Insider Trading Policies and Procedures

12 Months Ended

Dec. 31, 2025

Insider Trading Policies and Procedures [Line Items]

Insider Trading Policies and Procedures Not Adopted

The Board has not established any committees, including an audit committee, a compensation committee or a nominating committee, or any committee performing similar functions. The functions of those committees are undertaken by the Board. The Board may designate from among its members an executive committee and one or more other committees in the future.

IPALCO’s securities are not quoted on a securities exchange. IPALCO is not required by law, rule, or regulation to have a majority or any portion of the Board be independent. IPALCO is also not required by law, rule, or regulation to establish or maintain an audit committee or other Board committee and thus we do not have an “audit committee financial expert” as defined under applicable SEC rules.

The AES Board of Directors has adopted an insider trading policy and related procedures that govern the purchase, sale, and other dispositions of AES’ securities by directors, officers, and employees of AES and its subsidiaries, including IPALCO, as well as by AES itself. AES’ insider trading policy and related procedures are reasonably designed to promote compliance with insider trading laws, rules and regulations, and the listing standards of the New York Stock Exchange. IPALCO has not adopted a separate insider trading policy because none of its securities are publicly traded and it only has two shareholders of its common stock: AES U.S. Investments and CDPQ, whose obligations as shareholders are governed by the Shareholders’ Agreement (as defined below).