The principles of information policy of regarding capital adequacy

The principles
of information policy of PKO BP SA
regarding capital adequacy

§1

The principles of information policy of PKO BP SA regarding capital adequacy, further referred to as the "Principles", determine the scope, frequency, place and form of disclosures, as well as means of verification of the disclosures regarding capital adequacy and information subject to disclosure, as determined in the Resolution No. 385/2008 of the Polish Financial Supervision Authority (KNF) dated 17 December 2008 on the specific principles and means of disclosure by the banks of qualitative and quantitative information regarding capital adequacy, and the scope of information subject to disclosure.

§2

The terms used herein shall signify:

1. Bank - Powszechna Kasa Oszczędności Bank Polski SA,
2. KNF Resolution - Resolution no. 385/2008 of the Polish Financial Supervision Authority dated 17 December 2008 on the specific principles and means of disclosure by the banks of qualitative and quantitative information regarding capital adequacy, and the scope of information subject to disclosure,
3. PKO BP SA Group - the Bank together with its subsidiaries.

§3

1. The Bank discloses the information, referred to in Appendices no. 1 and no. 2 to the KNF Resolution, and further referred to as "Information".
2. The Information concerns in particular:
   1. the aims and principles of policies regarding the management of individual risk categories,
   2. the scope of application of prudential norms,
   3. the Bank's capital,
   4. compliance with capital requirements,
   5. the use of credit assessments issued by the External Credit Assessment Agencies,
   6. the methods of calculating the capital requirements, used in the Bank,
   7. equity exposures in the banking book,
   8. securitization exposures,
   9. credit risk mitigation techniques, used in the Bank.
3. The Information is disclosed in the Polish and English languages.
4. The Bank discloses the information, except for:
   1. the information whose omission or misrepresentation, according to the Bank's knowledge, should not result in a changed evaluation or decision of a person making use of such information in taking financial decisions or affect such an evaluation or decision (irrelevant information),
   2. the information whose disclosure may have a negative impact on the Bank's position on the relevant market in the light of the competition and consumer protection regulations,
   3. the information protected under the law.
5. For the cases referred to in par. 4.2 and par. 4.3 the Bank states the reasons of resignation from information disclosure and discloses general data in that connection, unless they constitute the information referred to in par. 4.2 and par. 4.3.

§4

1. The Bank, being the holding company of the PKO BP SA Group, discloses the Information based on the Bank's data solo and consolidated data.
2. The full scope of Information is subject to disclosure by the Bank annually.
3. The Bank discloses quarterly the Information regarding the level of capital adequacy ratio, the level and structure of the Bank's capital, as well as capital requirements and risk profile.

§5

1. The annual Information, referred to in par. 4.2, is subject to disclosure by the Bank in a separate report on capital adequacy, published not later than 30 days following the acceptance by the Ordinary General Shareholders' Meeting of the annual financial report.
2. The quarterly Information, referred to in par. 4.3, is subject to disclosure by the Bank in a quarterly financial statement, being part of the consolidated quarterly report of the PKO BP SA Group; it is published at the date of disclosing the report.

§6

1. The report on capital adequacy, referred to in par. 5.1, is approved by the Management Board of the Bank, and acknowledged by the Bank's Supervisory Board.
2. The quarterly financial report, referred to in par. 5.2, is subject to approval in accordance with the Bank's internal regulations.

§7

The Bank discloses the statement and the reports, referred to in par. 5, on the Bank's website (www.pkobp.pl).

§8

1. The Information which is subject to review or audit as a part of the financial statement, is verified by the certified auditor.
2. The report on capital adequacy, referred to in par. 5.1, is subject to verification by the Bank's internal audit unit.
3. The report on capital adequacy, as referred to in par. 5.1, is verified taking into account, in particular, the completeness of capital adequacy-related disclosures, referred to in the KNF Resolution, compliance with the financial report and correctness of the information published.
4. The quarterly Information, referred to in par. 4.3, is subject to verification in accordance with the Bank's internal regulations.

§9

1. The Principles are published on the Bank's website (www.pkobp.pl).
2. In the place where banking activities are performed, the Bank publishes the information regarding the means of publication of the Principles.

§10

1. The Principles and the amendments hereto are adopted by the Management Board of the Bank, and approved by the Bank's Supervisory Board.
2. The Principles are subject to review at least once a year.
3. The Principles are verified by the organizational unit of the Bank's Head Office in charge of capital adequacy management at the Bank.
4. The Principles are verified taking into account, in particular, market practices regarding the capital adequacy-related disclosures, compliance with the applicable legal regulations, and the development of risk management methods.