Bank of America : Europe D.A.C. (formerly Bank of America Merrill Lynch International D.A.C.) 2021

Introduction

The following remuneration disclosure sets forth a summary of the remuneration principles and programmes executed by Bank of America Europe Designated Activity Company ("BofA Europe"), including its branches, as at 31 December 2021. Additionally, the disclosure sets forth information regarding the remuneration of staff identified as Material Risk Takers ("MRTs") for BofA Europe, taking into account the qualitative and quantitative criteria to identify categories of staff whose professional activities may have a material impact on an institution's risk profile contained in Capital Requirement Directive 2019/878/EU ("CRD V") and Commission Delegated Regulation (EU) No 2021/923 (the "RTS").

This document therefore incorporates the qualitative disclosure requirements under Article 450(1) and 450(2) of the Capital Requirements Regulation (Regulation (EU) No 575/2013, as amended, including by Directive (EU) No 2019/876 - the "CRR II") and the quantitative disclosure requirements under paragraphs (g) to (i) of Article 450(1) of the CRR II, as well as corresponding guidance as set out in the European Banking Authority Guidelines on Sound Remuneration Policies (the "EBA Guidelines") as applicable.

BofA Europe is a wholly owned subsidiary of Bank of America, N.A and their ultimate parent is Bank of America Corporation (the "Company" or "Bank of America"), a corporation organised and existing under the laws of the United States of America. BofA Europe therefore falls within Bank of America's global remuneration governance framework and global remuneration policies, in addition to operating a local remuneration governance framework and the BofA Europe Remuneration Policy Statement ("RPS").

Governance and the Decision-making Process for Determining the Remuneration Policy

As a U.S.-based firm, Bank of America's primary regulator is the U.S. Board of Governors of the Federal Reserve System (the "Federal Reserve"). Bank of America's remuneration programmes and practices are consistent with the Federal Reserve's requirements, in addition to those of other regulators globally, including the Central Bank of Ireland (the "CBI") and European Central Bank. Additionally, shares of Bank of America's common stock are traded on the New York Stock Exchange (the "NYSE") and, as such, Bank of America is subject to requirements imposed by the NYSE, including those specified in the NYSE Listed Company Manual. The NYSE Listed Company Manual provides that the Bank of America Board of Directors Compensation and Human Capital Committee ("CHCC") is responsible for recommending to Bank of America's Board of Directors the approval of incentive and equity-based compensation plans that are subject to the Company's Board approval.

Bank of America therefore designs and governs its remuneration programmes on a global basis so that its programmes are consistent with Bank of America's Global Compensation Principles as described in Bank of America's Compensation Governance Policy ("CGP") and sound risk management practices as well as compliant with applicable laws and regulations. The CHCC has adopted and annually reviews (most recently in June 2021) the CGP to govern incentive remuneration decisions and define the framework for design oversight of incentive remuneration programmes across Bank of America, including BofA Europe. The CGP is designed to be consistent with global regulatory initiatives so that Bank of America's incentive remuneration plans do not encourage excessive risk-taking.

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Bank of America's remuneration policies and processes, including those in operation within BofA Europe, are gender-neutral, complement the Company's philosophy of Responsible Growth and its commitment to Diversity and Inclusion, and assist the Company and BofA Europe in achieving its strategic objectives, creating long-term value, maintaining our culture of compliance and contributing to our environmental, social and governance activities.

In order to provide an appropriate balance of risk and reward, incentive remuneration plans are developed in accordance with Bank of America's Global Compensation Principles, which are applicable to all entities including BofA Europe. These Compensation Principles are referred to within the RPS which governs the remuneration processes and practices of BofA Europe:

Principle 1. Compensation should be comprised of an appropriate mix of salary, benefits and incentives paid over time that properly aligns employee and stockholder interests.

Principle 2. Criteria for payment of incentive compensation should take into account Company-wide, business unit and individual factors.

Principle 3. Compensation should be determined on the basis of a combination of financial and non-financial factors that reflect both the current period and a longer period.

Principle 4. Compensation programmes should incorporate appropriate governance processes and procedures.

Bank of America applies prudent risk management practices to its incentive compensation programmes and is committed to a compensation governance structure that effectively contributes to Bank of America's overall risk management policies. BofA Europe is part of Bank of America's remuneration governance process and the following bodies are responsible for the governance of BofA Europe's remuneration plans:

• · the BofA Europe Remuneration Committee (the "BofA Europe RemCo"), operated in accordance with the CBI's Corporate Governance Requirements for Credit Institutions 2015, whose duties are set out in the BofA Europe Remuneration Committee Charter,

• · line of business management and independent control functions aligned to the line of business ("LOB Compensation Governance"),

• · the Management Compensation Committee (the "MCC"),

• · the CHCC, which is wholly made up of independent directors and functions as Bank of America's global Remuneration Committee, and

• · Bank of America's Board of Directors.

The intention of the above governance process is to drive debate, encourage consistency and calibrate across lines of business, countries and legal entities. This allows for a greater focus on the correlation and consistency of remuneration recommendations at a local and global level, whilst taking into account conduct and diversity.

BofA Europe effectively governs and aligns remuneration with prudent risk taking, considering the business strategy, objectives, values and long term interests of BofA Europe, and provides an appropriate local level of responsibility for the preparation of decisions regarding remuneration. The BofA Europe RemCo is responsible for local remuneration governance, as necessary, to address local issues.

The role of the BofA Europe RemCo, in accordance with Paragraphs 51 and 52 of the EBA Guidelines 3

and Regulation 83 of S.I. 158/2014, as amended by S.I. 710/2020, amongst other matters, is to assist the Board of BofA Europe in fulfilling its oversight responsibility relating to the development and implementation of BofA Europe's remuneration policies and practices, as reflected in the RPS, in particular the policies and practices which have an impact on the risk profile and risk management of BofA Europe. The BofA Europe RemCo is responsible for the governance and oversight of remuneration decisions for BofA Europe employees in accordance with the BofA Europe RemCo Charter. The BofA Europe RemCo collaborates with other committees of the Board of BofA Europe, as well as the CHCC.

The BofA Europe RemCo is charged with oversight of the development and implementation of BofA Europe's remuneration policies and practices. The RPS sets forth the overall approach to the execution of BofA Europe's remuneration philosophy and the operation of its remuneration programmes, including BofA Europe's approach to complying with the remuneration requirements applicable to BofA Europe and its branches. In accordance with CRD V, the RPS may be updated periodically and as required to reflect changes with BofA Europe's remuneration processes and practices and/or changes with remuneration regulation. The BofA Europe RemCo will at least annually, or more frequently as necessary, review and recommend the RPS to the BofA Europe Board for approval.

BofA Europe benefits from being part of Bank of America's global remuneration governance framework by aligning its RPS with the CGP, which provides dual oversight of remuneration processes and practices within BofA Europe. The BofA Europe RemCo has a direct connection and open flow of communication with the CHCC, allowing any escalation of concerns and changes required relating to the operation of Bank of America's remuneration system for BofA Europe.

During performance year 2021, the BofA Europe RemCo held six (6) meetings.

It is critical to the effective implementation of the CGP and the RPS that the independent control functions operate independently from the lines of business they support. To this end, independent control functions operate as separate lines of business, and therefore the remuneration of independent control function employees (including salary levels and incentive awards) is independently determined and are not based on the financial performance of the individual lines of business they support.

As part of its global governance routine, the CHCC meets with the heads of Bank of America's independent control functions (including the Chief Risk Officer ("CRO")) and lines of business to discuss their feedback on the pay-for-performance process, including their experience managing risk and conduct matters. In addition, Bank of America's CRO also certifies all incentive plans across Bank of America as part of the MCC's governance process. The BofA Europe RemCo considers risk and conduct matters as relevant and appropriate through the performance year, and interacts with the BofA Europe CEO and other local Board committees, including the BofA Europe Risk Committee, regarding the operation of Bank of America's remuneration system as applicable to BofA Europe. In line with CRD V, BofA Europe Corporate Audit performs an annual review of BofA Europe's remuneration processes. The scope of each annual audit is determined by applicable regulatory requirements for audit coverage as well as assessment of potential areas of key risk within the remuneration processes.

As a result of these processes and reviews, and in combination with the risk management and clawback features of Bank of America's remuneration programmes, BofA Europe believes that its

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remuneration policies and practices appropriately consider the balance of risk and reward in a way that does not encourage excessive or imprudent risk-taking or create risks that are reasonably likely to have a material adverse effect on BofA Europe or Bank of America. Moreover, oversight by the CHCC, MCC, BofA Europe RemCo, independent control functions, and line of business management helps Bank of America maintain a remuneration programme that is intended to mitigate the potential for conflicts of interest.

The BofA Europe RemCo has the authority to obtain, at its discretion, advice and assistance from internal or external advisors as appropriate and/or necessary. The CHCC's independent remuneration consultant, Farient Advisors, LLC, meets regularly with the CHCC outside the presence of management and alone with the CHCC Chair, and also reviews management's incentive plan certifications with the CHCC.

The Link between Pay and Performance

The cornerstone of Bank of America's remuneration philosophy across all lines of business is to Pay for Performance ("P4P") - Bank of America (inclusive of BofA Europe), line of business and individual performance. Through Bank of America's Performance Management process, employees understand performance expectations for their role through ongoing dialogue with their manager. The Performance Management process is designed and monitored by the Leadership Development function in Human Resources. This process is reviewed periodically so that it meets the needs of managers to assess and communicate performance expectations. Throughout the year, employees receive coaching on their performance and ultimately receive a rating for their full year of performance based upon their achievement of goals for their job.

BofA Europe does not remunerate or assess employees' performance in a way that encourages employees to act in a manner that creates conflicts of interest. In addition, each employee's performance is assessed on quantitative and qualitative objectives as well as specific behaviours, and performance is factored into each employee's incentive remuneration award. Depending on the employee, quantitative performance objectives may be focused on Bank of America (inclusive of BofA Europe), line of business, or individual results. Qualitative performance objectives may include quality and sustainability of earnings, successful implementation of strategic initiatives, adoption of risk culture/adherence to the Risk Framework and operating principles, adherence to the Code of Conduct, and other core values of Bank of America and BofA Europe. To support Responsible Growth, all employees receive Great Place to Work, Diversity and Inclusion and Risk Management performance objectives.

Employees receive two ratings - a Result rating (based on factors such as business performance) and a Behaviour rating (based on factors such as conduct, broader contributions to Bank of America and/or BofA Europe, leadership, teamwork, Responsible Growth such as diversity and inclusion, etc.). The scale for both ratings is Exceeds Expectations, Meets Expectations, and Does Not Meet Expectations. Both the Result and Behaviour ratings are used in determining employees' remuneration. As a result, an employee's remuneration can be influenced not only by what the employee achieves, but how the employee achieves it and the employee may receive no variable award if performance is not sufficiently strong.

The P4P programme also requires that all employees complete annual mandatory risk and compliance training.

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