Grupo Aval Acciones y Valores S A : Double Materiality Process 2025

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DOUBLE MATERIALITY ANALYSIS AND DEFINITION PROCESS DOUBLE MATERIALITY 2025 CONTEXT OF DOUBLE MATERIALITY The double materiality analysis allows us to evaluate the impact of environmental, social and corporate governance factors on the financial performance of the organization (financial materiality), as well as the effects of our operations on the environment and society (materiality of impact) to define those priority issues for the business strategy and our stakeholders. We align this process with national and international requirements related to ESG disclosure, such as: Circular 031 of the Financial Superintendence of Colombia. Global Reporting Initiative - GRI. Sustainability Accounting Standards Board - SASB. Task Force on Climate-related Financial Disclosures - TCFD. IFRS S1 - Sustainability-related disclosures. IFRS S2 - Climate-related disclosures. 2 DOUBLE MATERIALITY PROCESS This is a comprehensive process that we review annually and update every two years to ensure its validity and alignment with our strategy; It includes dialogue with our key stakeholders, both internal and external, and the assessment of the impacts, risks and opportunities that drive long-term value creation. This analysis guides our strategic decisions and ensures that our sustainability initiatives are aligned with global standards and meet the expectations of our stakeholders. Identification of best practices and benchmarking: We analyze the internal and external context of the organization, considering Grupo Aval's subsidiaries and industry peers at a national and international level, and the frameworks, requirements of regulatory entities and main challenges of the sector. Stakeholder involvement: We invite our stakeholders, internal and external, to evaluate the material matters previously identified according to the relevance of the impacts, risks and opportunities they represent for Grupo Aval. Double materiality analysis: We integrate the vision of financial materiality, referring to how ESG issues affect Grupo Aval's financial performance, and impact materiality, understanding how the company's activities affect the environment, society and the economy. We build the matrix with the prioritized issues. Strategic alignment: We align the prioritized issues with Grupo Aval's strategic planning and establish corporate objectives that consider the national and international sustainability agenda. Review: We present material matters to the Board of Directors, our highest governing body, for approval. The results of this assessment are integrated into the comprehensive enterprise risk management process. 3 STAKEHOLDER MANAGEMENT At Grupo Aval we recognize that constant and transparent dialogue with our stakeholders is essential for the sustainable development of the organization. We identify and analyze our main audiences, promote communication through channels and mechanisms of participation and develop actions that strengthen the link and allow us to respond to their needs effectively . Our main stakeholders are: Board of Directors: The highest management body, in charge of approving the policies, strategies, monitoring, and evaluation of the work proposed by the Holding's senior management and our subordinate entities. Subsidiaries: Entities over which Grupo Aval exercises direct or indirect control. Shareholders and Investors: Shareholders and bondholders of the company. Collaborators: Human team that makes it possible for organizational objectives to be met and those who manage projects in our subordinate entities. Media and opinion leaders : Mass and digital media, and people who publish information about us and our subsidiaries and who are important for brand and reputation management. Government and regulatory entities : Organizations that issue regulatory requirements and carry out constant and permanent monitoring of the financial and non-financial information of the Holding Company and our subordinates. Suppliers: People and companies that provide us with supplies and services. Community: People and communities that we impact directly or indirectly with the activities, decisions and programs we carry out. 4 Other: Those identified and prioritized by the subsidiaries. DOUBLE MATERIALITY MATRIX Relevance for Stakeholders Business Relevance Priority Medium relevance Low relevance Business and Corporate Governance Economical and Profitable Performance Information Security and Cybersecurity Innovation and Digital Transformation Comprehensive Risk Management Responsible Investment Sustainable Finance Corporate Governance, Ethics and Compliance 13. Sustainable Supply Chain Generation of Social Value Diversity, Equity, and Inclusion Social 11. Financial inclusion and education 12. Human Talent Management 16. Human Rights 8. Climate Change Management Environmental 14. Biodiversity 15. Operational Efficiency 280 representatives of our Stakeholders were surveyed. External Assurance: The methodological process of double materiality analysis was ensured by an external third party in accordance with the guidelines of the International Standard for Assurance Engagements ISAE 3000 (revised), assurance engagements other than auditing or reviewing historical financial information issued by the International Auditing and Assurance Standards Board (IAASB). 5

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