The primary document governing remuneration matters within the Bank’s Capital Group is the Remuneration Policy for Employees of the Bank and the PKO BP S.A. Capital Group, adopted and updated by the Management Board. This regulation is of a superior nature; therefore, internal remuneration systems, including those developed within subsidiaries based on the Bank’s recommendations—particularly regarding Management Board members and Material Risk Takers—must comply with its requirements. The Policy ensures a coherent remuneration framework aligned with both market trends and the Bank’s overall strategy. Among other provisions, it guarantees that remuneration is linked to work performance and assessed through objective evaluation criteria. Since its adoption, the Policy has been publicly available to all persons working within the Capital Group, with communication tools adapted to the specific entities. It serves as the Bank’s key instrument for implementing regulations across the Capital Group that ensure employees’ financial security and the alignment of their remuneration with market conditions. The Policy ensures a coherent remuneration framework aligned with both market trends and the Bank’s overall strategy. Among other provisions, it guarantees that remuneration is linked to work performance and assessed through objective evaluation criteria. Since its adoption, the Policy has been publicly available to all persons working within the Capital Group, with communication tools adapted to the specific entities. It serves as the Bank’s key instrument for implementing regulations across the Capital Group that ensure employees’ financial security and the alignment of their remuneration with market conditions.

Periodic remuneration reviews are conducted to determine the Bank’s and Capital Group’s remuneration position in relation to the market and, if necessary, to plan appropriate pay adjustments.

Another tool supporting employees’ financial security is the Collective Bargaining Agreement (Zakładowy Układ Zbiorowy Pracy, ZUZP), which sets out, among other things, the rules for remuneration and work-related benefits.

The ZUZP covers employees of two entities in the Capital Group: PKO Bank Polski S.A. and KREDOBANK S.A. In both cases, the agreement is signed by the President of the Management Board and employee representatives from trade unions. The ZUZP is accessible via the internal regulations database at PKO Bank Polski S.A. and the internal website of KREDOBANK S.A.

No collective bargaining agreements are in place within other Group companies.

Under the ZUZP, Bank employees are entitled to the following remuneration components:

• base salary,
• allowances for overtime, night shifts, and work under particularly arduous or hazardous conditions,
• bonuses and awards for outstanding professional achievements.

The ZUZP also guarantees minimum base salary rates, determined as a percentage of the statutory minimum wage, depending on the job grade.

The ZUZP also guarantees minimum base salary rates, determined as a percentage of the statutory minimum wage, depending on the job grade. The agreement applies to all Bank employees on employment contracts but excludes those under management contracts or other civil law agreements. The content of the ZUZP does not exclude employees of foreign branches; however, local laws and market conditions may affect its application. At KREDOBANK S.A., the ZUZP applies to all employees, regardless of position, type, or duration of employment. While the collective agreements do not define specific objectives or actions, Management Board representatives meet with employee representatives (trade unions and Works Council) to discuss working conditions and employment stability, thereby addressing and leveraging the opportunities associated with collective agreements identified under the double materiality assessment.

In addition, the Bank operates a bonus system regulated by the Rules for Employee Bonuses at the Bank, adopted by a Management Board resolution. This document sets out the process for defining and settling bonus objectives and tasks, as well as the rules for awarding individual bonuses to employees under employment contracts (excluding MRTs). It is available in the internal regulations database accessible to all employees. Employee bonus objectives are linked to the Bank’s key management indicators. Due to the nature of the regulated area, the procedure does not establish specific objectives or actions nor monitoring processes for implementation.

The Bank also maintains an Employee Benefits Fund (Zakładowy Fundusz Świadczeń Socjalnych), which finances additional employee benefits to support their financial security. These include non-repayable cash allowances for employees and families facing difficult life circumstances or random events. Applications for such assistance can be submitted by the affected person or by other employees on their behalf. The Fund also finances a Voluntary Pension Scheme.

The commitment to employees’ financial security also extends to other Capital Group companies. Depending on the size of the workforce, remuneration rules are set out in pay regulations and employment contracts, and separate bonus systems may be in place.

Some companies also offer additional financial security measures, such as project bonuses, holiday bonuses, or the option to request salary advances.

The effectiveness of financial security measures, including remuneration adjustments to economic conditions, is regularly monitored. One of the tools used is the eNPS satisfaction survey, particularly the “remuneration and benefits” index. Although the Capital Group has not set a measurable target in line with ESRS 2, it aimed to maintain the eNPS result at least at the 2023 level.

Adequate Pay

The Capital Group strives to ensure adequate remuneration for employees, meeting the needs of both the employee and their family in the context of national economic and social conditions. The adequate pay indicator is based on the statutory minimum wage—i.e., the lowest salary an employer is legally required to pay to an employee under an employment contract. For entities operating in Poland, this level is determined by the national minimum wage published by the Central Statistical Office. For entities operating in Ukraine, it is determined in accordance with the Ukrainian Budget Code. In 2024, all employees of the Bank and the Capital Group companies received remuneration above the established adequate pay threshold.

Pay Gap

The Bank’s remuneration policy is gender-neutral. The process of determining pay levels is based on job evaluation results. Job evaluation, in line with widely adopted market methodology, involves determining appropriate indicator levels for precisely defined criteria: skills (technical knowledge, managerial skills, interpersonal skills), problem-solving (freedom of thought, challenges, freedom of action), and impact on results (type of impact, scope of influence). The essence of job evaluation is that it applies to the position, not the individual holding it.

The Bank regularly reviews remuneration for individual positions, including the salaries of women and men, taking into account internal benchmarks as well as data from pay reports and salary surveys when shaping and optimising its remuneration strategy.

To ensure comparability for identical positions and eliminate the influence of other factors on salary levels, the Bank also applies the market comparatio index (CR – Comparatio), which compares the salary offered to an employee against the relevant market benchmark. Internal analyses using the CR index indicate that no pay differences exist between women and men in the Bank, and both groups are remunerated in line with the market.

 

The Bank’s Capital Group actively supports and encourages employees to engage in continuous development and strives to meet the growing demand for training and development activities. Although training and development matters are not addressed at the level of a group-wide regulation, Capital Group entities undertake initiatives to provide support in enhancing employee competencies. At the Bank, training activities are governed by the Method of Organising and Delivering Development Activities at PKO Bank Polski S.A., adopted by a decision of the HR Management Division Director and made available in the Internal Regulations Database. This document describes in detail the organisation of development activities (both individual and group) for employees under employment contracts, as well as opportunities to participate in training—both from the Bank’s open development offering and in internal and external training programmes. While this regulation does not set out specific ESRS-aligned objectives or required actions, the Bank consistently seeks to strengthen employee competencies in the area of professional development. In 2024, numerous initiatives, training and development programmes, and individual activities were implemented across the Bank’s units.

As part of the open development offering, a series of workshops (both in-person and online) and video training sessions were delivered, covering topics such as communication skills, teamwork, personal effectiveness, time and task management, change management, negotiation skills, stress and emotion management, presentation skills, motivation, creativity and innovation, and self-development management. Development activities were offered in a variety of formats, including traditional workshops, workshops using educational games, VR goggles, and video training. In 2024, e-learning-based initiatives were also implemented to enhance employee competencies, with around 20 new courses developed in this format.

In addition to the open development offering, Bank employees had access to the following initiatives:

• participation in the Knowledge in a Nutshell programme, where employees share experiences and knowledge on their passions and interests;
• access to the Multilife education platform, including a language learning app, Legimi, and Youniversity;
• access to the Application Zone educational platform offering technical training in, among others, Excel, SQL, Python, and PowerPoint;
• participation in the Language Zone project, based on four pillars: access to the language platform provided via Multilife, thematic employee meetings held in English, language webinars, and book recommendations available on Legimi and Inspiro;
• access to the Training Catalogue, an open development offer including workshops, video training, and short video formats;
• participation in the Time for Development Inspiration project—regional meetings for sales network employees offering various development opportunities;
• participation in monthly live events from the Time for Our Development series, showcasing the Bank’s training and development offer.

Capital Group companies also provide development opportunities to their employees. These most often include soft skills and specialist training, access to educational platforms and e-learning courses, co-financed language courses, co-financing of university studies, access to knowledge bases, individual training tailored to specific needs, knowledge capsules, webinars, instructions, and presentations. The effectiveness of initiatives aimed at promoting employee development and meeting the growing training demand is not tied to a formal ESRS 2 target. However, it is regularly monitored via the eNPS satisfaction survey, particularly the “Development” index. In 2024, no measurable eNPS targets were set in this area, but the Capital Group aimed to maintain the index at a level comparable to 2023.

The training and development area is subject to continuous change, driven not only by growing employee demand but also by the Bank’s Capital Group’s efforts to reduce its negative environmental impact. Employees serving clients from high-emission sectors, including those covered by the decarbonisation plan, will need to expand their competencies and update their qualifications to provide professional advice and support during the transformation process.

Collaboration with internal stakeholders, including in the area of collective bargaining and social dialogue [S1-2]

Cooperation with employee representatives is an essential channel for understanding employees’ perspectives, obtaining their feedback, and incorporating it into the Bank’s business operations.

Employee Representation and Freedom of Association

Recognising the role of dialogue, the Bank actively engages with its employee representatives. It imposes no obstacles to joining or participating in trade unions or the Bank’s Works Council. Employee organisations within the Bank are entitled to establish their internal rules of operation, freely elect representatives, appoint management boards, conduct activities, and define their programmes. This is in line with the principles of freedom of association as set out in International Labour Organization Convention No. 87 on Freedom of Association and Protection of the Right to Organise.

Employee representation in the Bank consists of three company-level trade unions:

• National Trade Union of PKO BP S.A. Employees,
• Independent and Self-Governing Trade Union “Solidarity” of PKO BP S.A. Employees,
• Intercompany Organisation of Banking and Services Employees No. 06-005 OPZZ “Confederation of Labour”.

The framework for cooperation between the Bank and trade unions is primarily defined by the provisions of the Labour Code and the Act of 23 May 1991 on Trade Unions. Additionally, the Bank operates a Works Council, which serves as an internal body facilitating communication between the Bank and employees under employment contracts.

The Bank also maintains a Social Labour Inspection function, whose inspectors are members of trade unions. Their role is to protect employee rights as defined in labour law and to ensure that working conditions are safe and hygienic. The Director of the HR Partnership Department is responsible for coordinating cooperation with the trade unions and the Works Council.

Collaboration with employees does not rely solely on formal representation. The Bank also provides direct communication channels with employees, such as mechanisms for reporting grievances and irregularities, as well as employee satisfaction surveys. The design and implementation of surveys assessing the experiences and opinions of employees and job candidates is the responsibility of the Director of the Organisational Culture and Engagement Department.

Through its extensive cooperation channels with employee representatives, the Bank and its Capital Group address opportunities associated with promoting social dialogue and freedom of association.

Internal Communication and Workplace Atmosphere

The Bank’s Capital Group actively promotes effective internal communication to ensure high employee satisfaction, a supportive work environment, and a positive workplace atmosphere. The Group also undertakes initiatives aimed at improving employee satisfaction levels. Initiatives such as the #HowIsWork survey (eNPS) are used to conduct in-depth analyses of interpersonal relationships within the organisation and their impact on employee satisfaction.

The Bank also offers initiatives such as the #IAmMyself programme, which—through communication, education, and workshops—supports the creation of an inclusive work environment. Employees have access, via the intranet, to webinars, podcasts, and knowledge capsules on inclusive culture, microaggressions, bias, neurodiversity, and non-violent communication. Activities under the #IAmMyself programme also implement the commitments of the Diversity Charter. In addition, the Bank organises the recurring #RotundaOfDiversity event, featuring both internal and external experts, dedicated to various aspects of diversity, tolerance, and non-discrimination in life and at work, breaking stereotypes, and building a friendly workplace for all.

The Policy supports the implementation of the objectives outlined in the United Nations Convention against Corruption, adopted by the UN General Assembly on 31 October 2003. To ensure compliance with the Policy, an Anti-Corruption Officer will be appointed and tasked with implementing measures to safeguard adherence to its provisions. Oversight of the Policy’s execution will be entrusted to a designated member of the Management Board and conducted on a cyclical basis. The Policy applies universally across the organization and does not provide for any exemptions.

Previously, anti-corruption and anti-bribery matters were not governed by a single overarching regulation. Instead, they were addressed by various internal regulations concerning the prevention of corruption, including rules on the acceptance of benefits, gifts, or gratuities; the PKO Bank Polski S.A. Code of Ethics; the Rules on Ensuring Compliance and Managing Compliance and Conduct Risk; as well as the Code of Banking Ethics (Principles of Good Banking Practice) of the Polish Bank Association.

As part of strengthening measures to prevent any corrupt practices, the Bank appointed an Anti-Corruption Officer, namely the Director of the Security Division. In the absence of the Officer, these duties are performed by the Director of the Procurement Validation and Monitoring Office.

The adoption of the Policy addresses significant impacts associated with corruption and bribery, including: safeguarding reputation in the banking sector [IRO: I169]; maintaining international reputation [IRO: I208]; avoiding the costs of investigations and proceedings [IRO: I209]; preventing market disruptions caused by anti-competitive behavior [IRO: I211]; combating corruption [IRO: I205]; mitigating the risk of corruption scandals [IRO: I206]; and sustaining investor trust [IRO: I207].

The Bank operates an anonymous whistleblowing system (the whistleblower mechanism covers all unethical conduct, violations of law or the Bank’s internal regulations, as well as breaches of supervisory and control authority recommendations). Bank employees are required to report any suspected criminal activity related to the Bank’s operations. Reports concerning a Management Board member are submitted to the Chair of the Supervisory Board, while all other reports are addressed to the President of the Management Board. The Bank has established internal regulations that define the procedures for handling such cases. Information on reported irregularities, including those involving corrupt practices, as well as the results of their verification, is regularly reported to the Management Board and the Supervisory Board. Equivalent solutions are applied in selected entities of the Bank’s Capital Group, appropriately scaled to their scope of activities.

With regard to reporting incidents of corruption and bribery, the Bank’s Capital Group does not have a separate fast-track procedure beyond those described in the section “Whistleblower Protection.” The system for preventing allegations or incidents of corruption or bribery is based on regulations governing compliance risk management and the rules for conducting internal investigations and procurement procedures.

In addition, the matter is regulated by the Anti-Corruption Policy of PKO Bank Polski S.A. and the PKO Bank Polski S.A. Capital Group, as well as by the Procedures for Implementing the Anti-Corruption Policy of PKO Bank Polski S.A. and the PKO Bank Polski S.A. Capital Group, both effective as of April 2025.

Every employee of the Bank is required to undergo training on the principles of preventing corrupt practices.

This training is delivered as part of the compliance risk management program, which includes a dedicated module on information protection and anti-corruption, specifically addressing the acceptance of benefits and gifts. The training is mandatory for all new employees, regardless of their form of employment.

The training focuses in particular on ethical conduct, anti-corruption regulations, and the admissibility of accepting benefits, gifts, and tokens of appreciation from contractors and other entities. Under the Bank’s newly introduced Anti-Corruption Policy, mandatory cyclical anti-corruption training sessions will be conducted for all employees. To further strengthen qualifications and enhance competencies related to the Anti-Corruption Policy, the Bank’s Anti-Corruption Officer will collaborate with relevant units of the Bank to ensure effective delivery of these programs. Training for members of management and supervisory bodies is organized according to individual needs.

Additionally, once a year a communication is sent to all employees regarding the conditions under which benefits and gifts may be accepted. Further training sessions are planned under the new internal regulation – the Procedures for Implementing the Anti-Corruption Policy of PKO Bank Polski S.A. and the PKO Bank Polski S.A. Capital Group.

In 2024, the Bank’s Capital Group recorded no convictions in corruption-related cases, and consequently, the total amount of fines imposed was zero. Accordingly, no remedial actions were identified as necessary.

The Bank’s Capital Group has not adopted a Group-level human rights policy. Neither the Bank nor its subsidiaries maintain formal policies in this area that explicitly reference international frameworks such as the United Nations, the International Labour Organization, or the OECD.

Human rights issues are addressed through internal documents that implement standards arising from both international and national legal frameworks. In particular, these concern the rights to:

• recognition of the legal personality of every employee,
• freedom of expression, opinion, thought, conscience, and religion,
• protection of personal rights,
• equal treatment,
• access to information,
• access to healthcare,
• privacy,
• rest and leisure,
• safe and hygienic working conditions,
• fair remuneration,
• freedom to establish an employment relationship,
• opportunities for professional development and skills enhancement.

The Bank’s approach to respecting human rights is embedded in the following internal regulations: the Code of Ethics of PKO Bank Polski S.A., the Rules for Counteracting Mobbing and Discrimination and the Procedure for Handling Complaints Regarding Violations of Employee Rights, the Work Regulations of the Bank, the Remuneration Policy for Employees of PKO Bank Polski S.A. and the PKO Bank Polski S.A. Capital Group, and the Recruitment Policy of PKO Bank Polski S.A. and the PKO Bank Polski S.A. Capital Group. In the context of human rights, the Code obliges all individuals employed by or performing activities on behalf of 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 also supports its subsidiaries in promoting shared values, principles, and standards of conduct. Codes of Ethics derived from the Code of Ethics of PKO Bank Polski S.A. are in effect at, among others: 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., and KREDOBANK S.A.

Within the Work Regulations of the Bank (an annex to the order of the President of the Management Board), emphasis is placed on respecting the dignity and other personal rights of employees, ensuring equal treatment, access to information, and counteracting discrimination and mobbing. The document also specifies the implementation of rights to rest and safe and hygienic working conditions. Furthermore, it regulates the employment of underage workers in accordance with standards arising from the Labour Code. Each employee is introduced to the content of the Regulations prior to commencing employment, while employees already on staff are informed via the intranet portal. Human rights standards are also embedded 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., and PKO BP Finat Sp. z o.o.

Respect for human rights is further ensured through the right to fair remuneration.

The instrument governing this area is the Group-level Remuneration Policy for Employees of PKO Bank Polski S.A. and the PKO Bank Polski S.A. Capital Group, as described earlier in this chapter.

Support for the observance of human rights is also reflected in the recruitment process, which standardizes employee selection based exclusively on objective criteria. To this end, the Group-wide Recruitment Policy of PKO Bank Polski S.A. and the PKO Bank Polski S.A. Capital Group has been adopted. This document sets out the core objectives and principles of the recruitment process, ensuring equal treatment, gender neutrality, and non-discrimination of candidates (particularly on the grounds of gender, age, disability, race, skin colour, religion, nationality, political beliefs, trade union membership, ethnic or social origin, property status, birth, or sexual orientation), while upholding the highest ethical standards. The Policy also requires that diversity objectives be taken into account in the recruitment of candidates for managerial positions. Subsidiaries have been granted access to the Policy and are expected to appropriately align their internal regulations and processes with its principles.

All regulations described in this subsection are available in the internally maintained regulatory database, to which all employees have access.

The Bank’s Capital Group incorporates respect for human rights into its internal regulations, operational processes, and day-to-day practices. It also adheres to the principles set out in international initiatives such as the UN Global Compact and the OECD Guidelines for Multinational Enterprises, as these are consistent with the general principles of labour law applied both in Poland and in foreign branches. The Bank has not concluded a framework agreement with employee representatives regarding the protection of human rights.

With respect to the policies described above, the Bank and its Capital Group entities manage the potential impact of human rights violations on employees’ health. Although the Group does not maintain a separate policy dedicated exclusively to this issue, adverse impacts are mitigated through the assurance of compliance with human rights standards. This impact, identified as potential, does not have a widespread or systemic nature [IRO: I118].

In the event of an incident involving human rights violations, employees are obliged to report the occurrence through the available channels described in the section “Reporting Misconduct.” These channels are accessible to both employees of the Group and external stakeholders.

The Bank’s Capital Group does not identify any business operations that may be exposed to significant risks of forced labour or child labour, as:

• the prohibition of forced labour derives from Article 4 of the Convention for the Protection of Human Rights and Fundamental Freedoms,
• the prohibition of employing persons under the age of 15 is enshrined in Article 190 § 2 of the Polish Labour Code.

In December 2024, the Bank introduced a regulation concerning the methodology for assessing compliance with minimum safeguards and implementing a due diligence mechanism for evaluating the negative impacts of business activities on human rights within the framework of such safeguards by the Bank’s clients and counterparties. The assessment of compliance with minimum safeguards will be 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 Bank is currently planning to integrate the methodology for assessing compliance with minimum safeguards into its internal banking processes.

The Bank’s Capital Group does not maintain a Group-wide policy specifically aimed at eliminating discrimination (including harassment), promoting equal opportunities, or fostering diversity and social inclusion.

Within the Bank, internal regulations are in place to address, among others, the elimination of discrimination, including:

• The Bank’s Code of Ethics,
• Principles of Counteracting Bullying and Discrimination and Procedures for Handling Complaints Related to Violations of Employee Rights,
• The Bank’s Work Regulations.

In line with the provisions of the Code of Ethics of PKO Bank Polski S.A., the Bank prevents bullying, harassment, discrimination, and other forms of unequal or inappropriate treatment. Furthermore, the Work Regulations obligate the employer to counteract discrimination in employment, in particular on the grounds of gender, age, disability, race, religion, nationality, political beliefs, trade union membership, ethnic origin, creed, and sexual orientation, as well as on the basis of the form or dimension of employment.

Through a Management Board Resolution, the Bank also introduced the Principles of Counteracting Bullying and Discrimination and Procedures for Handling Complaints Related to Violations of Employee Rights. These provisions apply both to employees employed under an employment contract and to individuals performing tasks for the Bank on a basis other than an employment contract. The purpose of these regulations is to prevent adverse phenomena in employee relations and to establish methods of responding to interpersonal conflicts. The document outlines measures undertaken by the Bank, such as promoting ethical attitudes and behaviours, supporting managers in developing relevant knowledge, ensuring objectivity in the evaluation process, and fostering communication with employees. It obliges managers to refrain from conduct infringing on dignity and, above all, to respond to reported concerns. Although the regulation does not introduce objectives meeting ESRS requirements nor actions necessary for their achievement, these aspects are reflected in the employee satisfaction survey (eNPS), specifically in the “Direct Supervisor” and “Work Environment” indices. The effectiveness of implemented anti-bullying and anti-discrimination regulations can also be assessed through the analysis of reported cases. In accordance with the policy, any employee (including both current employees under an employment contract and former Bank employees) may submit a complaint concerning violations of employee rights (see: Reporting Misconduct).

Dedicated policies, procedures, or principles regarding the prevention of bullying and discrimination have been adopted, among others, by PKO Bank Hipoteczny S.A., PKO Faktoring S.A., PKO Leasing S.A., PKO Ubezpieczenia, PKO Towarzystwo Funduszy Inwestycyjnych S.A., Prime Car Management S.A., and PKO Finat sp. z o.o. In the remaining subsidiaries, the prevention of bullying and discrimination has been regulated through the implementation of the provisions of the Code of Ethics of PKO Bank Polski S.A.

In 2024, 58 cases of discrimination and bullying were reported.