Key Pay Equity Commitment

Our analysis is based on total compensation (base salary and all discretionary incentives) covering all teammates throughout our organization eligible for discretionary incentives, other than our Executive Leadership Team, whose pay is set by our Board of Directors.

We report our pay parity measures annually and will continue to evolve our disclosure as the landscape develops.

How we support pay equity

Key’s commitment to pay equity is foundational to our culture, which is supported through our policies and practices in the following ways:

• We maintain a formal compensation structure to establish pay based on objective factors, including external market survey data, required education, and experience. We regularly review this structure relative to market trends and internal equity.
• We have a pay-for-performance philosophy in which pay decisions are based on the assessment of individual performance, business unit performance, and the performance of Key. These decisions also consider performance against risk expectations and whether a teammate has exhibited behaviors consistent with our values.
• As part of our year-end compensation process, we complete a pay practice review of our entire workforce by race/ethnicity and gender to make sure pay and performance are aligned. If disparities are found, adjustments are made as warranted.
• In compliance with various state and local laws and as part of Key’s long-standing commitment to equal employment opportunity, we do not seek current base compensation information from applicants, regardless of location, or consider an applicant’s compensation history when formulating an offer. Key also provides salary range information when requested by applicants and includes it in job postings when required by law, supporting greater pay transparency during the hiring process and further enhancing practices that support pay equity and fairness.
• We continually assess and enhance our practices and engage third-party partners to consult on our pay analyses and practices as needed. Our process continues to evolve over time to become even more comprehensive. As a result, we believe our practices are an effective control to monitor and address pay equity.

Leadership representation

In 2021, we committed to increasing representation of people of color in our senior leadership ranks by a rate of 25% over the next five years and a rate of 50% over the next 10 years. These targets are not quotas, but they are Board-approved aspirational continuous improvement measures as we work to raise the bar for ourselves and for the financial services industry as a whole.

Since 2021, our focus to attract, develop, and retain diverse talent drove a 32% rate increase in senior leadership representation for people of color and a 13% rate increase for women.

While we have achieved our 2025 representation goal for racial or ethnically diverse senior leaders, our efforts to achieve our 2030 goal must also focus on talent development and promotions, as well as retention. We remain committed to achieving our 10-year goal with strong momentum.