ASSOCIATED BANC-CORP

Each year, the Committee, with the input of our compensation consultant, reviews and assesses the peer group. After a comprehensive review, the Committee approved the 2023 peer group, which consisted of 21 bank holding companies that the Committee and compensation consultant believe are appropriate for comparison purposes in terms of size (based on total assets) and business composition (engaged in lines of business similar to Associated). Our peer group selection process considers the following:

•Regional banks generally with asset size between 0.5x to 2.0x of Associated’s assets;

•An overall comparison of company structure and services; and

•How frequently the banks were selected as peers by other banks.

For 2023, based on the advice of our compensation consultant, the Committee refined the peer group by removing two companies that exceeded the asset size criteria (East West Bancorp, Inc. and Zions Bancorporation) and two other companies that were acquired (First Midwest Bancorp and Sterling Bancorp). Four new peers were added considering their respective sizes and business model similarities to Associated (Bank OZK, Simmons First National Corporation, Texas Capital Bancshares, Inc. and United Bankshares, Inc.). Overall, the companies included in the 2023 peer group ranged in asset size from approximately $17.6 billion to approximately $57.3 billion. The median asset size of the companies in the peer group was approximately $36.5 billion, compared to Associated’s assets of $35.1 billion.

The 2023 peer group companies were:

While the peer group is a key point of comparison in the total compensation strategy, the Committee also took into account broader banking and financial services industry survey data as part of its compensation determinations to provide additional market context. The compensation consultant analyzed compensation data from the McLagan and Willis Towers Watson executive financial services surveys, each of which included members of Associated’s peer group, and peer company public filings. In analyzing the data, the compensation consultant advised that the additional comparisons, beyond the peer group, provided a broader perspective from which to appropriately compare compensation.