Bancolombia S.A. (2025)

At Bancolombia, we are committed to sustainability in our processes and products. Accordingly, we adhere to the following agreements: the Equator Principles; the United Nations Environment Programme Finance Initiative (UNEP‑FI); the Dow Jones Sustainability Index; the Partnership for Carbon Accounting Financials (PCAF); and the standards defined by the International Finance Corporation (IFC), among others, as applicable. Through these commitments, we seek to promote sustainable economic development and, as a financial actor, to foster actions that ensure the adequate management of environmental and social risks and impacts across our clients’ economic sectors.

With respect to Environmental and Social Risk Analysis (ARAS), Bancolombia manages its internal processes and policies aligned with the fourth version of the Equator Principles and their full application framework. These policies include the identification of activities that require Environmental and Social Risk Analysis, environmental risk studies for the acceptance of guarantees, assets received in payment, and assets delivered under leasing arrangements, thereby preventing risks associated with environmental liabilities in real estate where environmentally sensitive activities are carried out.

Environmental and Social Risk Analysis includes the assessment of physical risks associated with Climate Change, Biodiversity and Human Rights, both in project financing and in ordinary operations, including corporate loans, bridge loans, and financial advisory services, across the Corporate Banking, Business Banking, SME Banking, Investment Banking, Leasing and Fiduciary business units.

The criteria and parameters for risk categorization and the structuring of environmental and social covenants are applied to each analysis using the tools generated by the Equator Principles and the IFC Performance Standards, adapted to the needs of Colombian and regional regulations.

Additionally, this Policy seeks to align with the requirements described in External Circular 0015 of 2025 from the Financial Superintendency of Colombia (SFC), which defines the guidelines for managing environmental and social risks, including climate risks, in entities supervised by this authority.