Comerica Incorporated : Corporate Responsibility Report (Diversity Equity Inclusion)

CMA

Published on 07/02/2025 at 11:37

‌CEO

Letter

About This Report

About Comerica

Corporate Responsibility at Comerica

Customers Colleagues Inclusion Community Environment

Responsible Business

Additional Information

Inclusion is integral to our Core Value -

A Force for Good - and is also a business imperative. We work tirelessly to ensure all colleagues have fair treatment, merit-based access and opportunity to advance at Comerica. We also seek to develop leaders with compassionate empathy to achieve two basic human needs for our colleagues: to feel they are valued for who they are and that they belong.

Nate Bennett

Senior Vice President, Chief Inclusion Officer

Tenure Fosters Long-Term Relationships 40

Governance and Performance 41

Growing Awareness to Build Empathy 41

Impact Teams 42

Supplier Engagement 44

Talent Outreach 44

2024 Comerica Corporate Responsibility Report 39

Our Leadership Focus

At Comerica, inclusive leadership for executives, senior leaders, managers and our colleagues throughout the company has contributed to our high-performing culture and improved retention of our colleagues. Key focus areas include improving awareness, advancing empathy to improve relationships and building followership.

In 2024, Comerica completed Phase III of our Inclusion Education Program "Fearless Teams," which centered around three key areas:

What is psychological safety?

How psychologically safe is your team?

How to create a psychologically safe environment.

Strong Culture

Comerica colleagues participate in culture building through a variety of learning programs. Our culture-building learning programs target new hires, new managers and all colleagues annually. To ensure the continued effectiveness of colleague education, our programs are measured through qualitative assessments like our "Voice of the Colleague" engagement survey, where we assess the impact of our programs on our colleague's overall well-being.

Banking is a business that relies heavily on the personal relationships and the quality of service provided by colleagues. To meet and exceed our customers' expectations, we strive to make Comerica the preferred place to work in our markets. We recognize our colleagues' hard work and are dedicated to fostering an inclusive workplace.

The tenure of our colleagues allows Comerica to sustain long-term relationships with clients, customers and our vendor partners in all markets.

Our commitment to supporting an inclusive workforce has contributed to our ability to both grow and retain top talent as shown in our colleague average tenure.

Colleague Tenure for 2024 (%)

We want to hear from our colleagues to ensure transparent communication through assessing the following:

Fair Treatment Colleagues feel fairly rewarded and recognized

Empathy Colleagues respect and value others' opinions

50%

0-5 years

15%

23%

6-15 years

12%

Decision-Making Team members give fair consideration to others' ideas

Psychological Safety Colleagues feel welcome to express their true feelings

Trust Communications received from the company are honest and open

Belonging People in the organization care

16-25 years

26+ years

CEO

Letter

About This Report

About Comerica

Corporate Responsibility at Comerica

Customers

Colleagues

Inclusion

Community

Environment

Responsible Business

Additional Information

Pay Equity Commitment

Comerica is committed to investing in our colleagues in various forms, such as training, development, benefits programs and equitable pay. To help support equitable pay, we use various policies and practices.

Pay Analysis

Our company-wide Awareness Program is foundational to Comerica's inclusive education platform focused on bringing colleagues together in an ever-changing society. This elective program was developed to advance empathy and recognize the commonalities we all share. Some of the dimensions of the program are as follows:

We regularly review our main components of compensation, such as salaries and bonuses by grade level and position, to determine if similar positions receive similar pay to the extent other factors can be equalized (e.g., time in position, performance and education). We also use a formal compensation structure that is aligned to market each year, as competitive compensation helps us keep and attract talent. We have made a corporate-wide decision to prohibit the solicitation of salary history from applicants in all of our markets and are committed to identifying and promoting best practices to reduce bias in hiring, promotion and compensation decisions.

Pay for Performance

Comerica has a pay-for-performance philosophy to align with the interests of our shareholders. Pay decisions are based upon the assessment of individual results (both

Generation

Leveraging Inclusion in the Workplace

Mental/Physical Ability

quantitative and qualitative) as well as business unit or corporate performance. Manager training on compensation practices reinforces sound compensation governance and mitigates excessive risk.

The program provides certifications at bronze, silver, gold and platinum levels. In 2024, 68% of Comerica colleagues were enrolled in the program:

Certification Level

Bronze-level certified

Gold-level certified

Silver-level certified

Platinum-level certified

CEO

Letter

About This Report

About Comerica

Corporate Responsibility at Comerica

Customers

Colleagues

Inclusion

Community

Environment

Responsible Business

Additional Information

14 Impact Teams with 22 chapters in California, Michigan and Texas

All Abilities and Allies • PRISM - LGBTQIA+

African American • Quantitative Professionals

Asian • Salam

Comerica Speaks • Veteran Leadership

European Connection • Women in Technology

Jewish Heritage • Women's Forum

Mi Gente - Hispanic • Young Professionals

Comerica's colleague-led Impact Teams are open to everyone to contribute to the empowerment of our colleagues. They consist of colleagues interested in promoting inclusion in support of the many communities represented in our colleague base, as well as promoting career opportunities, colleague connection and community impact.

2024 Impact Teams Metrics

colleagues participated in Impact Teams

events held by Impact Teams

Comerica Asian and Pacific Islander chapter of the Asian Impact Team Celebrates Lunar New Year (LNY)!

The Asian and Pacific Islander chapter of the Asian Impact Team is committed to ensuring that all colleagues have access to the support they need to reach their fullest potential.

We successfully hosted the following events in celebration of the LNY with our colleagues:

LNY celebration in Frisco, Texas, on February 13, 2024: We welcomed more than 70 colleagues to enjoy games, festivities and food for this Year of the Dragon. Additionally, Comerica's Chief Inclusion Officer, Nate Bennett, and Comerica's Chief Economist, Bill Adams, reflected on the importance of the event and welcomed colleagues to the celebration.

LNY Celebration at our Operational Center in Auburn Hills, Michigan on February 14, 2024: We hosted a panel discussion on how colleagues celebrate LNY and welcomed more than 80 colleagues to enjoy Asian food, games, festivities and food for this Year of the Dragon. Additionally, Comerica's Chief Information Security Officer, Juan Rodriguez, and Chief Procurement Officer, Gloria Oldani, joined with colleagues in a dragon dance performance.

In collaboration with our community partners, we proudly sponsored and actively participated in the following events:

Cranbrook Chinese New Year Concert and Celebration on February 18, 2024 (Bloomfield, Michigan): Over 200 guests enjoyed the concert, face painting, Chinese tea and more cultural interaction activities.

Detroit, Michigan, Chinese Business Association Lunar New Year Gala on February 25, 2024.

Impact Teams Strategic Objectives

Commerce

Promote Comerica as the best bank for business within the communities we serve.

Community Promote activities that support the growth of all communities and the social impact interests of Comerica.

Culture Promote the cultural and social differences among our colleagues through positive representation and open discussion.

CEO

Letter

About This Report

About Comerica

Corporate Responsibility at Comerica

Customers

Colleagues

Inclusion

Community

Environment

Responsible Business

Additional Information

Our Impact Teams also provide business development and community outreach support, partnering with relevant associations and nonprofits. Since each Impact Team is focused on creating strategies to support and promote business outreach and financial education to a specific community group, their goals and efforts target a narrower pool of

community members.

Our Impact Teams partner with members of the External Affairs team and local organizations to serve our diverse communities across our markets.

in closed business related to Comerica's Impact Teams (IT) in 2024

2024 Impact Team Highlights:

In California, our Women's Forum Impact Team teamed up with the Danville Area Chamber of Commerce to host a Business Owner/Financial Management Seminar as part of the Chamber's Women's Enterprise Initiative program.

Our Texas and California South Asian Indian and Asian Pacific Islander chapters within the Asian Impact Team hosted Diwali celebrations for our customers and members of the community.

Through our Texas chapter of the Mi Gente - Hispanic Impact Team, we supported women small business owners and entrepreneurs by sponsoring the Social Chica's third annual La Poderosa Conference's Fast Pitch Contest.

African American IT

CA, MI, TX

Salam IT

Asian IT

CA, MI, TX

Veteran Leadership IT

Mi Gente - Hispanic IT

CA, MI, TX

PRISM - LGBTQIA+ IT

CA, MI MI

Women's Forum IT

CA, MI, TX

CA, MI

CA - California TX - Texas MI - Michigan

Our Impact Teams embody our A Force for Good Core Value - they are our boots on the ground striving to ensure we are doing what's right across the communities we serve. By providing business development and community outreach support, they continue to help us raise expectations of what a bank can be.

LaToya Rowell

Vice President,

National Community Affairs Manager

CEO

Letter

About This Report

About Comerica

Corporate Responsibility at Comerica

Customers

Colleagues

Inclusion

Community

Environment

Responsible Business

Additional Information

Disclaimer

Comerica Inc. published this content on June 30, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on July 02, 2025 at 15:36 UTC.