SEC Form 6-K filed by Grupo Aval Acciones y Valores S.A.

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 6-K

Report Of Foreign Private Issuer

Pursuant To Rule 13a-16 Or 15d-16 Of

The Securities Exchange Act Of 1934

For the month of March 2025

 Commission File Number: 001-36631

Grupo Aval Acciones y Valores S.A.

(Exact name of registrant as specified in its charter)

Carrera 13 No. 26A - 47

Bogotá D.C., Colombia

(Address of principal executive office)

Indicate by check mark whether the registrant files or will file annual reports under cover of Form 20-F or Form 40-F:

GRUPO AVAL ACCIONES Y VALORES S.A.

TABLE OF CONTENTS

Item 1

	FORM 6K	2024

This translation from the original Spanish version is provided for convenience purposes only. No representation is made as to the accuracy of this document and the company does not assume any liability based upon it.

Context:

Practices, policies, processes and indicators in relation to social and environmental issues, including climate issues (Chapter Extracted from Sustainability Report).

At Grupo Aval we value the role we play in building a better country, with opportunities for its people, economic development, thousands of dreams fulfilled and with the contribution we make to the conservation of the environment for this and future generations.

When we say, “Tú vas adelante, nosotros somos tu aval”, we truly believe that the strength of a financial conglomerate is not only measured in numbers, but in its ability to promote and transform lives. Every credit granted, every investment made, and every financial innovation developed has the potential to close gaps, generate opportunities, and build a fairer and more equitable future. Banking is not only a vehicle for economic growth; It is a platform for social mobility and the promotion of the conservation and preservation of the environment.

That is why, at Grupo Aval, we finance progress: we support small and medium-sized enterprises that generate employment, we promote projects that strengthen education, we facilitate access to housing, we support initiatives that improve the quality of life of thousands of people, and we are committed to managing our environmental impacts, and the conservation of the planet.

Our commitment to sustainability translates into concrete actions that positively impact millions of people:

	FORM 6K	2024

We focus on aligning management with material issues, ESG factors, and regulatory changes within the financial industry, both globally and locally. We firmly believe in sustainability as a fundamental lever for generating value through risk mitigation, access to new markets, better positioning, and the search for new opportunities for products and services, among others.

In addition, we have the firm conviction that in order to improve, we must measure ourselves and that it is essential to compare ourselves, challenge ourselves and adopt the national and international frameworks and standards that most encourage us to continue strengthening our strategy. That is why we are part of the Principles for Responsible Banking – PRB – both at the level of Grupo Aval holding and our banks: Banco de Bogotá, Banco de Occidente, Banco AV Villas and Banco Popular, who published their first PRB report in which they identified the main work objectives to contribute to responsible banking, and of the Principles for Responsible Investment – PRI at the level of Porvenir, our pension fund and Corfi, the holding company of investments in the real sector.

We integrate the highest international standards into our sustainability strategy and performance reporting. We use the Sustainability Accounting Standards Board (SASB) framework to ensure transparency on the ESG issues most relevant to our sector, align our climate risk management with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), report under the Global Reporting Initiative (GRI) standards to ensure comprehensive and comparable disclosure, and follow the criteria of the Dow Jones Sustainability Index (DJSI) to assess our sustainability performance against global best practices.

We have a governance structure for sustainability matters that allows us to guarantee alignment and have the necessary institutional framework to achieve the goals we set for ourselves. We have a robust framework of policies on ESG issues that allow us to define principles, guidelines, responsible parties and guarantee coordination in the sustainability strategy. These policies include:

	FORM 6K	2024

During 2024, we strengthened our governance structure by creating, updating and reviewing essential corporate policies, including the Sustainability Policy, the Human Rights Policy, the Board of Directors Regulations and the Code of Good Governance. In addition, the Board of Directors approved the Sustainable Finance Statement in which we reaffirm our commitment to the inclusion of ESG criteria in investment decisions and in the management of our investments.

In addition, we consolidated our governance model with the creation of ESG and ICT Committees within the Board of Directors, ensuring greater follow-up, monitoring and decision-making with greater alignment with best practices. At the executive level, we created the Vice-Presidency of Sustainability and Strategic Projects of Grupo Aval, which will be in charge of designing, leading and coordinating the sustainability strategy of Grupo Aval and its entities.

Regarding the relationship with our entities, in 2024 we strengthened the governance model, recomposing the Holding’s ESG Committee with the sustainability leaders of each entity and redefining the functions and role of the Committee, as a coordination space to share best practices, monitor the performance of ESG issues and indicators, strengthen guidelines and principles, evaluate reporting frameworks and national and international regulations and standards, and develop cross-cutting initiatives for all entities that allow us to generate a greater impact as a Group.

A relevant milestone of 2024 refers to the way in which we continue to advance in the implementation of best practices in sustainability at a global level, taking as a reference the Corporate Sustainability Assessment – CSA, which is the basis for the definition of the Dow Jones Sustainability Index. Thanks to this effort, we achieved continuous improvement in the three dimensions: Environmental, Social and Governance, increasing 16 points in the 2024 measurement compared to 2023, and accumulating an improvement of 32 points since the beginning of our evaluation in 2021.

In turn, our entities Banco de Bogotá and Corfi obtained 83 and 90 points respectively. Banco de Bogotá was ranked in the top 15% and was included in the S&P Sustainability Yearbook. Corfi, for its part, obtained an

	FORM 6K	2024

outstanding result, positioning itself as the leading company in its industry in Colombia, and as one of the three best worldwide in the Sustainability index. Corfi was also included in the S&P Sustainability Yearbook in the top 10%. Banco de Occidente, for its part, participated for the first time in the measurement and obtained 49 points.

GRI 2-14, 3-1, 3-2

At Grupo Aval, materiality analysis allows us to identify and prioritize the environmental, social, and governance (ESG) issues most relevant to our business and our stakeholders. Through a comprehensive process that includes dialogue with investors, customers, employees, regulators and communities, we assess 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.

By regularly updating our materiality assessment, we reaffirm our commitment to transparency, continuous improvement, and responsible business practices. Every two years we update our double materiality exercise, through a comprehensive process of consultation with our stakeholders. In addition, annually our Board of Directors and management team review material issues considering the national context, the evolution of regulation, the best practices and the challenges of the sector. This approach allows us to strategically manage sustainability, aligning ourselves with the expectations of our stakeholders and global trends, to make informed and responsible decisions.

	FORM 6K	2024

We have identified 10 material issues that reflect our sustainability priorities and priority issues for our stakeholders. These material issues are integrated within the 7 pillars defined in Grupo Aval’s strategy to ensure greater coherence, alignment and the determination of objectives.

Material Issue – Profitable and sustainable economic performance: Grupo Aval’s growth and financial stability depend on efficient management, ensuring long-term sustainable profits. Technological innovation and the strengthening of the relationship with stakeholders are key to maintaining competitiveness in a dynamic and regulated environment.

Material issue – Sustainable finance: The financial sector has a fundamental role to play in the transition to a more sustainable economic model. Through our subsidiaries, we promote responsible investments and financing that drive the country’s development, aligning ourselves with regulatory and investor expectations.

Material issue – Ethics, corporate governance, compliance, and internal control: Strong corporate governance is essential for the trust of investors, customers, and other stakeholders. The implementation of internal control standards and procedures ensures transparency, minimizes risks, and strengthens the long-term sustainability of the business.

Material issue – ESG risk management: The consideration of environmental, social, and governance (ESG) risks in financial decision-making allows us to anticipate impacts that could affect the stability and growth of Grupo Aval. Integrating these aspects into risk management strengthens the resilience and credibility of the organization.

	FORM 6K	2024

Material issue – Security, information privacy, and data protection: In a digitalized world, data protection and cybersecurity are essential for operational continuity and customer trust. Implementing robust information security measures minimizes vulnerabilities and reinforces corporate reputation.

Material issue – Climate change management and mitigation: Climate change adaptation and mitigation not only respond to a global need but also represent opportunities for the development of financial products and services aligned with a low-carbon economy. Complying with environmental regulations strengthens competitiveness and reduces financial risks associated with the climate crisis.

Material issue – Human talent: The success of the business depends on the ability to attract, develop and retain highly qualified talent. Fostering a safe, inclusive, and human rights-respecting work environment increases productivity, innovation, and employee engagement.

Material issue – Financial inclusion and education: Financial inclusion and education are key factors for the economic well-being of the population and the reduction of inequalities. Offering access to financial services and training through our entities, reinforces market stability and expands the customer base.

Material issue – Diversity, equity and inclusion: Promoting policies, good practices and programs that encourage the development of diverse, equitable and inclusive spaces inside and outside organizations, not only generates a fairer and more productive work environment but also improves innovation and financial performance by attracting diverse talent and strengthening our relationship with stakeholders.

Material issue – Corporate reputation and marketing: Corporate reputation is a strategic asset that directly impacts the trust of customers, investors and allies. Strengthening brand positioning and corporate communication allows differentiation in the market, manages reputational risks and generates sustainable value.

Innovation is a cross-cutting strategic pillar at Grupo Aval, driving the evolution of our business and the creation of sustainable and high-impact solutions. It is not associated with a specific material theme, but it is essential to enhance each of them. Through digital transformation, process optimization and the development of new value propositions, we strengthen our ability to respond to the challenges of the environment, improve our customers’ experience and generate a positive impact on society.

	FORM 6K	2024

In the double materiality assessment exercise, the impact of the 10 material issues for stakeholders and for the business was analyzed. Based on the analysis, the material issues were mapped, thus determining the priorities according to their degree of relevance to the business and stakeholders. These are: 1) Ethics, corporate governance, compliance and internal control, 2) Climate change management and mitigation, 3) Profitable and sustainable economic performance, 4) Financial inclusion and education, and 5) Human talent.

Double Materiality Matrix

The table below summarizes some relevant milestones that demonstrate the progress we made in 2024 on each of the material issues:

	FORM 6K	2024

	FORM 6K	2024

GRI 2-29

At Grupo Aval, we recognize that constant and transparent dialogue with our stakeholders is essential for the sustainable development of our organization. We have identified our main stakeholders, analyzing our interaction with each one and developing actions that allow us to strengthen the bond and respond to their needs effectively. Through various communication channels and participation mechanisms, we promote relationships of trust and collaboration, aligning our decisions and strategies with the issues that most impact our audiences.

	FORM 6K	2024

	FORM 6K	2024

GRI 2-12, 2-13, 2-22

Grupo Aval’s sustainability model is a solid model that allows us to ensure decision-making aligned with our purposes. The Board of Directors is the highest management body with respect to ESG matters and is responsible for approving the sustainability strategy and corporate policies related to social and environmental issues, including climate change, to ensure the correct management of these matters. For monitoring and decision-making, the Board of Directors relies on the ESG Committee, made up of 3 Directors with a diversity of knowledge and experience in ESG matters. In turn, the Presidency of Grupo Aval, supported by the Vice-Presidency of Sustainability and Strategic Projects, leads the sustainability strategy, communicates to the Board of Directors and integrates sustainability into the decision-making of the business model.

Through the Sustainability and DEI Committee, we promote the adoption of best practices, standards, and follow up ensuring that environmental, social, and governance principles are effectively integrated into our strategies and operations. This approach allows us to not only mitigate risks and strengthen regulatory compliance, but also drive innovation, operational efficiency, and business resilience. By consolidating sustainability as a key pillar of corporate development, we generate a positive impact on our communities, optimize resource management and foster a company culture based on transparency, equity and responsible growth.

	FORM 6K	2024

As a leading financial group, we are aware of our responsibility to promote actions that contribute to the global goals framed in the United Nations Sustainable Development Goals (SDGs), as a roadmap that puts people, the planet, prosperity and partnerships for development at the center. Under this premise, through our activities we impact on the 17 SDGs, but we have prioritized nine of them as the most relevant and coherent with our objectives.

SDG	Action
	We contribute to dignifying the health service in the country for all people, contributing to cancer research and treatment through the CTIC.
	We promote and foster inclusive and equitable spaces through corporate policies and actions in Grupo Aval and its subsidiaries. We have 3 entities with more than 30% women on their Boards of Directors.
	With the Misión La Guajira program, we contribute to ensuring that underserved populations in the country have drinking water, with the installation of water treatment plants. In 2024 we impacted nearly 21,000 people in 80 Wayúu communities.
	We are one of the largest private sector employers in Colombia, with more than 70 thousand employees.   Our investments, payment of taxes and the generation of quality employment are multiplying engines of resources in Colombian society.
	We develop new products and solutions for our clients aimed at achieving greater financial inclusion, leveraging technology to solve the needs of the country’s population.
	We provide opportunities to the Colombian population, tending to reduce banking gaps with financial solutions according to their needs, providing savings, investment and financing options. We develop programs and initiatives with the aim of bringing alternatives to dignify their quality of life to communities in isolated areas of the country.

	FORM 6K	2024

	We seek to be facilitators in the processes of mitigation and adaptation to climate change, for which each of the subsidiaries designs strategies and measures their carbon footprint.
	We have an organizational structure in accordance with all legal requirements. We adopt the best practices of disclosure of information in terms of corporate governance and information security for our clients. We carry out anti-corruption, anti-fraud, and anti-bribery risk assessments.
	We generate alliances with key actors at the national and international level that have allowed us to promote actions with an environmental and social approach.

As a holding company, at Grupo Aval we are clear that our greatest ESG impact is generated through our entities. For this reason, we lead and promote our sustainability strategy in all our subordinate entities, promoting the integration of environmental, social and governance practices, the determination of objectives and goals related to these issues, promoting cross-cutting initiatives, and promoting a culture of sustainability in all our organizations. Through strategic coordination and the establishment of common guidelines, we promote initiatives aligned with our sustainability pillars, adapted to the particularities of each entity. We facilitate the exchange of good practices, promote collaborative projects and accompany the implementation of programs that generate a positive impact on communities and the environment. These synergies allow us to strengthen our commitment to sustainable development, maximizing impact and creating shared value for our stakeholders.

All our entities have determined their sustainability strategy, determining their stakeholders and prioritizing the Sustainable Development Goals, based on analyses of material issues and their impact on the business and its stakeholders. All of them also have, according to their context, segments and realities, goals and objectives related to their ESG impact, governance models promoted by their boards of directors for sustainability issues, and policies that provide guidelines on ESG issues. In terms of standards, adhesions and associations, we have encouraged the adoption of the highest standards in sustainability-related issues in our entities. The banks are part of UNEP-FI, the United Nations initiative for Sustainable Finance, and since 2022 they have subscribed to the Principles for Responsible Banking – PRB. Porvenir and Corfi, for their part, are part of the Principles for Responsible Investment. Our entities are part of the United Nations Global Compact and are promoters of the Asobancaria Green Protocol, committing to the transition to an environmentally friendly economy. The entities also have climate strategies under the framework of the Task Force for Financial Related Disclosures – TCFD.

Regarding the reporting of ESG matters, all our entities publish Management and/or Sustainability Reports annually, under GRI and SASB standards.

Sustainable Finance

At Grupo Aval and our entities, we understand the power of finance to transform realities and promote solutions to major social and environmental challenges. For this reason, we promote a sustainable finance model that mobilizes capital towards projects with a positive impact, from renewable energies and sustainable cities to inclusive ventures.

	FORM 6K	2024

Through our Sustainable Finance Statement, as well as our sustainable finance and responsible investment policies, we reaffirm our commitment to integrating ESG criteria into each of our decisions and actions. We also work with our institutions to design and structure responsible financial products, such as green bonds and sustainable credit lines, which channel resources towards initiatives that generate economic and social value. We also generate sustainable products and services from several of our entities such as carbon credits in Mavalle (a subsidiary of Corfi) or the Energy Services Unit of Promigas (a subsidiary of Corfi).  

In 2024, the sustainable portfolio of our entities continued to grow and reached $23.05 trillion. At Banco de Bogotá, the growth of the green portfolio went from $2.6 trillion to $4.8 trillion, which represents an increase of 84.6% compared to 2023. In the same bank, the social portfolio amounts to more than $14.7 trillion, highlighting that 76% corresponds to SME portfolios and of these, 34% corresponds to SMEs led or owned by women, while 21% has been directed to municipalities in situations of poverty.

Banco de Occidente, for its part, has a social portfolio that amounts to $2.6 trillion, which highlights the support for SMEs led mainly by women. In 2024, it obtained a US$ 50 million social loan from Citi to finance the working capital needs of SMEs. Its green portfolio amounts to 981 billion.

Some of our entities’ achievements in sustainable finance include:

	FORM 6K	2024

At Grupo Aval, our greatest pride is the impact we have on the lives of millions of people who trust us to move forward and build their future. Through our entities, we not only provide access to financial products and services, but we also create opportunities that drive progress for individuals, families, and businesses across the country.

We are driven by more than 70,000 employees who find in our entities a space to grow professionally and contribute with their talent to change realities and generate opportunities. There are 21,404 suppliers, whom we consider strategic allies, strengthening the business ecosystem together and promoting a virtuous circle of development, job creation and economic growth.

There are also millions of Colombians who have been able to make their dreams come true because we have been their “Aval” (guarantee): entrepreneurs who have given life to their businesses, families who have acquired their first home, people who have managed to finance their education, or access a vehicle that improves their quality of life.

Thus, our commitment to social impact goes beyond our operations; It is reflected in every story of progress that we make possible, reaffirming our purpose of being an engine of development for the country.

GRI 201-1

In 2024, we looked for methodologies that would allow us to understand how we are generating and distributing value to society from our activity. To this end, we work to measure the economic value generated in a consolidated way for our stakeholders in accordance with the GRI 201-1 standard.

¹ When comparing 2024 with the previous year, a contraction of 2.6% related to the decrease in interest rates is observed.

	FORM 6K	2024

We generated value for our suppliers of goods and services in 2024 for about $11.3 trillion. This represents 27% of the value generated and distributed by Grupo Aval.  

Our employees received $3.8 trillion in wages, about 9% of the total.

We contributed more than $2.7 trillion to the State, in operational taxes such as GMF, assumed VAT, ICA, deposit insurance and income taxes reaching 6% of the value generated. And we distributed dividends of $1.4 trillion to our shareholders, about 3% of the value generated.

GRI 3-3, 401-1

At Grupo Aval we seek to attract, compensate, develop and retain the best talent because we believe that our employees are the fundamental pillar of the development and success of our companies. We have a team of 70,271² people at a consolidated level where more than 47,000 employees are direct, approximately 4,500 employees are temporary and we generate about 18,000 indirect jobs, through the companies that provide us with outsourcing services.

We promote in our employees a culture led by the corporate values we share:

We are driven by working in a pluralistic, equitable and inclusive organization, where we guarantee equal opportunities for all our employees, recognizing the capacity of human talent for their merits and values, without discrimination. We have diverse and inclusive talent, where 54.3% are women and 45.7% men.

Within the framework of our Corporate Diversity and Inclusion Policy, we continue to strengthen our commitment to equitable and respectful work environments. As a reflection of this effort, we achieved the Friendly Biz recertification for Grupo Aval and all its subsidiaries, reaffirming our best practices in inclusion and respect for diversity. In addition, our work has been recognized in the Ranking of Inclusive Organizations in Latin America, where we reached 6th place, consolidating ourselves as a leading company in the promotion of a diverse and inclusive organizational culture in the region.

² The variation with respect to 2023 is -5.1%, equivalent to -3,765 jobs.

	FORM 6K	2024

Employees by gender Grupo Aval consolidated³
GRI 405-1; SASB FN-AC-330a.1

Employees by job category and gender Grupo Aval Consolidated⁴

As a Group, we actively work to promote female leadership and gender equality at all levels of the organization. Our president, María Lorena Gutiérrez, was recognized as “She Is 2024” Woman of the Year, reflecting the impact and relevance of the presence of women in strategic positions. In 2024, 34.78% of management positions in Grupo Aval holding are held by women.

A relevant milestone in the leadership of Aval’s entities is the increase in the presence of women in the top positions, 43% of the entities have a woman as president. As for our entities:

³ Employees with direct and temporary contracts consolidated Grupo Aval, Entities and subsidiaries

⁴ Collaborators with direct contracts, temporary contracts and outsourcing Grupo Aval and Entities

	FORM 6K	2024

In addition, we generate initiatives that promote sisterhood and empowerment such as Más equidad por el país, which benefits young digital talents, for women who want to study STEM (science, technology, engineering and mathematics) careers. 41% of the women in Grupo Aval hold positions in STEM areas, promoting innovation and equity in key sectors for development.

We also lead initiatives, which by example contribute to the development of Colombia to continue being transformative and inclusive agents:

At Grupo Aval we recognize that good results are achieved when we build an environment where everyone, with their unique skills and challenges, can shine and contribute to a more inclusive future.

Our commitment is to create spaces where each employee feels valued, motivated and with opportunities for growth

We are committed to creating work environments that foster collaboration, mutual respect, and personal development, promoting a healthy work environment that benefits our employees. As a result of this commitment, Grupo Aval holding obtained the certification as a Great Place To Work. An outstanding milestone was BdO’s achievement in being recognized for the second consecutive year as “The best place to work in Colombia” in the category of more than 1,500 employees. Corfi, BdB, Aval Fiduciaria, and Aval Casa de Bolsa were also certified as excellent places to work.

During the year, we continue to strengthen our commitment to the well-being and satisfaction of our employees. In the entities where the organizational climate was measured, positive results were obtained, highlighting 80% in commitment, 78% in satisfaction, 83% in well-being and an eNPS of 69%. These indicators reflect the continuous effort to generate a positive work environment aligned with the needs of our teams. In addition, 94% of FTE employees participated in this measurement, which shows a high level of involvement in the construction of a solid and sustainable organizational culture.

	FORM 6K	2024

We also promote the growth and development of our talent, guaranteeing opportunities for internal growth and attracting the best professionals. In 2024, 22.73% of Grupo Aval holding’s new hires came from employees who previously worked in other entities of the Group, reaffirming our commitment to mobility and professional development within the organization.

As for the vacancies that are filled by internal candidates in Grupo Aval holding, this figure was 8%. For our entities, the figure is very outstanding, indicating that, on average, 58% of new vacancies are filled by internal collaborators.

The average cost of hiring an employee at Grupo Aval holding is $5,550,000.

⁵New hires of women and men Aval Group and Entities / open vacancies

⁶Calculated on the total number of Employees with an indefinite term contract, Grupo Aval holding and Entities

	FORM 6K	2024

We are aware that recognition is an essential component for the management of our teams, because it reinforces the emotional connection of employees with their work and with our organization. We are constantly exploring ways of recognition that are fair and motivate our employees to do their jobs better every day.  

With this purpose in 2024 we carried out the #YoSoyAval day. The event is a space to share with our thousands of employees that celebrates and values the commitment of employees to the achievement of our goals. On this occasion, the same employees were in charge of nominating their colleagues, highlighting their most outstanding contributions in each of the categories: empathy and connection, collaboration and teamwork, customer-centric innovation and sustainability and social impact. Subsequently, the 40 winners of the #YoSoyAval awards were chosen, reinforcing our sense of community and collaboration.

Education and Training

GRI 404-1, 404-2

We are committed to the development of our talent. In 2024, Grupo Aval holding provided more than 4,163 hours of training to our 124 employees. This corresponds to 35 hours of training per person during the year. The investment in this process was $1,049,420 per employee.

In our entities we have robust training and education processes to guarantee the development of skills, the strengthening of competencies and the adaptation to a constantly evolving environment. Through Corporate Universities, we offer training programs tailored to specific needs and promote holistic growth of our community. In this sense, investment in training translates into a strengthening of human capital and greater competitiveness in the market, promoting excellence, innovation and commitment to our corporate values.

Some of the Universities of our entities are:

In terms of regulatory training, at Grupo Aval holding we have the Lineamientos Aval program, which is a training program that allows us to strengthen regulatory issues with relevant impact on the business. This program addresses topics such as: code of ethics and conduct, purchase of goods and services, sustainability, related parties and conflicts of interest, relevant information, business continuity, exposure and concentration of risks, information security, occupational health and safety management system, SOX, money laundering prevention system, risk management of financial conglomerates, among others. 100% of our employees complied with the regulatory training.

	FORM 6K	2024

In relation to the Company’s Code of Ethics and Conduct, each employee upon joining the company receives training and undertakes to comply with the provisions of this code. By 2024, more than 60 hours of training on this topic were invested during the induction and within this Lineamientos Aval program.

Mi Grupo es Aval: Well-being and Benefits for Our People

Thinking about the well-being of our employees and their families, we created Mi Grupo es Aval, a comprehensive platform that brings together the benefits of all our entities and strategic allies. Through this initiative, we offer access to exclusive discounts, wellness programs, aid, insurance, educational agreements, financing options, and many more advantages designed to improve the quality of life of those who are part of our Group.

Recreation

In 2024 we promoted integration and mental well-being with 10 gastronomy and crafts activities, reaching an expected 86% participation. In addition, 29% of Grupo Aval Holding’s employees enjoyed #ExperienciasAval with a companion, accessing 26 cultural and musical events. We also carry out special activities for the children of employees on key dates and deliver Christmas gifts.

As part of our celebration of the achievements of 2024 and seeing all the employees of Grupo Aval holding and its entities as a Group, we organized, for the first time, an end-of-year celebration. We had a very special evening where we shared, related to each other and recognized the achievements of all our entities.  

Sports & Health

We continue with the De vuelta al podio program, with a participation of 37% of employees, promoting sports and recreational competitions. In addition, 20% of the employees participated in the Bogotá Half Marathon with specialized medical support. Through employee funds and compensation funds, 35% accessed health benefits, and 24% to sports and recreational activities for themselves and their families.

Work-Life Balance

All employees have a working week of 40 hours, less than that established by law. 42.86% maintained a hybrid work scheme and can work one day of the week from home. In addition, they received an additional 2.5 working days of rest. 19% obtained home or vehicle loans with preferential rates and 24% accessed other differential credit lines. 60% have free parking, and 42% participated in volunteering for the benefit of vulnerable communities.

3.4% of employees took maternity or paternity leave, and all returned to work once the leave ended.

Our entities offer a portfolio of benefits to their employees that include:

	FORM 6K	2024

We promote a safe environment for our employees

GRI 403-1, 403-5, 403-8, 403-9

At Grupo Aval Holding we have an Occupational Health and Safety Management System (hereinafter OH&S Management System), which has been implemented in compliance with the legal requirements contemplated in Resolution 312 of 2019, Decree 1072 of 2015 and other regulations in force in Colombia on occupational health and safety.

Our occupational Health and Safety Policy has among its main objectives to provide safe and healthy work environments for employees, suppliers, contractors, visitors and in general, for all people who carry out activities in the company’s facilities. To achieve this, our OH&S Management System has the technical, human and financial resources necessary to develop its work plan that contains activities aimed at identifying and intervening in hazards to minimize occupational accidents.

The scope of our OH&S Management System is aimed at 100% of employees in all positions and levels of the organization, as well as 100% of our suppliers, contractors and visitors. The OH&S Management System is at 100% implementation.

Our OH&S Management System has been subject to external audits that verify compliance with the standards required by current legal regulations. The last audit took place in November 2024 and was carried out by the firm Smart Solutions Technologies SAS. In this audit, there were no findings of non-compliance.

The occupational health and safety systems of our entities are 98.4% implemented.

In addition, on average, 14,454 hours were dedicated to training and education in occupational safety and health, covering all entities.

By 2024, there were no work-related fatalities in any of the Group’s entities.

Below is the registered absenteeism rate, which is due exclusively to medical causes and is not related to workplace accidents:

DJSI 3.4.3.

We promote free association

GRI 2-30

We support an environment where free association is respected and valued. At Grupo Aval holding we do not have unions or conventions. However, our entities Banco de Bogotá, Banco de Occidente, Banco Popular, Banco

	FORM 6K	2024

AV Villas, and Corfi⁷, have unions and conventions for employees with direct contracts. The consolidated figures of these entities show that 37% of their employees are unionized, and 16% are conventional.

Our entities maintain constant dialogue with union organizations, promoting communication spaces to strengthen the well-being of our employees and the sustainability of the business. To ensure comprehensive management in this area, they have tools such as Great Place to Work (GPTW) measurement, which allows them to know the perception of the teams and guide improvement actions. In addition, they have mechanisms for collective bargaining and conflict resolution, promoting agreements that benefit all parties. Likewise, they complement these initiatives with effective service channels that guarantee active listening and a timely response to the needs of our talent.

Our Human Rights Policy incorporates specific commitments such as respect for the right to free association and collective bargaining, equitable remuneration in accordance with the law, respect and non-discrimination, and recognition of the value of the culture and diversity of the people and territories where we operate.

Grupo Aval holding, Corfi and Porvenir do not have unions or conventions.

Our social impact translates into the way we generate opportunities for our stakeholders through comprehensive solutions that drive economic development and inclusion. We facilitate access to financial services that strengthen the autonomy of our customers, allowing them to grow and achieve their goals. At the same time, we promote the development of our suppliers, strategically integrating them into our value chain and strengthening their capacities for greater competitiveness. With a cross-cutting approach, we create synergies that enhance sustainability, equity and shared growth, consolidating a stronger, more innovative and resilient ecosystem.

5.3.1       Financial Inclusion and Education

GRI 3-3; SASB FN-CB-240a.4

At Grupo Aval, we believe that access to financial products and services is key to economic development and the reduction of social gaps. For this reason, we work so that more people and companies, in underserved populations, can access solutions that allow them to grow and improve their quality of life. Through digitalization, the expansion of service channels, products designed for different segments, and financial education programs, we facilitate banking penetration and promote responsible use of financial services.

Some figures that show that we work from our entities for true financial inclusion:

⁷ Corficolombiana Investments

	FORM 6K	2024

In our commitment to financial inclusion and economic development, we have implemented several initiatives that generate a real impact on people and businesses:

5.3.2       We impact our clients with transversal solutions and benefits

We are clear that together we are stronger. Although as a holding company we do not have direct customers, we are committed to generating synergies that amplify our impact, allowing us to improve the user experience, optimize the investment of our resources and develop strategic projects that align us under a common purpose. Through collaboration between our entities, we seek to be more efficient, offer better services and maximize the value we create for everyone.

Aval Valor Compartido - AVC

In September 2024, we began the transformation of ATH into AVC (Aval Valor Compartido), consolidating it as the strategic partner of Grupo Aval entities to develop new transversal capabilities and generate value for all its stakeholders. AVC is designing a strategic roadmap that will allow it to capture synergies and efficiencies through

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agile processes and the provision of administrative, operational and technological services to the group’s companies, optimizing costs and improving the quality of service. AVC’s commercial evolution will focus on three fundamental pillars:

Throughout 2024, AVC stood out for ensuring high availability in the physical and digital channels it operates. Specifically, the 2,853 ATMs that make up the Red Aval processed an average of 2,900 transactions per month, dispensing approximately $47.5 trillion pesos during the year. Meanwhile, the banking correspondents with whom Aval Banks work processed more than 105 million transactions, totaling nearly $23 trillion, representing a 2.6% increase compared to the previous year. In digital channels such as Aval Pay Center, more than 31.8 million collection and payment transactions were processed, for an approximate amount of $27 trillion, reflecting a growth of 38% compared to 2023. The average availability of the platform exceeded 99.86%.

During this same period, AVC played a key role in the launch of the Tag Aval, Grupo Aval’s alphanumeric key that initially allows money transfers between accounts of the Aval Banks within the Banco de la República’s Bre-B Immediate Payment System. To date, approximately 8.5 million Tag Avals have been consolidated into our customers’ products. Other notable milestones in 2024 include the renovation of 77.6% of the ATM network and the migration to cloud services, initiatives that contributed to a reduction of 786.65 metric tons of carbon dioxide emissions.

Finally, towards the end of the year, a transversal project was launched under the leadership of AVC, aimed at capturing synergies in the purchasing and supply chain processes for all the entities of Grupo Aval. In addition, in 2024 AVC was certified as a Great Place to Work (GPTW) for the first time, reinforcing its commitment to employee well-being and development.

Red Aval

The face-to-face service channels of the Aval Banks are integrated into our Red Aval. This network is managed by AVC. Through the Red Aval, we offer millions of users easy and secure access to their financial transactions throughout the country. With thousands of ATMs available, we facilitate operations such as withdrawals, inquiries, and payments quickly and efficiently. Our platform is fully integrated so this allows customers to transact from any of the Aval Banks. In 2024 we reinforced our commitment to innovation and service by upgrading 484 ATMs, improving our customers’ experience with more modern and accessible technology.

Similarly, the branches of the Aval Banks are integrated so that customers can carry out the most common transactions (withdrawals, deposits, balance inquiries and payments of obligations, among others) in any branch. As our transactional and service channels have evolved to non-face-to-face platforms, such as mobile and web banking, we have worked together with our entities so that these developments are made under corporate guidelines and on transversal platforms. This allows us to capture the synergies of development and maintenance, ensuring uniform service standards for Aval Banks’ customers.

The Tag Aval

In October 2024, we launched the Tag Aval, an initiative that seeks to promote the era of digital transactions, with immediate transfers between multiple banks and wallets. In preparation for the entry into operation of Banco de

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la República’s immediate payment system Bre-B, which will begin operating in 2025, we decided to move forward with the Tag Aval as the best alternative to make transactions immediately, easily and securely. And of course, with the same security and stability that has always characterized our technological infrastructure.

The Tag Aval is a unique alphanumeric indicator associated with our users’ account that is shared to receive money, without the need to provide personal data. The Tag Aval can be personalized so the person can freely choose the name they want to give it.

Nearly seven million customers of the banks of Grupo Aval and of our wallet dale! already have their Tag Aval.

ADL Digital Labs

ADL Digital Labs – ADL focuses on the development of transversal solutions and services for our entities, and is part of the strategy of innovation, transformation and digital payments. This strategy is based on the development of innovative, efficient solutions, where the user experience is the priority.

Our banks continue to consolidate their digital product portfolio in line with their product and segment focus. Aval Banks’ digital sales in 2024 reached 1.3 million products, and digital adoption by 7.2 million customers.

On the digital marketing front, Mathilde ADL (centralized digital marketing platform) has centralized the Group’s efforts, optimizing customer acquisition and retention strategies. Through strategic campaigns, we managed to impact key initiatives such as the refilling of personal loans and the commercial strengthening of CDT’s product. In addition, we gather, process and standardize the Group’s data through various information channels and grouped in the Augusta data-lake, under corporate data governance guidelines.

#ExperienciasAval

#ExperienciasAval has been, for more than ten years, a key driver for the democratization of culture and entertainment in Colombia. With more than 347 shows performed in different artistic genres and for all ages, it has brought music, theater and other cultural expressions closer to millions of people. Through this initiative, we have managed to differentiate our value proposition in the financial sector, generating tangible benefits for our customers and potential users, while strengthening the retention, placement and activation of cards of our entities.

Every year about one million people enjoy concerts and events supported by Grupo Aval, thanks to the network of its banks and dale!. In 2024 alone, we facilitated 52 exclusive pre-sales and sponsored 67 events, consolidating ourselves as the main driver of the entertainment sector in the country. Beyond the cultural offer, #ExperienciasAval positively impacts the Colombian economy by promoting job creation, boosting tourism and strengthening the value chain of the entertainment industry. By supporting national and international artists and promoting meeting spaces for the public, we reaffirm our commitment to the cultural and economic development of Colombia.

GRI 204-1

We consider our suppliers as strategic partners in the generation of value and sustainable development. The multiplier impact that our suppliers have drives us to grow together, by building relationships based on transparency, ethics and innovation, promoting high standards of quality and sustainability in our supply chain. Through fair processes, capacity building, and the promotion of best practices, we support the growth of our

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suppliers, thereby boosting employment, competitiveness, and positive impact on Colombia’s economy. By 2024, we generated value for our suppliers of 11.2 trillion, which translates into economic development for them and their environments.

We have 21,404 suppliers, of which 96% are domestic, to whom we allocate 97% of the total amount of purchases:

We have a Corporate Sustainable Procurement Policy, aligned with our environmental, social and governance (ESG) commitments, to promote responsible practices and foster sustainable development.

In addition, through different initiatives, we promote training in our suppliers in ESG criteria, and we continue to incorporate sustainability criteria in the process of selecting and evaluating our suppliers.

All our entities implement strategies for the proper management of suppliers. Banco de Bogotá, for example, has a structured sustainable sourcing model, aligned with global trends and the Sustainable Development Goals (SDGs). This program is based on six key phases: diagnosis, ESG development, supplier training, pilot phase, implementation, and positioning. Among its main initiatives are the Sustainable Seals, which recognize suppliers with good practices in circular economy, climate action and social responsibility, with Gold, Silver and Bronze levels. In addition, they implemented a carbon footprint calculator, based on the ISO 14064-1 standard, to help suppliers measure and reduce their emissions.

The BdB also organizes a Summit called Proveedores del Cambio that strengthens the relationship with them, promoting sustainability as a competitive advantage and providing training in key trends such as TikTok for business and alliances with Business Banking. Finally, the Bank’s Sourcing2Equal Colombia program, in partnership with the IFC, seeks to promote the participation of women entrepreneurs in corporate acquisitions.

Banco de Occidente, for its part, continued to promote sustainability-focused initiatives among its suppliers. It conducted an ESG assessment survey with the participation of 475 suppliers, allowing them to measure their performance in environmental, social and governance aspects, identify opportunities for improvement and align their practices with the Bank’s sustainability objectives. In addition, it conducted training for 535 suppliers on key topics such as climate change, corporate governance, human rights, personal data protection, SDGs, risk management and the SARLAFT Policy for procurement.

Corfi, through Creciendo Juntos program, developed the third version of the CORFISostenible Award, a recognition of suppliers that develop projects and initiatives focused on sustainability, where more than 106 suppliers participated, highlighting 12 winners for their innovative initiatives in sustainability. Of these, 40 were SMEs and 35 companies led by women. In addition, short training courses were offered to strengthen capacities, build confidence and create growth opportunities for Corfi’s suppliers and its strategic allies.

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Porvenir has also structured its procurement strategy with ESG criteria, achieving that 95% of its acquisitions are made under this approach and that 91% of its suppliers are domestic, with a growth in the participation of SMEs to 63%.

These efforts reflect Grupo Aval’s commitment to the country’s economic development, supporting suppliers from different sectors to reach their full potential.

Our social impact expands beyond our operations. We have a deep commitment to transform realities and that is why we work on the development of social projects that serve marginalized communities. In 2024, we invested more than $70 billion in these projects that impacted more than 106,000 people. These projects include initiatives to improve infrastructure, health, the development of productive projects, education programs, initiatives for the strengthening of skills, among others.

Directly and through different Foundations, at Grupo Aval and our entities we work as a group with communities to improve their quality of life and offer them opportunities for a sustainable future.

GRI 203-1

We are celebrating one year of Misión La Guajira, one of the most significant social projects in the country and one of the main programs of Grupo Aval in its commitment to improve the quality of life of the most marginalized populations. Misión La Guajira is a public-private partnership between the Presidency of the Republic, Grupo Aval and Promigas, with the support of Prisa Media and La W, whose main objective is to bring development to the Wayúu communities of the municipalities of Manaure and Uribia, through comprehensive and sustainable solutions that meet vital needs of access to drinking water, sustainable energy and food security.

Thanks to the immense work of our collaborators and the entities that make up Grupo Aval, and thanks to our allies and mainly to the communities, with whom we have worked as a team since the birth of the initiative, we have managed to transform the quality of life of 21,000 people, 3,000 families, in 80 communities, with solutions for access to water, energy or food security.

We committed to being an initiative with a sustainable, participatory, differential development approach, respectful of the worldview and knowledge of the Wayúu communities. And we have done so. We took the time to get to know the territory, the communities, their needs and in this process we characterized more than 190 communities.  

One of the main benefits of this process has been the collective construction and the solid team that we have formed with the Wayúu community with whom we have carried out rigorous processes of socialization, agreement and co-creation, which sought to ensure that the communities had clear, complete and timely information about the project, accepted its implementation, and committed to its sustainability.

In 2024, thanks to Misión La Guajira, the following solutions were implemented:

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In addition, we have implemented economic and environmental development initiatives that seek to strengthen the capacities required by communities for the sustainability of the solutions implemented. These initiatives include:

Finally, we have extensively strengthened the productive ecosystem, creating value for different stakeholders. $18 billion were invested and 20 local suppliers were hired, of which 4 operated for the first time in the territory. This is how we continue to boost the regional economy.

The Centro de Tratamiento e Investigación sobre Cáncer Luis Carlos Sarmiento Angulo (CTIC) continues to strengthen its higher purpose of being a leading reference in technology, treatment and research, at the service of all types of cancer patients. Its commitment to excellence is reflected in the comprehensive care it provides, standing out for the human and professional quality of its team, as well as for its advanced technological resources. Through prevention programs, community counseling, and robust research studies, the CTIC is an essential ally in the fight against cancer in Colombia.

In 2024, the CTIC provided care to 5,962 patients, reaching more than 15,279 since its opening, in different Clinical Functional Units and Functional Assistance Units. In a comprehensive manner, 27,546 specialized medical consultations, 14,847 radiotherapy sessions, 14,735 diagnostic images, 10,677 sessions in the infusion center and 2,508 surgeries, among other care, were provided. The perception of humanized care by patients was 95%.

CTIC is the first center in the country to open its doors to develop Phase I Clinical Trials for cancer patients who voluntarily wish to be part of these innovative treatments. In addition, the center has achieved an outstanding scientific impact with the publication of 132 articles, with an average H1 index of 9.56, and with the realization of 385 presentations at national and international congresses with the participation of specialist teams, reaffirming its leadership in medical research.

In 2025, the CTIC will continue to offer its current services by implementing the best treatments and research and will present to the national and international community health programs that contribute to the prevention and early detection of different pathologies.

⁸ The CTIC is a non-profit foundation of the Organización Luis Carlos Sarmiento Angulo, dedicated to comprehensive care and cancer research in Colombia and the region. In previous years, Grupo Aval and its entities supported with donations for its construction and start-up.

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We understand the transformative power of entertainment and the importance of ensuring equitable access to cultural and recreational experiences. For this reason, we work in alliance with 21 foundations and organizations with the purpose of sponsoring people from different populations, giving them the opportunity to enjoy events that ratify their right to entertainment.

Through these initiatives, we seek to democratize access to leisure and cultural spaces, allowing historically excluded communities to live enriching experiences.

Our entities’ commitment to their social impact

Banco de Bogotá Foundation

Banco de Bogotá, through its Foundation, developed strategic initiatives focused on social and climate entrepreneurship, education and social welfare, and the environment, promoting economic growth, inclusion and sustainability.

In 2024, in social entrepreneurship, the third edition of the Mujeres Cambiando la Moda program was launched, with the registration of 110 brands. After a selection process with experts from Inexmoda and the Banco de Bogotá team, 30 brands were chosen for a training plan in strategy, business model, product design, brand positioning, e-commerce and access to financial services.

In education and social welfare, the Desarrollo del Talento Digital Juan María Robledo program allocated $600 million to support 150 students with an economic aid of $2 million per semester for their maintenance, thus strengthening access to higher education. In addition, within the framework of the BdB’s philanthropy strategy, support for 26 foundations was prioritized with monetary donations, contributing to their social work.

In the environment, the BdB Foundation has led ecological restoration initiatives, with the planting of 26,000 trees and mangroves in the Amazon and the Caribbean coast.

Corficolombiana Foundation

Through the Corficolombiana Foundation, we promote sustainable development, education and productive strengthening in communities and sectors where Corfi’s investments are present. In 2024, the Foundation impacted about 34,027 people through its lines of work. The Destinos Sostenibles program, which seeks to promote places with a tourist vocation, benefited 6,000 people in San Luis de Palenque (Casanare) and Ambalema (Tolima), promoting innovation and local entrepreneurship to generate economic growth.

In Meta, Cultivando Talentos para el Campo initiative has strengthened educational trajectories and the socio-productive development of 5,300 children and young people in Cumaral, Puerto López and Puerto Gaitán. In addition, Proyectos Productivos Sostenibles program has supported initiatives such as Piedra Pelona Coffee in Antioquia and honey production in Meta, benefiting 472 people, promoting the balance between economic progress and environmental sustainability.

The volunteer activities of the Corficolombiana Foundation also reflect the organization’s commitment to sustainable development, inclusion and community strengthening. Some examples include the Revitalización del Centro de Bogotá program, in which 104 people participated in cleaning, maintenance and beautification of public spaces. Also in Medellín, volunteering in the Huerta Agroecológica benefited 218 boys and girls from the Internado PAN Miraflores, promoting environmental education and food sustainability. In addition, Manos a la Huerta initiative improved the production conditions of a community garden, benefiting 165 older adults, who in addition to receiving fresh vegetables, generate income from their commercialization.

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Other social impact initiatives of our entities

In the field of health, the bank has been the private company with the largest contributions to the Tapas para Sanar program of the Sanar Niños con Cáncer Foundation, contributing to the financing of medical and psychosocial treatments.

To promote education, 4,844 school kits were delivered in Boyacá, Casanare and Norte de Santander, and the Educando para la Paz initiative in Norte de Santander was supported with 1,500 school uniforms made by mothers who are heads of households, encouraging school attendance and support for vulnerable families. During the holiday season, the bank transformed its corporate gifts into 4,000 toys for vulnerable children and, in partnership with the Banco de Alimentos de Bogotá, delivered 6,000 groceries to families in poverty, victims of the conflict and migrants, with the support of employees in volunteer days.

TCFD Report

At Grupo Aval, we understand the role of the financial sector in the transition to a more sustainable economy. As one of the country’s leading financial conglomerates, our impact goes beyond the management of our operations; We are a key player in mobilizing capital towards projects that protect the environment, drive climate action, and

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foster sustainable development. We actively contribute to the conservation of the planet through our sustainable financing strategy, the strengthening of our ESG criteria in decision-making, the biodiversity conservation projects we develop, our strategy for climate change management, the reduction of our own environmental footprint, and the generation of awareness of environmental protection.

Our commitment can be summarized in the following basic elements in which we have developed specific actions with our institutions:

GRI 3-3

Climate change is one of the greatest threats to sustainable development and global financial stability. At Grupo Aval we not only recognize this challenge, but we have decided to act with determination. We know that measuring is the first step to management. That is why we measure our carbon footprint and that of our entities, and we are committed to achieving carbon neutrality in scopes 1 and 2 by 2025, reducing our emissions by 51% by 2030, and moving towards the goal of being Net Zero by 2050.

We have made progress, together with our institutions, in the definition of strategies for the management and mitigation of climate change, with plans framed within the framework of the Task Force for Financial Related Disclosures – TCFD. This is reflected in the progress made in terms of our climate strategy, climate risk management, governance model, and goals and objectives. In 2025 we will move towards the definition of our decarbonization route by generating guidelines from Grupo Aval to ensure greater alignment of the strategies of our entities, greater coordination, sharing experiences and for the development of high-impact cross-cutting projects.  

GRI 3-3, 305-1, 305-2, 305-3

As a financial holding company, we reaffirm our commitment to the transition to a low-carbon economy that is resilient to climate change, aligning ourselves with applicable regulations and supporting the actions of our entities in this regard.

In line with our sustainability strategy, which includes prioritizing climate issues within our material affairs and the Sustainable Development Goals, we believe that climate change management and mitigation offers opportunities for the development of financial products and services aligned with a low-carbon economy, which not only allows us to comply with environmental regulations, but also to strengthen our competitiveness and reduce the financial risks associated with the climate crisis.

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At Grupo Aval, we are adhered to the United Nations Environment Programme Finance Initiative (UNEP-FI) that allows us to guide our strategy and that of our banks, in coherence with the Sustainable Development Goals and the Paris Agreement.

Our strategy for managing climate change sets out the following main goals:

The definition of these objectives begins by measuring the impact that our activity generates on the environment. We carry out the greenhouse gas (GHG) inventory under the GHG Protocol methodology for scopes 1, 2 and 3, with the support of a specialized external consultant that allows us to guarantee the accuracy and comparability of the data under a standardized methodology, thus facilitating the monitoring of our progress and alignment with international best practices:

Note: The direct and indirect emissions of scopes 1 and 2 correspond to the offices located in Bogotá, in the Banco de Occidente Building (22nd and 23rd floors).

In 2024, the measurement of our carbon footprint yielded a higher value than in previous years, as we strengthened our measurement methodology by reclassifying some emission factors and including new factors in scope 3, such as financed emissions. Scope 1 emissions increased by the inclusion of a new emission factor and the reclassification of a factor that was classified in Scope 3. The increase in emissions in Scope 2 was mainly due to the increase in the emission factor of energy from the electricity grid, given that during the year thermal plants supplied the country’s energy to a greater extent due to the El Niño phenomenon.

⁹ The increase in scope 1 was mainly because the emission factor for HFC-410a/R-410a refrigerant is higher and also because the gasoline used by the courier was being accounted for in scope 3.

¹⁰ The main reason for the reduction in Scope 3 emissions between 2019 and the following years was the lower presence of employees in offices due to the COVID-19 pandemic. As a result, air travel and the use of ground transportation were significantly reduced. Additionally, water and paper consumption decreased due to the greater digitization of documents and the strategies implemented for efficient and responsible consumption of resources.

¹¹ Includes financed issuances of Grupo Aval (see section “Financed Emissions – Grupo Aval”).

¹² The figures for 2023 were updated. Regarding Scope 1, it went from 0.04 to 2.88 ton CO₂e as information related to the consumption of refrigerants from fixed sources was included. In relation to Scope 2, the energy emission factor from the electricity grid was updated, which generated an increase from 19.38 tons to 29.90 tons of CO₂e. Scope 3 did not change.

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As for Scope 3, this year we deepened its measurement by incorporating the following categories: (1) goods and services acquired, (2) capital goods, (5) waste generated in operations, (6) business trips, (7) employee commute, and (15) investments. As a result, our scope 3 emissions amounted to 8,406.46 tons of CO₂. With this adjustment in the measurement, we decided to establish 2024 as the base year to develop more precise mitigation strategies for the reduction and compensation of our carbon footprint.

We offset our carbon footprint for 2024 Scope 1, 2 and 3, without the category 15 investments, with the purchase of 600 carbon credits from Mavalle.

Financed emissions – Grupo Aval holding

SASB FN-CB-410b.1, FN-CB-410b.3, FN-CB-410b.4

At Grupo Aval Holding, we report the financed emissions, of Scope 3 (Category 15: Investments), generated by the most relevant entities in proportion to their controlling interest, taking into account financial materiality criteria. Thus, by 2024, the report includes four¹³ of Grupo Aval’s main entities (Banco de Bogotá, Banco de Occidente, Banco Popular and Corfi), which together comprise the majority of the emissions generated, in accordance with the methodology established in the GHG Protocol.

¹³ This information will be updated in 2025 once the measurement of the carbon footprint of our Banco AV Villas and Porvenir entities has been completed.

¹⁴ The calculation of Grupo Aval’s financed emissions is carried out according to the GHG Protocol methodology. The formula corresponds to ∑ [scope 1 emissions (ton CO₂e) entities + scope 2 emissions (ton CO₂e) entities] * percentage of participation (%) of Grupo Aval.

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In 2025, it is expected to strengthen the measurement with the inclusion of the emissions of other Grupo Aval entities. Additionally, the inclusion of the Scope 3 measurements of our entities (which include financed emissions) will be evaluated to identify how to report these within the Scope 3 issuances of Grupo Aval holding.

Financed emissions – Entities:

SASB FN-CB-410b.1, FN-CB-410b.2, FN-CB-410b.3, FN-CB-410b.4

As for the measurement of the financed emissions by our entities, these are:

Banco de Bogotá continued to strengthen the measurement of financed emissions following the methodology established by the Partnership for Carbon Accounting Financials (PCAF), while Banco de Occidente carried out its measurement using this same methodology for the first time.

Both banks carried out the calculation of the emissions of their portfolios for the year 2023. To do so, they identified and prioritized the sectors with the greatest contribution to the financed emissions and made an estimate of the scope 1, 2 and 3 of the clients of these sectors. In some cases, information on emissions was taken from their public management and sustainability reports.

The prioritized sectors were: Oil & Gas, Energy, Infrastructure/Construction, Steel, Cement, AFOLU and others:

The total financed emissions by our banks¹⁶ in 2023 corresponded to 10,141,133 tons of CO₂e. To mitigate them, we seek to promote a more environmentally responsible portfolio through the sustainable financing of our banks, and for our clients to invest in projects that generate fewer negative impacts (see section “Sustainable Finance”).

¹⁵ The estimated financed emissions of our banks’ portfolios correspond to 2023 (year prior to the current reporting period), due to the fact that the accounting closings of their 2024 clients are made in the second half of the following year.

¹⁶ Note: Given that this is an ongoing exercise, Banco Popular and Banco AV Villas are working on measuring their financed issuances to have an increasingly accurate approximation of the emissions we finance through all our banks. Due to the business strategies of these banks, their efforts are mainly concentrated on social finance.

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SASB FN-AC-410b.1, FN-AC-410b.2, FN-AC-410b.3, FN-AC-410b.4

Similarly, under the commitment to contribute to the reduction of the generation of emissions in investment portfolios, Corfi and Porvenir measure their financed emissions to identify sustainable investment strategies.

Corfi reports the calculation of its financed emissions as follows:

Reinforcing our commitment to reducing environmental impact, our entities have implemented reduction measures, reforestation strategies and emissions offsetting. In this sense, Banco de Bogotá and Banco de Occidente were certified by Icontec as carbon neutral in their operations, while Corfi offsets their footprint (scopes 1 and 2) through the purchase of carbon credits.

Porvenir continues to measure greenhouse gas (GHG) emissions derived from a portion of its investment portfolios under the PCAF methodology. These measurements will make it possible to establish a baseline and walk the path towards setting decarbonization targets.

The financed emissions and carbon footprint for the assets covered by Porvenir in terms of listed equities, corporate bonds and sovereign bonds were 2,691,408 tons of CO₂e in 2024. The carbon footprint for the year 2024 was 105.5 tons of CO₂e for every million dollars of assets under management. This measurement covers 50.9% of the assets under management of the Fund.

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Based on the objectives set and based on continuous improvement in the way we measure our impacts and manage them, we continue to consolidate our strategy for managing climate change. This strategy contemplates, in addition to the strengthening of the strategies that our entities have been developing, the definition of policies and guidelines, initiatives for the mitigation and adaptation of climate change, and incentives for the management of climate-related issues, among others.

Our strategy incorporates climate considerations into the objectives of our institutions, ensuring that climate change is not only a risk factor, but also a source of opportunities. This is reflected in i) the development of sustainable financial products, including loans for renewable energy, resilient infrastructure and sustainable mobility projects, ii) the expansion of the sustainable portfolio, with an increasing allocation of capital to sectors aligned with a low-carbon economy, iii) participation in green and sustainable bond markets to diversify responsible sources of financing, iv) the identification of new products and services in our non-banking entities (such as carbon credits or energy services offered by some Corfi subsidiaries).

Grupo Aval is developing a roadmap to ensure that its operations and financial decisions are resilient to future climate scenarios. This roadmap includes the analysis of climate scenarios to anticipate impacts on key sectors of the economy, the development of adaptation strategies, ensuring that its investment and credit portfolio is less vulnerable to physical and transition risks, and the incorporation of ESG criteria in financing decisions.

SASB FN-CB-410a.2

During 2024, we strengthened our strategic framework for climate change management and are committed to aligning with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) for managing climate change-related risks and opportunities. By 2025, Grupo Aval holding will define guidelines for the supervision and monitoring of climate change risks that affect the operations of our entities.

Climate risk analysis is integrated into the risk identification, management and monitoring process of Grupo Aval and our entities. Our banks have made progress in the design and implementation of the Environmental and Social Risk Management System (ESRMS), an analysis tool in the process of granting loans. The main objective of this system is to minimize the environmental and social risks associated with the financed projects, thus avoiding negative impacts that may generate regulatory, monetary or operational risks. ESRMS establishes a set of policies,

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guidelines, tools and procedures that allow identifying, evaluating, mitigating and monitoring environmental and social risks throughout the development of any project or financed economic activity, ensuring responsible and sustainable management of resources. Here are some highlights:

In addition, the Bank applies the Environmental and Social Risk Identification Form (E&S Risk Form), a tool through which it collects information from clients on their environmental, climate and social management. In 2024, BdB analyzed 445 credits through E&S Risk Form. Similarly, the Bank also conducts the technical feasibility study for the financing of a project or asset through sustainable lines. Although the evaluation carried out consists mainly of the validation of indicators and technical thresholds, the location of the asset/project is also verified, which validates whether it is located in an area of environmental or social importance. In 2024, it evaluated 768 credits with the technical feasibility study.

SASB FN-AC-410a.1, FN-AC-410a.2, FN-AC-410a.3

As for Corfi and Porvenir, both entities have made progress in climate risk management. Corfi and its investments apply a climate risk management cycle that includes the following stages: 1) identification of climate risks relevant to the operation, 2) evaluation of the impact and probability of such risks, and 3) administration of mitigation or adaptation measures. Corfi uses two climate scenarios, transition and physical, to carry out the risk analysis.

The evaluation of these risks was carried out with specialized teams of Corfi’s investments, considering key factors such as the probability of occurrence, the impact on income, costs and expenses, and the value of the assets. The result is reflected in a corporate risk map, in which 18 climate risks (transition and physical) were identified, which makes it possible to prioritize actions and monitor the effectiveness of the measures implemented.

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Porvenir, for its part, continues to consolidate and strengthen its internal processes to develop ESG ratings, including matters related to climate change. At the end of 2024, 54.61% of Porvenir’s assets under management already incorporated the evaluation of ESG criteria, reflecting a firm commitment to sustainability and responsible investment. In addition, a Relationship Policy was included in the Responsible Investment Policy, which establishes principles for dialogue and relationship in environmental, social and governance (ESG) matters with the companies or funds in which it invests, either individually or through collaborative engagement initiatives. In 2024, Porvenir continued to participate as an active member of the Asset Owner Technical Committee of the Principles for Responsible Investment (PRI), reaffirming its leadership in the promotion of good responsible investment practices globally.

We will continue to work together with our entities to strengthen the systems for identifying and managing risks derived from climate change, including those associated with the impact and loss of biodiversity.

The governance structure for climate change management is based on our ESG governance model. This structure assigns key roles and responsibilities to the Board of Directors, the ESG Board Committee, the Presidency, the Corporate Sustainability Committee, the Vice Presidency of Sustainability and Strategic Projects, and the Sustainability Committee, made up of the leaders of our entities.

In this way, we ensure that aspects related to climate change are considered in strategic decision-making at the corporate level and in all our entities, with the aim of identifying, evaluating and managing the risks and opportunities associated with climate change in Grupo Aval, our entities and investment portfolios.

Likewise, our corporate policies establish a solid framework for the definition of principles and guidelines, ensuring the monitoring and compliance of our sustainability and climate change management strategy at Group level.

To ensure an effective implementation of our strategy, we train key areas such as Risk and Compliance, Financial, Legal, Sustainability and Strategic Projects and Accounting Consolidation in disclosure regulations such as the TCFD, ensuring the transparency of our environmental metrics and proper management of climate impacts.

As mentioned in Chapter 3.6, sustainable finance is not only a commitment, but also a strategy for managing risks and seizing opportunities in a changing economic environment. Our ability to mobilize capital towards sectors with a positive impact allows us to strengthen the resilience of the economy and the financial system, aligning ourselves with international standards and the expectations of our investors and clients.

In line with Asobancaria’s Sustainable Finance Goals, which set the goal of reaching a balance of $140 trillion by 2030, our entities continue to strengthen their green portfolio, allocating resources to key sectors such as renewable energy, sustainable construction, energy efficiency, clean transportation, agro-sustainable certifications, resilient infrastructure and circular economy.

Our sustainable portfolio is composed as follows:

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At Grupo Aval, we understand the importance of ensuring an efficient and responsible operation. For this reason, we implement eco-efficiency strategies in our offices that optimize the consumption of resources, reduce carbon emissions and enable responsible waste management.

Energy Management

GRI 302-1, 302-3, 302-4

In 2024, we reduced our energy consumption by 3.9%, meeting our goal of reducing 1% of the holding’s annual energy consumption. This reduction is mainly due to changes in the lamps for LED lights, we continue with energy-saving lighting systems with presence sensors in infrequent spaces, and the programming of computers with suspension timers.

In addition, we made progress in raising awareness among our employees about the importance of saving energy, among others, through communications to promote the efficient and responsible use of energy.

¹⁷ Banco de Bogotá and Banco de Occidente financed the Puerta de Oro Solar Project, the largest independent solar park in Colombia, with an investment of $407.6 billion, which will supply 390,000 homes with clean energy and strengthen the country’s energy transition.

¹⁸100% of the energy we use in the holding company is non-renewable and is used for administrative activities in Grupo Aval’s offices. Additionally, energy consumption is updated from the base year (2020), since it was reported as renewable energy, so approximately 70% of the energy acquired from the grid in Bogotá comes from hydroelectric plants. However, with the improvement of the measurement of the greenhouse gas inventory, aligning with the indirect emissions reporting model (scope 2), in this report it is updated as non-renewable energy consumption.

¹⁹ Energy consumption per employee includes direct indefinite term and outsourcing employees.

²⁰ The increase between 2022 and 2023 was due to the fact that there were more face-to-face hours for employees in the offices.

	FORM 6K	2024

Water management

GRI 303-1, 303-5

The total water used in the offices of the holding comes from the Empresa de Acueducto y Alcantarillado de Bogotá (EAAB) and is destined for domestic use by the employees, which is why the same amount is discharged into the sewerage system. Water consumption decreased by 17.7% and our goal is to reduce 1% per year. This reduction was achieved thanks to failures detected in the registration system, efficient taps in sinks by means of sensors, flushometers in the toilets that control discharges and preventive maintenance to avoid leaks that generate losses.

Waste management

GRI 306-3, 306-4, 306-5

Regarding waste management, in 2024 there was an increase of 5.75 tons compared to 2023, given that we implemented actions to make a better measurement of the waste we generate in our offices. Additionally, waste was generated from remodeling in the facilities and the organic waste that is transferred to the landfill began to be weighed.

²¹ Water consumption per employee includes direct employees for an indefinite term and outsourcing.

²² The water consumption figure reported in 2023 is updated, according to the billing periods of the Empresa de Acueducto y Alcantarillado de Bogotá, so that the period between January and December is considered for each year.

²³ This figure corresponds to wood that resulted from remodeling in the offices.

²⁴ To improve the measurement of the waste we generate, in 2024 we began to measure organic waste, which is sent to landfill.

	FORM 6K	2024

We delivered 3.89 tons of usable waste to the Sanar Foundation and the Comercializadora la Nacional, mainly for proper management. Similarly, we deliver 0.82 tons of hazardous waste to authorized suppliers who are responsible for proper disposal.

Part of this waste is voluntarily brought by employees from their homes as a result of campaigns we develop to promote recycling.

As for our entities, during 2024, all implemented relevant actions for greater eco-efficiency. These include:

	FORM 6K	2024

We protect biodiversity

GRI 304-3

At Grupo Aval, we protect biodiversity because we understand its fundamental role in climate stability, water security and the well-being of communities. We believe that the financial sector can be a key ally in their conservation, promoting responsible investments and supporting initiatives that restore and protect ecosystems. For this reason, we promote reforestation projects, conservation of strategic areas and financing of sustainable solutions that contribute to the protection of nature. Through these actions, we reaffirm our commitment to economic development that balances growth with the preservation of the country’s natural capital. In 2024 we contributed with the planting of about 990,000 trees and the protection of about 2,200 species of fauna and flora.

We also signed, within the framework of the United Nations Conference on Biodiversity – COP16, with the British Embassy the United for Wildlife Mansion House Declaration. In this declaration we commit ourselves to the fight against illegal trafficking in wildlife species.

In addition, our entities lead a series of initiatives aimed at protecting biodiversity and generating knowledge. Banco de Bogotá has been a pioneer in the development of innovative financial products for the conservation of biodiversity. Through the Amazon Green debit card, 1% of purchases go to the restoration of strategic ecosystems: 50% for the Amazon and 50% for the mangroves of the Caribbean. Thanks to this initiative developed in partnership with Saving the Amazon, BdB has planted 98,000 trees in the Amazon and 3,000 mangroves in the Colombian Caribbean. Also with Saving the Amazon, our dale! digital wallet allows anyone to contribute to the reforestation of the Amazon through donations made through the app.

Banco de Occidente, for its part, is a leader in generating knowledge and awareness around the protection of biodiversity. The Planeta Azul National Ecology Award, which celebrated its 30th anniversary in 2024, is one of the largest efforts to highlight the natural wealth of aquatic ecosystems in the country. The Award encourages companies and individuals to work on the protection and conservation of water as a source of life and recognizes the best initiatives and projects that work towards this purpose. The Bank also publishes annual collection books that highlight the country’s biodiversity. In 2024 it decided to make the entire collection public, which includes 41 books in the following QR code:

	FORM 6K	2024

As for the planting of trees, a joint effort has been made to multiply the impact. Corfi, through its investments in infrastructure, energy and agribusiness, and its Corficolombiana Foundation, planted more than 934,400 trees in 2024. Banco AV Villas, for its part, planted 520 trees within the Wihbora Nuku Project of the Saving The Amazon Foundation, allowing indigenous women in the Amazon to plant and care for native trees. Grupo Aval holding planted 360 trees in San Antonio de Bitaco (Valle del Cauca) that it donated to passengers on flights that arrived in Cali within the framework of COP16.

Our entities promote the realization of reforestation volunteering to generate greater awareness in employees about the importance of conservation. Banco de Occidente mobilized more than 280 employees and planted more than 1,900 trees of native species in places such as: Vía Parque Isla Salamanca in Barranquilla, the Parque Nacional Natural Farallones in Cali, the Cerros Orientales in Bogotá and the Parque Arví in Medellín. Corfi, in turn, held a day of planting native trees of the high Andean Forest in La Calera in which more than 90 collaborators participated.

Concerning standards in terms of our commitment to the protection of biodiversity, following the guidelines established by the Taskforce on Nature-related Financial Disclosures (TNFD), we will initiate the roadmap for the analysis and disclosure of risks associated with nature, understanding the importance of biodiversity for our businesses and the positive or negative impact that we could generate on nature. In this direction, Banco de Bogotá, Banco de Occidente and Corfi have taken the initiative to evaluate the impact of their activities on nature and its dependence on ecosystem services. In turn, they participate in the TNFD pilot, led by Asobancaria and Global Canopy, as an opportunity to learn how to evaluate and disseminate critical information on environmental impact.

In addition, Banco de Bogotá, using the TNFD’s LEAP methodology, analyzes how the location of its customers relates to areas of high biological and cultural importance. This allows it to identify environmental risks and opportunities and positions the Bank as a pioneer in the fight against deforestation and illegal trade in wildlife species, being the first financial institution in the country to adhere to the Mansion House Declaration.

SASB Table of Contents – Commercial Banks

	FORM 6K	2024

	FORM 6K	2024

FN-CB-550a.2	Description of approach to integrate results of mandatory and voluntary stress tests into capital adequacy planning, long term corporate strategy, and other business activities	Although Grupo Aval does not have a regulatory obligation to carry out stress tests, the Holding plays a role in advising, coordinating and monitoring the stress tests carried out by the Group’s credit institutions. Different internal areas of these entities participate in the design, performance and validation of the stress tests, which are responsible for developing forecasts aligned with the business plan. Each area in charge implements and validates the assumptions and methodologies that were used for the forecasts. Stress testing exercises act as a tool in the planning and monitoring of the financial situation of the entities, which also allows coordinating efforts and advancing the steps that lead the organizations responsibly towards the objectives set by each of them.
FN-CB-000.A	(1) Number and (2) value of checking and savings accounts by segment: (a) personal and (b) small businesses	Checking and savings accounts   Unit of measure   Personal   SMEs   Number of checking accounts placed  # 10,396.0 68,093.0  Number of active checking accounts  # 87,405.0 61,366.0  Amount of checking accounts  COP 1,061,866,389,979.4 3.977,146,787,783.0  Number of savings accounts placed  # 1,323,407.0 43,922.0  Number of active savings accounts  # 3.788.866.0 38,578.0  Amount of saving accounts  COP 8,515,926,071,755.3 3,136,705,997,975.9
FN-CB-000.B	(1) Number and (2) value of loans by segment: (a) personal, (b) small business, and (c) corporate	Loans   Unit of measure    Total   Personal   #  2,478,091.0  Personal - amount   COP  44,594,610,493,889.5  SMEs   #  150,967.0  SMES - amount   COP  38,529,502,765,146.4  Corporate   #  71.356.0  Corporate amount   COP  47,540,611,202,962.3

SASB Table of Contents – Asset Management and Custody Activities

	FORM 6K	2024

Third party verification

Grupo Aval’s 2024 Management and Sustainability Report has been verified by BDO Audit SAS BIC.

SIGNATURE

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Date: March 27, 2025