Two Harbors adopts amended clawback policy effective Dec 1, 2023 to comply with SEC/NYSE rules

TWO HARBORS INVESTMENT CORP.

Board approved amended Incentive Compensation Recoupment Policy on September 19, 2023.
Policy requires mandatory recovery of erroneously awarded incentive compensation from current/former executive officers upon an accounting restatement.
Effective date December 1, 2023; applies to incentive compensation received during the three-year lookback period.
Also allows discretionary recoupment for detrimental conduct causing material harm to the Company.
No indemnification for recouped amounts; Company cannot pay insurance premiums for coverage against clawback.

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