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Bancolombia SA – ‘20-F’ for 12/31/23 – ‘EX-97.1’

On:  Tuesday, 3/26/24, at 4:46pm ET   ·   For:  12/31/23   ·   Accession #:  1558370-24-3957   ·   File #:  1-32535

Previous ‘20-F’:  ‘20-F’ on 4/3/23 for 12/31/22   ·   Latest ‘20-F’:  This Filing   ·   1 Reference:  To:  Bancolombia SA – ‘F-6’ on 1/14/08

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  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 3/26/24  Bancolombia SA                    20-F       12/31/23  263:100M                                   Toppan Merrill Bridge/FA

Annual or Annual-Transition Report by a Foreign Non-Canadian Issuer   —   Form 20-F   —   SEA’34

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 20-F        Annual or Annual-Transition Report by a Foreign     HTML  24.96M 
                Non-Canadian Issuer                                              
 2: EX-1.1      Underwriting Agreement or Conflict Minerals Report  HTML    176K 
 3: EX-2.4      Plan of Acquisition, Reorganization, Arrangement,   HTML    285K 
                Liquidation or Succession                                        
 4: EX-8.1      Opinion of Counsel re: Tax Matters                  HTML    136K 
 7: EX-13.1     Annual or Quarterly Report to Security Holders      HTML     73K 
 8: EX-13.2     Annual or Quarterly Report to Security Holders      HTML     73K 
10: EX-97.1     Clawback Policy re: Recovery of Erroneously         HTML     86K 
                Awarded Compensation                                             
 5: EX-12.1     Statement re: the Computation of Ratios             HTML     77K 
 6: EX-12.2     Statement re: the Computation of Ratios             HTML     78K 
 9: EX-15.1     Letter re: Unaudited Interim Financial Info         HTML     74K 
21: R1          Document and Entity Information                     HTML    165K 
22: R2          Consolidated Statement of Financial Position        HTML    163K 
23: R3          Consolidated Statement of Income                    HTML    159K 
24: R4          Consolidated Statement of Comprehensive Income      HTML    163K 
25: R5          Consolidated Statement of Comprehensive Income      HTML     74K 
                (Parenthetical)                                                  
26: R6          Consolidated Statement of Changes in Equity         HTML    119K 
27: R7          Consolidated Statement of Changes in Equity         HTML     80K 
                (Parenthetical)                                                  
28: R8          Consolidated Statement of Cash Flow                 HTML    218K 
29: R9          Consolidated Statement of Cash Flow                 HTML     81K 
                (Parenthetical)                                                  
30: R10         Reporting Entity                                    HTML     86K 
31: R11         Material Accounting Policies                        HTML    962K 
32: R12         Operating Segments                                  HTML    734K 
33: R13         Cash and Cash Equivalents                           HTML     99K 
34: R14         Financial Assets Investments and Derivatives        HTML    835K 
35: R15         Loans and Advances to Customers, Net                HTML   1.36M 
36: R16         Leases                                              HTML    531K 
37: R17         Investments in Associates and Joint Ventures        HTML    444K 
38: R18         Goodwill and Intangible Assets, Net                 HTML    456K 
39: R19         Premises and Equipment, Net                         HTML    602K 
40: R20         Investment Properties                               HTML    164K 
41: R21         Income Tax                                          HTML    402K 
42: R22         Assets Held for Sale and Inventories, Net           HTML    194K 
43: R23         Other Assets, Net                                   HTML    104K 
44: R24         Deposits by Customers                               HTML    152K 
45: R25         Interbank Deposits and Repurchase Agreements and    HTML    150K 
                Other Similar Secured Borrowing                                  
46: R26         Borrowings From Other Financial Institutions        HTML    165K 
47: R27         Debt Instruments in Issue                           HTML    219K 
48: R28         Employee Benefit Plans                              HTML    440K 
49: R29         Other Liabilities                                   HTML    103K 
50: R30         Provisions and Contingent Liabilities               HTML    270K 
51: R31         Share Capital                                       HTML    100K 
52: R32         Appropriated Reserves                               HTML     84K 
53: R33         Unconsolidated Structured Entities                  HTML    120K 
54: R34         Operating Income                                    HTML    658K 
55: R35         Operating Expenses                                  HTML    197K 
56: R36         Earning Per Share ('Eps')                           HTML     97K 
57: R37         Related Party Transactions                          HTML    336K 
58: R38         Liabilities From Financing Activities               HTML    170K 
59: R39         Fair Value of Assets and Liabilities                HTML   1.30M 
60: R40         Subsequent Events                                   HTML     73K 
61: R41         Impacts on Application of New Standards             HTML     97K 
62: R42         Risk Management                                     HTML   1.59M 
63: R43         Material Accounting Policies (Policies)             HTML   1.02M 
64: R44         Reporting Entity (Tables)                           HTML     79K 
65: R45         Material Accounting Policies (Tables)               HTML    661K 
66: R46         Operating Segments (Tables)                         HTML    717K 
67: R47         Cash and Cash Equivalents (Tables)                  HTML     98K 
68: R48         Financial Assets Investments and Derivatives        HTML    845K 
                (Tables)                                                         
69: R49         Loans and Advances to Customers, Net (Tables)       HTML    808K 
70: R50         Leases (Tables)                                     HTML    542K 
71: R51         Investments in Associates and Joint Ventures        HTML    452K 
                (Tables)                                                         
72: R52         Goodwill and Intangible Assets, Net (Tables)        HTML    454K 
73: R53         Premises and Equipment, Net (Tables)                HTML    603K 
74: R54         Investment Properties (Tables)                      HTML    166K 
75: R55         Income Tax (Tables)                                 HTML    399K 
76: R56         Assets Held for Sale and Inventories, Net (Tables)  HTML    195K 
77: R57         Other Assets, Net (Tables)                          HTML    103K 
78: R58         Deposits by Customers (Tables)                      HTML    154K 
79: R59         Interbank Deposits and Repurchase Agreements and    HTML    150K 
                Other Similar Secured Borrowing (Tables)                         
80: R60         Borrowings From Other Financial Institutions        HTML    171K 
                (Tables)                                                         
81: R61         Debt Instruments in Issue (Tables)                  HTML    215K 
82: R62         Employee Benefit Plans (Tables)                     HTML    430K 
83: R63         Other Liabilities (Tables)                          HTML    102K 
84: R64         Provisions and Contingent Liabilities (Tables)      HTML    224K 
85: R65         Share Capital (Tables)                              HTML     94K 
86: R66         Appropriated Reserves (Tables)                      HTML     84K 
87: R67         Unconsolidated Structured Entities (Tables)         HTML    116K 
88: R68         Operating Income (Tables)                           HTML    638K 
89: R69         Operating Expenses (Tables)                         HTML    200K 
90: R70         Earning Per Share ('Eps') (Tables)                  HTML     96K 
91: R71         Related Party Transactions (Tables)                 HTML    324K 
92: R72         Liabilities From Financing Activities (Tables)      HTML    169K 
93: R73         Fair Value of Assets and Liabilities (Tables)       HTML   1.27M 
94: R74         Impacts on Application of New Standards (Tables)    HTML     85K 
95: R75         Risk Management (Tables)                            HTML   1.50M 
96: R76         Reporting Entity (Details)                          HTML    118K 
97: R77         MATERIAL ACCOUNTING POLICIES - Revised              HTML     93K 
                presentation of Statement of Cash Flow (Details)                 
98: R78         MATERIAL ACCOUNTING POLICIES - Subsidiaries         HTML    363K 
                (Details)                                                        
99: R79         MATERIAL ACCOUNTING POLICIES - Funds                HTML     91K 
                administration (Details)                                         
100: R80         MATERIAL ACCOUNTING POLICIES - FCP Fondo            HTML    133K  
                Inmobiliario Colombia (Details)                                  
101: R81         MATERIAL ACCOUNTING POLICIES - Exchange rate        HTML     75K  
                (Details)                                                        
102: R82         MATERIAL ACCOUNTING POLICIES - Economic Scenario    HTML    147K  
                Weightings (Details)                                             
103: R83         MATERIAL ACCOUNTING POLICIES - Significant          HTML     85K  
                increase in risk (Details)                                       
104: R84         MATERIAL ACCOUNTING POLICIES - Written-Off loan     HTML    107K  
                portfolio (Details)                                              
105: R85         MATERIAL ACCOUNTING POLICIES - Premises and         HTML     94K  
                equipment and Intangible assets (Details)                        
106: R86         MATERIAL ACCOUNTING POLICIES - Additional           HTML     83K  
                information (Details)                                            
107: R87         OPERATING SEGMENTS - Financial performance by       HTML    237K  
                operating segment (Details)                                      
108: R88         OPERATING SEGMENTS - Financial information of the   HTML    105K  
                total assets and liabilities by operating segment                
                (Details)                                                        
109: R89         OPERATING SEGMENTS - Financial information of the   HTML     91K  
                investments in associates and joint ventures by                  
                operating segment (Details)                                      
110: R90         OPERATING SEGMENTS - Geographic information         HTML    101K  
                (Details)                                                        
111: R91         Cash and Cash Equivalents (Details)                 HTML    125K  
112: R92         FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    126K  
                Financial assets investments (Details)                           
113: R93         FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    193K  
                Debt instruments portfolio by maturity (Details)                 
114: R94         FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    127K  
                Equity instruments designated at fair value                      
                through other comprehensive income (Details)                     
115: R95         FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    113K  
                Securities pledged as collateral (Details)                       
116: R96         FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    135K  
                Changes in gross carrying amount of debt                         
                securities (Details)                                             
117: R97         FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    129K  
                Provisions detail for the debt instruments                       
                portfolio using the expected credit losses model                 
                (Details)                                                        
118: R98         FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    137K  
                Changes in allowance for debt instruments measured               
                at amortized cost and fair value through other                   
                comprehensive income (Details)                                   
119: R99         FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    103K  
                Carrying values of derivatives by type of risk                   
                (Details)                                                        
120: R100        FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    104K  
                Remaining contractual life of the derivatives                    
                portfolio (Details)                                              
121: R101        FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML     75K  
                Collateral for derivatives (Details)                             
122: R102        FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML     91K  
                Unrecognised gains or (Losses) for Derivatives                   
                Trading (Details)                                                
123: R103        FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    123K  
                Hedging instruments of net foreign investment                    
                (Details)                                                        
124: R104        FINANCIAL ASSETS INVESTMENTS AND DERIVATIVES -      HTML    135K  
                Offsetting of derivatives (Details)                              
125: R105        LOANS AND ADVANCES TO CUSTOMERS, NET - Loans and    HTML     99K  
                financial leasing operating portfolio (Details)                  
126: R106        LOANS AND ADVANCES TO CUSTOMERS, NET - Allowance    HTML    112K  
                for loans losses (Details)                                       
127: R107        LOANS AND ADVANCES TO CUSTOMERS, NET - Contractual  HTML     80K  
                cash flows of loan portfolio (Details)                           
128: R108        LOANS AND ADVANCES TO CUSTOMERS, NET - Impact of    HTML     88K  
                movements in the value of the portfolio and loss                 
                allowance by stage (Details)                                     
129: R109        LOANS AND ADVANCES TO CUSTOMERS, NET - Significant  HTML    324K  
                changes in the loans and the allowance for loans                 
                losses (Details)                                                 
130: R110        LEASES - Summary of finance leases as lessor        HTML     95K  
                (Details)                                                        
131: R111        LEASES - Unsecured residual value (Details)         HTML     84K  
132: R112        LEASES - Amounts recognized as income for           HTML     87K  
                extensions (Details)                                             
133: R113        LEASES - Operating leases as lessor (Details)       HTML     89K  
134: R114        LEASES - Rollforward of right of use assets         HTML    128K  
                (Details)                                                        
135: R115        LEASES - Change in lease liabilities (Details)      HTML     87K  
136: R116        LEASES - Maturity analysis of lease liabilities     HTML    102K  
                (Details)                                                        
137: R117        LEASES - Weighted average rates and average useful  HTML     84K  
                life of right of use assets (Details)                            
138: R118        LEASES - Statement of Income impact of leases       HTML    101K  
                (Details)                                                        
139: R119        LEASES - Minimum payments lease liabilities         HTML    101K  
                (Details)                                                        
140: R120        INVESTMENTS IN ASSOCIATES AND JOINT VENTURES -      HTML     82K  
                Investments in associates and joint ventures                     
                (Details)                                                        
141: R121        INVESTMENTS IN ASSOCIATES AND JOINT VENTURES -      HTML    151K  
                Investments in associates (Details)                              
142: R122        INVESTMENTS IN ASSOCIATES AND JOINT VENTURES -      HTML    123K  
                Changes in carrying amount of investments in                     
                associates (Details)                                             
143: R123        INVESTMENTS IN ASSOCIATES AND JOINT VENTURES -      HTML     99K  
                Significant associates (Details)                                 
144: R124        INVESTMENTS IN ASSOCIATES AND JOINT VENTURES -      HTML    124K  
                Investments in joint ventures (Details)                          
145: R125        INVESTMENTS IN ASSOCIATES AND JOINT VENTURES -      HTML    114K  
                Changes in carrying amount of investments in joint               
                ventures (Details)                                               
146: R126        INVESTMENTS IN ASSOCIATES AND JOINT VENTURES -      HTML    116K  
                Significant joint ventures (Details)                             
147: R127        GOODWILL AND INTANGIBLE ASSETS, NET - Intangibles   HTML     78K  
                assets and goodwill net (Details)                                
148: R128        GOODWILL AND INTANGIBLE ASSETS, NET - Intangible    HTML    124K  
                assets (Details)                                                 
149: R129        GOODWILL AND INTANGIBLE ASSETS, NET - Goodwill      HTML     79K  
                (Details)                                                        
150: R130        GOODWILL AND INTANGIBLE ASSETS, NET - Key           HTML     95K  
                assumptions used to determine recoverable amount                 
                of goodwill (Details)                                            
151: R131        GOODWILL AND INTANGIBLE ASSETS, NET - Sensitivity   HTML    132K  
                analysis (Details)                                               
152: R132        GOODWILL AND INTANGIBLE ASSETS, NET - PA FAI CALLE  HTML     87K  
                77 - Purchase Price Allocation (Details)                         
153: R133        GOODWILL AND INTANGIBLE ASSETS, NET - PA FAI CALLE  HTML     99K  
                77 - Net assets acquired (Details)                               
154: R134        GOODWILL AND INTANGIBLE ASSETS, NET - WOMPI S.A.S.  HTML     94K  
                Purchase Price Allocation (Details)                              
155: R135        GOODWILL AND INTANGIBLE ASSETS, NET - WOMPI S.A.S.  HTML    124K  
                - Net assets acquired (Details)                                  
156: R136        Premises and Equipment, Net (Details)               HTML    193K  
157: R137        INVESTMENT PROPERTIES - Reconciliation (Details)    HTML     95K  
158: R138        INVESTMENT PROPERTIES - Valuation Adjustments       HTML    108K  
                (Details)                                                        
159: R139        INVESTMENT PROPERTIES - Amounts recognized in the   HTML     79K  
                statement of income (Details)                                    
160: R140        INCOME TAX - Components recognized in income        HTML    124K  
                statement (Details)                                              
161: R141        INCOME TAX - Reconciliation of effective tax rate   HTML    114K  
                (Details)                                                        
162: R142        INCOME TAX - Other comprehensive income (Details)   HTML    137K  
163: R143        INCOME TAX - Deferred tax asset and liabilities     HTML    192K  
                classification (Details)                                         
164: R144        INCOME TAX - Temporary differences in               HTML     77K  
                subsidiaries, branches, associates (Details)                     
165: R145        INCOME TAX - Tax credits (Details)                  HTML     79K  
166: R146        ASSETS HELD FOR SALE AND INVENTORIES, NET -         HTML     77K  
                Summary (Details)                                                
167: R147        ASSETS HELD FOR SALE AND INVENTORIES, NET -         HTML     86K  
                Inventories, net (Details)                                       
168: R148        ASSETS HELD FOR SALE AND INVENTORIES, NET - Assets  HTML    138K  
                held for sale (Details)                                          
169: R149        Other Assets, Net (Details)                         HTML    104K  
170: R150        DEPOSITS BY CUSTOMERS - Summary of Deposits         HTML     83K  
                (Details)                                                        
171: R151        DEPOSITS BY CUSTOMERS - Summary of Time Deposits    HTML     97K  
                (Details)                                                        
172: R152        DEPOSITS BY CUSTOMERS - Maturity of Time Deposits   HTML     85K  
                (Details)                                                        
173: R153        INTERBANK DEPOSITS AND REPURCHASE AGREEMENTS AND    HTML     89K  
                OTHER SIMILAR SECURED BORROWING - Money market                   
                operations (Details)                                             
174: R154        INTERBANK DEPOSITS AND REPURCHASE AGREEMENTS AND    HTML     87K  
                OTHER SIMILAR SECURED BORROWING - Repurchases and                
                resale transactions (Details)                                    
175: R155        BORROWINGS FROM OTHER FINANCIAL INSTITUTIONS -      HTML     80K  
                Summary (Details)                                                
176: R156        BORROWINGS FROM OTHER FINANCIAL INSTITUTIONS -      HTML     95K  
                Obligations granted by foreign banks (Details)                   
177: R157        BORROWINGS FROM OTHER FINANCIAL INSTITUTIONS -      HTML     80K  
                Obligations granted by foreign banks maturity                    
                (Details)                                                        
178: R158        BORROWINGS FROM OTHER FINANCIAL INSTITUTIONS -      HTML    102K  
                Obligations granted by domestic banks (Details)                  
179: R159        BORROWINGS FROM OTHER FINANCIAL INSTITUTIONS -      HTML     80K  
                Obligations granted by domestic banks maturity                   
                (Details)                                                        
180: R160        DEBT INSTRUMENTS IN ISSUE - Summary (Details)       HTML    128K  
181: R161        DEBT INSTRUMENTS IN ISSUE - Bonds classified by     HTML    139K  
                currency, term and type of issue (Details)                       
182: R162        DEBT INSTRUMENTS IN ISSUE - Debt instruments in     HTML     77K  
                issue by maturity (Details)                                      
183: R163        EMPLOYEE BENEFIT PLANS - Liabilities relating to    HTML     88K  
                post-employment benefit and long-term benefit                    
                plans (Details)                                                  
184: R164        EMPLOYEE BENEFIT PLANS - Defined benefit pension    HTML    100K  
                plan (Details)                                                   
185: R165        EMPLOYEE BENEFIT PLANS - Defined benefit pension    HTML    106K  
                plan - Obligation (Details)                                      
186: R166        EMPLOYEE BENEFIT PLANS - Defined benefit pension    HTML     83K  
                plan - Plan assets (Details)                                     
187: R167        EMPLOYEE BENEFIT PLANS - Severance obligation       HTML     91K  
                (Details)                                                        
188: R168        EMPLOYEE BENEFIT PLANS - Retirement Pension         HTML    110K  
                Premium Plan and Executive Pension Plan Premium -                
                Obligation (Details)                                             
189: R169        EMPLOYEE BENEFIT PLANS - Retirement Pension         HTML     85K  
                Premium Plan and Executive Pension Plan Premium -                
                Plan assets (Details)                                            
190: R170        EMPLOYEE BENEFIT PLANS - Other long term benefits   HTML     99K  
                (Details)                                                        
191: R171        EMPLOYEE BENEFIT PLANS - Defined contribution       HTML     79K  
                plans (Details)                                                  
192: R172        EMPLOYEE BENEFIT PLANS - Economic assumptions used  HTML     99K  
                in the determination of the present value of the                 
                defined benefit plans (Details)                                  
193: R173        EMPLOYEE BENEFIT PLANS - Estimated payment of       HTML     92K  
                future benefits (Details)                                        
194: R174        EMPLOYEE BENEFIT PLANS - Sensitivity analysis       HTML    180K  
                (Details)                                                        
195: R175        EMPLOYEE BENEFIT PLANS - Short-term employment      HTML     78K  
                benefit plans (Details)                                          
196: R176        Other Liabilities (Details)                         HTML    100K  
197: R177        PROVISIONS AND CONTINGENT LIABILITIES - Provisions  HTML    100K  
                (Details)                                                        
198: R178        PROVISIONS AND CONTINGENT LIABILITIES - Changes in  HTML    113K  
                provisions of financial guarantees and loan                      
                commitments (Details)                                            
199: R179        PROVISIONS AND CONTINGENT LIABILITIES - Financial   HTML     86K  
                guarantees (Details)                                             
200: R180        PROVISIONS AND CONTINGENT LIABILITIES - Loan        HTML     86K  
                commitments (Details)                                            
201: R181        PROVISIONS AND CONTINGENT LIABILITIES - Contingent  HTML    153K  
                liabilities (Details)                                            
202: R182        Share Capital (Details)                             HTML    111K  
203: R183        Appropriated Reserves (Details)                     HTML     79K  
204: R184        Unconsolidated Structured Entities (Details)        HTML    100K  
205: R185        OPERATING INCOME - Interest and valuation on        HTML     86K  
                financial instruments (Details)                                  
206: R186        OPERATING INCOME - Interest expenses (Details)      HTML     93K  
207: R187        OPERATING INCOME - Revenue from contracts with      HTML    179K  
                customers (Details)                                              
208: R188        OPERATING INCOME - Contract assets and contract     HTML     84K  
                liabilities (Details)                                            
209: R189        OPERATING INCOME - Fees and Commissions Expenses    HTML     82K  
                (Details)                                                        
210: R190        OPERATING INCOME - Other operating income           HTML    101K  
                (Details)                                                        
211: R191        OPERATING INCOME - Dividends and net income on      HTML    143K  
                equity investments (Details)                                     
212: R192        OPERATING EXPENSES - Salaries and employee benefit  HTML     85K  
                (Details)                                                        
213: R193        OPERATING EXPENSES - Other administrative and       HTML    128K  
                general expenses (Details)                                       
214: R194        OPERATING EXPENSES - Impairment, depreciation and   HTML     98K  
                amortization (Details)                                           
215: R195        Earning Per Share ('Eps') (Details)                 HTML    104K  
216: R196        RELATED PARTY TRANSACTIONS - Summary (Details)      HTML    152K  
217: R197        RELATED PARTY TRANSACTIONS - Additional             HTML     87K  
                information (Details)                                            
218: R198        Liabilities From Financing Activities (Details)     HTML    103K  
219: R199        FAIR VALUE OF ASSETS AND LIABILITIES - Carrying     HTML    134K  
                amount and fair value of assets and liabilities                  
                (Details)                                                        
220: R200        FAIR VALUE OF ASSETS AND LIABILITIES - Assets       HTML    201K  
                measured at fair value on a recurring basis                      
                (Details)                                                        
221: R201        FAIR VALUE OF ASSETS AND LIABILITIES - Liabilities  HTML    117K  
                measured at fair value on a recurring basis                      
                (Details)                                                        
222: R202        FAIR VALUE OF ASSETS AND LIABILITIES - Fair value   HTML    111K  
                of assets that are not measured at fair value                    
                (Details)                                                        
223: R203        FAIR VALUE OF ASSETS AND LIABILITIES - Fair value   HTML    105K  
                of liabilities that are not measured at fair value               
                (Details)                                                        
224: R204        FAIR VALUE OF ASSETS AND LIABILITIES - Items        HTML     86K  
                measured at fair value on a non-recurring basis                  
                (Details)                                                        
225: R205        FAIR VALUE OF ASSETS AND LIABILITIES -              HTML    151K  
                Reconciliation for all assets measured at fair                   
                value (Details)                                                  
226: R206        FAIR VALUE OF ASSETS AND LIABILITIES -              HTML    108K  
                Reconciliation for all liabilities measured at                   
                fair value (Details)                                             
227: R207        FAIR VALUE OF ASSETS AND LIABILITIES - Transfers    HTML    113K  
                between levels (Details)                                         
228: R208        FAIR VALUE OF ASSETS AND LIABILITIES - Significant  HTML    167K  
                unobservable inputs and and the sensitivity of                   
                these fair values (Details)                                      
229: R209        FAIR VALUE OF ASSETS AND LIABILITIES - Valuation    HTML     85K  
                techniques (Details)                                             
230: R210        Impacts on Application of New Standards (Details)   HTML     87K  
231: R211        RISK MANAGEMENT - Maximum exposure to credit risk   HTML    133K  
                - Financial instruments subject to impairment                    
                (Details)                                                        
232: R212        RISK MANAGEMENT - Maximum exposure to credit risk   HTML     89K  
                - Other financial instruments (Details)                          
233: R213        RISK MANAGEMENT - Commercial and Financial Leases   HTML    123K  
                (Details)                                                        
234: R214        RISK MANAGEMENT - Analysis of the behavior and      HTML    110K  
                impairment of the loan portfolio and financial                   
                lease operations (Details)                                       
235: R215        RISK MANAGEMENT - Loans and financial leases by     HTML    134K  
                classification and type of collateral (Details)                  
236: R216        RISK MANAGEMENT - Financial assets classified in    HTML    110K  
                Stage 3 (Details)                                                
237: R217        RISK MANAGEMENT - Loans concentration by category   HTML    116K  
                (Details)                                                        
238: R218        RISK MANAGEMENT - Concentration of loan by          HTML    171K  
                maturity (Details)                                               
239: R219        RISK MANAGEMENT - Concentration by past due days    HTML    122K  
                (Details)                                                        
240: R220        RISK MANAGEMENT - Concentration of loans by         HTML    132K  
                economic sector (Details)                                        
241: R221        RISK MANAGEMENT - Credit concentration by country   HTML    107K  
                (Details)                                                        
242: R222        RISK MANAGEMENT - Credit concentration by economic  HTML     75K  
                group (Details)                                                  
243: R223        RISK MANAGEMENT - Credit quality of the borrower    HTML    106K  
                (Details)                                                        
244: R224        RISK MANAGEMENT - Stage 3 loans and advances by     HTML    113K  
                evaluation type (Details)                                        
245: R225        RISK MANAGEMENT - Changes in ECL (Details)          HTML     90K  
246: R226        RISK MANAGEMENT - Impact on ECL for each            HTML     86K  
                methodology (Details)                                            
247: R227        RISK MANAGEMENT - Credit Quality Analysis of the    HTML    109K  
                Group (Details)                                                  
248: R228        RISK MANAGEMENT - Individual evaluation of          HTML     93K  
                impairment for other financial instruments                       
                (Details)                                                        
249: R229        RISK MANAGEMENT - Level of collateral held          HTML     83K  
                (Details)                                                        
250: R230        RISK MANAGEMENT - Risk exposure by economic sector  HTML    116K  
                and risk region (Details)                                        
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‘EX-97.1’   —   Clawback Policy re: Recovery of Erroneously Awarded Compensation


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Exhibit 97.1

Bancolombia S.A.
CLAWBACK POLICY

I. BACKGROUND

Bancolombia S.A. (the “Company”) has adopted this policy (the “Policy”) to regulate the process of recuperating excess Incentive-Based Compensation granted to Executive Officers in the event of a Restatement of its financial statements.

This Policy is intended to comply with, and will be interpreted to be consistent with, the requirements of Section 303A.14 of the New York Stock Exchange (“NYSE”) Listed Company Manual (the “Listing Standard”).

The terms in uppercase will have the meaning assigned to them within this document.

II. STATEMENT OF POLICY

The Company will recover the amount of erroneously awarded Incentive-Based Compensation in the event that the Company is required to prepare an accounting restatement of its financial statements due to the material noncompliance of the Company with any financial reporting requirement under the securities laws, (the “Restatement”) including accounting restatements made to correct an error in previously issued financial statements that is material to the previously issued financial statements or that would result in a material misstatement if the error were corrected in the current period or left uncorrected in the current period.  

In compliance with this Policy, the Company must recover the erroneously awarded Incentive-based Compensation except to the extent provided under Section V below.

III. SCOPE OF POLICY

A.Covered Persons and Recovery Period


This Policy applies to Incentive-Based Compensation received by an  Executive Officer who served as such at any time during the performance period for that Incentive-Based Compensation, while the Company has securities listed on an American Securities Exchange.

The Company shall recover the erroneously awarded Incentive-Based Compensation received during the three completed fiscal years immediately preceding the date on which the Company is required to prepare a Restatement (the “Recovery Period”).

Notwithstanding this look-back requirement, the Company is only required to apply this Policy to the Incentive-Based Compensation received by the Executive Officers on or after October 2, 2023.

For purposes of this Policy, the Incentive-Based Compensation shall be deemed “received” in the Company’s fiscal period during which the Financial Reporting Measure is attained, even if the payment occurs after the end of that fiscal period.

B.Transition Period

This Policy applies to any transition period that results from a change in the Company´s fiscal year within the Recovery Period, provided that the transition period between the last day of previous fiscal year and the first day of the  new fiscal year that comprises a period of nine to 12 months and is considered a complete fiscal year.

C.Determining Recovery Period


For the purpose of determining the Recovery Period, the date on which it is considered that the Company was required to prepare the Restatement is the earliest that occurs between:

The date the Board of Directors concludes, or reasonably should have concluded, the Company is required to prepare a Restatement, and
The date a court, regulator, or other legally authorized body directs the Company to prepare a Restatement.

For clarity, the Company’s obligation to recover erroneously awarded Incentive-Based Compensation under this Policy is not dependent on if or when a Restatement is filed

IV. AMOUNT SUBJECT TO RECOVERY

(a)Recoverable Amount: The amount of Incentive-Based Compensation subject to recovery under this Policy is the amount that exceeds the amount of Incentive-Based Compensation that would have been received had it been determined based on the restated amounts, computed without regard to any taxes  or social security paid.

(b)Compensation based on stock price or TSR:  For Incentive-Based Compensation based on stock price or total shareholder return (“TSR”), where the amount of erroneously awarded Incentive-Based Compensation is not subject to mathematical recalculation, the recoverable amount will be determined by the Designation, Compensation and Development Committee

based on a reasonable estimate of the effect of the Restatement on the stock price or TSR upon which the Incentive-Based Compensation was received.  In such event, the Company must maintain documentation that supports the determination of the estimation and provide such documentation to NYSE.

V. EXCEPTIONS

In compliance with this Policy, the Company shall recover the overpaid Incentive-Based Compensation reasonably promptly, except to the extent that the conditions set out below are met and that the Designation, Compensation and Development Committee determines that recovery would be impracticable:

(a)Direct expense exceeds recoverable amount.  The direct expense paid to a third party to assist in the enforcement of this Policy would exceed the amount to be recovered; provided, however, that before concluding it would be impracticable to recover any amount of the erroneously awarded Incentive-Based Compensation based on expense of enforcement, the Company has made a reasonable attempt to recover the such erroneously awarded Incentive-Based Compensation, has documented said attempt, and has provided the documents to NYSE.

(b)Violation of Home Country Law.  Recovery would violate Colombian law where such law was adopted prior to November 28, 2022; provided, however, that the Company obtains an opinion of a Colombian counsel acceptable to NYSE in that sense and provides such opinion to NYSE.

(c)Recovery from Certain Tax-Qualified Retirement Plans.  Recovery would likely cause an otherwise tax-qualified retirement plan, under which benefits are broadly available to employees of the Company, to fail to meet the requirements of 26 U.S.C. 401(a)(13) or 26 U.S.C. 411(a) and regulations thereunder.

VI. PROHIBITION AGAINST INDEMNIFICATION

Notwithstanding the terms of any indemnification arrangement or insurance policy with any Executive Officer covered by this Policy, the Company will not indemnify any Executive Officer or former Executive Officer for the devolution of the overpaid Incentive-Based Compensation, nor will it pay or reimburse any costs associated with the hiring of insurance to finance the amounts recoverable under this Policy.  

VII. DISCLOSURE

The Company will file all disclosures with respect to this Policy in accordance with the requirements of the U.S. Federal securities laws, including the disclosure required by the applicable Securities and Exchange Commission (“SEC”) filings and the Colombian securities law regarding relevant information.

VIII. DEFINITIONS

The following terms will have the following definitions for the purposes of this Policy:

Executive Officer” means the Company’s president, principal financial officer, principal accounting officer (or if there is no such accounting officer, the controller), any vice-president of the Company in charge of a principal business unit, division, or function (such as sales, administration, or finance), any other officer who performs a policy-making function, or any other person who performs similar policymaking functions for the Company. Executive officers of the Company’s subsidiaries are deemed Executive Officers of the Company if they perform such policy making functions for the Company. Policy-making function is not intended to include policymaking functions that are not significant. Identification of an Executive Officer for purposes of this Policy will include at a minimum executive officers identified pursuant to 17 CFR 229.401(b).

Financial Reporting Measures” means any of the following:
(i) measures that are determined and presented in accordance with the accounting principles used in preparing the Company’s financial statements, and any measures that are derived wholly or in part from such measures, (ii) stock price and (iii) TSR.  A Financial Reporting Measure need not be presented within the Company’s financial statements or included in a filing with the SEC.

Incentive-Based Compensation” means any compensation that is granted, earned, or vested based wholly or in part upon the attainment of a Financial Reporting Measure.

IX. ADMINISTRATION; AMENDMENT; TERMINATION

All determinations under this Policy will be made by the Board of Directors, including determinations regarding how any recovery of the overpaid Incentive-Based Compensation under this Policy is effected.  Any determinations of the Board of Directors will be final, binding and conclusive and need not be uniform with respect to each individual covered by this Policy.


The Board of Directors may amend or terminate this Policy anytime.

X.  EFFECTIVENESS; OTHER RECOUPMENT RIGHTS

This Policy shall be effective as of December 1st, 2023. Any right of recoupment under this Policy is in addition to, and not in lieu of, any other remedies or rights of recoupment that may be available to the Bank and its subsidiaries and affiliates under applicable law or pursuant to the terms of any similar policy or similar provision in any employment agreement, equity award agreement or similar agreement.



Dates Referenced Herein

This ‘20-F’ Filing    Date    Other Filings
Filed on:3/26/24None on these Dates
For Period end:12/31/23
10/2/23
11/28/22
 List all Filings 


1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 1/14/08  Bancolombia SA                    F-6                    4:316K                                   Emmet Marvin & Mart… LLP
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