Commerzbank AG

Environmental & Social Information • Dec 9, 2025

Corporate Governance Roadshow

December 2025

Agenda

• 1. Strategy
• 1. Supervisory Board
• 1. Board of Managing Directors
• 1. Remuneration of the Board of Managing Directors
• 1. Sustainability

1. Strategy

We made great progress and can build on a very strong momentum

• Constant increase in profitability since 2020, combined with a positive share price development and attractive capital returns
• A business model deeply rooted in Germany with very good product and customer coverage, reflected in solid customer ratings and market shares
• An experienced team that has delivered and is highly motivated

Strength of our business model provides excellent baseline for future growth

Corporate Clients

No. 1 bank for German Mittelstand

Leading bank for German trade finance

Global presence in more than 40 countries

PSBC Germany

Leading universal bank with nationwide branch network and 24/7 multi-channel offering

First-class advice for Private and Small-Business Customers

comdirect as best direct bank in Germany and best online broker

mBank

Most efficient digital bank in Poland

Innovative mobile banking offering

Very attractive customer base

Commerzbank creates value for all stakeholder groups

Investors

Achieve competitive Net RoTE of 15% in combination with attractive capital return

Employees

Employee participation in the company's success and creation of attractive jobs

Customers

Financing growth and transformation as well as creating sustainable wealth

Well substantiated and ambitious targets based on prudent assumptions

Assumptions targets 2028

• Conservative rates assumption below current forward rates
• German GDP assumed to grow by ~1.0% p.a.
• Growth in commission income and linked investments managed in tandem
• No inorganic growth assumed
• RWA growth and significant risk transfer (SRT) managed in tandem

Commerzbank. Momentum. Growth and Transformation

We build on our proven strengths to grow profitably

We strengthen our customer focus by enhancing our digital sales channels

We raise our capital efficiency by portfolio optimisation and securitisation

We increase our operational productivity by modernising processes and by efficiently using technology and shoring

We enhance the motivation and performance of our employees

We created strong momentum in the last 12 months

Developed Momentum-strategy with ambitious targets Share price almost doubled

50% 15% 100%

CIR RoTE Payout

Accelerated growth in lending and revenues

12M loan growth Corporate Clients

NCI 9M vs 9M

13% 8% 11%

Revenues 9M vs 9M

Strengthened our leading client franchise

Strong 9M performance towards momentum targets

Operating result

Growth in fee income and mBank revenues drive operating result

Cost-income ratio (CIR)

Steadily increasing efficiency fully in line with targeted trajectory

Net RoTE

Double-digit return level new baseline for growth from 2026 onwards

thereof impact of restructuring expenses net of tax

Regular planning update confirms strategy and targets

Momentum Achievements

Customer focus

New client advisory model in PSBC Germany

Continuous roll-out and enhancement (e.g. KYC-

Implementation of restructuring fully on track

Growth

Successfully leverage franchise for capital accretive loan growth

processes)

First SRT completed – more to come in Q4

Topics of special strategic importance (for the coming quarters)

• Continue growth path and capitalise on German stimulus
• Usage of AI to transform the bank
• Optimise deployment of capital above 13.5% target

Improved SREP requirements underline confidence of regulators in our business model and our growth trajectory

2. Supervisory Board

Collaboration between the Supervisory Board and the Management Board in the German "Two-tier Board System"

Two-tier Board System

A company leadership structure of a company in certain European countries, such as Germany, that comprises two tiers:

• › a Supervisory Board (Aufsichtsrat), on which representatives of shareholders (and if applicable employees) are represented.
• › a Management Board (Board of Managing Directors or Executive Board) that is concerned with the day-to-day running of the business.

Supervisory Board

• › The Supervisory Board appoints the Management Board and ensures the effective composition of the Managing Directors team.
• › The Supervisory Board supervises and advises the Management Board and holds a joint discussion of the strategy.
• › The Supervisory Board oversees the remuneration system of the Board of Managing Directors.

Management Board

• › The Management Board is responsible for independently managing the enterprise.
• › It is obliged to act in the bank's best interest.
• › The Management Board is responsible for the development and execution of the bank's strategy.
• › The Management Board is responsible for the operating business and takes all related decisions.

Shareholders' representatives in the Supervisory Board

New shareholders' representatives since the last shareholders' meeting 2025

Dr. Michael Gorriz

Profound knowledge and experience in technology and operations for financial services, particularly in relation to the modernization of system landscapes and the digitization of business models, the development of procurement strategies, and the introduction of cloud computing due to the previous role as Global Chief Information Officer at Standard Chartered Bank based in Singapore.

Comprehensive experience in technology management in the automotive industry, including merger and de-merger activities, due to various roles in IT management at Daimler AG.

Extensive experience in supervisory board activities with a focus on innovation, technology, and cybersecurity due to various mandates in Europe and Asia.

Sabine Lautenschläger-Peiter

Profound experience in prudential supervision of German and European credit institutions, in particular in risk management und governance, due to previous roles as banking supervisor at the Federal Financial Services Authority of Germany (BaFin), at the Deutsche Bundesbank and at the Single Supervisory Mechanism at the ECB.

Comprehensive knowledge/experience in German, European and international banking regulation as former member of the European Banking Authority, the Basel Committee of Banking Supervision and the Financial Stability Board as well as currently as independent, nonexecutive Board member and member of the Legal Committee of the Dubai Financial Services Authority, Dubai – UAE.

Extensive experience in international institutions, in particular on the subject of banking supervision, banking regulation, financial stability and banking resolution.

Further shareholders' representatives

Prof. Dr. Jens Weidmann

Harald Christ Dr. Frank Czichowski Sabine U. Dietrich Burkhard Keese Daniela Mattheus Caroline Seifert Frank Westhoff

= Representative of the Federal Government

General information on the composition of the Supervisory Board

The Supervisory Board of Commerzbank consists of a total of 20 members of which 10 members are elected by the bank's employees in accordance with the German Co-determination Act – the remaining 10 representatives are elected by Commerzbank's shareholders.

Independence of the Supervisory Board

10 of the 10 shareholders' representatives in the Supervisory Board are independent according to the German Corporate Governance Code. None of them have a personal or business relationship with the bank, its corporate bodies, a controlling shareholder or a company affiliated with the controlling shareholder that could lead to a significant, not temporary conflict of interest. All members of the Supervisory Board are independent according to the European Sustainability Reporting Standards. None of them have an interest, position, association or relationship which, when judged from the perspective of a reasonable and informed third party, is likely to influence unduly or cause bias in decision-making.

Composition of the Supervisory Board

15

* since 09/2024 | no permanent Committee

(as of 07/2025)

Sascha Uebel Frank Westhoff

3. Board of Managing Directors

Board of Managing Directors

The Board of Managing Directors generally consists of a total of seven members, including one Chair and one Deputy Chair.

Dr. Bettina Orlopp Chairwoman

Carsten Schmitt Chief Financial Officer

Michael Kotzbauer Deputy Chairman Corporate Clients Segment

Bernhard Spalt Chief Risk Officer

Sabine Mlnarsky Chief Human Resources Officer

Christiane Vorspel-Rüter Chief Operating Officer

Thomas Schaufler Private and Small-Business Customers Segment

Average age of members of the Board of Managing Directors:

~55 years

Average period of being a board member:

~3 years

Commerzbank's target quota: at least 1 woman

Commerzbank's actual quota: 3 women

Composition of the Board of Managing Directors

Dr. Bettina Orlopp CEO, Board Member since 01.11.2017

Michael Kotzbauer Deputy chairman, Board Member since 14.01.2021

Sabine Mlnarsky CHRO, Board Member since 01.01.2023

Thomas Schaufler Board Member since 01.12.2021

Responsibilities

Previous Commerzbank positions

Former employers

Research Audit Legal Strategy, Transformation & Sustainability Corporate M&A and Investments Communications

• › CFO
• › Board Member Compliance, HR und Legal
• › Divisional Board Member Development & Strategy

› McKinsey & Company

Corporate Clients

• › Divisional Board Member Large Corporates South/East
• › Regional Board Member Asia
• › Divisional Board Member Mittelstandsbank

› Michael Kotzbauer started his career 1990 at Commerzbank

Human Resources

Organisation & Security

› Sabine Mlnarsky was directly appointed as Board Member when she joined the Executive Board

› Erste Group Bank AG › Austrian Airlines

Private and Small-Business Customers

• › Thomas Schaufler was directly appointed as Board Member when he joined the Executive Board
• › Erste Group Bank AG

Composition of the Board of Managing Directors

Carsten Schmitt CFO, Board Member since 19.02.2025

Bernhard Spalt CRO, Board Member since 01.01.2024

Christiane Vorspel-Rüter COO, Board Member since 01.09.2024

Responsibilities

Previous Commerzbank

Former employers

positions

Tax Treasury Investor Relations Finance

› Divisional Board Member (Head of Group Finance)

› Danske Bank A/S

Credit Risk Management Risk Control Cyber Risk & Information Sec. Compliance mBank

› Bernd Spalt was directly appointed as Board Member when he joined the Executive Board

› Österreichische Post AG › Erste Group Bank AG

Big Data & Advanced Analytics Operations Cross Functions Technology Foundations Digital Transformation comdirect Delivery CIO CC CIO PUK

• › CIO Commercial Banking › CIO Investment Banking &
• International

› Landesbank Baden-Württemberg (LBBW)

4. Remuneration of the Board of Managing Directors

Development of BoMD Remuneration System (Structure)

Separation of STI and LTI

• − STI (40%): one-year performance period
• − LTI (60%) three-year forward-looking performance period

STI Structure

• − Qualitative and quantitative objectives (≥80%)
• − Group KPI (operating profit or similar) (max. 20%)

LTI Structure

Group KPIs only

• − Financial KPIs (60%)
• − ESG (20%)
• − Relative TSR (20%)

Adjustments after investor sounding:

• − Financial Group KPI on Short Term
• − Clear und simple KPI structure on Long Term (incl. fixed weighting)
• − Transparency: Description of ex-ante disclosure of LTI KPIs in the remuneration system

Results

• Investors' feedback was considered:
• Separate targets for STI and LTI
• LTI targets for 3 years into the future
• Regulator had no concerns about the new approach
• Resolution of the Supervisory Board in February 2025 on the introduction of the new system
• Approval of the Annual General Meeting in May 2025 with an approval rating of 95.08 %.

Implementation with effect from 1 January 2026

Structure of KPIs (defined in the remuneration system)

Introduction of separate performance criteria for STI and LTI

• Focus on departmental targets (merging with individual targets)
• In addition, one-year Group target in STI to avoid "silo thinking"
• (e.g.) Operating profit as the most important financial indicator for Commerzbank's success
• Through op. profit also connection to the employee compensation system
• Weighting additional Group target max. 20% (total weighting of Group targets must not exceed 70% due to regulatory requirements

• Group targets only
• Within the financial group targets weighting can be flexibly determined by the Supervisory Board
• A maximum of 3 KPIs in financial targets
• NetRoTE, CIR, Net result by way of example only, decision at the discretion of the supervisory board
• The specific KPIs ESG and rTSR, on the other hand, are fixed in the system

KPIs for 2026:

Quant. and qual. criteria 80%

Operating profit 20%

NetRoTE 30%

CIR 30% rTSR 20% ESG 20%

Disbursement in the new system: Principle

Separation of short-term and long-term incentive; the long deferral complies with German legislation

5. Sustainability

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Commerzbank's sustainability strategy follows a holistic view, shaped by ESG building blocks

Our overarching goal is directed by our commitment to meet the global challenges as a responsible partner for sustainable economic and social development

The protection of the environment and climate as well as the support of our customers in their efforts are firmly anchored in Commerzbank.

Social

We value an open corporate culture and actively contribute to society with various commitments.

Governance

Solid values, binding codes of conduct as well as demanding commitments form the framework of our business activities.

Good progress on ESG priorities & consistent plan on Commerzbank's sustainability strategy

Key Achievements 2025

Updated ESG Framework

Commerzbank's updated ESG framework strengthens the commitment to responsible banking across all sustainability dimensions

European Diversity Leader 2026

European Diversity Leader 2026 by FT2 & Statista and listed on AllBright's "Green List" for leadership gender balance

Expansion of ESG Advisory

We established new ESG advisory team in our Capital Markets product division to address the importance of sustainable financing

¹Task Force on Climate-related / Nature-related Financial Disclosure

Nature and Climate Report

First publication aligned with TCFD and TNFD1, detailing governance, strategy and risks, and metrics on climate and nature-related impacts

ESG Transformation Award 2025

1st place for organizational transformation and 2nd place for supporting SME clients in decarbonization and transition financing

Climate Loan

Commerzbank launches Climate Loan to support financing for improving energy efficiency for residential real estate

Outlook

Driving our ESG strategy

Our Net Zero commitment is at the heart of our sustainability strategy. Furthermore, we actively address key topics related to biodiversity within the context of our ESG framework.

Empowering our customers

We want to continuously enhance our sustainable finance product portfolio with a special focus on green infrastructure and ESG-advisory activities. We are committed to supporting our clients in their transformation.

Looking into the future

We are building a robust ESG data infrastructure to adjust to growing reporting requirements and keep screening new business opportunities.

² Financial Times

Corresponding anchoring of sustainable transformation through KPIs in our strategy

Net Zero Portfolio

Net zero CO2 emissions from financing in the overall portfolio by 2050.

10 % Sustainable Loans

At least 10% of our new lending business¹ is issued as sustainable loans.

10 %

Net Zero Banking operations

Net zero CO2 emissions of its own banking operations by 2040.

¹ Sum of all new loan commitments recorded in the last 12 months and existing as of the reporting date. In the FK segment, this includes not only new contracts but also the extension of existing contracts.

The improved ESG framework takes sustainability into account in all dimensions

The most important changes

Sustainable Development Goals

• Alignment of the Sustainable Finance Target with a Sustainable Loan Ratio
• Four new social and governance goals

Structure

• New, improved structure, especially with chapters E, S & G, covering the full spectrum of sustainability
• Modern, streamlined design and simpler language (Promotional Document style)

Contents

• Adapted standards for sustainable loans
• New rating scheme for sustainable loans (Green, Social, Transition)
• Uniform application of the LMA principles for bilateral and syndicated loans
• MiFID II Art. 7a), b), c) as a standard for sustainable investment business
• Optimized list of sustainable uses
• New content in the areas of social affairs and governance (e.g. culture of integrity)

With responsible action and sustainable growth, the ESG framework sends a clear message that is in line with the ESG positioning1

¹ Our ESG positioning: We see sustainability as a responsibility and a success factor. We offer our clients tailored solutions and work with them to shape sustainable change.

Diversity & Inclusion: Essential Component of our Sustainability Strategy and Genuinely Practised

We take on social responsibility – this benefits our employees, our clients, and our business partners

Identifying and fostering potential

37.3% women in management positions1

Employees from 125 nations worldwide1

6.21% employees with disabilities1

¹ As of year-end 2024.

Facilitating worklife balance

Keep in Touch, return guarantee

Company-sponsored childcare, support for employees caring for relatives

Hybrid working, mobile working from abroad, flexible working time models, job sharing, joint leadership

Supporting commitment

Events and awareness sessions on all diversityrelated issues

Information offers and learning paths on all diversityrelated issues via learning platform cliX

1,500 employees in 7 employee resource groups We are committed beyond Commerzbank:

Signatory to and member of the

Co-founder and Participant council member in the BC4D of the Foundation Initiative

Signatory to the United Nations' Women's Empowerment Principles

Member of Unternehmens-Forum e. V. for the inclusion of individuals with disabilities

Our corporate culture includes everyone – regardless of age, gender, provenance, nationality, disability, religion, sexual orientation, or gender identity

Diversity at the center of our organisational culture

Having a diverse and inclusive organization is integral to the success of Commerzbank¹

Employee demographics

• The proportion of women in the Commerzbank Group is 52.5%
• The average age at Commerzbank is 45.4 years²
• 23% of the employees belong to the 40–49 age group²
• The ratio of apprentices (as of 12/2023) is 5.1%3
• Part-time working model is 27.4%

International employees

• 1,371 non-German employees from 100 nations² at Commerzbank AG in Germany
• Employees from about 125 nations work in the Commerzbank Group
• The largest foreign locations are Warsaw (mBank/CERI), Prague, Lódz, Sofia, Malaysia (CTS), London, Singapore, and New York

Disabilities

• 1,700 jobs at Commerzbank AG are filled by employees with disabilities
• 6.21% of all jobs at Commerzbank AG (exceeded requirement of 5% for the sixth year in a row)

Women in management positions

• The target is to staff 40% of all management positions with women by the end of 2030
• The proportion of women on Commerzbank's Supervisory Board is 45%
• Three women (one as CEO) sit on the seven-member Board of Managing Directors

Development: proportion of women in management positions (in %)

¹⁾ Figures as of 12/2024 – updated annually

²⁾ Commerzbank AG Germany, includes: permanent staff & junior-staff members + absences

³⁾ Commerzbank AG Germany, includes: permanent staff + apprentices + SdS

Appendix

Facts and Figures: an Overview

With a client-centric portfolio of financial services, Commerzbank in Germany is the leading bank in the Corporate Clients Business and for the Mittelstand and a strong partner for private and small-business customers with more than €400bn assets under management.

Private and Small-Business Customers

Customers Employees

Corporate Clients

• Customer focus with profitable revenue growth Shaping the digital and sustainable transformation
• Continuously improving capital efficiency

Facts and Figures: Commerzbank's Global Presence

Significant Group companies

Commerzbank Finance & Covered Bond S. A., Luxembourg

Commerz Markets LLC, New York

Commerz Real AG, Wiesbaden

mBank S. A., Warsaw

Operative foreign branches

Amsterdam, Beijing, Brno (office), London, Madrid, Milan, New York, Paris, Prague, Shanghai, Singapore, Tokyo, Vienna, Zurich

Representative Offices/Financial Institutions Desks (FID)

Abidjan, Addis Abeba, Almaty, Amman, Ashgabat, Bangkok, Beijing (FID), Brussels (Liaison Office to the EU), Buenos Aires, Cairo, Casablanca, Dhaka, Dubai, Ho Chi Minh City, Istanbul, Johannesburg, Karachi, Kiev, Lagos, Luanda, Melbourne, Moscow (FID), Mumbai, New York (FID), Panama City, São Paulo, Seoul, Shanghai (FID), Singapore (FID), Taipei, Tashkent, Tokyo (FID), Vilnius, Zagreb

Facts and Figures: Selected Group Financial Figures

Figures	Q3 2025	FY 2024	Q3 2024
Total revenues (in €m)	2,939	11,106	2,735
Operating result (in €m)	1,047	3,837	886
Consolidated result1 (in €m)	591	2,677	642
Cost-income ratio (in %)	57.1	58.8	58.3
CET 1 ratio (in %)	14.7	15.1	14.8
Operating RoTE (in %)	13.0	12.3	11.3
	30 Sep 2025	31 Dec 2024	30 Sep 2024
Employees (full-time equivalents incl. junior staff)	39,787	39,040	39,090

¹ Attributable to Commerzbank shareholders.

Evaluation and Training of the Supervisory Board

Evaluation Training

Annual and event-related review / evaluation of collective and individual suitability:

• At least annual and, if necessary, case-by-case review of collective and individual suitability, availability and reliability.
• At least annual evaluation of structure, size, composition and performance; results are presented to the Supervisory Board, discussed and measures derived from them, if necessary.

As a rule, every three years, the evaluation is carried out by an external consultant; otherwise, it is conducted internally. The last externally conducted evaluation was in 2023.

• Two-step concept: questionnaire and individual interview.
• Extensive evaluation and analysis by experts.
• In-depth discussion of results with whole Supervisory Board and within each Committee will take place.

Commerzbank AG ensures adequate and appropriate qualification of its members of the Supervisory Board, both when new Supervisory Board members are introduced and on an ongoing basis. This ensures that the members of the Supervisory Board meet the legal requirements of their office at all times:

• Offer of on-boarding training for new Supervisory Board members
• Offer of individual training plan as and when required
• Regular training courses and professional development on relevant topics
• As and when required opportunity to attend external training courses

Succession Planning and Stability of the Supervisory Board

The Presidential and Nomination Committee is responsible for succession planning for the shareholder representatives on the Supervisory Board.

The process of succession planning is regulated in Commerzbank's Suitability Guideline.

With sufficient time in advance, before the end of the term of office of a member of the shareholder representatives, the Presidential and Nomination Committee deals with the question of whether the member should be reappointed or proposed for re-election.

It also regularly checks whether the skills profile for the Supervisory Board needs to be adjusted and whether the required skills are covered in the current composition of the Supervisory Board. The skills of each individual Supervisory Board members are shown in the published Supervisory Board qualification matrix, which is regularly reviewed and adjusted.

If reappointment or reelection is not aimed, the Presidential and Nomination Committee begins the search for suitable successor candidates.

The search for suitable candidates is based on the competence profile for the Supervisory Board and the goals set for its composition (e.g. diversity). The results of the aptitude test/evaluation are also taken into account.

Succession Planning for the Management Board

The Presidential and Nomination Committee is responsible for the Management's Board succession planning. The process of succession planning is laid out in detail in Commerzbank's Suitability Guideline.

Commerzbank implemented a strategic and structured, long-term succession planning process. It is built on well-defined role profiles and combines a focus on internal potential development and selection with a thorough mapping of external potentials on the market.

Sufficiently in advance (about 12-9 months before the end of the term of office of a member of the Management Board), the Presidential and Nomination Committee initiates an internal and external potential mapping process based on the role profile and the targets defined for the composition of the Board (e.g. diversity,…). Both, external and internal potential candidates – including the current Board Member – will then be reviewed and assessed in a systematic process. If the current Board Member is deemed to remain suitable for the role, also in comparison to other internal and external potentials, the current Board Member will be re-appointed.

If a re-appointment is not an option, the Presidential and Nomination Committee will continue the search process focusing on those internal and external potential candidates identified in the mapping process. All available candidates will have to pass several rounds of structured interviews with the Committee members and the Management Board members as well as aptitude tests and a preemptive fit& proper-assessment. The candidate deemed the best fit will be recommended to the Supervisory Board for appointment. Before being appointed the final candidate will have to pass a last interview conducted by the whole Supervisory Board.

Remuneration system of the Supervisory Board

As approved by the regular general shareholders' meeting of Commerzbank Aktiengesellschaft on May 15, 2025

Basic remuneration		Additional remuneration
Basic remuneration (in €)		Additional remuneration (in €)
Chairman of the Board	270,000	Chairman of Committee	66,000
Deputy Chairman of the Board	180,000	Member of Committee	33,000
Member of the Board	90,000

• The additional remuneration is paid for a maximum of three committee activities, based on the remuneration of the three highest-paid positions.
• In addition, each member receives an attendance fee of € 1,500 for every meeting or video/telephone conference of the Supervisory Board or one of its committees. In 2025, the attendance rate was 99%.
• The additional compensation for filling committees is not linked to or dependent on the long- or short-term success of Commerzbank. Furthermore, no stock-based components and no variable remuneration are paid (apart from the attendance fee).

Strong commitments and partnerships build the foundation of Commerzbank's main target: Net Zero

2006

2019

2023

From 2025

2050

UN Global Compact

Principles for Responsible Banking (UN PRB)

Partnership for Carbon Accounting Financials (PCAF)

Task Force on Nature-Related Financial Disclosure (TNFD)

Every year, at least 10% of our new lending business is granted as sustainable loans

Net zero CO₂ emissions in the lending and investment portfolio

2008

2020

Charta der Vielfalt

Task Force on Climate-Related Financial Disclosure (TCFD)

Sience Based Targets initiative (SBTi)

2040

Net zero CO₂ emissions in banking operations

Legal Requirements1

• EU-Taxonomy: Framework for climate and environmentally friendly activities and investments
• Supply Chain Due Diligence Act: Law on the obligation of companies to monitor human rights and environmental risks in their supply chains
• Corporate Sustainability Reporting Directive (CSRD): Disclosure and reporting on environmental, social and governance impacts, risks and opportunities

Voluntary commitments1

• Principles for Responsible Banking (PRB): Framework to ensuring that signatory Bank's strategy and practice align with SDGs and Paris Agreement
• Task Force on Nature-Related Financial Disclosures (TNFD): Disclosure of naturerelated risks and opportunities
• Science Based Targets Initiative (SBTi): Management of the customer portfolio according to science-based goals, ensuring decarbonization targets align with the Paris Agreement

¹⁾ Exemplary excerpt

Comprehensive and holistic governance structure established sustainability as top priority

ESG is successively anchored in Commerzbank's policies in consultation with the relevant units

Holistic management by the central division "Group Sustainability Management" with reporting line to the CEO

Bank-wide information and exchange formats, (such as Sustainability Working Group)

Projects in segments and staff functions within the scope of the Group-wide Programme Sustainability 360°

Diversity has a long history at the bank and still enjoys high priority today

1989 today

over 36 years of diversity Currents Plans

First Diversity Initiative:

'Women in Modern Banking' initiative in 1989

Action Plan:

First bank to develop an action plan for the inclusion of people with disabilities

Diversity Charter:

We are one of the first members of the charter in Germany

Governance Anchoring:

Establishment of a global council structure with board commitment

Awareness Formats:

2024: Around 50 events nationwide involving the Board of Managing Directors, executives & role models

Fairness & Partnership:

Establishment of a works agreement, a recruitment policy and D&I purchasing guidelines

Awards & Certificates:

Many awards and certificates1 for our strong commitment to diversity

Female Clients:

New initiatives like 'Finanzheldinnen' and '#togetherstronger'

Women in Management:

We strive to reach a 40% proportion of women in management by 2030

Diverse Customer Groups:

Focusing on digital accessibility and fulfilling the voluntary Action Plan Inclusion 2.0

Leadership Training:

Anchoring D&I in the modern leadership of today and tomorrow

¹⁾ Certificate "audit beruf&familie", European Leader in Diversity, AllBright's "Green List", Total E-Quality-Prädikat, Max-Spohr-Preis and others

Wide range of lived diversity at Commerzbank

Committed employees make a valuable contribution to our open corporate culture in seven ERGs. Additionally, they also represent it to the outside world

Cyber risks are a regular part of the risk management framework of the bank

Board of Managing Directors Supervisory Board

• The Board of Managing Directors is responsible for managing the enterprise.
• The CRO is responsible among others for the Group Cyber Risk & Information Security unit. Within the bank's Three-Lines-of-Defence-modelI it forms the 2nd Line of Defence regarding ICT risks which include cyber risks. The unit is led by the Group CISO who directly reports to the CRO.
• The Cyber Risk and Information Security Committee (CRISCo) serves as the highest decision-making and escalation body for cyber risks below the Board of Managing Directors.
• It meets at least every two months or if needed more frequently.
• It is comprised of among others the CRO, the COO, and the CHRO (who is responsible for Group Organisation & Security).
• The CRO is the chairperson and has a veto right.
• The Group CISO regularly informs the Board of Managing Directors about cyber risks as part of "ICT Risk & Resilience Report."
• In case of a major cyber incident, an ad-hoc CRISCo will be assembled to support decision-making. It decides whether the Cyber Emergency Action Plan (EAP) should be initiated as escalation level. This incident response plan ensures coordination and alignment of response measures with relevant internal and external stakeholders.

Information and communication technology (ICT) risks including cyber risks are addressed by the Supervisory Board in the same way as other material risk types:

• The Supervisory Board is advised by the Risk Committee regarding monitoring the Board of Managing Directors' implementation of the current and future overall risk appetite and strategy.
• In this capacity, the Risk Committee is regularly informed about the cyber risk situation of the bank and acknowledges the "Sub-risk strategy for ICT Risk" and "Digital Operational Resilience Strategy".
• The members of the Risk Committee have, collectively and individually, the knowledge, skills and experience necessary to carry out the Committee's tasks. These, in particular, include knowledge and experience regarding bank-specific risk types, risk management and risk controlling.

Disclaimer

This presentation contains forward-looking statements. Forwardlooking statements are statements that are not historical facts; they include, inter alia, statements about Commerzbank's beliefs and expectations and the assumptions underlying them. These statements are based on plans, estimates, projections and targets as they are currently available to the management of Commerzbank. Forward-looking statements therefore speak only as of the date they are made, and Commerzbank undertakes no obligation to update any of them in light of new information or future events. By their very nature, forward-looking statements involve risks and uncertainties. A number of important factors could therefore cause actual results to differ materially from those contained in any forward-looking statement. Such factors include, among others, the conditions in the financial markets in Germany,in Europe, in the United States and elsewhere from which Commerzbank derives a substantial portion of its revenues and in which it hold a substantial portion of its assets, the development of asset prices and market volatility, potential defaults of borrowers or trading counterparties, the implementation of its strategic initiatives and the reliability of its risk management policies.

In addition, this presentation contains financial and other information which has been derived from publicly available information disclosed by persons other than Commerzbank ("external data"). In particular, external data has been derived from industry and customer-related data and other calculations taken or derived from industry reports published by third parties, market research reports and commercial publications. Commercial publications generally state that the information they contain has originated from sources assumed to be reliable, but that the accuracy and completeness of such information is not guaranteed and that the calculations contained therein are based on a series of assumptions. The external data has not been independently verified by Commerzbank. Therefore, Commerzbank cannot assume any responsibility for the accuracy of the externaldata taken or derived from public sources.

Copies of this document are available upon request or can be downloaded from Commerzbank AG – Investor Relations