Commerzbank : Remuneration Report 2023 pursuant to section 16 of the IVV

Remuneration Report on the Remuneration of Employees

2023

pursuant to Section 16 of the German Remuneration Ordinance

for Institutions (IVV) of February 14, 2023

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Table of Contents

1	Introduction	3
2	Remuneration strategy	4
3	Compensation governance structure	6
	3.1	Remuneration Control Committee	6
	3.2	Remuneration Officer	7
	3.3	Remuneration Committee	8
	3.4	London Branch Remuneration Committee	8
	3.5	Decision Board	9
4	Remuneration system	10
	4.1	Remuneration parameters	11
	4.2	Determination of the disbursement volume for variable remuneration	12
	4.3	Profit sharing for pay-scale employees	13
	4.4	Variable remuneration for non-pay-scale employees	13
	4.4.1		NPS model	14
	4.4.2	Variable remuneration for executives	15
	4.4.3.	Adaptions to the NPS model from the 2024 financial year onwards	16
	4.4.4.	Employees in control units	17
	4.4.5.	Remuneration of the Board of Managing Directors	17
	4.5	Variable remuneration regulations applicable to all models	17
	4.5.1		Risk Taker identification	17
	4.5.2		Remuneration rules for Risk Takers	18
	4.5.3	Performance assessment for Risk Takers	20
	4.5.4	Prohibition on hedging transactions	21
	4.6	Other remuneration regulations	22
5	Group-wide implementation	23
	5.1	Group-wide remuneration strategy	23
	5.2	Remuneration systems of affiliated institutions	24
	5.2.1 Commerzbank (Eurasija) AO	24
6	Remuneration information	25
	6.1	Quantitative information on remuneration by business area	25
	6.2	Quantitative information on remuneration of Risk Takers	26
	6.2.1		Remuneration paid for the 2023 financial year	26
	6.2.2		Sign-on bonuses and guarantees granted or paid to Risk Takers	28
	6.2.3		Outstanding and deferred variable remuneration from previous years	29
	6.2.4	Quantitative data on remuneration of Risk Takers broken down by business segment	31
	6.3	Number of persons with high remuneration	32
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1 Introduction

The German banking sector continues to operate in a demanding environment, characterised by economic uncertainties and, in Germany, a stagnating economy as well as increasing regulatory requirements. In addition, the year 2023 was overshadowed by wars and political turmoil.

Given the challenging economic conditions, Commerzbank experienced an excellent 2023 financial year. We achieved the key objectives of our "Strategy 2024" ahead of time and even exceeded some of them. This means we have achieved the best result in 15 years. This was followed in November 2023 by the publication of our strategic plan up to 2027. Commerzbank is aiming for further profitable growth in the coming years. Its main aim is to increase commission income in order to become less dependent on the interest rate environment. As the bank for Germany, Commerzbank wants to support its customers in the green and digital transformation and act as an advisor in uncertain times. The goal is to consolidate the trust regained on the capital market and to enable shareholders to participate increasingly in the Bank's success.

To successfully address the challenges, Commerzbank is also continually reviewing its remuneration strategy and structures. This applies to all remuneration models - both to the remuneration model for employees and the Management Board remuneration model - as described in the Remuneration Report pursuant to Section 162 of the German Stock Corporation Act (AktG), and which Commerzbank published separately in the 2023 Remuneration Report in March 2024.

Commerzbank revised its variable remuneration system for employees at the end of 2023. In doing so, the Bank is harmonising the remuneration system for pay-scale and non-pay-scale employees and rewarding success in sales more strongly than before. The new model has been in place since January 2024 and will come into effect for the first time in 2025 upon payment of the variable remuneration for employees.

As a major institution, Commerzbank AG is obliged, pursuant to Section 16 Paragraph 1 of the German Remuneration Ordinance for Institutions (German: Institutsvergütungsverordnung, IVV), in conjunction with Article 450 of Regulation (EU) No 575/2013, to disclose information on its remuneration structures and, pursuant to Section 27 Paragraph 1 Sentence 3 IVV, further information

in the Group context. Along with information on its remuneration policy in general, this disclosure includes in particular explanations on the remuneration systems, remuneration governance, and quantitative information on the overall amount of all remuneration, and in particular on the remuneration of so-called Risk Takers1.

At the European level, the remuneration regulations for banks and financial institutions have been laid down in EU legislation such as the Capital Requirements Directive (CRD)2 and the Capital Requirements Regulation (CRR)3, in their respective current versions.

At the national level, the remuneration requirements of CRD are implemented in German law through the German Remuneration Ordinance for Institutions and the German Banking Act (Kreditwesengesetz, KWG). As the final stage in a three-stage implementation process, they ensure that the principles and standards of the Financial Stability Board (FSB) and the compensation-related regulations of CRD are anchored in national law.

The "Guidelines on Sound Remuneration Policies under Directive 2013/36/EU" 4 (from the European Banking Authority, EBA) define the European-level provisions fixed in CRD more concretely in order to harmonise the sometimes-heterogeneous legislation implementing CRD in the various EU states. The EBA guidelines are implemented in German law through the German Remuneration Ordinance for Institutions as well as through the German Banking Act (Kreditwesengesetz).

This Remuneration Report summarises the employee remuneration systems applicable at Commerzbank AG and in the Group context for the 2023 financial year and provides supplementary information on subsidiaries included in the companies consolidated for regulatory purposes, which do not provide their own disclosures.

1	For the definition of Risk Takers, see Chapter 4.5.1.	3	Regulation (EU) No 575/2013 of the European Parliament and of the
2	Directive 2013/36/EU of the European Parliament and of the Council of 26		Council of 26 June 2013.
	June 2013.	4	EBA/GL/2021/04 of 02 July 2021.

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2 Remuneration strategy

The remuneration strategy sets the guidelines for the remuneration policy within Commerzbank Group in order to ensure competitive remuneration of employees in line with their performance and to satisfy the various regulatory requirements. The remuneration strategy is derived from the human resources strategy and is in harmony with the business strategy and risk strategy of Commerzbank Group. It is generally applicable to the entire Group.

In a challenging regulatory and economic environment, the human resources strategy, which is aligned to the Group's business and risk strategy, defines an operational framework and medium- and long-term goals for HR work (strategic core issues). To this end, the HR requirements of the 2027 strategy program (Group strategy) were analysed and fields of action and core topics for HR management were derived from this.

The three pillars of the Group strategy - growth, excellence and responsibility - also form the core of the HR strategy, with employees at its centre. With this in mind, the Bank is striving to achieve a sustainably high level of employee satisfaction through its HR work. Consequently, the HR strategy defines action areas through which a culture of trust within the Group can be supported and promoted in order to make both the people and the organisation sustainably successful though the development of each individual employee and respectful cooperation between employees.

The core topics identified include the development of a Bank-wide young talent strategy (Attraction & Sustaina- bility), the digitalisation of the HR portfolio (Employee Experience), the further development of an innovative learning portfolio (Learning & Development) as well as increasing employee engagement and promoting fair remuneration (Culture & Leadership).

The remuneration strategy is developed within the Human Resources Division and coordinated with the experts and managers responsible for the HR strategy. The remuneration strategy is submitted to the Remuneration Committee (please see Chapter 3.3) for review and approval and then passed by the Board of Managing Directors of Commerzbank AG.

The remuneration strategy was first approved by the Board of Managing Directors of Commerzbank AG in the 2015 financial year and subsequently acknowledged by the Supervisory Board. Since then, it has been reviewed regularly and amended as needed, especially with regard to the continually changing regulatory requirements, an increased focus on results and performance in conjunction

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with employee behaviour crucial to the Bank's success, and possible options to optimise the remuneration structures from a business-oriented point of view.

In December 2021, Commerzbank AG updated its remuneration strategy in response to the "Strategy 2024" business strategy and the fourth version of the German

Remuneration Ordinance for Institutions (Institutsvergütungsverordnung, IVV). In addition to the amendments required by the new version of the IVV, in particular with regard to retention periods and the amended regulation regarding the Risk-Taker threshold (see Chapter 4.5.2), supplementary provisions were added especially in connection with the implementation of the strategy and the establishment of the principle of gender- neutral remuneration on a common Group-wide basis and also to reinforce sustainability aspects in the Group's remuneration systems. The updated remuneration strategy has been in effect at Commerzbank AG since the beginning of the 2022 financial year and was gradually replacing the old version in the subsidiaries of Commerzbank Group.

As a result of the Strategy adjustment through the strategic programme up to 2027 and the derivation of a new HR strategy, the remuneration strategy will also be reviewed during the 2024 financial year to identify requirements for change.

The remuneration strategy applies to Commerzbank AG and the subsidiaries of Commerzbank's regulatory group, i.e., the entities included in the companies consolidated for regulatory purposes covered by the IVV and is implemented within those companies in accordance with their internal regulations (see Chapter 5). The business and risk strategy as well as the HR and remuneration strategies are accessible to all Bank employees via the company intranet.

The remuneration systems for the 2023 financial year supported the Bank in achieving its strategic goals in the period under review. At the same time, they ensure that the Bank will be able to attract and retain qualified employees in a dynamic market environment. In that regard, the Bank ensures at all times that both the remuneration models and parameters and the remuneration components are sustainable, i.e., that they are oriented towards long-term business success and structured transparently.

In particular, the remuneration strategy and systems help to avoid false incentives that run counter to fair and competent advice and to the needs of customers.

In line with the objectives of the remuneration strategy, overall remuneration at Commerzbank consists of several components:

• With competitive remuneration based on results and performance, primarily geared to the company's success, the Bank seeks to place equal emphasis on the interests of shareholders and employees while supporting long-term corporate success.

In addition, the Bank grants further non-discretionary benefits for defined groups of employees.

• With voluntary fringe benefits, the Bank also creates a working environment that encourages performance, recognises employee performance, and supports employees beyond the immediate workplace.
• In addition to statutory and private pension schemes, the Bank offers its employees a company pension scheme with various implementation options. This company pension scheme helps to ensure that employees can retire with a high level of security.

The various remuneration components result in competitive overall remuneration, taking into account an appropriate balance of variable to fixed remuneration.

The continuous further development of the remuneration models continues to ensure employee conduct supportive of the Group's success in the context of changing regulatory requirements.

All remuneration and assessment structures at Commerzbank AG are consistently designed in a gender- neutral manner. In this context, Commerzbank supports the professional development of employees of all genders in equal measure, thereby enabling them to apply their qualifications to challenging specialist, project, and management positions - irrespective of differing employment biographies and changing life circumstances.

Adequate and equal remuneration for equal activities irrespective of gender is one of the basic principles of the Bank's remuneration strategy.

Even beyond remuneration matters, Commerzbank does not tolerate people being disadvantaged in any way for reasons pertaining to gender, ethnic background, religion or world views, disability, age, or sexual identity.

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3 Compensation governance structure

Pursuant to Section 25d Paragraph 7 KWG, Commerzbank has established a Remuneration Control Committee as a committee of the Supervisory Board, and, pursuant to Section 23 et seq. IVV, a Remuneration Officer and a deputy have been appointed.

The Remuneration Committee ensures the proper involvement of control units in the structuring and monitoring of the employee remuneration systems as required in Section 3 Paragraph 3 IVV.

In addition, a Decision Board (see Chapter 3.5) supports the Board of Managing Directors, for example, in the context of the entitlement process with regard to the deferred components of the variable remuneration of Risk Takers.

Commerzbank's compensation governance structure ensures that compliance with all remuneration-related matters is decided and monitored appropriately.

3.1 Remuneration Control Committee

Pursuant to Section 25d Paragraph 7 in conjunction with Paragraph 12 KWG, Commerzbank has set up a Remuneration Control Committee. Pursuant to Section 10a Paragraph 1 and 2 KWG, the Remuneration Control Committee5 can, in principle, perform the function of the Remuneration Control Committee as defined in Section 25d

Paragraph 7 in conjunction with Paragraph 12 KWG for other institutes in the Commerzbank Group.

The Remuneration Control Committee is made up of the Chairman of the Supervisory Board, its Deputy Chairman pursuant to Section 27 Paragraph 1 of the Codetermination Act, two other shareholder representatives and one employee representative. At least one member of the Remuneration Control Committee must have sufficient knowledge and professional experience in the area of risk

5 See the Rules of Procedure of the Remuneration Control Committee on the Commerzbank website in the section Group/Investor Relations/Corporate Governance/Supervisory Board.

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management and risk controlling, in particular with regard to the mechanisms governing the alignment of the remuneration systems with the Bank's risk appetite and risk strategy and its capital resources. A member of the Remuneration Control Committee (not necessarily the same member) should also be a member of the Risk Committee and the Environmental Social Governance Committee (ESG Committee). The Remuneration Control Committee and the Supervisory Board are supported by the Remuneration Officer in performing their monitoring and structuring duties with regard to the remuneration systems.

The Remuneration Control Committee supports the Supervisory Board in appropriately structuring the remuneration systems of the Board of Managing Directors. To this end, it prepares the resolutions of the Supervisory Board on the remuneration of the members of the Board of Managing Directors and on the determination of the total amount of variable remuneration, taking into account the provisions of Section 7 IVV. It also prepares the resolutions to set appropriate remuneration parameters, performance contributions, performance and deferral periods, including the criteria for complete cancellation or partial reduction of deferred variable remuneration, or the clawback of variable remuneration amounts after disbursement. In performing those tasks, it considers in particular the effects of the resolutions on the company's risks and the risk management and takes into account the long-term interests of the shareholders, investors, other stakeholders, and the public.

It conducts regular reviews - at least once a year - of whether the resolutions are still appropriate. If deficiencies are identified, a set of measures is drawn up without undue delay to eliminate them.

The Remuneration Control Committee also supports the Supervisory Board in monitoring the appropriate structure of the remuneration systems for employees who are not executive managers. In particular, it checks on a regular basis, and at least once a year, whether the total amount of variable remuneration for the employees has also been determined in accordance with the regulatory requirements and whether the principles for determining remuneration parameters, performance contributions, disbursement and deferral periods are appropriate. It checks whether the criteria for the complete cancellation or partial reduction of the variable remuneration and the remuneration systems for the employees in control units meet the regulatory requirements, focussing in particular on the remuneration systems for the heads of risk controlling and the compliance function and the employees with a material influence on the

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Bank's overall risk profile (Risk Takers). In addition, the Remuneration Control Committee supports the Supervisory Board in monitoring the process for determining Risk Takers and Group Risk Takers.

It supports the Supervisory Board in its monitoring tasks to ensure proper inclusion of the internal control units and all other division relevant to the structuring of the remuneration systems.

As part of its responsibilities, the Remuneration Control Committee assesses the effects of the remuneration systems on the Bank's risk, capital, and liquidity situation and monitors them to ensure that they are aligned with the Bank's business and risk strategy and take the corporate culture into account.

The Remuneration Control Committee cooperates in particular with the Risk Committee and the ESG Committee and shall obtain advice from persons who are independent of the Board of Managing Directors.

The tasks of the Remuneration Control Committee are set out in its own Rules of Procedure, which are published on the Commerzbank AG websites.

In the 2023 financial year, the Remuneration Control Committee of Commerzbank convened five times. Among other topics, the Remuneration Control Committee addressed the appropriate structuring of the employee remuneration system of Commerzbank AG. The Remuneration Control Committee also reviewed the control units' remuneration system and monitored the control units' and all other relevant divisions' involvement in structuring the employee remuneration system. More information on the contents of the meetings is available in the report of the Supervisory Board, which is part of the Annual Report.

3.2 Remuneration Officer

As a major institution pursuant to Section 1 Paragraph 3c KWG, Commerzbank AG is required to appoint a remuneration officer and a deputy, pursuant to Section 23 IVV, to ensure appropriate, ongoing, and effective monitoring of the employee remuneration systems.

The tasks of the Remuneration Officer are defined in Section 24 IVV and are published in the Bank's internal organisational guidelines. The Remuneration Officer has the necessary authority and adequate material and staff resour- ces, both in terms of quantity and quality, to perform their

monitoring activities effectively and independently, and they take part in training activities on a regular basis.

The Remuneration Officer monitors the employee remuneration systems and the related internal regulations and processes in particular with regard to the IVV. A particular focus is placed on the requirements for remuneration systems for Risk Takers.

In this context, the Remuneration Officer is involved in the new and ongoing conceptual development of remuneration systems for Commerzbank AG and in their ongoing processes. They support the chairperson of the Remuneration Control Committee and the supervisory committee in the performance of their monitoring duties with regard to the employee remuneration systems.

To support the Remuneration Control Committee, the Remuneration Officer checks, inter alia, whether the total amount of variable remuneration for employees was set taking into account Section 7 IVV. Moreover, the Remuneration Officer reviews, among other things, whether the principles for assessing remuneration parameters, performance contributions, and the performance and deferral periods as well as for defining the criteria for complete cancellation or partial reduction of variable remuneration of the employees are in line with the regulatory requirements.

3.3 Remuneration Committee

The Remuneration Committee was set up in order to involve the Bank's control units appropriately in the structuring and monitoring of the employee remuneration systems. The Committee shall also ensure that the control units are involved appropriately in the process for determining Risk Takers in accordance with Section 25a (5b) KWG and Group Risk Takers in accordance with Section 27 Paragraph 2 sentence 1 and Paragraph 4 IVV within Commerzbank Group pursuant to Section 3 Paragraph 3 IVV.

For this reason, the control units as defined in Section 2 Paragraph 11 IVV6 along with the divisions Group Human Resources, Group Finance, and Group Legal have permanent representatives on the Remuneration Committee. The Remuneration Committee is chaired by Group Human

Resources. The Remuneration Officer is a non-voting participant in the Remuneration Committee.

This includes in particular being provided with detailed information and having its views heard when remuneration systems are designed, changed, developed, or withdrawn from use. In these cases, the Remuneration Committee is involved prior to the decision in question being implemented.

In that context, the Remuneration Committee assesses whether the remuneration systems are compatible with the Bank's business, risk, and HR strategy, and whether they must be adjusted or changed in case of changes to the above-mentioned internal standards.

In addition, the Remuneration Committee is involved, giving due regard to the functions of its members, when the total bonus pool is determined. It also performs the appropriateness assessment pursuant to Section 12 IVV.

Section 12 IVV notwithstanding, the Remuneration Committee is obliged to inform the Board of Managing Directors of Commerzbank AG of any adverse developments and, if applicable, to suggest possible courses of action to correct them.

The tasks, composition, and regulations on passing resolutions and the organisation of the Remuneration Committee are set forth in Rules of Procedure, which are published on the Bank's intranet.

In the 2023 financial year, the Remuneration Committee convened seven times and, in addition, was kept up to date on current issues by means of the circulation procedure.

3.4 London Branch Remuneration Committee

In the context of Brexit, Commerzbank AG worked with external consultants to assess whether the London branch would be subject to UK regulations supplementing or deviating from the provisions of the IVV after the end of the Brexit transition period. In this context, the Bank concluded that the London Branch, due to its classification through the British Prudential Regulation Authority (PRA) and the resulting expectations of the supervisory authority, will be required to set up a separate, local remuneration committee

6 At Commerzbank AG the Group Risk Management, including Group Compliance, and Group Audit divisions are considered as control units.

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Group Audit sends a non-voting representative to the Remuneration Committee.

for additional oversight of remuneration-related topics at the branch on the basis of the PRA regulations.

Consequently, the Commerzbank AG Remuneration Committee approved the establishment of a separate committee which commenced its work at the beginning of the 2022 financial year. The rules of procedure for the London Remuneration Committee were approved by the Board of Managing Directors of Commerzbank AG. The composition of the committee is similar to that of the Remuneration Committee of Commerzbank AG, with the branch director and Head of Human Resources in London participating as non-voting members.

The London Remuneration Committee can be consulted on the structuring of the remuneration systems of Commerz- bank AG when decisions affect the London branch, in particular in the Risk Taker identification process and when setting the remuneration of local Risk Takers. In addition, the committee is responsible for structuring the remuneration systems, guidelines, processes and procedures for the London Branch. This includes in particular the identification and classification of Risk Takers at the branch, possible (appropriate) adjustments to the variable remuneration pool of the branch and ensuring that remuneration guidelines and procedures are in place for compliance with the British regulations.

If the committee determines that adjustments are needed, it will submit proposals to the Remuneration Committee of Commerzbank AG. Within the framework of its tasks, it must also notify of possible adverse developments.

The London Remuneration Committee conducts an annual review of the remuneration systems at the branch, taking into account the provisions of British law pursuant to the PRA/FCA guidelines and informs the Remuneration Committee of Commerzbank AG of the results.

The London Remuneration Committee convened three times in the 2023 financial year.

3.5 Decision Board

The sustainable entrenchment of the Culture of Integrity is of essential importance at Commerzbank not only in the wake of increasing regulation. It is also one of the fundamental pillars of its corporate values, thereby forming part of the Bank's self-conception.

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In order to ensure fundamentally uniform decisions in connection with the sanctioning of misconduct by employees and managers, the full Board of Managing Directors of Commerzbank AG has had a cross-segment Decision Board in place for several years in addition to publishing all of the Bank's rules and regulations centrally and creating an Evidence Office as a central control and documentation office.

In this context, the Decision Board is to contribute towards strengthening the Culture of Integrity and guaranteeing sustainable consequence management, which, in turn, supports compliance with the Code of Conduct and the corporate values and promotes these sustainably.

In the context of the remuneration policy, the following matters are presented to the Decision Board:

• All cases in which the manager proposes a (percentage) reduction in variable remuneration due to identified incidents of misconduct.
• All negligent or grossly negligent violations of known rules and regulations as well as statutory or regulatory provisions that result in major/significant damage and/or pose a potential threat to the company's existence.
• All deliberate/intentional violations of known rules and regulations and legal or regulatory provisions that result in medium or extensive/significant damage and/or pose a significant or existential risk potential.

In addition, the Decision Board supports the full Board of Managing Directors of Commerzbank AG as well as the management board or senior management and supervisory or advisory boards of subsidiaries in the context of the entitlement process with regard to the deferred components of the variable remuneration of Risk Takers in Germany and abroad. It ensures a consistent and uniform assessment of the violations and claims identified.

In these cases, the Decision Board also examines whether the conditions for a reduction of the deferred variable remuneration up to the complete loss of the same (malus) or the conditions for the clawback of a variable remuneration already paid out within the meaning of Section 20 Paragraph 6 IVV are met. The final decision in this regard rests with the Board of Managing Directors of Commerzbank AG and the management or supervisory board of the subsidiary in question.

4 Remuneration system

For employees of Commerzbank, the fixed remuneration7 constitutes the main part of their remuneration. The fixed remuneration is based primarily on the employee's qualifications and competencies and the requirements of the function exercised by them. For pay-scale employees of Commerzbank AG in Germany, the remuneration is set in accordance with the criteria of the Framework Collective Agreement for the Private Banking Sector. For non-pay- scale (NPS) employees and employees abroad, the requirements are described in successive career levels (Commap levels). Through the career levels, the Bank's non-pay-scale functions are structured in ascending order in relation to their internal importance. For this purpose, the Bank has defined a remuneration band for each career level on the basis of external market comparisons.

In the 2023 financial year, too, employees of Commerz- bank AG and some subsidiaries received inflation compensation benefits under the regulation passed by the German government in addition to the agreed payments under the collective agreement and remuneration models. The benefit was tax-free and exempt from payroll deductions.

The fixed remuneration may be supplemented by variable remuneration. Along with fixed, market-oriented remuneration on all levels, this guarantees a performance-oriented variable remuneration which takes into consideration the Group's and the various segments' contributions to overall success. In the case of Risk Takers and all employees abroad, their individual performance contributions are also taken into account when determining their variable remuneration.

In the 2023 financial year, apart from the employees' fixed remuneration the following variable remuneration models were applied:

• Profit sharing: for all pay-scale employees at Commerzbank AG in Germany
• Non-pay-scale(NPS) model: for all non-pay-scale employees of Commerzbank AG with the exception of the

management level below the Board of Managing Directors

• Executive model: for all employees of Commerzbank AG working at the management level below the Board of Managing Directors
• Board of Managing Directors model: for all members of the Board of Managing Directors of Commerzbank AG8

In terms of minimising remuneration-induced risks, the various remuneration models are aligned to the respectively applicable regulatory requirements and harmonised as far as possible. This applies in particular with regard to the remuneration parameters, budgeting, the pool proviso pursuant to Section 7 IVV, and the individual distribution. As a result of this, the remuneration system is transparent and understandable for all groups of employees. Subsequently, the aim was to harmonise all existing models further.

Within this scope, the remuneration models of the Board of Managing Directors and employees were aligned with each other in order to strengthen links between remuneration and performance.

Starting from the 2023 financial year, the first step was to align variable compensation more closely for the management level immediately below the Board of Managing Directors (executives of Commerzbank AG) with the Board remuneration model (see Chapter 4.4.2). This will be followed by the variable remuneration models for other employees in the 2024 financial year. To this end, the variable remuneration models for pay-scale and non-pay- scale employees, with the exception of the management level below the Board of Managing Directors, have been merged, with the parameters for calculating the variable remuneration budgets being aligned with the Board and executive models (see Chapter 4.4.3).

Both the current version of the NPS model for all non-pay- scale employees from the 2023 financial year and the version in effect from the financial year 2024 distinguish, in terms of bonus distribution, between Germany and the international locations and between Risk Takers and

7 In addition to the base monthly salary, "fixed salary" or "fixed remuneration" refers to allowances (for international assignments, specific functions), premiums for working on Sundays, on public holidays, and at night, capital accumulation benefits (CAB), discretionary pension contributions, anniversary bonuses, sick pay/transitional allowances, cost reimbursements

for, inter alia, ongoing education, relocations, or costs for maintaining two households, as well as certain non-cash benefits.

8 For detailed information on the Board of Managing Directors remuneration system, please refer to the Remuneration Report pursuant to Section 162 of the German Stock Company Act (AktG) on the Commerzbank website.

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