CLEVELAND-CLIFFS INC.

2024 EMPI Plan Performance Measures. The EMPI Plan uses a performance scorecard with performance standards that are related to our financial metrics, strategic initiatives and safety. The annual incentive program is based 50% on financial performance, 40% on strategic initiatives and 10% on a safety scorecard (the “Safety Scorecard”) evaluation. Cliffs believes that a significant portion of our NEOs’ potential compensation should be dependent on our business results as well as our NEOs’ successful leadership.

2024 EMPI Plan Target Setting and 2024 Results. Performance targets and ranges under the EMPI Plan were established and approved by the Compensation Committee in the first quarter of 2024, taking into consideration management's financial plans and business strategy for that year, as well as market expectations. The financial performance measure of Adjusted EBITDA and the Safety Scorecard measure were assigned a minimum threshold level, a target level and a maximum level, representing attainment of 25%, 50% and 100%, respectively, of the EMPI Plan maximum award opportunities associated with those elements. For performance below the minimum threshold performance requirement for each such metric, funding would be zero percent for that factor.

For 2024, the Compensation Committee made the following determinations regarding the annual incentive metrics: