust variable remuneration in the event that performance metrics are weak, including the institution's criteria for determining "weak" performance metrics.
	Specific entry conditions link the bonus pool to company performance, based on profitability, capital and liquidity indicators.
	The bonus pool is confirmed only if all entry conditions are met. If even one entry condition is not met, the Zero Factor clause is applied to the Identified Staff thus zeroing out the bonus pool for the reference year while previous systems deferrals could be reduced from 50% to 100% of their value, based
	on final actual results. For the rest of the population a significant reduction will be applied. It is understood that the BoD can allocate part of the pool for retention purposes or to ensure the competitiveness on the market. For the Identified Staff belonging to the Control Functions, Human Resources and Manager in Charge of the Financial
	Statements, the implications on the annual bonus of the application of the Zero Factor will be specifically assessed by the Board of Directors, considering their independence with respect to the economic results of the areas subject to their control.
f) Description of the ways in which the institution seeks to adjust remuner	informazioni sui criteri dell'ente per le rettifiche ex post (malus durante il periodo di differimento e restituzione dopo la maturazione, se consentiti dal diritto nazionale);
ation to take account of long-term performance.	Bonus is delivered through immediate (upfront) and deferred installments - in cash or in FinecoBank ordinary shares - over a maximum 6-year period. The payment structure has been defined in line with Bank of Italy provisions requiring a retention period for both upfront and deferred shares. The 2024 payment schemes are based on two time horizons (5 and 6 total years) differentiated on the basis of the target
	population and of the total amount of variable remuneration awarded for the performance year. For the CEO and GM and other roles provided by law with a significant amount of total variable remuneration in the per formance year 2024 (≥ 435,000 €) a 5-year deferral scheme applies with an overall payout structure of 6 years, with 60% of bonus deferred. 56% of the variable remuneration is delivered in shares (of which 20% upfront and 36% deferred),
	while 44% is paid in cash (of which 20% upfront and 24% deferred). For the other roles provided by law with no significant amount of total variable remuneration (< 435,000 €) a 5-year payout scheme applies with an overall payout structure of 6 years, with 50% of bonus deferred. 55% of the variable remuneration is delivered in shares (of which 25% upfront and 30% deferred), while 45% is paid in cash (of which 25% upfront and 20% deferred).
	For the other identified staff with no significant amount of total variable remuneration a 4-year deferral scheme applies with an overall payout structure of 5 years, with 40% of bonus deferred. 50% of the variable remuneration is delivered in shares (of which 30% upfront and 20% deferred), and 50% is paid in cash (of which 30% upfront and 20% deferred). No deferral is applied in the presence of an annual variable remuneration equal to or less than € 50,000 and equal to
	or less than one third of the total annual remuneration. Regarding Financial Advisors, for the Identified Staff with a significant amount of total variable remuneration a 4-year deferral scheme applies with an overall payout structure of 5 years, with 60% of bonus deferred. 40% of the bonus is deferred over a 4-year period for the Identified Staff with no significant amount of total variable remuneration. In order to align the long-term interests of the Bank's Management with the long-term value creation for shareholders, a
	share based long-term incentive plan for employees was launched. The Plan sets performance goals for the three-year performance period 2024-2026 in terms of value creation, industrial sustainability, risk and stakeholder value (ESG), in line with the 2024-2026 Multi Year Plan. In particular, financial performance goals such as ROAC, Net Sales of AUM, Total Net Sales, Cost Income Ratio and Ope
	rational Losses on Revenues have been set. Three ESG parameters have been identified with regard to Scope 1 and 2 (market-based) emissions reduction, the achievement of Diversity, Equity & Inclusion goals, and the enlargement of the ESG product offering with article 8 e 9 SFDR funds.
	The Plan provides for entry and malus conditions, claw-back conditions and a specific risk-adjustment mechanism. The plan provides for the allocation of FinecoBank ordinary shares to be delivered in several instalments over a mul ti-year period, defined according to the categories of beneficiaries and in line with applicable regulatory provisions. For further details, please refer to Section I paragraph 5 of the 2024 Remuneration Policy.

9

	if permitted by national law).
	Malus and claw-back clauses may be activated in order to take into account individual behaviors in violation of external regulations or internal codes adopted in the reference period in which the variable remuneration is accrued (malus and claw back clauses apply also to Financial Advisors, compatibly with the specificity of their role). The malus clause (i.e. the reduction/cancelation of the variable remuneration) can be activated to the variable remuneration to be awarded or awarded but not already paid related to the performance period, which the compliance "violation" is referred to.
	The claw-back clause, (i.e. the return of all or part of the variable remuneration) can be activated with reference to the overall variable remuneration already paid, awarded for the performance period which the "violation" is referred to, without prejudice to more restrictive local laws or provisions and as legally enforceable, for a period up to 5 years after each instalment (upfront or deferred) has become available to the beneficiary (that means after deferrals and/or applicable holding period), even after the termination of the employment relationship. Malus and claw-back can be activated in case the individual:
	- has displayed conduct that does not comply with legal, regulatory or statutory provisions or with codes of ethics or conduct applicable to the bank, in the cases envisaged by the latter; has adopted further conduct that does not comply with legal, regulatory or statutory provisions or with codes of ethics or conduct applicable to the bank, which resulted in a significant loss for the bank or for customers; - has contributed with fraudulent behavior or gross negligence to incurring significant financial losses, or by his conduct had a negative impact on the risk profile or on other regulatory requirements at Bank or FinecoBank Group level;
	- has engaged in misconduct and/or fails to take expected actions which contributed to significant reputational harm to the Bank or the FinecoBank Group, or which were subject to disciplinary procedures, included those still in progress, or measures by the Authority;
	- is the subject of disciplinary measures and initiatives envisaged in respect of fraudulent behavior or characterized by gross negligence during the reference period; - has infringed the requirements set out by articles 26 TUB and 53 TUB, where applicable, or the obligations regarding remuneration and incentives.
	Furthermore, malus and claw-back reflect the performance levels net of the risks assumed or actually achieved. The entry conditions as described in point e) work as malus conditions for the deferrals of previous year's incentive
	systems. For more details, refer to Section I paragraph 2.5.3 of the 2024 Remuneration Policy.
	Where applicable, shareholding requirements that may be imposed on identified staff.
	In line with the "pay for sustainable performance" principle, minimum levels for company share ownership are set for Executives, aiming to align interests of top management to those of shareholders by assuring appropriate levels of personal investment in FinecoBank shares over time. Effective January 1st, 2023, the Board of Directors has increased the share ownership requirements for the Chief Executive Officer and General Manager and the other Executives with strategic responsibilities, respectively to 200% and to 100% of the fixed remuneration. As a rule, the established levels described should be reached within 5 years from the first appointment in the covered role or starting from January 1st, 2023, for those already holding the above positions, and they should be maintained for the entire duration of the role covered.
	The established levels should be reached through a linear pro-rata approach, providing for a minimum portion every year.
	For more details, refer to Section I paragraph 2.5.4 of the 2024 Remuneration Policy.
g) The description of the main parameters and rationale for any variable components scheme and any other non-cash	Information on the specific performance indicators used to determine the variable components of remuneration and the criteria used to determine the balance between different types of instruments awarded, including shares, equivalent ownership interests, share-linked instruments, equivalent non cash-instruments, options and other instruments.
benefit in accordance with point (f) of Article 450(1) CRR.	The overall variable remuneration (bonus pool) is defined consistently with the performance of the Bank, by applying the funding rate, a percentage of the Net Operating Profit (net of Provisions for Risk and Charges, corresponding to Profit Before Tax), and taking into consideration historical data analysis, expected profitability, business strategy and previous year pool.
	Further adjustments to the bonus pool can be applied on the basis of the overall assessment of the risk factors included in the so-called "CRO dashboard (as described in point c). Furthermore, as described in point e), in order to confirm the bonus pool, all entry conditions - which take into account corporate performance indicators such as Adjusted Net Operating Profit, Net Profit, CET1 Ratio etc. - must be met. The incentive system for Identified Staff provides a balanced structure of "upfront" and "deferred" payments, in cash and/or in shares, to be paid over a multi-year period for all Identified Staff. With reference to the criteria adopted for balancing the share and cash components, please refer to point e) and for the description of the payout schemes refer to point f).
h) Upon demand from the relevant Member State or competent authority, the total remuneration for each member of the management body or senior management.	Please refer to the 2024 Remuneration Report, Section II of the 2025 Remuneration Policy and Report.

CRR.	i) Information on whether For the point, institutions that benefit from such a derogation shall indicate whether this is on the institution benefits the basis of point (b) of Article 94(3) CRD. They shall also indicate for which of the remuneration from a derogation laid principles they apply the number of stoff members that benefit from the derogation(s) and their down in Article 94(3) total remuneration, split into fixed and variable remuneration. CRD in accordance with With reference to the remuneration paid in 2024, in line with the Circular no. 285/2013, the derogation was applied point (k) of Article 450(1) pertaining to art. 94 paragraph 3 letter b) of the CRD, according to which no deferral is applied in the presence of an annual variable remuneration equal to or less than € 50,000 and equal to or less than one third of the total annual remuneration. The derogation therefore applies to the Remuneration Policy concerning the deferral of at least 40% of variable remuneration. The Identified Staff who benefited from the derogation are 2, with a total remuneration of € 237,964, of which fixed € 182,964 and variable € 55,000.
disclose the quantitative information the on remuneration of their collective management differentiating body, between executive and non-executive members accordance with in Article 450(2) CRR.	j) Large institutions shall Please refer to the 2024 Remuneration Report, Section II of the 2025 Remuneration Policy and Report.

FinecoBank S.p.A. - Internal Use Only

1.2 QUANTITATIVE DISCLOSURE

Template EU REM1 - Remuneration awarded for the financial year

			a	b	c	d
			MB Supervisory function	MB Management function	Other senior management	Other identified staff
1		Number of identified staff	10	1	4	31
2		Total fixed remuneration	€ 1.534.251	€ 1.000.000	€ 1.890.000	€ 15.902.255
3		Of which: cash-based	€ 1.534.251	€ 1.000.000	€ 1.890.000	€ 15.902.255
4 EU-4a		(Not applicable in the EU) Of which: shares or equivalent ownership interests
5	Fixed remuneration	Of which: share-linked instruments or equivalent non-cash instruments
EU-5x		Of which: other instruments
6		(Not applicable in the EU)
7		Of which: other forms
8		(Not applicable in the EU)
9		Number of identified staff		1	4	31
10		Total variable remuneration		€ 1.000.000	€ 2.292.000	€ 4.674.022
11		Of which: cash-based		€ 440.000	€ 1.011.250	€ 2.290.923
12		Of which: deferred		€ 240.000	€ 539.000	€ 1.001.959
EU-13a		Of which: shares or equivalent ownership interests		€ 560.000	€ 1.280.750	€ 1.991.099
EU-14a	Variable remuneration	Of which: deferred		€ 360.000	€ 808.500	€ 944.359
EU-13b		Of which: share-linked instruments or equivalent non-cash instruments
EU-14b		Of which: deferred
EU-14x		Of which: other instruments				€ 392.000
EU-14y		Of which: deferred				€ 252.000
15		Of which: other forms
16		Of which: deferred
17	Total remuneration (2 + 10)		€ 1.534.251	€ 2.000.000	€ 4.182.000	€ 20.576.277

Other Identified Staff - includes the recurring and non-recurring remuneration of the 11 Financial Advisors classified as Identified Staff for the year 2024.

FinecoBank S.p.A. - Internal Use Only

Template EU REM2 - Special payments to staff whose professional activities have a material impact on institutions' risk profile (identified staff)

		a	b	c	d
		MB Supervisory function	MB Management function	Other senior management	Other identified staff
	Guaranteed variable remuneration awards
1	Guaranteed variable remuneration awards - Number of identified staff
2	Guaranteed variable remuneration awards -Total amount
3	Of which guaranteed variable remuneration awards paid during the financial year, that are not taken into account in the bonus cap
	Severance payments awarded in previous periods, that have been paid out during the financial year
4	Severance payments awarded in previous periods, that have been paid out during the financial year - Number of identified staff
5	Severance payments awarded in previous periods, that have been paid out during the financial year - Total amount
	Severance payments awarded during the financial year
6	Severance payments awarded during the financial year - Number of identified staff
7	Severance payments awarded during the financial year - Total amount
8	Of which paid during the financial year
9	Of which deferred
10	Of which severance payments paid during the financial year, that are not taken into account in the bonus cap
11	Of which highest payment that has been awarded to a single person

Template EU REM3 - Deferred remuneration

		a	b	c	d	e	f	EU-g	EU-h
	Deferred and retained remuneration	Total amount of	Of which due to vest in the financial year Of which vesting in		Amount of	Amount of performance	Total amount of adjustment during the	Total amount of deferred	Total of amount of deferred remuneration
		deferred		subsequent financial years	performance	adjustment	financial year due to ex post implicit	remuneration awarded	awarded for previous performance period
		remuneration			adjustment made in	made in the financial	adjustments (i.e.changes of value of	before the financial year	that has vested but is subject to retention
		awarded for previous			the financial year to	year to deferred	deferred remuneration due to the	actually paid out in the	periods
		performance periods			deferred	remuneration that was	changes of prices of instruments)	financial year
					remuneration	due to vest in future
						performance years
1	MB Supervisory function
2	Cash-based
	Shares or equivalent ownership
3	interests
	Share-linked instruments or equivalent
4	non-cash instruments
5	Other instruments
6	Other forms
7	MB Management function	€ 4,434,000	€ 1,448,400	€ 2,985,600			€ 296,332	€ 648,860	€ 1,872,000
8	Cash-based	€ 754,800	€ 205,200	€ 549,600				€ 290,000
	Shares or equivalent ownership
9	interests	€ 3,679,200	€ 1,243,200	€ 2,436,000			€ 296,332	€ 358,860	€ 1,872,000
	Share-linked instruments or equivalent
10	non-cash instruments
11	Other instruments
12	Other forms
13	Other senior management	€ 5,507,641	€ 1,622,027	€ 3,885,615			€ 247,380	€ 1,991,812	#FinecoBank S.p.A. - Internal Use Only € 1,174,282
14	Cash-based	€ 1,647,643	€ 461,188	€ 1,186,455				€ 626,952
	Shares or equivalent ownership
15	interests	€ 3,859,999	€ 1,160,839	€ 2,699,160			€ 247,380	€ 1,364,860	€ 1,174,282
	Share-linked instruments or equivalent
16	non-cash instruments
17	Other instruments
18	Other forms
19	Other identified staff	€ 5,298,957	€ 1,648,044	€ 3,650,913			€ 205,397	€ 1,810,941	€ 1,035,352
20	Cash-based	€ 2,398,754	€ 631,968	€ 1,766,786				€ 642,138
	Shares or equivalent ownership
21	interests	€ 2,165,461	€ 814,794	€ 1,350,667			€ 181,573	€ 1,078,509	€ 878,870
	Share-linked instruments or equivalent
22	non-cash instruments
23	Other instruments	€ 734,742	€ 201,282	€ 533,460			€ 23,824	€ 90,294	€ 156,482
24	Other forms
25	Total amount	€ 15,240,598	€ 4,718,471	€ 10,522,128			€ 749,109	€ 4,451,613	€ 4,081,634

Note column f : the total amount considers the amounts vested in the financial year (column b) and results from the change in the prices of the instruments (value at the grant compared to the current value).

Note column EU-h : the total amount includes the deferred portions of previous years's incentive systems vested before 2024 and subject to retention in 2024.

Note Other identified staff : includes the recurring and non-recurring remuneration of the 11 Financial Advisors classified as Identfied Staff for the year 2024.

FinecoBank S.p.A. - Internal Use Only

FinecoBank S.p.A. - Internal Use Only

Template EU REM4 - Remuneration of 1 million EUR or more per year

		a
		Identified staff that are high earners as set out in
	EUR	Article 450(i) CRR
1	From 1 000 000 to below 1 500 000	6
2	From 1 500 000 to below 2 000 000	5
3	From 2 000 000 to below 2 500 000	1
4	From 2 500 000 to below 3 000 000
5	From 3 000 000 to below 3 500 000
6	From 3 500 000 to below 4 000 000
7	From 4 000 000 to below 4 500 000
8	From 4 500 000 to below 5 000 000
9	From 5 000 000 to below 6 000 000
10	From 6 000 000 to below 7 000 000
11	From 7 000 000 to below 8 000 000

13

Column a : Financial Advisors classified as Identified Staff for the year 2024 are included.

Template EU REM5 - Information on remuneration of staff whose professional activities have a material impact on institutions' risk profile (identified staff)

		a	b	c	d	e	f	g	h	i	j
		Management body remuneration			Business areas
		MB Supervisory function	MB Management function	Total MB	Investment banking	Retail banking	Asset management	Corporate functions	Independent internal control functions	All other	Total
1	Total number of identified staff										46
2	Of which: members of the MB	10	1	11
3	Of which: other senior management							4
4	Of which: other identified staff							15	5	11
5	Total remuneration of identified staff	€ 1,534,251	€ 2,000,000	€ 3,534,251				€ 9,620,057	€ 1,081,455	€ 14,056,765
6	Of which: variable remuneration		€ 1,000,000	€ 1,000,000				€ 4,765,000	€ 258,000	€ 1,943,022
7	Of which: fixed remuneration	€ 1,534,251	€ 1,000,000	€ 2,534,251				€ 4,855,057	€ 823,455	€ 12,113,743

Column i: All other - includes the recurring and non-recurring remuneration of the 11 Financial Advisors classified as Identified Staff for the year 2024.