ASSOCIATED BANC-CORP

Effective December 1, 2023, the Committee approved a new clawback policy (the “Clawback Policy”) that is intended to satisfy Section 303A.14 of the Listed Company Manual of the NYSE that was adopted to implement Rule 10D-1 under the Securities Exchange Act of 1934. The Clawback Policy mandates the recovery of executive officer incentive-based compensation if payments were based on financial statements that were later restated and executive officers received Erroneously Awarded Compensation (as defined therein), from current and former executive officers. The Clawback Policy applies to the ELT, including the NEOs, and recovery is subject to only very limited exceptions. The Committee does, however, have the discretion to determine the appropriate means and method of recovery based on all applicable facts and circumstances which may include the reimbursement of all or part of any cash or equity-based award; cancelling prior cash or equity-based awards whether vested or unvested or paid or unpaid; cancelling or offsetting against any planned future cash or equity-based awards; forfeiture of deferred compensation (subject to compliance with 409A of the Internal Revenue Code), and any other method authorized by applicable law or contract.