Social Area

The primary document governing remuneration matters within the Bank’s Capital Group is the “Remuneration Policy for Employees of PKO BP S.A. and the PKO BP S.A. Capital Group”, adopted and regularly updated by the Management Board. The Policy is of an overarching nature; therefore, internal remuneration systems, including those developed by Group companies based on the Bank’s recommendations, particularly with regard to Management Board members and Material Risk Takers, must comply with its requirements.

The Policy ensures a consistent remuneration framework aligned both with market trends and the overall corporate strategy. Among other things, the document ensures that remuneration is linked to achieved performance and based on objective criteria for performance assessment. The Policy is disclosed as required.

The Policy constitutes the principal instrument used by the Bank to implement regulations within the Capital Group aimed at ensuring employees’ financial security and aligning remuneration levels with market conditions. As an overarching document, however, the Policy does not define specific objectives or actions necessary to achieve them. Nevertheless, the Bank’s Capital Group undertakes a range of initiatives and activities aimed at improving working conditions, including matters related to remuneration. One such activity is the analysis of salary surveys and market trends.

Another instrument supporting employees’ financial security is the Collective Labour Agreement (CLA), which establishes, inter alia, the principles of remuneration and the granting of work-related benefits.

The CLA applies to employees of two entities within the Bank’s Capital Group: PKO Bank Polski and KREDOBANK S.A.. In both cases, the parties to the agreement are the President of the Management Board and representatives of trade union organisations acting on behalf of employees. The CLA is available through the internally operated regulatory database in the case of PKO Bank Polski S.A. and on the internal website maintained by KREDOBANK S.A.

No collective labour agreements are in force in the remaining companies of the Bank’s Capital Group.

In accordance with the CLA, Bank employees are entitled to the following remuneration components:

• base salary,
• additional remuneration for overtime work, night work, and work performed under particularly burdensome or hazardous conditions,
• bonuses and awards for outstanding professional achievements.

Furthermore, the CLA guarantees employees minimum base salary rates. These are determined based on a percentage relationship to the statutory minimum wage defined under generally applicable labour regulations, depending on the job classification level.

The agreement applies to all Bank employees employed under employment contracts. However, it does not apply to persons employed under management contracts or other civil law contracts. The provisions of the CLA do not exclude employees of foreign branches. Nevertheless, external legal regulations and the specific market conditions in which foreign branches operate may affect the manner or scope of application of the CLA.

Representatives of the Management Board meet with employee representatives (trade union organisations and the Employees’ Council) in order to conduct dialogue concerning working conditions and employment stability.

In addition, the Bank operates a bonus system based on the “Principles for Employee Bonuses”, adopted by a resolution of the Management Board. These principles regulate the process of setting and evaluating bonus-related objectives and tasks, as well as the rules for determining individual bonuses for employees employed under employment contracts (excluding MRTs). The document is made available through the internally operated regulatory database accessible to all employees.

The Bank also operates a Company Social Benefits Fund, from which additional employee benefits supporting employees’ financial security are financed. Furthermore, an Employee Pension Scheme is maintained.

Ensuring employees’ financial security also includes a range of measures undertaken by entities within the Bank’s Capital Group. Depending on the size of employment, the principles of employee remuneration are defined in remuneration regulations and employment contracts. Separate employee bonus systems are also applied.

The effectiveness of measures undertaken to ensure employees’ financial security, including aligning remuneration levels with economic conditions, is monitored on a regular basis. One of the tools used for this purpose is the eNPS employee satisfaction survey, in particular the “Remuneration and Benefits” index. Although the Capital Group has not established a measurable target in line with ESRS 2, it aimed to maintain the eNPS result at least at a level comparable to that achieved in 2023.

The Bank’s Capital Group makes every effort to ensure that employees receive adequate remuneration enabling them and their families to meet their needs, taking into account current economic and social conditions. The applicable minimum wage level, i.e. the minimum remuneration that an employer is required to pay to an employee employed under an employment contract, was adopted as the reference indicator for wage adequacy. For entities operating within the territory of Poland, this level was determined on the basis of the national minimum wage published by the Central Statistical Office, while for entities operating in Ukraine, it was determined on the basis of the Budget Code of Ukraine. In 2025, all employees of the Group received remuneration above the adequacy threshold.

The remuneration policy implemented within the Bank is gender-neutral. The remuneration-setting process is based on the results of job evaluation. In accordance with commonly applied market methodology, job evaluation consists of determining the appropriate level of indicators for strictly defined criteria (e.g. scope of responsibility, complexity of tasks) assigned to a given position. In 2025, the adjusted gender pay gap indicator amounted to 0.8% for the Bank and 2.8% for the Capital Group.

The Bank regularly reviews remuneration levels for individual positions, including remuneration levels for women and men, and takes into account internal benchmarks, as well as data contained in salary reports and remuneration surveys, in the process of developing and optimising its remuneration strategy.

In order to ensure comparability of equivalent positions and eliminate the overall impact of other factors affecting remuneration levels, the Bank also applies the market-based CR (Comparatio) indicator as a comparison between the remuneration offered to an employee and the relevant market benchmark.

Internal analyses conducted using the CR indicator demonstrate that there are no differences in remuneration between women and men within the Bank, and that both groups are remunerated in line with market standards.

The Bank actively supports the development of employees’ competencies by continuously expanding its development offering in line with the needs identified through employee experience surveys. One of the elements of this support is a co-financing system for educational expenses, covering, among others, coaching, postgraduate studies, MBA programmes and legal traineeships.

In 2025, 95 training agreements for the co-financing of various forms of education were concluded, compared to 144 in 2024.

An important area supporting employee development is also the strengthening of soft skills. In 2025, 71 dedicated training courses were made available, covering, among others, communication, cooperation and conflict resolution, personal effectiveness and motivation, change management and adaptability, coping with stress and emotions, and personal branding.

With regard to sustainability education, the Bank successfully implements the #ESGo initiative addressed to all employees. The programme focuses on ESG-related topics, taking into account the global context, the Bank’s strategic objectives and the key environmental, social and governance challenges. In 2025, one webinar and a comprehensive development programme entitled “ESG in Practice” were organised under the #ESGo initiative. For comparison, in 2024 the programme included five webinars and three training sessions. Furthermore, a mandatory e-learning course entitled “ESG – Sustainability from the Bank’s Perspective” was developed. In 2025, the course was completed by 4,731 employees, compared to 15,326 employees in 2024. The visible discrepancy in the number of participants results from the fact that the training was organised for the first time in 2024.

Cooperation with Own Workforce, Including Collective Bargaining and Social Dialogue

The Bank systematically collects employees’ opinions through two main processes. The first process involves ongoing dialogue with social partners, namely workplace trade union organisations and the Bank’s Employees’ Council. In fulfilling its statutory obligations, the Bank informs, consults and agrees with the above-mentioned bodies on selected matters, in particular organisational changes that may significantly affect work organisation, employment levels or the basis of employment. The scope and frequency of such consultations are determined by generally applicable legal regulations. Dialogue with social partners is of key importance because, as representatives of employees’ interests, they constitute an important source of information and opinions taken into account by the Bank in its operations. The second source of information consists of direct employee opinion surveys. These include the recurring #JakCiSięPracuje (“How Is It Working for You?”) survey addressed to all persons employed under employment contracts.

In 2025, two editions of the survey were conducted, monitoring employee satisfaction in three key areas:

• cooperation with the direct supervisor;
• work environment;
• development opportunities.

The survey enjoys strong recognition among employees, who actively participate in it. The average participation rate across the two editions conducted in the Bank in 2025 amounted to 68%, while in 2024 (across four editions) it exceeded 65%.

These results demonstrate that the Bank effectively uses this tool to obtain opinions and information, while the collected data serve as the basis for designing both local and Bank-wide initiatives.

In order to ensure the continuity and systematic nature of the employee feedback collection process, responsibility for individual elements of the process has been assigned to the relevant specialist organisational units. Oversight of cooperation with social partners is exercised by the Director of the HR Partnership Department, who coordinates ongoing dialogue with employee representatives of the Bank. Responsibility for the regular conduct of employee experience surveys rests with the Director of the Organisational Culture and Engagement Department. This division of responsibilities ensures that the process of collecting employee feedback is conducted regularly and that key information is continuously monitored and used in decision-making processes.

The Bank also implements other forms of direct employee satisfaction measurement, such as exit interviews, surveys concerning satisfaction with internship programmes, and assessments of the onboarding process.

Employee Representation and Freedom of Association

The Bank fully respects the right of employees to freedom of association and does not impose any obstacles to joining trade union organisations, standing as candidates for the Employees’ Council, or carrying out activities within such organisations. These organisations are free to establish their internal operating rules, elect representatives, appoint governing bodies and plan their programmes of activity.

This approach remains fully aligned with the principles of freedom of association set out in Convention No. 87 of the International Labour Organization concerning Freedom of Association and Protection of the Right to Organise.

Employee representation within the Bank consists of workplace trade union organisations and the Bank’s Employees’ Council.

In 2025, four organisations operated within the Bank:

• National Trade Union of Employees of PKO BP S.A.;
• Independent Self-Governing Trade Union “Solidarity” of Employees of PKO BP S.A.;
• Inter-Company Organisation of Banking and Services Employees No. 06-005 OPZZ “Konfederacja Pracy”;
• Trade Union No. 1 with its registered office in Żory.

As at 31 December 2025, the share of Bank employees who were members of trade union organisations amounted to 23.5%, representing an increase compared to the previous year (20.4%).

This trend reflects growing employee engagement in trade union activities, which consequently strengthens the influence of the social partners on decision-making processes and the shaping of working conditions within the Bank.

Employee representation in the form of trade unions is also present in KREDOBANK S.A. and PKO Leasing S.A.. In 2025, the percentage of employees affiliated with these organisations amounted to 12.4% and 17.5%, respectively.

The Employees’ Council constitutes a representative body for employees employed under employment contracts in dialogue with the Bank. The principles governing cooperation between the Employees’ Council and the employer are regulated by the Act of 7 April 2006 on informing and consulting employees, as well as by a separate agreement.

In accordance with these regulations, the Bank provides the Employees’ Council with information concerning, in particular:

• the employer’s activities and economic situation related to employment, as well as anticipated changes in this respect;
• the status, structure and anticipated changes in employment, as well as measures aimed at maintaining employment levels;
• activities that may result in significant changes in work organisation or the basis of employment.

Internal Communication and Workplace Atmosphere

The Bank’s Capital Group actively promotes effective internal communication, thereby striving to ensure a high level of employee satisfaction and to create a supportive environment and positive workplace atmosphere. The Bank’s Capital Group also undertakes initiatives aimed at improving employee satisfaction levels. Initiatives such as the eNPS surveys – #JakCiSięPracuje (“How Is It Working for You?”) – are used to conduct in-depth analyses of interpersonal relations within the organisation and their impact on employee satisfaction levels.

The Bank also offers, among others, the #JestemUSiebie (“I Feel at Home Here”) programme, which includes communication activities and workshops supporting the creation of an inclusive working environment. The programme, addressed to all employees, highlighted the benefits arising from diversity within teams. As part of the initiative, nearly 30 workshops were conducted on topics including neurodiversity, intergenerational cooperation, unconscious bias, anti-discrimination and empathetic communication.

Complementing these informational activities was the mandatory training course entitled “#JestemUSiebie – A Friendly Work Environment Starts with You”, focused on inclusiveness, which was completed by 9,055 employees.

In 2025, the Bank continued the implementation of the recurring #RotundaRóżnorodności (“Rotunda of Diversity”) initiative, constituting one of the key elements of activities aimed at building an inclusive organisational culture.

As part of the initiative, six educational events were organised, focusing on tolerance, anti-discrimination, breaking stereotypes, and creating a friendly and safe working environment. For comparison, seven such events were held during the previous edition of the programme.

In 2025, the Bank devoted significant attention to parents returning to work following extended absence. The #PonownieUSiebie (“Back at Home Again”) initiative, launched at the end of 2024, includes a range of activities facilitating the reintegration of parents returning to work after the birth of a child, including a structured reboarding process.

At the end of 2025, a grassroots employee network called #Neuroentuzjaści (“Neuro-Enthusiasts”) was also established, bringing together individuals interested in promoting neurodiversity and neuroatypicality. The network includes persons diagnosed as neuroatypical, parents of neuroatypical children, and supporters of these issues. In 2025, approximately 20 employees were actively involved in the network’s activities.

The Bank operates various reporting channels that ensure employees can safely and confidentially report irregularities. These include both reports submitted pursuant to whistleblower protection regulations, as well as reports concerning violations of employee rights and interpersonal conflicts in the workplace.

With regard to reports submitted under whistleblower protection regulations, the reporting channels include, in particular, the publicly available external whistleblowing channel – Sygnanet, a detailed description of which is provided in the Management Board Report on the activities of the PKO Bank Polski S.A. Capital Group for 2025, section 13.4.1 “Information related to conduct in business”.

Additionally, employees may report violations through:

• the dedicated mailbox: sygnalisci@pkobp.pl;
• the personal email inbox of the President of the Management Board or the Vice-President of the Management Board supervising the work of the Management Board;
• the personal email inbox of the Chairperson of the Supervisory Board, where the report concerns a member of the Management Board;

as well as by post to:

• Supervisory Board of PKO Bank Polski S.A., ul. Świętokrzyska 36, 00-116 Warsaw, marked “WG”, where the report concerns a member of the Bank’s Management Board;
• President of the Management Board of PKO Bank Polski S.A., ul. Świętokrzyska 36, 00-116 Warsaw, marked “WG” – in other cases;
• PKO Bank Polski S.A., Compliance Department, ul. Świętokrzyska 36, 00-116 Warsaw, marked “WG”.

In the event of identified breaches of the diversity, equal treatment and mutual respect policy, employees may submit reports in the following forms:

• electronically, from the employee’s official named email account to a dedicated mailbox established for such reports;
• electronically, from the reporting person’s private email account, provided that the identity of the reporting person and the authenticity of the report can be verified;
• in writing, to the correspondence address of the Director of the HR Division or the Director of the HR Partnership Department.

Reports concerning violations of employee rights are treated individually; therefore, the optimal timeframe and method for handling each case are determined on a case-by-case basis. As a rule, however, the process should not exceed 60 calendar days. Where irregularities are identified, appropriate remedial measures are implemented. All interested parties, including the employee submitting the report, are informed of the outcome of the proceedings. In situations requiring further supervision, progress monitoring is also conducted in cooperation with the involved parties. The purpose of these activities is to verify whether, and to what extent, the agreed measures are being effectively implemented. Where further difficulties are identified, discussions are held with supervisors in order to implement additional corrective measures.

Individuals submitting reports are guaranteed full confidentiality and discretion. No retaliatory actions may be taken against them. A detailed description of the whistleblower protection mechanism is provided in section 13.4.1 “Information related to conduct in business”. Additionally, the Bank offers employees a broad support package tailored to the specifics of a given case, including:

• specialist medical and psychological support;
• training in stress management and conflict resolution;
• the possibility of temporary reassignment to another position for the duration of the investigation proceedings.

Employees are aware of their right to report irregularities. Detailed information regarding the submission and handling of reports is published:

• on the intranet – with respect to reports concerning violations of employee rights;
• on the publicly available website “Reporting Violations of Law – PKO Bank Polski” – with respect to violations reported under the provisions of the Whistleblower Protection Act.

The Bank’s Capital Group has not adopted a dedicated Group-level human rights policy. Neither the Bank nor its subsidiaries have formal policies in this area that directly refer to documents such as the acts and guidelines of the United Nations, the International Labour Organization (ILO) or the OECD.

Issues related to the respect for human rights are regulated through internal documents implementing standards arising from international and national legal frameworks. In particular, these relate to the rights to:

• recognition of the legal and personal dignity of each employee;
• freedom to express opinions and views, as well as freedom of thought, conscience and religion;
• protection of personal rights;
• equal treatment;
• access to information;
• access to healthcare protection;
• privacy;
• rest and leisure;
• safe and hygienic working conditions;
• fair remuneration;
• freedom to establish employment relationships;
• professional development and skills enhancement.

The Bank’s approach to respecting human rights is reflected in the following internal regulations: the “Code of Ethics of PKO Bank Polski S.A.”, the “Principles for Counteracting Mobbing and Discrimination and the Procedure for Handling Complaints Concerning Violations of Employee Rights”, the “Work Regulations of the Bank”, the “Remuneration Policy for Employees of the Bank and the PKO BP S.A. Capital Group”, and the “Recruitment Policy of PKO Bank Polski S.A. and Companies of the PKO Bank Polski S.A. Capital Group”.

In the context of human rights, the Code of Ethics obliges persons performing work or activities for the Bank to foster a working environment based on respect and dignity, openness to diversity, and the prevention of unequal or inappropriate treatment. The Bank supports its subsidiaries in promoting common values, principles and standards of conduct. Codes of ethics implementing the “Code of Ethics of PKO Bank Polski S.A.” are in force, among others, in: PKO Towarzystwo Ubezpieczeń S.A., PKO BP Finat Sp. z o.o.,  PKO BP Bankowy PTE S.A., PKO Bank Hipoteczny S.A., PKO Towarzystwo Funduszy Inwestycyjnych S.A., PKO Agencja Ubezpieczeniowa Sp. z o.o., Prime Car Management S.A., PKO Faktoring S.A., PKO Leasing S.A., PKO Leasing Finanse Sp. z o.o., KREDOBANK S.A.

Within the framework of the Bank’s Work Regulations (constituting an appendix to the resolution of the President of the Management Board), particular emphasis is placed on respecting the dignity and other personal rights of employees, ensuring equal treatment, providing access to information, and preventing discrimination and mobbing. At the same time, the Regulations define the implementation of the rights to rest and to safe and hygienic working conditions.

The Bank’s Work Regulations also govern the employment of juvenile workers in accordance with the standards arising from the Polish Labour Code. Each employee is acquainted with the content of the Regulations prior to commencing work, while information for existing employees is communicated via the intranet portal.

Human rights issues are also regulated in the Work Regulations of: PKO Bank Hipoteczny S.A., PKO Faktoring S.A., PKO Leasing S.A., PKO Ubezpieczenia S.A., PKO BP BANKOWY PTE S.A., PKO Towarzystwo Funduszy Inwestycyjnych S.A., Sopot Zdrój Sp. z o.o., Prime Car Management S.A., PKO BP Finat Sp. z o.o.

Respect for human rights is also implemented through ensuring the right to fair remuneration.

The relevant instrument is the Group-wide “Remuneration Policy for Employees of the Bank and the PKO Bank Polski S.A. Capital Group”, described earlier in this chapter.

Compliance with human rights standards is also supported through the recruitment process, which standardises employee selection based solely on objective criteria. To this end, the Group adopted the “Recruitment Policy of PKO Bank Polski S.A. and Companies of the PKO Bank Polski S.A. Capital Group”. The document defines the key objectives and principles of the recruitment process based on objective employee selection criteria, ensuring equal treatment, gender neutrality and non-discrimination of candidates (including, in particular, on the grounds of gender, age, disability, race, skin colour, religion, nationality, political beliefs, trade union membership, ethnic or social origin, property, birth or sexual orientation), while maintaining the highest ethical standards. The Policy also requires that the diversity objectives adopted for managerial positions be taken into account during recruitment processes. Group companies have been granted access to the Policy and are expected to ensure appropriate alignment of their internal regulations and processes with its assumptions.

All regulations described in this subsection are available within the internal regulatory database accessible to all employees.

The Bank’s Capital Group incorporates human rights considerations into its internal regulations, implemented processes and day-to-day operations. It also adheres to the principles arising from international initiatives such as the United Nations Global Compact and the OECD Guidelines, as these principles are consistent with the general principles of labour law applied both in Poland and in the Group’s foreign branches. The Bank has not entered into a framework agreement with employee representatives concerning respect for human rights.

With regard to the policies described above, the Bank and the Capital Group companies manage the impact of potential human rights violations on employees’ health. Although the Group does not have a separate policy dedicated specifically to this issue, adverse impacts are mitigated through ensuring compliance with human rights standards. Such impacts, identified as potential in nature, are neither widespread nor systemic.

In the event of a human rights violation incident, employees are obliged to report the matter through the available channels described in the section “Reporting Violations”. These channels are available both to Group employees and to individuals outside the organisation.

The Bank’s Capital Group does not identify any business operations exposed to a significant risk of forced labour or child labour, because:

• the prohibition of forced labour arises from Article 4 of the Convention for the Protection of Human Rights and Fundamental Freedoms;
• the prohibition on employing persons under the age of 15 arises from Article 190 §2 of the Polish Labour Code.

The Bank has developed a tool for assessing minimum safeguards within the meaning of Regulation (EU) 2020/852 of the European Parliament and of the Council. The scope of the assessment covers the UN Guiding Principles on Business and Human Rights, the International Labour Organization Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. The methodology was adopted by decision of the Director of the Sustainable Development Department. As part of its self-assessment, the Bank considers compliance requirements across five areas: anti-corruption, tax risk management, prevention of unfair competition, management of risks related to digital security, respect for human rights and labour rights. Based on the assessment carried out for 2025, the Bank’s Capital Group meets the minimum safeguards requirements. The assessment of compliance with minimum safeguards for the Group is conducted at least annually. The assessment is voluntary in nature and is not included in disclosures made pursuant to Article 8 of Regulation (EU) 2020/852, under which compliance with minimum safeguards by corporate clients was considered in the calculation of the Green Asset Ratio (GAR).

A key element of preventing workplace bullying and discrimination within the Bank’s Capital Group is the implementation of mechanisms for reporting unwanted incidents. In 2025, 70 reports were recorded within the Bank’s Capital Group. Two of these concerned potential discrimination; however, none were ultimately confirmed or deemed substantiated. Based on the assessment conducted for 2025, the Bank’s Capital Group did not identify any material issues or incidents related to human rights.

In 2025, the Bank’s Capital Group recorded 70 reports concerning discrimination and bullying. Two of these concerned potential discrimination; however, none were ultimately confirmed or deemed substantiated.