Environmental Responsibility

The Bank’s Capital Group undertakes a range of initiatives aimed at managing identified material climate-related impacts and opportunities.

Under its 2025–2027 Strategy, the Bank has committed to supporting sustainable development through the following actions:

• covering more than 50% of the loan portfolio by the Transformation Plan by the end of 2027 (Scope 3);
• applying advanced technologies for predictive analytics and the development of tools for measuring and monitoring CO₂ emissions;
• updating environmental risk requirements within credit policies;
• reduce its own emissions (Scopes 1 and 2);
• improve the energy efficiency of buildings;
• support clients in enhancing energy efficiency (Scope 3).

The Group’s strong capital position enables business growth while addressing sustainability-related challenges. Advanced analytics used in risk assessment and process optimisation enhance lending capacity. Environmental risk is continuously monitored and reported through:

• this Sustainability Statement, published annually;
• the report “Capital Adequacy and Other Disclosures of the Capital Group of Powszechna Kasa Oszczędności Bank Polski Spółka Akcyjna”, published semi-annually;
• the Internal Capital Adequacy Assessment Process (ICAAP) and Capital Management Review Report, published annually;
• the Credit Risk Report, published quarterly;
• materials and documentation (including minutes of meetings) prepared for the Sustainability Committee, which meets at least quarterly and is responsible, among other duties, for monitoring the implementation of the Group’s sustainability objectives and initiatives.

For internal management purposes, the Bank additionally monitors information regarding:

• light-green and dark-green credit exposures (monthly);
• GHG emissions of the loan portfolio by PCAF asset class (monthly);
• Energy Performance (EP) indicators for real estate-secured loans (monthly);
• emissions intensity indicators for selected sectors in accordance with Template 3 of Commission Implementing Regulation (EU) 2024/3172 (quarterly);
• the strategic ESG risk tolerance limit (quarterly).

The Bank’s Capital Group has not developed estimates of the capital expenditures or operating expenditures required to implement the actions undertaken or planned. The key performance indicators required under Commission Delegated Regulation (EU) 2021/2178 are presented in Section 13.2.1.

In line with the assumptions adopted in the Bank’s 2025–2027 Strategy and the objective of achieving net-zero emissions by 2050 for Scopes 1 and 2, a CO₂e emissions reduction pathway for Scopes 1 and 2 through 2050 was developed. The planned measures are intended to achieve the complete elimination of greenhouse gas emissions within Scopes 1 and 2, in accordance with the GHG Protocol methodology. The planned reduction levels for Scope 1 and Scope 2 emissions are as follows:

• 2025 – approximately 71% reduction compared with the base year and approximately 14% reduction compared with 2023 levels, corresponding to emissions not exceeding 27.8 thousand tonnes of CO₂e;
• 2030 – approximately 72% reduction compared with the base year and approximately 17% reduction compared with 2023 levels, corresponding to emissions not exceeding 26.8 thousand tonnes of CO₂e;
• 2050 – approximately 81% reduction compared with the base year, corresponding to emissions not exceeding 19.0 thousand tonnes of CO₂

For the base year (2019), emissions amounted to approximately 96.87 thousand tonnes of CO₂e.

The Bank’s reduction targets for Scope 1 and Scope 2 emissions are based on feasible measures, including the replacement of internal combustion engine company vehicles with low-emission or electric vehicles. The emissions reduction action plan also identifies the need to eliminate vacant premises, optimise office space, and modernise properties used by the Bank.

As part of its own operations, the Bank has conducted scenario analyses exclusively for physical climate risks, enabling the identification of locations exposed to such risks.

The Bank calculated its own emissions for the first time for 2019 and designated that year as the base year. The base year has remained unchanged for the calculation of Scope 1 and Scope 2 emissions in subsequent reporting periods. Each year, when preparing the emissions inventory, analyses of weather conditions and the number of heating degree days are performed.

Greenhouse gas emissions (tCO₂e) by gas category for the Bank’s Capital Group

Scope 3 categories reported by the Bank’s Capital Group for 2025 (own emissions):

• Category 1 – Purchased Goods and Services;
• Category 2 – Capital Goods;
• Category 3 – Fuel- and Energy-Related Activities (not included in Scope 1 or Scope 2);
• Category 5 – Waste Generated in Operations;
• Category 6 – Business Travel;
• Category 7 – Employee Commuting (including Remote Working);
• Category 11 – Use of Sold Products;
• Category 13 – Downstream Leased Assets;
• Category 14 – Franchises;
• Category 15 – Investments.

In 2025, the Group’s GHG emissions intensity amounted to 0.70 thousand tonnes per PLN 1 million of net revenue under both Scope 2 calculation methods (location-based and market-based). The calculation was based on the net revenue reported in the Bank Capital Group’s financial statements prepared in accordance with IFRS.

The instrument used by the Bank to reduce Scope 2 GHG emissions is the purchase of Guarantees of Origin for electricity. In 2025, the Group purchased 72.69 GWh of electricity generated from renewable energy sources (RES), representing 36% of the Capital Group’s total energy consumption.  As a financial institution, the Bank’s Capital Group is not directly subject to the EU Emissions Trading System (EU ETS). Consequently, the calculations do not include emissions covered by regulated emissions trading schemes.

Within Scope 3, Category 13 includes emissions associated with leasing activities (the portfolios of PKO Leasing and Prime Car Management), for which the full emissions of the underlying asset are attributed to the exposure, in accordance with the requirements of the GHG Protocol and the assumption that the leasing company bears full responsibility for the operational emissions of leased assets. By contrast, Scope 3 Category 15 relates to financed emissions arising from other financing and investment activities (e.g. loans, debt securities and equity investments). The calculation of financed emissions under Scope 3 Category 13 covers exposures of the subsidiary PKO Leasing S.A. (including Prime Car Management S.A.), comprising:

• leasing of machinery and equipment, excluding renewable energy assets (PCAF asset class: Business Loans and Unlisted Equity);
• leasing of renewable energy machinery and equipment (PCAF asset class: Project Finance);
• vehicle leasing (PCAF asset class: Motor Vehicle Loans);
• commercial real estate leasing (PCAF asset class: Commercial Real Estate).

The following tables present financed emissions attributable to PKO Leasing S.A. (including Prime Car Management S.A.) by type of leased and rented asset as at 31 December 2025 and 31 December 2024. Financed emissions decreased by 4% year-on-year, reaching 4.1 million tCO₂e as at 31 December 2025. The financed emissions intensity metric (expressed as tCO₂e per gross carrying amount of exposures included in the calculation) decreased from 181 tCO₂e per PLN million to 164 tCO₂e per PLN million. This decrease was primarily attributable to improvements in the methodology used to estimate vehicle emissions, as well as to the amortisation and repayment of the run-off commercial real estate portfolio.

The calculation of financed emissions under Scope 3 Category 15 covers the Bank Capital Group’s exposures within the following asset classes:

• corporate loans (PCAF asset class: Business Loans and Unlisted Equity);
• listed equities and corporate bonds (PCAF asset class: Listed Equity and Corporate Bonds);
• project finance (PCAF asset class: Project Finance);
• motor vehicle loans (PCAF asset class: Motor Vehicle Loans);
• commercial real estate loans (PCAF asset class: Commercial Real Estate);
• residential mortgage loans (PCAF asset class: Mortgages);
• sovereign debt (PCAF asset class: Sovereign Debt).

Calculations for the individual asset classes were performed in accordance with the Global GHG Accounting and Reporting Standard for the Financial Industry developed by the Partnership for Carbon Accounting Financials (PCAF).

For the purpose of calculating financed emissions, the Bank’s Capital Group used, among other sources:

• reported emissions (information on emissions disclosed by the client or investee entity receiving financing);
• emissions estimated on the basis of physical activity data of the client or investee entity, including energy consumption, production volumes, and information obtained from Energy Performance Certificates (actual or estimated) of financed properties;
• emissions estimated on the basis of the economic activity of the client or investee entity, including, among other data, revenue information obtained from clients’ financial statements.

The following tables present Scope 3 financed emissions (Category 15) for the Bank and its subsidiaries, broken down by PCAF asset class, as at 31 December 2025 and 31 December 2024. Detailed information in this regard is provided in the Management Board Report on the Activities of the PKO Bank Polski S.A. Capital Group for 2025.

Financed emissions increased by 23% year-on-year, reaching 25.5 million tCO₂e (2024: 20.8 million tCO₂e). The financed emissions intensity metric increased to 62 tCO₂e per PLN million (excluding sovereign debt: 77 tCO₂e per PLN million; 2024: 59 and 66, respectively). The increase was primarily attributable to higher emissions within the Corporate Loans asset class, reflecting changes in the portfolio structure and a higher proportion of actual data used in the emissions calculations.

In 2025, the Bank’s Capital Group reported total greenhouse gas emissions of 29,870,341 tCO₂e, including both own operational emissions and portfolio emissions.

The Bank’s Capital Group did not identify any biogenic emissions arising from its own operations (Scope 1 and Scope 2). Biogenic emissions were not included in the portfolio emissions calculation, as they are not covered by the PCAF methodology, which served as the basis for the calculation of financed emissions.

The base year for the calculations is 2019, with the exception of portfolio emissions (Categories 13 and 15), for which the base year is 2023. Financed emissions are reported in tCO₂e, as the emission factors provided in the PCAF database are not disaggregated by individual greenhouse gas type.

The decarbonisation pathway for the power generation sector, residential real estate, commercial real estate, and the PKO Leasing portfolio, together with the associated emission reduction targets and emissions intensity targets, is presented in the Bank’s Capital Group Transition Plan.

The Bank’s Capital Group does not undertake greenhouse gas removal or greenhouse gas mitigation projects financed through carbon credits. The Group also does not apply an internal carbon pricing mechanism.

In the second year of sustainability reporting, the Bank’s Capital Group has applied the transitional relief provided for in Appendix C to ESRS 1 and, accordingly, does not disclose information on the anticipated financial effects of material physical and transition risks, nor on potential climate-related opportunities. This exemption is applied in accordance with Commission Delegated Regulation (EU) 2025/1416 of 11 July 2025 amending Delegated Regulation (EU) 2023/2772 as regards the postponement of the date of application of certain disclosure requirements for specific undertakings.

The Bank’s Capital Group has established four policies through which it manages climate-related impacts, risks and opportunities (IROs) [I1] [I2] [O1] [R1] [R2] [R3]: the High-Emission Energy Sector Financing Policy, the Renewable Energy Sources (RES) Financing Policy, the Chemicals, Oil and Gas Policy, and the Principles for Managing and Preventing Greenwashing at PKO Bank Polski S.A. The Group has also adopted a Transformation Plan, which supports actions aimed at reducing its own emissions [O2].

The objective of the Renewable Energy Sources (RES) Financing Policy is to progressively increase the Bank’s share in financing renewable energy projects and to define the preferred directions for the development of this portfolio. The Policy focuses primarily on financing photovoltaic and wind farm projects, while also allowing for the financing of other renewable energy investments. In December 2025, the existing RES financing principles were updated to incorporate more conservative project financing parameters and to specify the aspects subject to assessment in relation to biogas and biomethane projects. The Bank’s Credit Committee is responsible for the implementation of the Policy. The Policy applies across the entire Bank Capital Group and is available to all employees through the Bank’s intranet.

The objective of the High-Emission Energy Sector Financing Policy is to progressively transform the structure of the loan portfolio by gradually reducing exposure to clients and transactions related to hard coal and lignite mining, as well as carbon-intensive energy generation based on coal as an energy source, while simultaneously increasing support for zero- and low-emission energy sources. The Policy covers, among others, the hard coal and lignite mining industries, coal-related sectors (e.g. manufacturing of mining machinery, coal and coal derivative trading), electricity and heat generation (excluding renewable energy sources), and ancillary energy-related activities, including transmission, distribution and combined heat and power generation. The Policy also applies where a client’s core business activity is not directly linked to carbon-intensive operations, but the purpose of the requested financing is related to such activities. The areas of transition supported under the Policy include not only zero- and low-emission energy generation sources, but also improvements in the energy efficiency of entities with high energy consumption required for production processes, as well as the modernisation of transmission networks. The Bank’s Capital Group supports the transformation of the Polish energy sector and does not engage in transactions financing coal-based investments. At the same time, the Bank’s Capital Group may provide financing for transactions that include binding contractual commitments requiring clients to improve energy efficiency and comply with increasingly stringent environmental requirements. The Bank’s Credit Committee is responsible for the implementation of the Policy. The Policy applies across the entire Bank Capital Group and is available to all employees through the Bank’s intranet. The Policy was not updated in 2025.

The Chemicals, Oil and Gas Policy establishes the framework for financing entities operating in the sectors of crude oil and natural gas extraction, the production and distribution of liquid and gaseous fuels, the manufacture and trade of chemicals and chemical products, as well as the production and sale of rubber and plastic products. The Policy applies to entities generating at least 50% of their revenues from the sale of petroleum-based products (liquid fuels, chemicals or other chemical products), natural gas, or related activities. The objective of the Policy is to reduce exposure to entities covered by the EU Directive on plastics and to introduce a more prudent assessment approach for other sectors within its scope. In particular, the Bank applies enhanced due diligence requirements to the oil and gas extraction industry and to the production of chemicals, chemical products and rubber products, taking into account compliance with environmental standards, environmental and social impacts, and the alignment of business models with sustainable development principles. The Bank’s Credit Committee is responsible for the implementation of the Policy. The Policy applies across the entire Bank Capital Group and is available to all employees through the Bank’s intranet. The Policy was not updated in 2025.

The Principles for Managing and Preventing Greenwashing at PKO Bank Polski S.A. entered into force on 30 June 2025 pursuant to a resolution of the Management Board. The Principles cover activities related to the drafting, verification and assessment of external and internal communications, the introduction of new banking products and services, the identification and classification of products financing environmental protection activities, the definition of the Bank’s sustainability objectives and approach to sustainable development, the identification and assessment of greenwashing risk, the implementation of good practices and educational initiatives aimed at preventing greenwashing, and the identification of legal and regulatory requirements relevant from a sustainability perspective. The purpose of the resolution is to define the activities undertaken by the Bank that are subject to greenwashing prevention measures, the responsibilities and competencies specified in other internal Bank regulations to which the greenwashing prevention principles apply, as well as the categories of risk within which greenwashing risk is identified and the organisational units responsible for its identification. The Principles are available to all employees through the Bank’s intranet.