Santander Bank Polska S.A.

Transaction in Own Shares • Mar 13, 2025

13-03-2025

Current report no.: 11/2025

Subject: Information about transactionsexecuted in the course of the own shares buy-back and the completion ofthis year's share buy-back to implement Incentive Programme VII

In relation to current report no. 3/2025,4/2025 and 9/2025, the Management Board of Santander Bank Polska S.A.(Bank) hereby announces that as part of exercising the buy-backprogramme of the Bank's shares, the conditions of which were establishedin the Banks' Management Board resolution of 25 February 2025(Resolution and Buy-back) pursuant to the authorisation granted in theAnnual General Meeting resolution no. 46 of 18 April 2024 regardingauthorising the Management Board to purchase (buy-back) the Bank sharesto execute Incentive Plan VII and to create a capital reserve for thatpurpose, the Bank purchased its own shares in transactions described inappendix 1 and 2 to this report in order to meet its commitments toallot shares to the Bank's group employees who are participants inIncentive Plan VII, i.e. to pay out awards for 2024 and the deferredawards due for years 2022-2023 to be paid in 2025 to these participants.

Appendix 1 includes detailed data ontransactions and appendix 2 includes the aggregated data - related totransactions made from 10 March 2025 to 12 March 2025.

Transactions were carried out through theBank's brokerage house, i.e. Santander Biuro Maklerskie.

Taking into account the share purchasetransactions presented in appendix 1 and 2, as at the end of 12 March2025 the Bank, in the course of current Buy-back implementing theIncentive Plan VII, has entered into transactions involving 155 605 ofits own shares in total (including its own shares purchased as part ofthe Plan and outside the Plan) which represent 0.15% of the Bank's sharecapital and which give 0.15% of votes in the total number of votes atthe General Meeting. At the same time, the Bank informs that as at theend of 12 March 2025 it has given instructions to transfer 155 605shares to the brokerage accounts of the participants of Incentive PlanVII.

Given that the Bank purchased enough of itsown shares to pay awards to the participants in Incentive Plan VII duefor 2024, payable in 2025, as well as the deferred awards due for2022-2023 payable in 2025, the Management Board hereby confirms that on12 March 2025 it closed 2025 buyback programme of its own shares set upfor this purpose.

Legal basis:

Article 2 (2) and (3) of the of CommissionDelegated Regulation (EU) 2016/1052 of 8 March 2016 supplementingRegulation (EU) No 596/2014 of the European Parliament and of theCouncil with regard to regulatory technical standards for the conditionsapplicable to buy-back programmes and stabilisation measures and inrelation to Article 5 (3) of Regulation (EU) No 596/2014 of the EuropeanParliament and of the Council of 16 April 2014 on market abuse (marketabuse regulation) and repealing Directive 2003/6/EC of the EuropeanParliament and of the Council and Commission Directives 2003/124/EC,2003/125/EC and 2004/72/EC.