Zions Bancorporation N A : Report

CORPORATE RESPONSIBILITY REPORT 2023

SUSTAINABILITY ACCOUNTING STANDARDS BOARD (SASB) INDEX

The index below includes SASB standards for the Financial Sector that are relevant for our business: Commercial Banks, Consumer Finance, and Mortgage Finance. Unless otherwise noted, all data and descriptions are for the year ended Dec. 31, 2023.

For additional information about Zions Bancorporation's financial performance, please refer to our quarterly and annual reports and investor presentations published on our website at www.zionsbancorportion.com.

Certain information may not be disclosed within the index below if it is not considered material; privileged or confidential; could cause a competitive disadvantage to our business if publicly disseminated; or is not currently collected in a manner wholly correlative with the related SASB metric.

Commercial Banks

SASB Code/Metric	Response
Data Security
FFN-CB-230a.1 (1) Number of data breaches, (2) percentage involving	We did not experience any material data breaches during 2023. If
personally identifiable information (PII), (3) number of account holders	material data breaches had occurred, they would have been addressed
affected	in either an 8-K or discussed further in our 2023 Form10-K.
FN-CB-230a.2 Description of approach to identifying and addressing	See the Data Security and Customer Privacy section of our 2023
data security risks	Corporate Responsibility Report; the relevant sections of our 2023 Form
	10-K(pages 19, 24-25); sections of our Code of Business Conduct
	and Ethics for Employees(2.3, 4.5, 5); and page 20 of the 2024 Proxy
	Statement.
Financial Inclusion & Capacity Building
FN-CB-240a.1 (1) Number and (2) amount of loans outstanding	The number and amount of our loans to small businesses and small
qualified to programs designed to promote small business and	farms are reported in Schedule RC-C Part II, Items 3 and 4, of our Call
community development	Report for Dec. 31, 2023. Additional information on our Small Business
	Diversity Banking Program to provide additional access to capital to
	women-,minority-,veteran-, and LGBTQ-owned businesses, as well as
	other programs may be found in our Corporate Responsibility Reportin
	the section titled "Bringing Access to Underserved Markets."
FN-CB-240a.2 (1) Number and (2) amount of past due and nonaccrual	The number and amount of our loans to small businesses and small
loans qualified to programs designed to promote small business and	farms are reported in Schedule RC-C Part II, Items 3 and 4, of our Call
community development	Report for Dec. 31, 2023.
	The Nonaccrual and Past Due Loans discussion (pages 111-113) in the
	Loans, Leases, and Allowance for Credit Losses footnote of our 2023
	Form10-Kpresents a summary of the past due and nonaccrual status
	for our loan portfolio by segment and class at Dec. 31, 2023.
FN-CB-240a.3 Number of no-cost retail checking accounts provided to	Our Bank On certified OnBudget Banking and OnBudget Student
previously unbanked or underbanked customers	Banking accounts and other products to assist clients who are
	developing financial literacy, on fixed incomes, previously un-banked
	or financially distressed are described in our Corporate Responsibility
	Reportin the section titled "Bringing Access to Underserved Markets."
FN-CB-240a.4 Number of participants in financial literacy initiatives for	See the Financial Literacy section of our Corporate Responsibility
unbanked, underbanked, or underserved customers	Report.

CORPORATE RESPONSIBILITY REPORT 2023

Incorporation of Environmental, Social, and Governance Factors in Credit Analysis

FN-CB-410a.1 Commercial and industrial credit exposure, by industry	See Schedule 6, Credit Exposure by Industry, in our Dec. 31, 2022 Basel
	III Regulatory Capital Disclosures Report, and Schedule 23, Commercial
	Lending by Industry Group (page 55), in the MD&A section of our 2023
	Form10-K.
FN-CB-410a.2 Description of approach to incorporation of	Our approach to effectively managing ESG risks in our lending practices
environmental, social, and governance (ESG) factors in credit analysis	is described in the Environmental Risk Management section of our
	Corporate Responsibility Reportand the Credit Risk Management
	section (page 54), in the MD&A section of our 2023 Form10-K.
Business Ethics
FN-CB-510a.1 Total amount of monetary losses as a result of legal	See Note 16 (pages 138-139) of our 2023 Form10-Kfor disclosure of
proceedings associated with fraud, insider trading, anti-trust, anti-	material legal proceedings.
competitive behavior, market manipulation, malpractice, or other related
financial industry laws or regulations
FN-CB-510a.2 Description of whistle blower policies and procedures	We discuss our whistleblower protection policies and procedures in the
	following areas:
	•	The Speak Up section (page 33) of our Code of Business Conduct &
		Ethics
	•	The Ethical Practices section of our Corporate Responsibility Report
Systemic Risk Management
FN-IB-550a.1 Global Systemically Important Bank (G-SIB) score, by	According to the Basel Committee on Banking Supervision's assessment
category	methodology, we are not considered a G-SIB and therefore have not
	assessed a G-SIB score.
FN-IB-550a.2 Description of approach to incorporation of results of	An overview of how our stress testing influences our capital adequacy
mandatory and voluntary stress tests into capital adequacy planning,	assessment is provided in the Capital Structure section (page 3), of our
long-term corporate strategy, and other business activities	Dec. 31, 2023 Basel III Regulatory Capital Disclosures Report, and in the
	Capital Planning and Stress Testing (page 9) and Capital Management
	(page 72) sections of our 2023 Form10-K.
Activity Metrics
FN-CB-000.A (1) Number and (2) value of checking and savings	The dollar value of our consumer deposit account products is reported in
accounts by segment: (a) personal and (b) small business	Schedule RC-E of our Call Report for Dec. 31, 2023.
FN-CB-000.B (1) Number and (2) value of loans by segment: (a)	The distribution of our loan and lease portfolio by segment and class is
personal, (b) small business, and (c) corporate	reported in both Schedule 16: Loan and Lease Portfolio in the Balance
	Sheet Analysis section of the MD&A, and Note 6 Loans, Leases, and
	Allowance for Credit Losses (page 107) of our 2023 Form10-K.

Consumer Finance

SASB Code/Metric

Customer Privacy

Response

FN-CF-220a.1 Number of account holders whose information is used	We do not sell our customer data to third parties. For details on data we
for secondary purposes	collect and how it is used internally, see the Privacy Noticeand Digital
	Privacy Statementon each of our affiliate bank websites.
FN-CF-220a.2 Total amount of monetary losses as a result of legal	See Note 16 (pages 138-139) of our 2023 Form10-Kfor disclosure of
proceedings associated with customer privacy	material legal proceedings.
Data Security
FN-CF-230a.1 (1) Number of data breaches, (2) percentage involving	We did not experience any material data breaches during 2023. If
personally identifiable information (PII), (3) number of account holders	material data breaches had occurred, they would have been addressed
affected	in either an 8-K or discussed further in our 2023 Form10-K.
FN-CF-230a.2 Card-related fraud losses from (1) card-not present	See Note 16 (pages 138-139) of our 2023 Form10-Kfor disclosure of
fraud and (2) card-present and other fraud	material legal proceedings.

CORPORATE RESPONSIBILITY REPORT 2023

FN-CF-230a.3 Description of approach to identifying and addressing	See the Data Security and Customer Privacy section of our 2023
data security risks	Corporate Responsibility Report; the relevant sections of our 2023 Form
	10-K(pages 10, 24-25); sections of our Code of Business Conduct
	and Ethics for Employees(2.3, 4.5, 5), and page 20 of the 2024 Proxy
	Statement.
Selling Practices
FN-CF-270a.1 Percentage of total remuneration for covered employees	We purposefully align our compensation philosophy for all associates
that is variable and linked to the amount of products and services sold	with how we manage risk. We also reinforce our client centered culture
	through a series of checks and balances that help ensure we work in
	our clients' best interests. Our processes to incorporate these goals into
	associate compensation are discussed in the following areas:
	•	Proposal 3: Advisory (Nonbinding) Vote Regarding 2023 Executive
		Compensation ("Say on Pay") (page 24) and Compensation
		Philosophy and Objectives (pages 30-31) of our 2024 Proxy
		Statement
	•	Fair Banking section of our 2023 Corporate Responsibility Report
	We also disclose the terms of certain incentive plans by filing those
	plans as exhibits to our 2023 Form10-K.
FN-CF-270a.2 Approval rate for (1) credit and (2) pre-paid products for	Not disclosed.
applicants with FICO scores above and below 660
FN-CF-270a.3 (1) Average fees from add-on products, (2) average	Not disclosed.
APR, (3) average age of accounts, (4) average number of trade lines,
and (5) average annual fees for pre-paid products, for customers with
FICO scores above and below 660
FN-CF-270a.4 (1) Number of complaints filed with the Consumer	Data on complaints filed with the CFPB can be accessed through the
Financial Protection Bureau (CFPB), (2) percentage with monetary	CFPB's Consumer Complaint Database. Our material loss contingencies
or nonmonetary relief, (3) percentage disputed by consumer, (4)	related to regulatory investigations are disclosed in Note 16 (Contingent
percentage that resulted in investigation by the CFPB	Liabilities and Legal Matters section) (pages 138-139) of our 2023 Form
	10-K.
	Regulatory expenses are reported in the Noninterest Expense table
	(page 40) of our 2023 Form 10-K.
FN-CF-270a.5 Total amount of monetary losses as a result of legal	See Note 16 (pages 138-139) of our 2023 Form10-Kfor disclosure of
proceedings associated with selling and servicing of products	material legal proceedings.
Activity Metric
FN-CF-000.A Number of unique consumers with an active (1) credit	Not disclosed - see introduction.
card account and (2) pre-paid debit card account
FN-CF-000.B Number of (1) credit card accounts and (2) pre-paid debit	The distribution of our loan and lease portfolio by segment and class is
card accounts	reported in the Loans, Leases, and Allowance for Credit Losses footnote
	(page 107) of our 2023 Form10-K.

Mortgage

SASB Code/Metric

Lending Practices

Response

	FN-MF-270a.1 (1) Number and (2) value of residential mortgages of the	We discuss our consumer loan portfolio in the Consumer Loan section
	following types: (a) Hybrid or Option Adjustable-rate Mortgages (ARM),	(pages 58-59) of the MD&A in our 2023 Form10-K. The distribution
	(b) Prepayment Penalty, (c) Higher Rate, (d) Total, by FICO scores above	of our loan and lease portfolio by segment and class is reported in the
	or below 660	Loans, Leases, and Allowance for Credit Losses footnote (page 107) of
		our 2023 Form10-K.
	FN-MF-270a.2 (1) Number and (2) value of (a) residential mortgage	We report information on (1) loan modifications, by class and
	modifications, (b) foreclosures, and (c) short sales or deeds in lieu of	modification type, (2) the amount of foreclosed residential real estate
	foreclosure, by FICO scores above and below 660	property, and (3) consumer mortgage loans collateralized by residential
		real estate property that are in the process of foreclosure in the Loan
		Modifications, Troubled Debt Restructuring Disclosures, Collateral-
		dependent Loans and Foreclosed Residential Real Estate sections
		(pages 118-123 of our 2023 Form10-K.

CORPORATE RESPONSIBILITY REPORT 2023

FN-MF-270a.3 Total amount of monetary losses as a result of	See Note 16 (pages 138-139) of the 2023 Form10-Kfor disclosure of
legal proceedings associated with communications to customers or	material legal proceedings.
remuneration of loan originators
FN-MF-270a.4 Description of remuneration structure of loan originators	We purposefully align our compensation philosophy for all employees
	with how we manage risk. We also reinforce our client-centered culture
	through a series of checks and balances that help ensure we work in
	our clients' best interests. Our processes to incorporate these goals into
	employee compensation are discussed in:
	•	Proposal 3: Advisory (Nonbinding) Vote Regarding 2023 Executive
		Compensation ("Say on Pay") (page 24) and Compensation
		Philosophy and Objectives (page 30) of our 2024 Proxy Statement
	•	Fair Banking section (page 20) of our 2023 Corporate Responsibility
		Report.
	We also disclose the terms of certain incentive plans by filing those
	plans as exhibits to our 2023 Form10-K.
Discriminatory Lending
FN-MF-270b.1 (1) Number, (2) value, and (3) weighted average Loan-	Not disclosed.
to-Value (LTV) ratio of mortgages issued to (a) minority and (b) all other
borrowers, by FICO scores above and below 660
FN-MF-270b.2 Total amount of monetary losses as a result of legal	See Note 16 (pages 138-139) of the 2023 Form10-Kfor disclosure of
proceedings associated with discriminatory mortgage lending	material legal proceedings.
FN-MF-270b.3 Description of policies and procedures for ensuring	The following policies ensure our nondiscriminatory mortgage
nondiscriminatory mortgage origination	origination practices monitored by our Compliance and Internal Audit
	departments:
	•	Equal Credit Opportunity Act (Reg B) Policy
	•	The Home Mortgage Disclosure Act (Reg C) Policy
	•	Residential Lending Regulations Policy
	•	Fair Banking Policy
Environmental Risk to Mortgaged Properties
FN-MF-450a.1 (1) Number and (2) value of mortgage loans in 100-year	Not disclosed - see introduction.
flood zones
FN-MF-450a.2 (1) Total expected loss and (2) Loss Given Default (LGD)	Not disclosed.
attributable to mortgage loan default and delinquency due to weather-
related natural catastrophes, by geographic region
FN-MF-450a.3 Description of how climate change and other	Our approach to effectively managing environmental risks in our lending
environmental risks are incorporated into mortgage origination and	practices is described in the Environmental Risk Management section of
underwriting	our Corporate Responsibility Report and the Credit Risk Management
	section (page 54), in the MD&A section of our 2023 Form10-K.
Activity Metric
FN-MF-000.A (1) Number and (2) value of mortgages originated by	For residential mortgage information, see the Consumer Loans section
category: (a) residential and (b) commercial	(pages 58-59) of our 2023 Form10-K.
FN-MF-000.B (1) Number and (2) value of mortgages purchased by	The distribution of our loan and lease portfolio by segment and class is
category: (a) residential and (b) commercial	reported in the Loans, Leases and Allowance for Credit Losses footnote
	(page 107) of our 2023 Form10-K.