ESG Risk Management at PKO Bank Polski
ESG (Environmental, Social and Governance) risk management constitutes an important element of the management framework at PKO Bank Polski. Due to its cross-sectional nature, ESG risk affects multiple areas of the Bank’s operations, encompassing both the assessment of the impact of ESG factors on the functioning of the Bank’s Capital Group and a detailed analysis of the effects of its activities in the context of the broadly understood external environment.
Definitions relating to ESG have been included in the “Risk Management Strategy of PKO Bank Polski S.A. and the PKO Bank Polski S.A. Capital Group”. These include:
- ESG factors – environmental, social and governance factors that may have a positive or negative impact on the Bank’s clients and counterparties or on the Bank’s balance sheet positions; ESG factors with a negative impact are referred to as ESG risk factors;
- ESG risk – the risk of adverse financial consequences for the Bank resulting from the current or prospective impact of ESG risk factors on the Bank’s clients and counterparties or on the Bank’s balance sheet positions.
The Bank verifies and assesses its financial, capital and strategic plans in terms of the level of risk generated and their alignment with sustainable development objectives, taking into account ESG risks over the short-, medium- and long-term horizons.
In December 2024, the Bank introduced regulations concerning the assessment of compliance with minimum safeguards and the implementation of a due diligence mechanism for assessing adverse impacts of business activities on human rights within the framework of minimum safeguards applicable to the Bank’s clients and counterparties. The assessment of compliance with minimum safeguards is linked to the examination of the following areas: anti-corruption, taxation, fair competition, science, technology and innovation, as well as human rights and labour rights. The methodology for assessing compliance with minimum safeguards is subject to review, at least annually, to ensure alignment with generally applicable laws and regulations.
In the process of assessing the loan portfolio, the Bank applies the definitions of environmental (including climate-related) physical risk and transition risk in accordance with the CRR Regulation.
ESG Risk Management Structure
- ESG risk management is supervised by the Bank’s Management Board, which defines the risk framework, oversees the implementation of established objectives, strategies and policies, and determines the principles for their management in the context of environmental risk management.
- Organisational units are responsible, within the scope of their respective competencies, for the coordination and management of ESG risk and its impact on the Bank’s operational risk profile.
- Committees operating within the Bank, within the scope of their responsibilities and competencies, take into account analyses and opinions related to ESG risk-related activities when making decisions.
- The ESG risk management process also involves units responsible for strategic planning, sustainability disclosures, legal support and compliance assessment.
The Bank assesses, on a case-by-case basis, the impact of environmental, social and governance factors on a client’s creditworthiness within the credit process for corporate banking clients and business banking clients assessed using the rating method. The Bank also analyses the impact of credit transactions on ESG matters and classifies them into the aforementioned ESG categories. An assessment of the credit transaction itself is likewise carried out within the credit process.
ESG risk assessment within the credit process is also implemented through the application of credit policies dedicated to specific industries/sectors, as described in the Sustainability Report.
The Bank has implemented principles for the classification of the loan portfolio for the purposes of ESG risk management and reporting, which define, in particular, the criteria for identifying and classifying exposures financing activities related to environmental protection, social policy and corporate governance.
The Bank distinguishes four classes of exposures financing activities related to environmental protection, social policy and corporate governance:
- Exposures supporting sustainable development – light green exposures (including exposures recognised in the calculation of the BTAR), relating to the financing of:
a) environmentally sustainable objectives;
b) the transition towards a climate-neutral and sustainable economy – exposures supporting the environmental objectives referred to in Article 9 of the EU Taxonomy;
c) sustainable development (including the sustainable transformation of the economy) – exposures meeting market standards for sustainable finance;
d) sustainable development transactions co-financed with public funds and co-financed by national and supranational institutions;
e) social objectives concerning the financing of activities generating a positive impact on society and local communities. - Environmentally sustainable (taxonomy-aligned) exposures – dark green exposures (recognised in the calculation of the GAR), relating to the financing of economic activities meeting the conditions set out in Article 3 of the EU Taxonomy, namely:
a) making a substantial contribution to at least one of the six environmental objectives;
b) doing no significant harm to any of the other environmental objectives (the DNSH principle);
c) being conducted in compliance with minimum safeguards;
d) meeting the technical screening criteria specified in delegated acts issued by the European Commission supplementing the EU Taxonomy Regulation. - Exposures with a neutral environmental impact – white exposures relating to the financing of economic activities for which it is not possible to assign an environmental objective and which have not been classified as exposures supporting sustainable development, environmentally sustainable exposures or exposures with a negative environmental impact.
- Exposures with a negative environmental impact – brown exposures relating to the financing of economic activities contributing to significant greenhouse gas emissions, air, water and soil pollution, deforestation, waste generation, biodiversity loss or the excessive use of natural resources.
The Bank assesses, on a case-by-case basis, the impact of environmental, social and governance factors on a client’s creditworthiness within the credit process applicable to corporate banking clients and business banking clients assessed using the rating method. The Bank also analyses the impact of credit transactions on ESG matters and classifies them into the above-mentioned ESG categories. Furthermore, an assessment of the credit transaction itself is conducted as part of the credit process.
On the one hand, the Bank examines the impact of a given credit transaction on ESG matters, while on the other hand it assesses how ESG factors may affect the credit transaction. In assessing ESG factors, the Bank takes into account, inter alia, climate change risk and its impact on the client’s operations, as well as the client’s potential contribution to climate change.
Detailed information regarding climate risk management is available in the report entitled “Capital Adequacy and Other Information Subject to Disclosure by the Powszechna Kasa Oszczędności Bank Polski Spółka Akcyjna Capital Group as at 31 December 2025”.
ESG Risk Monitoring