.

The Code of Ethics adopted by the bank is a collection of the most important values, principles, and standards of conduct, compliance with which is required from all bank employees, particularly from those representing the bank. The Code defines the way of shaping mutual relations between individuals performing work for the bank, regardless of the legal basis of their cooperation with the Bank. It supports the bank’s organizational culture, contributing to the conscious shaping of its internal environment.

The Code also defines ethical attitudes in relations with clients, in the bank’s business activities, and in the bank’s relations with its external environment. It is a tool supporting the dissemination and implementation of the bank’s values, which are credibility, customer satisfaction, entrepreneurship, and continuous improvement. All bank employees are expected to act in accordance with these values, regardless of their position or role. With a long tradition in the financial market, the Bank is perceived as a public trust institution. The nature of our activity obliges us to adhere to the highest ethical standards.

We want all our employees to feel responsible for the functioning of the bank and to identify with its values – to be credible and entrepreneurial, and by continuously improving, to contribute to the growth of customer satisfaction. We value the individuality of each employee and the contribution they make toward achieving common goals. Different perspectives and diverse beliefs are, for us, a source of inspiration and creative search for new solutions. That is why we ensure that employees can openly express their views and professional opinions. Taking care of our employees’ safety, we counteract all forms of mobbing as well as the misuse of official relationships for private purposes. We strongly oppose intolerance or discrimination, that is, any behaviors that contradict the bank’s values.

In December 2023, by resolution of the Management Board, the bank amended the Code of Ethics, and in January 2024, the Supervisory Board approved the modified Code. The bank’s values were revised and redefined. Three key values were introduced for the effective implementation of the bank’s mission and strategy:

• Partnership – we care together about the best experiences of clients and employees, building partner relations based on mutual respect, openness, and trust,

• Development – we respond to changes and take on ambitious challenges, we care about our own development and support others in theirs, we offer clients assistance in developing in a dynamically digitalizing world,

• Impact – we act boldly, value agency, responsibility, and engagement, we are innovative in creating solutions and effective in achieving goals.

The primary objective of the bank’s information activities is to ensure high standards of communication with capital market participants, reflecting respect for the principles of universal and equal access to information. The Investor Relations Office is responsible for implementing the information policy in the area of investor relations.

The bank communicates with investors directly by organizing online broadcast earnings meetings, participating in numerous investor conferences and bilateral meetings, as well as actively using the corporate website, which includes a dedicated investor relations section. This site contains key information about the bank and its issued securities, including the bank’s strategy, financial reports, presentations, basic financial data in a format enabling direct use, contact details, and other information typically published by companies in line with relevant recommendations.

In its communication with the market, the bank takes into account the interests of all investors, provided they do not conflict with the bank’s interests. The bank pursues its information policy in a manner that guarantees proper, reliable, and complete access to information for all investors, without granting preference to any of them. Equal access to information for every shareholder is ensured by conducting information activities in accordance with applicable laws, including in particular the Commercial Companies Code, the MAR Regulation, the Act on Trading in Financial Instruments, the Public Offering Act (…), and the Regulation on Current and Periodic Information (…). These principles are formally adopted in the Information Policy Rules of PKO Bank Polski S.A. in the area of relations with investors and clients. The bank’s information activities also follow higher standards of the Best Practices for GPW Listed Companies 2021 and the Corporate Governance Principles for Supervised Institutions. Compliance with disclosure obligations is assessed annually by the Supervisory Board and presented in its activity report for the given year.

The ESG area is one of the pillars of PKO Bank Polski S.A.’s 2023–2025 strategy. The bank’s ESG strategy includes a set of metrics across three areas of sustainable development: environmental, social, and corporate governance

The bank’s dividend policy assumes the intention of stable dividend payments in the long term, while maintaining the principle of prudent management of the bank and the Bank’s Capital Group.

The goal of the Dividend Policy is to optimize the capital structure of the bank and the Bank’s Capital Group, taking into account return on capital and its cost, as well as capital needs related to growth, while ensuring adequate levels of capital adequacy ratios and meeting the requirement for the minimum level of own funds and eligible liabilities subject to write-down or conversion (MREL).

According to the adopted Dividend Policy, an additional tool for capital redistribution is the possibility of repurchasing own shares for redemption. The Dividend Policy stipulates that consent for the bank to repurchase its own shares is granted by the General Meeting, following prior approval by the Supervisory Board, defining the terms of the acquisition, including the maximum number of shares to be acquired, the authorization period for the acquisition (not exceeding five years), and the maximum and minimum purchase price if the acquisition is for consideration. Any repurchase of own shares for redemption requires prior consent from the Polish Financial Supervision Authority.

 

The Security Policy defines the basic principles for maintaining an appropriate level of security in the bank, including preventing and managing security incidents, as well as building and implementing necessary security mechanisms. It also covers principles of business continuity management developed in compliance with applicable laws and international standards. This policy also applies to supervising the outsourcing of activities to external entities other than agents and intermediaries.

According to the adopted policy, the bank exercises particular diligence in preventing crimes related to its operations and shapes the desired behavior of employees in situations of suspected crime, while upholding the highest corporate standards in this area. The bank enforces zero tolerance for crimes connected with its operations. All bank employees, individuals performing work for the bank, and employees of cooperating companies—regardless of the scope or form of cooperation—are obliged to exercise particular diligence in preventing crimes and abuses, reporting potential criminal activity, conducting clarifications in matters that could have financial or reputational consequences for the bank, and acting in accordance with applicable laws.

Security issues in specific areas are defined in the bank’s internal regulations, including those related to the protection of people and property, IT system security, and security incident management.

To improve crime prevention methods, the bank conducts periodic analyses of potential security threats, based on which it implements or modifies security mechanisms.

The diversity policy for members of the Management Board and Supervisory Board of the Bank is an important part of the suitability assessment policies for members of the Bank’s governing bodies.

The Bank has introduced regulations defining the principles for selection, appointment, and succession planning, including staffing support, as well as the assessment of the suitability of Management Board members and individuals performing key functions in the Bank. These individuals are evaluated in terms of their competencies, knowledge and skills, experience appropriate to the position, as well as their reputation—understood as a sufficiently unblemished opinion, integrity, and ethical conduct.

Based on these regulations, the General Meeting makes decisions regarding the selection and assessment of the suitability of candidates and members of the Supervisory Board; the Supervisory Board makes decisions regarding the selection and assessment of the suitability of members of the Management Board; while the Management Board members make decisions regarding the selection and assessment of the suitability of Material Risk Takers (MRTs).

The suitability policies for members of the Bank’s governing bodies state that they are implemented with regard to the principle of diversity of composition, ensuring access to a broad range of competencies, knowledge, and skills (including Polish language proficiency) adequate for the positions held. This guarantees that members of the Supervisory Board and the Management Board—individually and as a body—issue independent opinions and decisions across the Bank’s entire scope of operations. Additional criteria supporting the diversity of governing bodies include age and gender.

According to the objectives defined in the diversity policy for the Bank’s governing bodies, the minimum gender diversity threshold (30%) in the composition of each Supervisory Board and each Management Board should be achieved no later than upon the appointment of these bodies for a new term after December 31, 2025. The achievement of these objectives will be pursued by applying the principle of equal opportunities in the selection process.

The Bank has introduced regulations defining the principles for selection, appointment, and succession planning, including staffing support, as well as the assessment of the suitability of Management Board members and individuals performing key functions in the Bank. These individuals are evaluated in terms of their competencies, knowledge and skills, experience appropriate to the position, as well as their reputation—understood as a sufficiently unblemished opinion, integrity, and ethical conduct.

Based on these regulations, the General Meeting makes decisions regarding the selection and assessment of the suitability of candidates and members of the Supervisory Board; the Supervisory Board makes decisions regarding the selection and assessment of the suitability of members of the Management Board; while the Management Board members make decisions regarding the selection and assessment of the suitability of Material Risk Takers (MRTs). Detailed information on the actual diversity of the Bank’s governing bodies, broken down by gender, age, and tenure, is available in the Diversity Management section.

As a result of the annual review of the Management Board Suitability Policy, in December 2023 the Supervisory Board adopted changes to the diversity policy provisions concerning the specification of the deadline and method for achieving gender diversity goals in the Management Board. It was adopted that the target minimum gender diversity threshold (i.e., 30%) in the composition of each Management Board should be achieved from the appointment of the Management Board for a new joint term after December 31, 2025. This goal is to be implemented through the principle of equal opportunities in the selection of Management Board members and through shaping a culture of diversity within the organization.

Analogous changes to the diversity policy concerning members of the Supervisory Board are planned for 2024.

Under the Suitability Policy for Supervisory Board Members adopted by the General Meeting, it was established that the policy is implemented with regard to the principle of diversity in the composition of the Supervisory Board. The principle of diversity ensures the appropriate selection of Supervisory Board members to provide access to a broad range of competencies, knowledge, and skills appropriate to the position, guaranteeing that Supervisory Board members—individually and as a body—issue independent opinions and decisions across the Bank’s entire scope of operations.

The entity conducting the audit of the bank’s financial statements is selected by the Supervisory Board of the Bank based on the recommendation of the Audit Committee. The detailed tasks of the Audit Committee include developing the policy and detailed procedure for selecting the audit firm, as well as presenting recommendations to the Supervisory Board regarding the adoption of this policy. According to the resolution of the Supervisory Board, the bank applies the following policy:

1. The maximum uninterrupted duration of statutory audit engagements carried out by the same audit firm, or an audit firm affiliated with that firm, or any member of the network operating in the European Union to which those audit firms belong, is 10 financial years. The maximum uninterrupted duration referred to above may be extended by two years, up to a total of 12 financial years, with the approval of the Polish Financial Supervision Authority, in the case of the simultaneous engagement of more than one audit firm in a joint audit, provided that the statutory audit results in a joint audit report.

2. The contract for auditing financial statements is concluded for a period of not less than 2 financial years and no more than 3 financial years, with the possibility of extension for another period of at least two financial years.

3. After the maximum uninterrupted engagement period referred to in point 1, the audit firm may resume statutory audit of the bank’s and the Bank Capital Group’s financial statements only after a minimum of 4 years has passed since the conclusion of the previous audit.

4. The key statutory auditor may not conduct a statutory audit of financial statements for a period longer than 5 financial years.

5. The key statutory auditor may resume statutory audit of financial statements only after a minimum of 3 years has passed since the conclusion of the previous statutory audit of the bank’s and the Bank Capital Group’s financial statements.

The main responsibilities of the bank in the area of anti-money laundering (AML) and counter-terrorist financing (CFT) include: analyzing and assessing the money laundering and terrorist financing risk of each client starting a relationship with the bank; identifying and verifying clients and beneficial owners; determining the risk of money laundering and terrorist financing; monitoring client transactions; and, in cases where circumstances indicating money laundering or terrorist financing are identified, or where there is reasonable suspicion of money laundering, taking appropriate actions, including suspending transactions, freezing accounts, or blocking funds.

The AML/CFT policy is one of the bank’s internal procedures, defining the scope of data sharing, regulations, obligations, standards, and measures applied in the area of combating money laundering and terrorist financing. The bank and its group companies develop, implement, update, and apply internal AML regulations.

In 2023, the AML/CFT policy (hereinafter “Group Policy”) was updated for all entities within the Bank Capital Group and foreign branches, aimed at strengthening oversight of AML/CFT obligations in those entities. The adopted document established standards that must be observed by the bank and Group entities that are obliged institutions, as well as by all individuals working within them, including permanent and temporary staff, consultants, contractors, agents, intermediaries, and their employees.

In line with obligations under the AML Act, the Group applies financial security measures before establishing a business relationship with a client, and subsequently throughout the relationship, at intervals appropriate to the client’s risk profile.

In 2023, PKO Bank Polski S.A. continuously implemented restrictions and changes resulting from sanctions imposed on Russia and Belarus and applied guidelines concerning financing and banking services for entities engaged in business activities related to Russia and Belarus, including clients subject to, or potentially subject to, sanctions or restrictions. The Group operates in compliance with legal requirements in every country where it is active and cooperates with institutions tasked with combating money laundering and terrorist financing (GIIF in Poland and relevant financial intelligence units for foreign branches).

Changes were also introduced in the organizational structure to strengthen continuity in handling the critical AML/CFT process in the bank by conducting real-time and post-transaction analyses of suspicious transactions, as well as providing findings to authorized institutions.

The compliance and conduct risk management principles at PKO Bank Polski define the compliance policy, which covers preventing unlawful activities, ensuring information security (including client data protection), creating advertising and marketing content, ethical standards, conflict of interest prevention, anti-corruption and anti-bribery procedures, rules on accepting gifts and tokens of appreciation, as well as complaint and appeal handling. The principles also define responsibility for managing compliance and conduct risks and specify how these risks are to be reported.

When designing product offers and conducting product sales, entities within the Group make every effort to ensure that products are adequate to the needs of the clients to whom they are offered, and that the manner and form of offering are appropriate to their nature. Before concluding a contract and during its performance, clients must be provided with information required by law and market practice. This includes information understandable to the average client that is reliable, complete, and truthful, particularly regarding the product’s nature, structure, contract terms, as well as benefits, risks, fees, commissions, and other costs associated with entering into, performing, or terminating the agreement early.

The bank’s work regulations are based on the principle that every employee is important, regardless of gender, age, disability, race, religion, nationality, political beliefs, trade union membership, ethnic origin, faith, sexual orientation, or whether they are employed on a fixed-term or indefinite contract, or on a full-time or part-time basis. The employer undertakes, among others, to prevent discrimination and mobbing in employment, ensure equal treatment of employees performing the same or equivalent work, and apply objective and fair criteria for assessing work performance.

The regulations stipulate the employer’s obligation to organize work in a way that ensures employees achieve high efficiency and quality, making use of their qualifications and abilities, while also ensuring working conditions that comply with occupational health and safety (OHS) regulations and the Labor Code. The bank’s work regulations also specify employee obligations, which include diligent and careful performance of official duties in line with internal regulations, including the principles of the bank’s Code of Ethics. Each employee is obliged, among other things, to comply with IT system security rules, ensure special protection of data contained therein, safeguard entrusted property, and participate in OHS training. Employees should also identify circumstances that may give rise to conflicts of interest involving them and are required to disclose such cases to their supervisor and the Compliance Department for further analysis.

Each employee is obliged to adhere to the bank’s Code of Ethics and to participate in developing and promoting the organizational culture and its associated values.

The Group also applies recruitment principles based on high standards of anti-discrimination and personal data protection, supported by modern technologies and IT systems. In the recruitment process, the bank and Group companies respect human rights and ensure equal opportunities, aiming to attract the best external candidates while also promoting internal talent. This approach enables the employment of individuals with diverse experience and professional skills. The bank also encourages employees to participate in internal recruitment across the Group to foster professional development in different business areas.

To ensure a positive candidate experience in the recruitment process, the bank diversifies outreach channels to different applicant groups, shortens recruitment time, and applies modern selection methods. Candidate experience surveys are also conducted, with results used to improve activities influencing the recruitment process.

The remuneration policy of the bank’s employees and the companies of the capital group aims to ensure a consistent remuneration system that takes into account the adjustment of tools and salary levels to specific job groups and local labor market conditions, as well as the economic and financial situation of the bank and the group’s companies.

The policy ensures a consistent remuneration system by shaping the salary structure based on work performance and employee competence assessment, building in employees responsibility for tasks assessed on the basis of objective criteria, applying a remuneration system consistent with market trends, shaping fixed pay based on job evaluation, and adjusting remuneration mechanisms, tools, and levels to the organization’s strategy and objectives. The policy assumes the parameterization of variable remuneration components to take into account the cost of risk, cost of capital, and liquidity risk of the bank and the group in the long-term perspective. It also points to ensuring such a system in which cash or non-cash forms of remuneration do not encourage those involved to favor their own interests or the interests of the bank and other entities of the group to the detriment of clients.

The Bank’s Supervisory Board is responsible for adopting and updating the policy, in particular monitoring whether remuneration policy and practices are properly implemented and adapted to the general corporate governance framework, corporate culture, risk-taking readiness, and related management processes. The policy is subject to an annual performance assessment by the Supervisory Board. The implementation of the remuneration policy is also subject to an independent internal review carried out by the bank’s Internal Audit unit. The review report is presented to the Supervisory Board and the Remuneration Committee.

The rules of organization and implementation of development activities at PKO Bank Polski define the principles of organization and the conditions under which development activities for bank employees are carried out.

Development activities are adapted to the specifics of the bank and the individual entities of the Bank’s Capital Group and defined in internal regulations. This ensures a flexible approach to development policy. “The method of organization and implementation of development activities at PKO Bank Polski S.A. defines the goals, directions, and methods of the bank’s actions in the field of employee or other co-worker development management.”

The main assumptions in the adopted training policies are:

• supporting the implementation of the strategic objectives of the entities of the Bank’s Capital Group and business goals,

• onboarding new employees,

• ensuring the improvement of employees’ professional qualifications and adapting their knowledge and skills to the changing requirements of the market in which a given entity operates,

• preparing employees for the implementation of new solutions and products offered by the entities of the Bank’s Capital Group or for the implementation of changes in existing solutions or offered products.

The implementation of development activities results from the business objectives of the bank’s unit (business development activities), the business objectives of the entire bank (strategic development activities), and the bank’s obligations resulting from generally applicable legal provisions and the recommendations, guidelines, and instructions of supervisory authorities for the banking sector or supervisory authority decisions issued with respect to the bank (mandatory development activities).

The bank offers all employees access to the Training Catalogue – a non-compulsory, generally accessible offer for the development of soft skills.
It includes various forms of development activities: in-person and online workshops (both classical and using educational games or VR technology), video trainings, and short five-minute knowledge capsules in video form, which can be watched at a convenient time.
The catalogue is updated quarterly and available on the intranet portal, where it is easy to register for selected activities.

In 2023, the #ESGo development program was launched. The aim of the program is to educate all employees in the field of sustainable development. Building basic and expert competencies in this area is intended to enable the bank’s effective ESG transformation. During this time, over 18,000 employees participated in an e-learning course dedicated to sustainable development issues from the bank’s perspective, and more than 3,800 employees took part in ESG training and online webinars.

The procurement policy defines the overarching objectives and principles applicable in the process of carrying out all purchases in the bank. Its details are specified in the regulations set out in the Rules for the Purchase of Goods and Services, the Procedure for the Purchase of Goods and Services, and the Code of Ethics for suppliers and bidders.

The objective of the Procurement Policy is to ensure effective and sustainable development of the bank. The policy defines purchasing patterns, sets purchasing priorities, and specifies good practices of the purchasing process.

One of the issues regulated in the Procurement Policy is the application of ESG criteria in all purchasing procedures conducted in the tender mode. As the purchasing standard, the inclusion of environmental, social, and governance (ESG) aspects in the assessment of bidders and suppliers has been adopted.

The main procurement objectives set out in the Procurement Policy are: quality, efficiency, and development aimed at optimizing functional requirements while minimizing the life cycle costs of goods and services. The procurement policy also indicates desirable actions in the purchasing process, related among others to bid analysis, such as:

• evaluation based on adopted criteria and weights (including ESG) as well as documents and information,

• proper division of eliminating criteria and assessed criteria,

• application of criteria related to the need being satisfied and adequate for making a choice,

• objectivity of evaluation,

• avoidance of unjustified preferential evaluations.

In accordance with the Procurement Policy, activities are carried out to develop uniform procurement standards in the companies of the Bank’s Capital Group.

Currently, the Procurement Policy adopted by the Bank’s Management Board resolution of October 31, 2023 is in force. Regulations concerning the purchase of goods and services, defining the principles and procedures for procurement, are updated on an ongoing basis, in line with the changing regulatory environment and market trends.

In 2024, the Anti-Corruption Policy of PKO Bank Polski S.A. and the PKO Bank Polski S.A. Capital Group was adopted. The purpose of the policy is to ensure the highest standards of the Group’s operations by applying the principles of: zero tolerance for corruption, cronyism, and nepotism, as well as minimizing the risk of committing corruption offenses.

In the Bank, a special plenipotentiary has been appointed: the Bank’s Plenipotentiary for Anti-Corruption Activities, who is the head of the Security Division.

The Bank and the Group entities:

• do not accept any behavior that could bear the hallmarks of corruption, nepotism, or cronyism,

• strive for honest and fair conduct in all areas of activity, without favoring on the basis of family or acquaintance relations.

The anti-corruption policy applies to all areas of the Bank’s and the Group’s activities, the Bank’s employees, in particular in relations with:

• a client or potential client,

• an entity cooperating with the Bank or Group entity or its representatives, employees, subcontractors, suppliers,

• an entity applying to establish cooperation with the Bank or Group entity or its representatives, employees, subcontractors, suppliers,

• a person holding a public function performing official activities concerning the Bank or Group entity.

In 2021, the Bank’s Management Board adopted, and the Supervisory Board approved, the Bank’s tax strategy as an entity operating in a responsible and transparent manner. The Director of the Tax Department is obliged to review the Strategy at least once a year and, if necessary, to present recommendations for its update or amendment.

The tax strategy contains the following tax objectives of the Bank along with a brief description of how to achieve them:

• fulfillment of tax obligations in accordance with applicable regulations,
• acting in accordance with the intentions of the legislator,
• market-based transactions concluded with related parties,
• active participation in legislative initiatives,
• limiting tax risk,
• maintaining high standards in relations with tax authorities,
• use of modern technologies in the performance of tax obligations.

In accordance with statutory obligations, the Tax Capital Group of Powszechna Kasa Oszczędności Bank Polski Spółka Akcyjna (hereinafter: PGK), comprising: the Bank, PKO Bank Hipoteczny S.A. and PKO Leasing S.A., prepared another annual Information on the Implemented Tax Strategy for 2023. The Bank’s tax strategy and the information on the implemented tax strategy for the years: 2020, 2021, 2022, and 2023 prepared by PGK are available on the Bank’s website

(https://www.pkobp.pl/grupa-pko-banku-polskiego/pko-bank-polski/strategia-podatkowa/).

Taking into account the aforementioned documents, the Bank’s activities focus, among others, on:

• implementation and application of internal regulations that ensure proper performance of tax obligations and proper documentation of transactions
The Bank’s Management Board adopted resolutions concerning: the rules of performance of tax obligations, reporting of tax schemes (MDR), and performance of obligations in the field of transfer pricing. Based on the above-mentioned resolutions, decisions were issued regarding: settlement of individual taxes by the Bank as taxpayer and remitter (including foreign branches), performance of reporting obligations, reporting of tax schemes (MDR), performance of obligations in the field of transfer pricing, performance of obligations under FATCA and CRS. The Bank’s internal regulations are subject to regular reviews and updates to ensure their compliance with generally applicable legal provisions.

• supervision and control over the performance of tax obligations, including the internal control system
Management of the performance of tax obligations in the Bank:

a) Supervision over the Finance and Accounting Area, including the Tax Department, is exercised by the Vice-President of the Bank’s Management Board,
b) The Tax Department, together with other relevant Bank units, is responsible for the performance of tax obligations and ensures the proper performance by other units of activities relevant to the Bank’s tax obligations,
c) High quality of performed activities is guaranteed by the specialized competencies of the Bank’s employees, including tax advisors,
d) The Bank also uses the services of external tax advisors,
e) The process of performing tax obligations in the Bank is subject to the internal control system.

• limiting tax risk using the tax risk management system functioning in the Bank

Mechanisms and principles of tax risk management:

a) The Bank regularly analyzes and minimizes tax risk using instruments permitted by generally applicable legal regulations, including submitting applications for individual tax law interpretations and protective opinions.
b) In the Bank, the so-called appetite for tax risk is low. The Bank limits undertaking activities where elimination of tax risk using legally permissible tools is not possible.
c) The performance of tax obligations in the Bank is a separate process subject to assessment, among others, from the perspective of operational risk and compliance risk.

• avoiding the use of structures intended for aggressive tax planning or tax avoidance (including the use of tax havens) and avoiding solutions inconsistent with the intentions of the legislator or the spirit of the law (the principle of tax fairness)

The Bank does not engage in tax planning whose basis would be regulations allowing artificial or apparent reduction of the effective tax burden. Before undertaking a specific activity, the Bank conducts a risk analysis of the application of the general anti-avoidance rule (GAAR) and the specific anti-avoidance rule (SAAR).

• promoting tax awareness among employees
The Bank provides employees with information on applicable tax law regulations, their planned amendments, and interpretations. Specialized training and guidelines for employees are prepared in the Bank, as well as analyses of the tax consequences of new products, the Bank’s business processes, investment projects, and agreements.

The Bank firmly opposes all forms of discrimination, intolerance, and other behaviors that contradict the organization’s values, and promotes attitudes among employees based on mutual respect. Any behavior that may indicate the occurrence of mobbing is not accepted. The Bank has internal regulations concerning the principles of counteracting mobbing and discrimination, as well as the procedure for examining complaints regarding violations of employee rights.

These principles guarantee the prevention of adverse phenomena in employee relations and define the way of responding in the event of interpersonal conflict. Based on these principles, every Bank employee may, without fear of consequences, file a complaint regarding any violation of employee rights defined in generally applicable law and in internal law. The employee has the right to additional support in the complaint clarification process through the possibility of appointing a representative of a trade union organization or an employee representative designated in accordance with the Bank’s internal regulations to participate in meetings with the employee or to submit an opinion on the legitimacy of the complaint. Ongoing support in the area of employee relations is offered by the HR Contact Center, so that employees can also obtain up-to-date information on the procedure for filing complaints and anonymous reports regarding violations of employee rights.

Complaints concerning broadly understood violations of employee rights are considered individually, therefore for each of them the optimal method of handling is determined, allowing for the formulation of appropriate conclusions and recommendations or, if necessary, the undertaking of appropriate additional actions or personnel decisions. Various methods are used in the process of verifying complaints (including anonymous surveys, in-depth employee interviews, verification of turnover rates and other HR data). When determining the course of action, care is always taken to ensure the greatest possible objectivity of assessment, hence representatives of various units, in line with the Bank’s organizational structure, often participate in clarifying the case.

Other entities of the Bank’s Capital Group also include in their internal regulations the necessary solutions guaranteeing compliance with applicable law in the field of counteracting mobbing and discrimination, contained in separate regulations or through relevant provisions in work regulations, codes of ethics, and other adequate documents of a given company.

The Diversity, Equal Treatment and Mutual Respect Policy adopted in the Bank and the Bank’s Capital Group (hereinafter: the “Group”) is a declaration of joint commitment to creating a workplace in which all employed persons feel needed, heard, and equal. The policy aims to support respect for diversity and the elimination of all manifestations of discrimination. It is an expression of the conviction that cooperation in an atmosphere of openness, respect, and inclusiveness translates into the best professional experiences for employees and persons employed under other legal bases, and also contributes to the development of potential and trust. In this way, it enables the joint development of the best solutions for clients, contractors, and other stakeholders of the Bank and the Group.

Promoting diversity is present in many aspects of the Bank’s and the entire Capital Group’s activities. It assumes, among others, respect for others, equal treatment, and the use of employee potential. The understanding of diversity is reflected in the belief that people are important regardless of the aspects in which they differ, including, among others, gender, age, health status, sexual orientation, religion, marital status, or country of origin. When building teams, the Bank understands that diversity is an asset in creating innovations as well as in efficient operational performance. The Bank ensures that diversity as a value, but also as a practice, is present in organizational culture, undertaken initiatives and activities, as well as in policies, regulations, and processes adequate to the subject, including:

• in the processes of recruitment, promotions, and succession planning for key positions,
• in the processes of shaping remuneration, employee development, access to training and employee benefits, as well as in the process of performance review,
• in regulations concerning equal treatment and the prohibition of discrimination,
• in regulations concerning counteracting violations of employee rights and the protection of whistleblowers.

The policy aims to fulfill a number of expectations and obligations concerning diversity issues – resulting from legal acts, guidelines, as well as initiatives to which the Bank has joined. The aforementioned obligations result, among others, from the Diversity Charter – signed by the Bank in November 2024 – providing for the obligation to create an atmosphere and organizational culture that ensures respect for diversity, by including diversity management issues, including age management and gender equality, in all relevant policies and procedures applied in the organization.

An element of the Bank’s concern for diversity is the diversity policy for members of the Management Board and the Supervisory Board.