Remuneration Policy_Agricultural Bank of China (Luxembourg) Limited

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Remuneration Policy

AGRICULTURAL BANK OF CHINA (Luxembourg) S.A.

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Remuneration Policy

(July 2025)

Disclaimer on Public Disclosure of the Remuneration Policy

This document provides an overview of Agricultural Bank of China (Luxembourg) S.A.'s remuneration policy in compliance with applicable regulatory requirements. The purpose of this disclosure is to enhance transparency regarding the Agricultural Bank of China (Luxembourg) S.A.'s remuneration practices while safeguarding confidential and proprietary information.

The information contained herein excludes any personal or sensitive data relating to individual employees, undisclosed financial targets, strategic remuneration methodologies, and any commercially sensitive details that may impact the Agricultural Bank of China (Luxembourg) S.A.'s competitive position. This document is a high-level summary and does not include specific contractual terms or individualized remuneration arrangements.

For further details or inquiries, please contact luxhr@abchina.com.

1 PURPOSE AND SCOPE

1.1. Agricultural Bank of China (Luxembourg) S.A. (the Bank) recognizes that its human resources are one of its most important assets.

1.2. The Bank operates in a European context characterized by competitiveness and complexity. Hence, it is pivotal for the Bank to attract, motivate and retain employees, who have appropriate professionalisms and competencies, while ensuring an appropriate management of risks and compliance, and promoting the Bank’s values.

1.3. The remuneration policy of the Bank (the Remuneration Policy) defines a competitive remuneration system, balancing strategic business targets and correctly rewarding employees who promote and apply its corporate values.

1.4. The Bank strives to ensure that remuneration packages reflect the relevant duties and responsibilities, are fair and equitable, and incorporate rewards clearly and measurably linked to performance both on an individual and on a corporate basis.

1.5. The remuneration system of the Bank is structured, at the same time, in such a way as to avoid incentives that would encourage employees to take unnecessary and/or excessive risks or to sell products that are not fit for clients.

1.6. For all employees, including identified staff, remuneration decisions made under the Remuneration Policy, are based on a combination of business results, performance against objectives set out in performance scorecards, general individual performance of the role and adherence to the Banks values, business principles, Bank risk-related policies and procedures. Gender-neutral fixed remuneration of employees reflect their professional experience and organisational responsibility, taking into consideration accordingly to the EBA Guidelines.:

1.7. The Remuneration Policy is an internal document focused on informing and educating employees with regard to the Bank’s compensation strategy, governance processes as well as compensation practices and structures. It is not intended to create any right in favour of the employees.

1.8. This Remuneration Policy includes all levels of the Bank and all categories of employees with special emphasis on the identified risk takers i.e. the members of the Board of Directors (the Board), the authorized management (the Authorized Management) and other material risk takers as defined in the Remuneration Policy (together the MRT).

1.9. This Remuneration Policy has been published on the Bank’s intranet site and is available to all employees.

2. REGULATORY COMPLIANCE

2.1. With the ongoing changes in the European financial services industry, international bodies and regulatory environment are forcing banks to a growing attention to remuneration matters, especially with regard to the governance (with a special focus on the role and responsibility of corporate bodies and control functions), the design of remuneration structure and transparency with shareholders, overall aiming at ensuring a sound remuneration practice.

a) Ensuring compliance with regulatory requirements is an overriding consideration in the Bank’s remuneration strategy. The Bank has strived to be at the forefront of compensation regulatory changes and will continue to work to be in compliance with all existing and new requirements.

2.2. In order to be always compliant with the prevailing banking regulation, the Bank foresees the possibility to modify, as appropriate, this Remuneration Policy, in case of new regulations published during the year.

3. CORPORATE GOVERNANCE OF REMUNERATION POLICY

3.1. Overview

The Bank’s governance model aims at guaranteeing an appropriate control on remuneration practices in all the Bank areas, ensuring that decisions are taken with sufficient independence and in an informed way, by such functions and Bank bodies, to which different responsibilities are delegated. Such model is transparent and clear, to prevent possible conflicts of interest and to guarantee the full compliance with external and internal standards and regulations.

4. BANKS MATERIAL RISK TAKERS (“MRT”) IDENTIFICATION PROCESS

4.1. Some employees of the Bank have activities, which may have a material impact on the risk profile of the Bank. This is because they are, for instance, responsible for the material business department, for management of specific risk categories such as liquidity, operational or interest rate risk, and for control functions within the Bank or because they are responsible for the day-to-day management of the business, its risks, or its control functions. Likewise, members of the Board have the ultimate responsibility for the Bank, its strategy and activities and therefore are always able to have a material impact on the Bank's risk profile (all those employees and directors, a MRT, as such term is defined above under Clause 1.8).

4.2. Given the potential risk that those MRT may generate for the Bank, certain additional restrictions on variable remuneration are applicable to all them.

4.3. As required by the EBA Guidelines, the Bank must identify its MRT on the basis of the following criteria:

a) qualitative criteria, which relate to the role, the decision-making power and managerial responsibilities of the personnel and are aimed at identifying top management members, risk takers and the personnel engaged in control functions;

b) quantitative criteria, which relate to the thresholds associated with the level of total gross remuneration attributed to a member of personnel, in absolute or relative terms, and to the parameters that enable to place the personnel in the same remuneration range as that one applicable to top management and risk takers.

4.4. The Bank shall keep records of the identification process and its results and should be able to demonstrate to the CSSF how the MRT have been identified according to both the qualitative and quantitative criteria provided for in Regulation (EU) No 604/2014 and any additional criteria used by the Bank. Those records are kept in accordance with Clause 17 herein.

5. EXEMPTIONS

5.1. In compliance with regulatory exemptions, the Bank is not required to:

a) establish a remunerations committee

b) make proportional payment of variable remuneration in shares or share equivalence

c) defer proportional payment of variable remuneration

d) make proportional and deferred payment of discretionary pension benefits in shares or share equivalence

5.2. Whenever the Bank is defined as significant in terms of size and internal organization, and the nature, scope and complexity of the Bank’s business activities are also considered significant, the Bank is required to establish a remunerations committee (regulatory exemptions (5.1 (a)) no longer apply), to exercise competent and independent judgement of the Bank’s remunerations policies and practices.

6. STRUCTURE AND COMPONENTS OF REMUNERATION

6.1. Overview

6.2. The remuneration of the employees of the Bank consists of a fixed remuneration reflecting the employees’ role, qualifications and experience and, when relevant, a variable component (otherwise referred to herein as a “bonus”).

6.3. The variable component aims to reward collective and individual performance, depending on objectives defined at the beginning of the year and the payment is conditional on results, the context and also the behaviour displayed to meet said objectives, according to the corporate value of the Bank.

6.4. The composition and the amount of total remuneration are reviewed each year, by the Board, ensuring that there is a fair balance between its components.

6.5. There must be proportionate ratio between fixed remuneration and variable remuneration. The relation between fixed and variable remuneration is of reasonable proportion. It has been set by the Board to 100:60 (i.e. 100 = the fixed remuneration and 60 of the variable remuneration). To put it otherwise, the maximum variable remuneration that may be granted to an employee for a given year, cannot exceed 60% of his/her fixed remuneration) (the Bonus Cap). This Bonus Cap has been set with a view to ensuring stability of the Bank and with the expectation of a positive and sustainable development over the next years. This Bonus Cap applies to both MRT and non-MRT, with the exception of the Authorized Management. In addition, the calculation of the threshold of low amount of variable remuneration falls under the same principle.

6.6. Employees should not have to rely on their variable remuneration. The variable portion is clearly connected to the work and performance of the employee, the performance of his/her department and the overall performance of the Bank. The goals are based on factors that support the Bank’s long-term strategy. The variable component varies across the Bank’s business areas and management levels.

6.7. Fixed remuneration

6.8. The fixed part (base salary) is paid monthly and is composed of a basic monthly remuneration, which does not take into consideration performance criteria. The base salary of each employee is defined in his / her employment contract. The base salary takes into account the level of education, the job experience, the level of expertise and skills, the role and the degree of seniority in the Bank.

6.9. The Bank is willing to adapt in a reasonable time frame – where budgets and corporate conditions make it possible – the fixed part of its employees’ remuneration to market standards, in particular to review it in case of internal mobility, if new positions involve growing responsibilities. The Bank pays particular attention to adjust, in a reasonable period of time, the fixed salary of these employees who, due to changes in duties and responsibilities, would qualify as “key personnel” in order to align it with the new levels of responsibilities taken on.

6.10. Variable Remuneration

6.11. Variable remuneration rewards employees for their performance during the year based on the achievement of quantitative and qualitative targets and individual assessments according to fixed objectives.